Think twice the next time you log a “time share” flight or act as a safety pilot on a cross country flight. According to legal interpretations from the FAA dated in 2009, only the pilot flying is allowed to log cross country time under § 61. As explained in the Gebhart Interpretation:
Section 61.65(d) contemplates that only the pilot conducting the entire flight, including takeoff, landing, and en route flight, as a required flight crewmember may log cross-country flight time. Because a safety pilot does not conduct the entire flight, a person acting as a safety pilot for a portion of the flight may not log any cross-country flight time for the flight.
How does this apply to a typical cross country flight? Let’s assume Pilot A flies from KGYI to KAFW in 1.0 hours. Of that time, 0.7 hours are flown in simulated instrument conditions with Pilot B acting as the pilot in command (PIC) and the safety pilot. On the return leg, Pilot B flies from KAFW to KGYI in 1.0 hours with 0.7 simulated instrument and Pilot A acting as PIC and safety pilot.
Pilot A may log 1.0 total, 1.0 cross country, 1.0 PIC, and 0.7 simulated instrument hours for the first leg, plus 1.0 total and 0.7 PIC for the second leg. Overall, Pilot A gained 2.0 total, 1.7 PIC, 1.0 cross country, and 0.7 simulated instrument hours.
The Assistant Chief Counsel further explained that it is not permitted for pilots to take turns acting as the safety pilot on a single flight. According to the Hilliard Interpretation:
Pilot A and Pilot B each are the sole manipulator of the controls for a portion of the flight…. In this scenario, neither pilot may log cross-country time.
For a list of related interpretations, try a search for “safety pilot”.