Ronald Bruce Natalie

Restore exemption to instrument rating requirement for second in command safety pilots. In 2005, a change was adopted to 14 CFR 61.55 regarding safety pilots. In the reorganization of the regulatory paragraphs, a blanket exemption to all aspects of 61.55 for pilots ?designated as a safety pilot for the purposes of 91.109(b).? The new rule extended that exemption only to the familiarization training requirements (paragraph (b) of this section). This has the effect of requiring the second-in-command safety pilot to possess an instrument rating if the flight is conducted under instrument flight rules (IFR). My proposal extends the exemption for the safety pilot. Proposal: add an additional paragraph to 61.55 (k) The requirement for an instrument rating or privilege of paragraph (a)(2) of this section do not apply to a person who is designated as a safety pilot for purposes required by 91.109(b) of this chapter. This change was not mentioned in the accompanying text of the proposed rulemaking, nor evidently mentioned by those submitting comments, nor mentioned in the preamble to the final rule. Further, as demonstrated by frequent discussions amongst even experienced pilots and flight instructors, the restrictions added by this rule were unknown. I find this rule is contrary to safety. The role of the safety pilot as second in command is purely to provide for the necessary visual vigilance against traffic that the pilot wearing a view limiting device can not provide. This task is not contingent of any particular skill that the instrument rating would provide. Safety would not be impacted if this restriction was restored to the old rule. Many pilots avail themselves of the use of simulated instrument flight as a way of maintaining proficiency in addition to regulatory currency. Finding safety pilots without instrument ratings is much easier. In my own example, my wife, who is a pilot but not instrument rated, is always willing to provide the safety pilot role so I can maintain my currency. We can not get the added benefit of also conducting the flight under an IFR flight plan (even in visual conditions) with the added restriction. This rule would restore an important training opportunity without adversely affecting safety. It would not negatively impact or burden any groups nor change record keeping requirements.