"David Brooks" wrote in message ...

Just a minute. The operation does so require more than one pilot, since we
have specified that the actual PIC (TopDog) isn't manipulating the controls.

The complete phrase is "an operation requiring more than one pilot under the
regulations under which the flight is conducted."

The rule was primarily designed for things like Part 135 and 121 where a
Second In Command is specifically called out for in the regs, but the FAA has
agreed that Simulated Instrument Flight also meets the definition.

Your scenario, only requires one pilot in the regulations. The fact that you
ended up using more than one, doesn't count.'