Hmmmm...

From Legal Interpretation # 92-52:

The two pilots may, however, agree prior to initiating the flight that
the safety pilot will be the PIC responsible for the operation and
safety of the aircraft during the flight. If this is done, then the
safety pilot may log all the flight time as PIC time in accordance with
FAR 1.1 and the pilot under the hood may log, concurrently, all of the
flight time during which he is the sole manipulator of the controls as
PIC time in accordance with FAR 61.51(c)(2)(i). Enclosed please find a
prior FAA interpretation concerning the logging of flight time under
simulated instrument flight conditions. We hope that this
interpretation will be of further assistance to you.

This seems to say that the entire flight, including takeoff, landing,
and the part where the other pilot was sole manipulator while VFR and
not under the hood, could be loggable by the safety pilot as PIC time.
This implies that a pilot may log PIC time ("in accordance with FAR
1.1") when he acts as PIC, irrespective of the number of pilots
required, and irrespective of who is sole manipulator. This seems to
contradict FAR 61.51(e)(1), which in (iii) provides for time when acting
as PIC in a multi-pilot-required situation, but does not address
multi-pilot-used-but-not-required situations. By its omission there one
may infer it is intended to be omitted.

I wonder if the Chief Councel intended this contradiction. I've found
that Legal Interpretations are not all that well worded.

Jose
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