"Jose" wrote in message
...
It would be possible for someone to interpret "... the regulations under
which the flight is conducted" to indicate that because the pilot flying
cannot legally fly in IMC, due to currency, that the pilot not flying is
required.

Yes. But the pilot flying is not required.

OTOH, in VFR, the pilot flying (under the hood) =is= required, because the
whole point of the flight is to train =that= pilot. A reasonable argument
can be made that if the purpose of the IFR flight is also to train the
pilot flying, then the pilot flying =would= also be a required crewmember,
but this has not been addressd by chief counsel to my knowledge.

I think the FAA's rationale for allowing the PIC safety pilot (along with
the sole manipulator) to log PIC time under 61.51e1iii is that in order to
fly according to 91.109b, you need to have the two pilots mentioned by that
section; otherwise, you're flying according to some other regulation
instead. In contrast, there's no regulation that mentions both pilots in the
IMC/IFR training scenario. I agree that's a weak argument for letting the
safety pilot log PIC time; but at rate, it's stronger than any argument that
can be made for letting the IR-rated PIC log PIC time in the IMC/IFR
scenario.

--Gary