Yes, please post the entire letter.



"Bob Moore" wrote in message
46.128...
| Jim Macklin wrote
| A safety pilot who is not a CFI should log that time as
SIC
| because that is what it is. Required crew member not
| manipulating the controls.
|
| Bull****!!!
|
| I'll post the entire opinion if you need it.
|
| Bob Moore
|
| Here is the Chief Counsel decision on the matter:
|
| ---
| October 30, l992
|
|
| Mr. David M. Reid
|
|
| Dear Mr. Reid:
|
| Clip...Clip....Clip
|
| Therefore, while it is not possible for two pilots to act
as PIC
| simultaneously, it is possible for two pilots to log PIC
flight
| time simultaneously. PIC flight time may be logged by
both the
| PIC responsible for the operation and safety of the
aircraft
| during flight time in accordance with FAR 1.1, and by the
pilot
| who acts as the sole manipulator of the controls of the
aircraft
| for which the pilot is rated under FAR 61.51. Enclosed
please
| find two prior FAA interpretations concerning logging of
PIC
| time. We hope that these will be of further assistance to
you.
|
| In your second question you ask "[h]ow shall two Private
Pilots
| log their flight time when one pilot is under the hood for
| simulated instrument time and the other pilot acts as
safety
| pilot?" The answer is the pilot who is under the hood may
log
| PIC time for that flight time in which he is the sole
manipulator
| of the controls of the aircraft, provided he is rated for
that
| aircraft. The appropriately rated safety pilot may
concurrently
| log as second in command (SIC) that time during which he
is
| acting as safety pilot.
|
| 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).