On Mon, 22 Jan 2007 14:49:04 -0600, "Jim Macklin"
wrote:

FAR 1.1 does not and is not controlling for the PURPOSE of
logging flight time. Logging time is required only to show
compliance with some regulation for some certificate or
privilege. To that end, 61.51 is controlling. 61.51
requires manipulation of the controls to LOG PIC.

Perhaps you should either cite the legal counsel's letter or
re-read it.




Legal opinion citation:

June 22, 1977 to Mr. Thomas Beane

....
A pilot may log PIC time in accordance with Section 61.51(c)(2)(I)
when he is not actually "flying the airplane", if the airplane is one
on which more than one pilot is required under its type certificate or
under the regulations under which the flight is conducted and he is
acting as PIC. Also, a pilot, rated in category and class (e.g.
airplane single-engine) could, as the pilot who "Has final authority
and responsibility for the operation and safety of the flight" log PIC
time if another pilot, not appropriately rated, was actually
manipulating the controls of the aircraft.
....

ORIGINAL SIGNED BY EDWARD P. FABERMAN

for NEIL R. EISNER Acting Assistant Chief Counsel Regulations &
Enforcement Division Office of the Chief Counsel

=============================

He actually notes three instance under which the non-manipulating pilot may
log PIC time:

1. More than one pilot required under type certificate.
2. More than one pilot required under regulations (e.g. safety pilot)
3. Pilot manipulating not appropriately rated.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)