"Ron Rosenfeld" wrote in message
...

Legal opinion citation:

June 22, 1977 to Mr. Thomas Beane

...
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.
...

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

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.



I wonder what regulation the lawyer bases #3 on.

He says "rated", meaning has the appropriate ratings on his pilot
certificate. I wonder if that is what he intended, or if he intended
"qualified", which to me would include endorsements, currency and medical.
Seems like the intent must have been if the pilot manipulating was not
qualified as PIC, then the one not manipulating but acting as PIC could log
PIC. But regardless, he said "rated", and we have to take it as written, if
we accept the opinion as valid.

Anyway, that opinion from the chief counsel's office is very interesting.