"Ron Rosenfeld" wrote in message
...

It's an old opinion (1977), and I've not seen that question addressed
recently.

I don't think the opinions die of old age unless the underlying regulations
change, and I would think it could be relied upon unless rescinded. I
haven't gone back to the old part 61 and compared.

However, I don't have a problem accepting "rated" as
differentiated from "qualified to act as PIC".


Nor do I. He said "rated", and as I said, we have to accept what he said.
I was just speculating that the actual intent might have been different.

I guess I would put that in the same category as being able to log PIC if
a
"pilot" with "no" ratings (e.g. your kid sister) were manipulating the
controls.

I agree, except that you are not allowed to log PIC during the time the kid
sister is manipulating the controls, except perhaps under this legal
opinion.