"Mark Hansen" wrote in message
Now I would guess that every pilot in this situation is logging the time
as
PIC, but the statement was that a strict interpretation of the regulations
do not allow it (except that now, the legal opinion provides a way, in
that
it allows for an exception if the person operating the controls is not
"rated").



Maybe allows a way. The continued effectivity of the opinion would have to
be researched. As Dr. Rosenfeld said, it is old. Part 61 underwent a major
rewrite since that opinion, and the basis for the opinion may have changed.