"John R Weiss" writes:

First, 91.109(b) does not apply; Jill is not acting as a "safety pilot" for
simulated instrument flight.

But she *could*.

This was recently pointed out to me at PJY as a way that two pilots out of
night currency can legally fly together at night. Clever! I wouldn't have
thought of it.

Time to practice those zero/zero landings again...

--kyler