RST Engineering wrote:
Well, when you DO, come back and entertain us with them. Until then,
opinions are like assholes and sex ... everybody has one, and most of them
smell.

However, there are Chief Council decisions based on these, I just don't
have access to them in front of me.

Here is the Chief Counsel decision on the matter:

---
October 30, l992


Mr. David M. Reid


Dear Mr. Reid:

Thank you for your letter of June 12, 1992, concerning the
logging of pilot-in-command (PIC) time under the Federal Aviation
Regulations (FAR).

In your letter you ask four questions. First, you ask whether
there are "any circumstances when, during a normal flight, two
Private Pilots may simultaneously act as (and therefore log the
time as) Pilot-In-Command?" The answer is two private pilots may
not simultaneously act as PIC but they may, under certain
circumstances, simultaneously log PIC time.

There is a difference between serving as PIC and logging PIC
time. PIC, as defined in FAR 1.1, means the pilot responsible
for the operation and safety of an aircraft during flight time.
FAR 61.51 deals with logging PIC flight time, and it provides
that a private or commercial pilot may log as PIC time only that
flight time during which he is the sole manipulator of the
controls of an aircraft for which he is rated, or when he is the
sole occupant of the aircraft, or when he acts as PIC of an
aircraft on which more than one pilot is required under the type
certification of the aircraft, or the regulations under which the
flight is conducted. It is important to note that FAR 61.51 only
regulates the recording of PIC time used to meet the requirements
toward a higher certificate, higher rating, or for recent flight
experience.

Therefore, while it is not possible for two pilots to act as PIC
simultaneously, it is possible for two pilots to log PIC flight
time simultaneously. PIC flight time may be logged by both the
PIC responsible for the operation and safety of the aircraft
during flight time in accordance with FAR 1.1, and by the pilot
who acts as the sole manipulator of the controls of the aircraft
for which the pilot is rated under FAR 61.51. Enclosed please
find two prior FAA interpretations concerning logging of PIC
time. We hope that these will be of further assistance to you.

In your second question you ask "[h]ow shall two Private Pilots
log their flight time when one pilot is under the hood for
simulated instrument time and the other pilot acts as safety
pilot?" The answer is the pilot who is under the hood may log
PIC time for that flight time in which he is the sole manipulator
of the controls of the aircraft, provided he is rated for that
aircraft. The appropriately rated safety pilot may concurrently
log as second in command (SIC) that time during which he is
acting as safety pilot.

The two pilots may, however, agree prior to initiating the flight
that the safety pilot will be the PIC responsible for the
operation and safety of the aircraft during the flight. If this
is done, then the safety pilot may log all the flight time as PIC
time in accordance with FAR 1.1 and the pilot under the hood may
log, concurrently, all of the flight time during which he is the
sole manipulator of the controls as PIC time in accordance with
FAR 61.51(c)(2)(i). Enclosed please find a prior FAA
interpretation concerning the logging of flight time under
simulated instrument flight conditions. We hope that this
interpretation will be of further assistance to you.

In your third question you ask "[d]uring instrument training, how
shall a VFR Private Pilot log the following flight time: Pilot-In-
Command time, Simulated Instrument time, and Actual Instrument
time, when that pilot is...A)...under the hood? B)...in actual
instrument conditions? C)...under the hood in actual instrument
conditions?" The answer is the VFR private pilot may log all of
the flight time you described as PIC flight time under FAR
61.51(c)(2)(i) if he was the sole manipulator of the controls of
an aircraft for which he is rated. Under FAR 61.51(c)(4) the
pilot may log as instrument flight time only that time during
which he operates the aircraft solely by reference to
instruments, under actual or simulated instrument flight
conditions. Please note that the FARs do not distinguish between
"actual" and "simulated" instrument flight time. Enclosed is a
prior FAA interpretation concerning the logging of instrument
flight time. We hope this interpretation will further assist
you.

Finally you ask "[d]oes FAR 61.57 affect how the VFR Private
Pilot shall log Pilot-In-Command time during instrument training,
either before or after meeting the 6/6/6 requirement, and if so,
how?" FAR 61.57 does not affect how a pilot logs PIC time during
instrument training; FAR 61.51(c)(2) and
(4) govern logging of instrument flight time. FAR 61.57(e)
provides currency requirements for acting as PIC under instrument
flight rules (IFR) or in weather conditions less than the
minimums for visual flight rules (VFR). Enclosed
please find a prior FAA interpretation on instrument flight time
and FAR 61.57(e). We hope this interpretation will further
assist you.

We hope this satisfactorily answers your questions.

Sincerely,



Donald P. Byrne
Assistant Chief Counsel
Regulations Division

Enclosures