On Tue, 29 Jul 2003 02:03:40 GMT, Sydney Hoeltzli
wrote:

Yes, exactly. That appears to be the General Counsel interpretation --
Andrew Sarangan had a General Counsel letter on his website relevant to
the topic. Ron Rosenfeld referred to one.

Actually, the CC opinions I referred allowed the *PF* to log PIC time.
They did not allow the PNF (acting PIC) to log PIC time. Although if the
acting PIC were either a CFI(I) giving instruction, or a safety pilot in
simulated instrument conditions, then the regulations would allow the PNF
to log PIC time.

At one time, there was information in the Part 61 FAQ's suggesting that the
PNF acting PIC could also log PIC time when the PF was not instrument
rated/current/confident. However, I just looked at that source again and
cannot locate that information in the revision dated 12/19/2000.

There was a letter from Alan Pinkston (in the FAA CC office) also
suggesting the PNF might be able to log PIC time during IMC, however, the
wording is "When the person in the right seat is acting as safety pilot as
a result of 91.109 for avoidance of traffic, or in the case of instrument
meteorological conditions since that person provides safety for the flight,
(***as well as legal rating requirements***) both persons may log pilot in
command time. "

(Emphasis mine). This implies that if the PNF is required for legal rating
requirements (or under 91.109) then PNF could log PIC time.




Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)