Sydney Hoeltzli wrote in message ...

Correct.

The regs have to *require* more than one pilot. Usually an ASEL flown under
IFR does not require more than one pilot by regulation. So it would seem not
to count.

However, if you are saying "given that this is a flight under IFR where the
controls are manipulated by a non-IR pilot, then the regulations do require
two pilots: the PF and the PNF/PIC", then they can log it.

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. I have an email
correspondence with John Lynch of a few years back where he initially
disagreed, then consulted the GC office and came back concurring.

That's why we felt it was appropriate to log it as we did (why we
chose to log it that way is a seperate issue)


But the flying pilot must be under a hood in order for the non-flying
(acting as PIC ) pilot to log PIC too. Actual instrument doesn't cut
it because there is no FAR requiring multiple crew for part 91 IFR,
there is one for wearing a hood.