Dumb Reg question

From the FAA website, part 61 FAQ (Word format). The FAA appears to
validate the scenario of both a safety pilot and hood-pilot both LOGGING
PIC.

In another question/response, the FAA is careful to emphasize not to
confuse "BEING" the PIC with "Logging PIC time).

QUESTION: I have two instrument students who wish to build time to
credit for the 50 hours of cross-country PIC flight time required for
the instrument and commercial certificates. They intend to fly
cross-country flights together, trading off legs with one flying as
safety pilot and the other manipulating the controls while under the
hood. I've counseled them that the safety pilot may log the time as PIC
only for the duration the manipulating pilot was under the hood and can
not count the flight as cross-country towards the instrument and
commercial rating requirements. Is it acceptable for the safety pilot
PIC flight time to count towards these specific cross-country requirements?

ANSWER: Ref. §§ 61.1(b)(3)(ii), § 61.51(e)(1)(iii); No. Your advice
is good. The pilot performing the takeoff and landing, i.e., conducting
flight in an appropriate aircraft per the definition of cross-country,
is the person acquiring the cross-country credit. A safety pilot can
not possibly log 100% of a flight since during visual operations
[takeoff, landing, etc.] the safety pilot services are not required.
The person that acts as safety pilot is no more than a passenger during
the VFR portions of the flight. There is no logic, common sense or
regulatory provision for a passenger, even a part time safety pilot, to
log cross-country flight time.
{Q&A-536}


RST Engineering wrote:

That is ABSOLUTELY false. Did you really READ 61.51(e) or did you simply
parrot somebody that you didn't check for accuracy?

61.51 lists a whole LOT of folks that can log PIC time. Your scenario isn't
among them. Suggest that you READ rather than QUOTE.


Jim




FAR 61.51(e) describes who can log PIC time. In the case of a
simulated instrument flight, both the pilot under-the-hood (sole
manipulator of the controls) and the safety pilot (required crewmember
on a flight requiring more than one pilot, such as a simulated
instrument flight) can log PIC at the same time.

Charles.
-N8385U