"Brian" wrote in message
oups.com...
[...]
My somewhat simplfied interpretation of the FARS for PIC is as follows.

As long as people understand they are overly simplified...that is, some
nuance is lost in the simplification. It's not so much that it's wrong, but
that it's incomplete and could lead to wrong interpretations of the FARs.

1. A pilot may only log PIC only if they are legally qualified to fly
the airplane as the solo, Note 90 day currency must be met if any
passengers are on board. (note there may be a few exceptions)

More to the point, this is *sometimes* a "necessary" but not "sufficient"
requirement for logging PIC.

In addition, whether one is current to carry passengers or not is completely
unrelated to *logging* PIC. IMHO, a discussion about *logging* PIC should
not introduce that issue, as doing so just complicates the discussion
without need.

2. Both a Pilot and Safty pilot my log PIC when performing simlulated
instrument flight. Both must meet #1.

Almost.

But in absence of passengers (two pilots, both are required crew members, no
passengers) the passenger currency requirement need not be met by either
pilot. See what I mean about needlessly complicating the discussion.

Additionally, if the safety pilot is acting as PIC, the pilot flying need
only meet the category and class rating requirement. He doesn't even need a
current BFR.

IMHO, the attempt to tie *logging* PIC with the requirements to *act* as PIC
(which, in spite of your use of the word "log" in #1 is really what #1 is
about) is the classic mistake people make when talking about the issue.
Logging PIC and acting PIC are two entirely different things. Only in very
specific situations does the question of acting as PIC affect the question
of logging as PIC.

Trying to come up with a general interpretation that always includes the
question of acting as PIC is doomed to failure; there are too many ways to
log PIC time without being qualified to act as PIC.

Pete