Originally Posted by
flyandive
It's been a while since I have done any instruction but it seems to me that based on the FARs and backed up by the first letter you do not need to have the endorsements if you were acting as a safety pilot and therefore logging SIC time.
However according to the second letter, if both pilots agreed ahead of time that the safety pilot would act as PIC (and therefore log PIC time) then he/she would need the endorsements.
You got it. Here's what's going on:
The first letter only answers the question, "do you have to have the endorsements to act as a safety pilot." (no) It doesn't attempt to answer the question of (a) whether the SP is PIC or SIC or something else, nor (b) how you log the time.
The second question answers the logging question and tells us the same thing 61.51 does. If a pilot in a required 2-pilot crew (in this case, the safety pilot) is acting as PIC, he may log the time as PIC. If not acting as PIC, he may log the time as SIC.
Neither one goes on to say the (hopefully) obvious: To act as PIC, you need to be qualified to act as PIC in the aircraft and the operation - ratings, endorsements, currency, etc.
Misunderstanding occurs when you don't break down the question into its parts. A lot of people get "a safety pilot may log PIC time" somewhere along the way and think it's a universal. It's not; like any other multi-pilot situation, it depends on their roles and what they are doing. Start doing that (assuming it's important to you) and even those weird 2-pilots-log-PIC scenarios begin t make some kind of sense.