If anyone is going to use the "AS" in the "must have logged 50 hrs x/c time AS pilot in command towards an opinion that it must be time while acting as the pic, I would argue that the FAA references "acting as pilot in command" when they talk about carrying passengers or flight reviews or instrument currency and the absence of that phraseology in 61.65 would lead me to believe they simply want logged pic time not necessarily time that u acted as the pic.