Originally Posted by
ftaba1
I've re-read 61.31 (d) and it talks about serving (or acting) as a PIC. I'm talking about logging PIC time though. The CFI would ACT as a PIC during a training flight. But I'd be the sole manipulator of the controls. Which I think makes it leagal to log this time as a PIC. Am I wrong agian?
Yes, If I understand correctly, you're wrong. If you are not the sole occupant of the aircraft, you need to be rated to log PIC as the sole manipulator of the controls.
But I think I may understand where the CFI is coming from. Until a recent change, 61.51(e)(1)(i)'s sole manipulator clause referred to "rated or has privileges." A number of folks (not the FAA) took the position that the 61.31(d) solo endorsement was a "privilege" that counted. I'm not aware of a Chief Counsel interpretation on it but the FAA ended up amending 61.51(e)(1)(i) to make it clear that it was referring to "rated or has
sport pilot privileges" which, AFAIK, was always the intent.