I'm not arguing for his point but he could come up with ideas for explaining why two MEI's were working together (IE Multi-Engine ATP cert...etc).

But that isn't the problem. He proposed that two MEI's time building is better than safety pilot time. #1 MEI's logging each other is obviously not legal and #2 Safety pilot time should be used for what it is intended for...to practice instrument approaches or to get currency...not as time building. It may not be a reg but is conscience and good judgment.

No gray area. Rental rules, insurance etc fall under "operating privilege". The only area I don't see covered by the regs that I think is reasonable is the "...that approach is beyond my skill level and I want a CFI along". I agree, the FAA is not going to make an issue out of having a CFI along for improving the skill and safety of a pilot.

Agreed. I have no problem with using a safety pilot. Practicing IFR is a very good idea and I think the safety pilot rules are a good way to encourage it.

As long as airlines are still hiring guys that build multi time using a safety pilot, it makes no sense to not do it this way financially. You can learn a lot on those flights if you take them seriously and fly into unfamiliar airspace.