The FAA Legal Interpretation (Gebhart) makes it clear that if:
- Pilot A flies the whole XC flight (> 50 nm), including the enroute portion under the hood, and
- Pilot B acts as safety pilot enroute
- Pilot A can log PIC XC for the whole flight, and simulated instrument for the time spent under the hood, and
- Pilot B can log PIC time when acting as safety pilot.
The reason Pilot B cannot log PIC XC time is given as follows:
Section 61.65(d) contemplates that only the pilot conducting the entire flight, including takeoff, landing, and en route flight, as a required flight crewmember may log cross-country flight time. Because a safety pilot does not conduct the entire flight, a person acting as a safety pilot for a portion of the flight may not log any cross-country flight time for the flight.
I'm wondering about a slightly different scenario:
- Pilot A flies only the enroute portion of the XC flight under the hood, and
- Pilot B acts as safety pilot enroute, and flies the takeoffs and landings.
In this scenario, Pilot B is "conducting the entire flight [...] as a required flight crewmember," as required by the legal interpretation. If Pilot B satisfies the other cross-country requirements specified in 61.1 (ex. navigates using navaids while giving simulated vectors to Pilot A under the hood), can Pilot B log PIC XC time while Pilot A logs simulated instrument for the enroute portion?