Could someone tell me how this view is consistent with the following?
61.3(e) Instrument rating. No person may act as pilot in command of a civil aircraft under IFR or in weather conditions less than the minimums prescribed for VFR flight unless that person holds:
(1) The appropriate aircraft category, class, type (if required), and instrument rating on that person's pilot certificate for any airplane, helicopter, or powered-lift being flown;
Because not only do the regulations themselves make a distinction between "logging" flight time and "acting" as a required crewmember but almost 35 years ago, the FAA Chief Counsel made it clear
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Section 61.51 is a flight-time logging regulation, under which PIC time may be logged by one who is not actually the pilot in command (i.e., not "ultimately" responsible for the aircraft) during that time. This is consistent with the purpose of Section 61.51, which as stated in 61.51(a) is to record aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of Section 61.
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The same 35 year old discussion then lists seven specific examples, including
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3. The purpose of the flight is instrument instruction actual IFR conditions.
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and says about all of them
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In each situation, the CFI may log PIC time for all flight time during which she or he acts as flight instructor. The pilot receiving instruction may also log PIC time in each of these situations, as the pilot is the sole manipulator of the controls of an aircraft for which she or he is rated.
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Does that help?
