I finally got the legal interpretaion from the FAA. You can log PIC without a 299, but you have to be current and qualified in the airplane. Also have to be the sole manipulator of the controls. The 299 is also not seat specific. But, you still must have done a 297 since it is the PIC check usually done in a sim. The 299 is only for a signing captain. If you have had a 299 and you are the signing captain for that flight, you log all of it as PIC regardless of what the other guy is logging. So, this is a situation where both pilots can log PIC. Similar to using a safety pilot for practice approaches. This is all straight from the FAA.
I've read the thread, and it's the same old tired comments, virtually every one of which is wrong.
First of all, opinion is irrelevant. The poster asked a regulatory question. Simply put, if the poster is rated in the aircraft, does he need any 135 checks at all to log time in the airplane NO!!! He does not.
Logging PIC, and acting as PIC are entirely different subjects. You do not need to be the PIC, to log PIC as sole manipulator of the controls. This is not disputable, and is clearly spelled out in the regulation, as well as numerous legal interpretations.
Now, as far as your own "legal interpretation," I get the awful feeling that you spoke to someone at the FSDO level and came away with what you thought was an answer. Bottom line here; if that answer came from the FSDO level, even from your POI, it has no weight and no merit beyond a personal opinion. It's not defensible, you can never hold it up to scrutiny or in defense of your actions, and the Administrator doesn't recognize it, nor support it.
If that interpretation came from the regional or chief legal counsel, that's another matter...but as it disagrees with the FAA Chief Legal Counsel interpretations, it would appear you got a personal observation at the lower levels.
Now, from a legal point of view, PilotYip is incorrect. You may log the time. From a practical point of view, Pilotyip is very correct; if you log the time and attempt to use that time toward a 121 or 135 job, most employers will consider it inappropriate, discount it, and most likely view you in a lesser light as a result. If you log it and use it toward a Part 91 job, most employers will count it just like any other time.
Are you legal to log the time? Yes. Should you? That's really up to you. If you're applying to a certificate holder then you will need to be sure to separate the times, and not claim time that you weren't actually the acting PIC.
Back to the legality...I said if you were rated in the airplane (category, class, and if appropriate, type), you could log the time as sole manipulator. I also said you don't need the 135 checks at all to do this. This is true, HOWEVER: you must pass your 135 checks in order to manipulate the controls in the first place.
Your specific question is if you can be a rated SIC (rated in the airplane) and still log PIC legally. Yes, you may. Should you...again, up to you, but be sure you don't hold that time out as PIC to a certificate holder, because it will make you look bad. As a rated SIC, you can log the time as PIC if you wish. You can only do it as sole manipulator, and can only be sole manipulator if you are qualified to manipulate the controls in this case, under Part 135...your SIC checks, at a minimum, must be complete.
People get wrapped around the axle over the differences between logging PIC and acting as PIC. These are very different subjects, and shouldn't be confused.
Remember too that under the regulation, it's the certificate holder that designates the PIC before the flight, and the PIC remains the PIC throughotu the flight. Some pilots try to switch back and forth every other leg, and you can do that as manipulator of the controls...but the PIC remains the PIC, even if you're swapping legs. Sometimes pilots are under the mistaken impression that if they call themselves "cocaptains," they alternate being PIC every leg. In a 121 or 135 operation, this doesn't happen. You can still log it legally as PIC, but unless you're the designated PIC, that's as far as it goes.
Pilotyip is worth listening to on the subject; his advice here is strictly practical. He does the hiring and interviewing at his company, which includes light jets and big jets, and he sees a lot of people come and go. He's giving it to you straight from the horses mouth, as one who is sitting in the hiring seat, and makes the decisions that he's described. He's telling it to you as a benifit; you'll do well to listen.
