All I asked was about the legalities of logging PIC time to meet R-ATP requirements. I never mentioned logging thousands of hours as PIC time to make myself look better during an interview. Acting and logging PIC are completely different things. I specifically stated it was for the purpose of meeting R-ATP requirements. After calling the FAA examiner who did my CFI checkride, he agreed with me but told me he cannot legally interpret any regulations for me and pointed me to the right place...FAA letter of interpretations. I have quoted parts of those interpretations to clarify multiple comments made in here. If you disagree, point the specific reference that would make logging such a flight time illegal.
It does not matter if you use autopilot you can still log PIC under "sole manipulator".
FAA 2015 letter of interpretation for Murphy states:
"The first logbook question, briefly stated, asks whether a pilot who uses an autopilot is sufficiently "manipulating the controls" of the aircraft to allow the pilot to log that time as pilot-in-comment (PIC) flight time. For the reasons stated below, a pilot may
log PIC time as the sole manipulator of the controls when the pilot uses an autopilot."
The term rated does not apply to the operation (part 135/121) but only applies to the aircraft. It does not matter if you are IFR/VFR in part 91, 121, or 135. Therefore, you do not need to be 135 IFR PIC qualified. All you need is the SIC ride to be able to legally log any sort of flight time during such operation.
FAA 2009 Interpretation for Speranza:
"The FAA previously has stated the term "rated," as used in 61.51(3), refers to the pilot holding the appropriate aircraft ratings (category, class, and type, if a type rating is required), and these rating are listed in 14 C.F.R 61.5 and are placed on the pilot certificate. ..As correctly noted in your letter, for the purpose of logging PIC time under 61.51(e), a pilot must hold ratings for the aircraft rather than for the conditions of flight. "
If you are still not convinced (idk what will) than answer this. How come a Private pilot, who is not instrument rated, can log PIC time with a CFII during a instrument lesson in IMC conditions in an IFR flight plan?
The Private pilot is not the "real Pic" but is still logging PIC time. Weird.