There is no regulatory requirement that you be able to act as PIC in order
to log PIC under any circumstances.
[...(^-1)]
A strict reading of these two [quoted below] regulations would indicate that a
private
pilot holding a certificated for single engine land airplanes may log PIC
for the time he is acting as safety pilot in a complex or high performance
airplane whether he is signed off for those airplanes or not.


In this case, I think not.


(e) Logging pilot-in-command flight time. (1) A recreational, private, or
commercial pilot may log pilot-in- command time only for that flight time
during which that person --

(i) Is the sole manipulator of the controls of an aircraft for which the
pilot is rated;


Well, this doesn't apply to a safety pilot, unless the flight is already going
badly.


(ii) Is the sole occupant of the aircraft; or


Doesn't apply to a safety pilot. I'll let you figure out why.


(iii) Except for a recreational pilot, is acting as pilot in command of an
aircraft on which more than one pilot is required under the type
certification of the aircraft or the regulations under which the flight is
conducted.


So we're left with this. In this case the safety pilot must be able to act as
PIC. He or she can't do this unless they have the endorsements appropriate to
the aircraft (i.e. if high performance, tailwheel, or whatever).

So, you can't log PIC as a safety pilot unless you ARE PIC, and have the
(necessary) endorsements to act as PIC.

Jose



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