Roger Long wrote:

Here is the letter:

http://baldeagleflyingclub.org/FAAopinion.pdf

It really does say "to build flight time". So not using that time would
appear to be a loophole. Wild!

[...]
The insurance company will probably follow the same dynamics but you
should
check with them. I have had excellent experience discussing things like
this very frankly with Avemco. You get points with them for asking and
appearing to be concerned and attempting to do the right thing. They'll
remember that if there is an incident.

Thanks for the letter and the suggestion.

- Andrew