Jose wrote:
There is no regulation in the above proposal that requires multiple
pilots (the requirement for the non-flying pilot to log PIC under
61.51(e). The FAR that requires multiple pilots says "simulated
instrument conditions".

As soon as you put the hood on, you are in simulated instrument
conditions, whether in cloud or not, and whether IFR or not. You may
=also= be in actual instrument conditions, but that is irrelevant.

Are you sure about that part? I wouldn't have thought so.

Brad