"Mark Hansen" wrote in message
...
This flight is for regaining currency on the part of the pilot flying.
Without the pilot flying, there is no purpose for the flight. For this
flight, the pilot flying is required - as you must have a pilot flying.

You're right that the sole-manipulator pilot is required for the purpose of
that flight. And since the instrument-rated PIC is required too (to be legal
for IFR), you're right that that does add up to more than one pilot required
for the purpose of the flight.

Nonetheless, there is not more than one pilot required *by the regulations
under which the flight is conducted* (as opposed to being required by the
purpose of the flight). And requirement *by the regulations under which the
flight is conducted* is the criterion set forth by 61.51e1iii.

If instead the criterion were just that more than one pilot is required *for
the purpose of the flight*, then the criterion that more than one pilot is
required could be met on *any* flight--because if the purpose of a
particular flight is to allow the sole-manipulator and the acting-PIC both
to log PIC time simultaneously (therefore at half the cost to each), then of
course both pilots are indeed required *for that purpose*! But then the
multiple-pilots-required criterion would be meaningless. Therefore, the
multiple-pilots-required criterion couldn't reasonably be interpreted to
mean that the multiple pilots are merely required *for the flight's
purpose*. (And again, the regulation explicitly says that multiple pilots
must be required *by the regulations under which the flight is conducted*.)

I would really like to see something from the FAA on the subject.

That's certainly appropriate. I'm only addressing what the FARs can
reasonably be intepreted to mean, which is something we can analyze on our
own. But how the FAA actually interprets the FARs is a separate question
that requires additional evidence to answer.

--Gary