That's a good idea. ANO 129 defines crew as flight crew plus others, and flight crew as "those members of the crew of the a/c who respectively undertake to act as pilot, flight navigator, flight engineer, and flight r/t operator". Define your reporter as the navigator and you're in the clear.
I can't see if you need a special qualification to be a flight navigator so to be even more secure get your reporter a FRTOL license (should only take a week or so) and call him the r/t operator. Then he can patch his reports back via a VHF company frequency !