I don’t disagree
The EASA regs do not forbid to log DUAL and PIC …
Credit for a licence, rating, or certificate under the Aircrew Regulation will be given for flight time in only one of those capacities during any given portion of a flight.
FCL.035 Crediting of flight time and theoretical knowledge
(a) Crediting of flight time
(2) PIC or under instruction
… they especially encourage that with the definition of SPIC
The meanings applied to student pilot-in-command and dual instruction time in FCL.010 Definitions are mutually exclusive.
These times are not conformable to being recorded concurrently.
“Dual instruction time” means flight time or instrument ground time during which a person is
receiving flight instruction from a properly authorised instructor.
“Student pilot-in-command” (SPIC) means a student pilot acting as pilot-in-command on a flight
with an instructor where the latter will only observe the student pilot and shall not influence or
control the flight of the aircraft.
It is worth pointing out that SPIC time applies only to a student pilot, cf FCL.020. Normally these are student pilots undergoing integrated training courses although the term is also used in the AMC for the helicopter night rating course.
None of this precludes recording flights differently for separate purposes as others have mentioned. To add to NCYankee’s comment see the opinion given to John Speranza on 4 Dec 2009 by Rebecca B MacPherson, Assistant Chief Counsel for Regulations.
The safety pilot required by SERA.3220(b) for simulated instrument flight should not record time in the capacity of co-pilot for Aircrew Regulation purposes. At least that is the received wisdom here in the UK and I am not aware of a single provision in Part-FCL that easily resolves the matter.
According to FCL.050 “[t]he pilot shall keep a reliable record of the details of all flights flown in a form and manner established by the competent authority.” The UK CAA for example wants candidates to log PICUS after a successful test/check, eg the UK Flight Examiners’ Handbook (link) at para 4.6.3 (disregarding the obvious contradiction):
“Examiners may countersign the applicants’ logbook as PICUS following a successful test or
check. PU/T is to be entered when the test is not passed or when the applicant does not hold a
current medical or class/type rating.”
To be consistent with Part-FCL the successful candidate would have been a co-pilot whereas the unsuccessful one would have been under instruction. The meanings applied to PICUS and co-pilot in FCL.010 are:
‘Pilot-in-command under supervision’ (PICUS) means a co-pilot performing, under the supervision of the pilot-in-command, the duties and functions of a pilot-in-command.
‘Co-pilot’ means a pilot operating other than as pilot-in-command, on an aircraft for which more than one pilot is required, but excluding a pilot who is on board the aircraft for the sole purpose of receiving flight instruction for a licence or rating.
So it follows in the mind of UK CAA that a co-pilot can exist without the rules governing multi-pilot operations needing to be followed, cf FCL.720.A(a) (MCC & advanced UPRT) and the appendix 9 requirement on passing a proficiency check in multi-pilot operations. If it is true for a test or check then why not also on a simulated instrument flight with a safety pilot? Or on flights requiring a safety pilot by reason of an OSL/ORL limitation endorsed on medical certificate of the PIC? The UK CAA Safety Pilot Briefing Sheet (link) dated Jan 2013 states “[u]nless you have to take over the controls you are supernumerary and cannot log any flying time.”
Personally I’m of the view that safety pilots are not co-pilots and that co-pilots exist only in multi-pilot operations, as defined in FCL.010, but I have been wrong before…
@Malibuflyer Thinking about it again, there are at least two scenarios where it is important to know, whether I use the EASA or the FAA license.
The topics are IFR flight and Night landings. As the currency is different according to EASA and FAA, you might be current on one, but not the other. So which currency is now required for a flight that can be done on any license?
Again I think it is an academic exercise that will only be important, once there is an accident or another type of investigation.
@Qalupapik What is meant with PU/T and where is this in EASA regs? Same question regarding P1, is this all old (and after leaving the EASA)/new UK CAA terminology?