Rustle wrote to EA:
Under your interpretation two non-rated (vanilla PPL) pilots could fly with the screens up, RHS doing the VFR compliance bit, LHS "practicing" in simulated IMC, with the RHS being P1 and neither qualified to fly in IMC.
And indeed EA is correct.
In France, a pilot is legally permitted to simulate flight in Instrument Conditions providing he carries an appropriate lookout. This lookout pilot does not need to be Instrument Rated but must be able to maintain an adequate look-out despite any vision limiting devices that are in use. The Lookout is supernumary, and may not log time. Flight conducted in this fashion must obey VFR. This extends to ensuring that the flight is flown at the appropriate VFR cruising level (semi+500).
If two such pilots elect to practise an instrument approach, they are free to do so in France, although it is customary to telephone in advance for permission. In requesting the approach, the PIC must make it clear that the approach will be flown under a VFR clearance. This clarifies (especially in Class E airspace such as LFAT) just who is responsible for separation between the flight and other VFR traffic.... ie The PIC, not ATC.