rudestuff, thank you for your patience and the references to CAP804.
Section 3.6
Logging of Flight Hours gained in the USA
Some flight hour recording practices allowable in the USA do not comply with European
and UK requirements. In particular:
• 2 pilots flying together in a single pilot aircraft both claiming P1 hours;
• One pilot accompanying another on newsgathering or traffic control flights and
claiming P1/PIC when they have not acted as Captain or signed for the aircraft.
Flying hours of this nature cannot be credited towards the requirements for Part-FCL or
UK Licences.
This advisory information will result in the absurd situation in which neither pilot may log time for Part-FCL, and UK, licensing purposes. Specifically, it contradicts Part-FCL which allows for pilot-in-command time accumulated when acting as pilot-in-command to be counted towards Part-FCL requirements.
For UK and Part-FCL purposes a non-instructed person manipulating the controls, who does not act as pilot-in-command, is deemed to be either a passenger or a candidate undergoing a test, check, or assessment. It is entirely reasonable that such a person when he is a passenger may not log any time on a single-pilot aircraft for Part-FCL or UK purposes. It is not, however, reasonable to discredit the acting pilot-in-command who has undertaken the responsibilities and duties of the position, who has been liable for the safe operation of the aircraft and the safety of its occupants (ironically this outcome under the right conditions can exist under US regulations—Speranza 2009 refers).
Those of you who advocate that a safety pilot cannot be credited with pilot-in-command time for the period when he
acted as pilot-in-command are in fact advocating for a rule disallowing creditable logging by the acting pilot-in-command for the period during which a passenger manipulate the controls. Alternatively, permitting one of the two persons to log pilot-in-command time, but prohibiting the acting pilot-in-command from doing so, results in the passenger logging PIC. Both of these outcomes are absurd.
Section 9: Guide to log annotations
Case A specifies that the pilot whose operating capacity is pilot-in-command should enter time in the P1 column of the logbook. Case N specifies that a pilot whose operating capacity is safety pilot may log supernumerary time. Within the framework of UK and European regulations these designations are mutually exclusive. The designations are
not mutually exclusive under US regulations where a safety pilot may also be the acting pilot-in-command so this section in CAP804 fails to provide a clear indication of UK policy.