I completed my IFR checkride on the 15th of May this year, the next day I moved to Spain to study my EASA ATPL (airline transport pilot license).

A friend of mine here in Spain is doing his time building and I am allowed to sit in the right seat with him. Would I be allowed to log my approaches (66HIT) from the right seat even though I don't have an EASA PPL and the aircraft is registered in Spain?

I ask because that would save me the cost of paying for an instructor and a checkout flight as well as the hassle of flying alone in airspace which is completely new to me!


The short answer is no, because - I assume, based on what you said - you have no legal way to log the approaches (and the holding and tracking!).

14 CFR 61.57 says (my emphasis):

Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered-lift, helicopter, or airship, as appropriate

And 61.51 says you must log:

(2) Type of pilot experience or training—

(i) Solo.

(ii) Pilot in command.

(iii) Second in command.

(iv) Flight and ground training received from an authorized instructor.

(v) Training received in a flight simulator, flight training device, or aviation training device from an authorized instructor.

Unless you can legally - i.e. under Spanish/EASA rules - log time in the Spanish aircraft as PIC, SIC or training time then you can't use the time for FAA purposes. Although I can't find a regulation or legal interpretation for that, I can share some personal experience: I've logged training time in South Africa where I was receiving post-PPL instruction in an aircraft and I was the sole manipulator of the controls. Under FAA rules I could log PIC for that time but under SA rules I couldn't (because their regs say/said that each flight has only one person who can log PIC).

My local FSDO told me that according to the regulations in force for the flight, I couldn't log PIC time and therefore I couldn't count it as 'FAA PIC time'. I should say that I didn't have an FAA license at the time, only an SA one, but the FSDO's point was that you can only do (and log) whatever is legal for each individual flight at the time it happens.

On the other hand, if you did have an EASA PPL, it would be fine: the FAA doesn't care where you log time as long as you log it legally and correctly.

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    $\begingroup$ You don't have to be able to operate as PIC to log PIC. Consider 61.51(e)(1)(i): you just need to be rated in category + class for the aircraft. Don't know if the rating only extends to N-registered aircraft, though that may be elsewhere in pt. 61 $\endgroup$ – NathanG Nov 11 '16 at 17:29
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    $\begingroup$ I'm not sure this is correct. AFAIK as long as he is "sole operator of the controls" he can log PIC regardless of whether he is legally PIC. As long as he is properly rated for the aircraft under FAA rules he can log any time he is sole operator. The distinction between logging PIC and acting as PIC has been made in numerous questions on aviation.se $\endgroup$ – TomMcW Nov 11 '16 at 19:07
  • $\begingroup$ @TomMcW That'a true, but the regulation actually says "sole manipulator of the controls of an aircraft for which the pilot is rated". So, is a US pilot rated to fly a Spanish aircraft in Spain, using only a US certificate? I would say no. $\endgroup$ – Pondlife Nov 11 '16 at 19:35
  • $\begingroup$ If he's rated for that same aircraft type I the US I don't see why not $\endgroup$ – TomMcW Nov 11 '16 at 19:37
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    $\begingroup$ Logging approaches and instrument time does not require that PIC or SIC time be logged as well. $\endgroup$ – J Walters Nov 11 '16 at 21:17

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