Some interesting points here, clearly the TSA views the issuance of a non 61.75 license to a otherwise qualified pilot as a security issue. Although it’s just another tedious bunch of restrictions to be complied with it’s hardly a barrier to anything; more of a pay up and look big situation.
It is strange, however, that they don’t go the whole hog and require TSA approval for any license issue rather than exempting 61.75 but, hey it makes it a lot easier to just go out and fly!
As mentioned above 61.39 C is a little perplexing. Presumably, the intent is to allow those who have been trained to ICAO standards to be accepted as trained pilots, but as SoCal states there is no mention of whether you need current validity. In fact, my letter of validity stated that the CAA could not verify that the currency (24 month check with an instructor) had been complied with. It is, however, logged and signed off – just not certified by the issuing state. So in this case a letter from the CAA will be of no help other than to show that a valid license has been obtained.
The real barrier is the visa requirement. A M1 visa, as far as I can make out, requires a course of approved training. Clearly, if that is the case, a few ad hoc trips with and instructor on board can’t be seen as that either by the chosen school or the visa issuing folks.
Applying for a visa and getting turned down is not good news and complicates an already difficult procedure. On the other hand, training, which seems to be the TSA definition of this, on a B2 visa could lead to more drastic conclusions. I also don’t think the training schools will want to be bothered with a few hours ad hoc on an M1 especially when they state right up front that they want 10hrs minimum flying and 22 hrs weekly total study time.
Aviation training in the US since 911 has become a very thorny subject. What used to be very relaxed and lead to amicable chats with immigration officials upon arrival has turned into something rather sinister. The real problem is that you can’t just phone up the consulate service and say this is what I would like to do, how do I proceed? It’s apply and then find out – by which time it’s too late.