Originally Posted by Capt Loop
A visa is ONLY required on a FULL TIME training course doing over 18hrs of flying a week.
A visa to study is required when a "course of study" is being undertaken. See above memorandum and 8 CFR 248.1(c).
Your reference to 18 hours is a conditional requirement for a "full course of study" under a vocational curriculum (not provided by a high school), e.g. training requiring an M-class visa.
Originally Posted by 8 CFR 214.2(m)(9)(iii)
Full course of study. Successful completion of the course of study must lead to the attainment of a specific educational or vocational objective. A “full course of study” as required by section 101(a)(15)(M)(i) of the [Immigration and Nationality Act] means ... [s]tudy in a vocational ... curriculum ... certified ... to consist of at least eighteen clock hours of attendance a week if the dominant part of the course of study consists of classroom instruction, or at least twenty-two clock hours a week if the dominant part of the course of study consists of shop or laboratory work.
Originally Posted by Capt Loop
If you were not up to speed and needed more flying then as long as you dont exceed the 18 hrs then your good.
Flying is closer to shop/laboratory work than to classroom instruction so the lower bound for an M-visa should be 22 "clock hours" per week. You're a bit screwed if doing fewer hours than this since a "course of study" can't lawfully be pursued on a B visa (visitors / visa waiver program). I'm sure Uncle Sam is willing to turn a blind eye if the money flows fast enough.