View Full Version : Differences Training

11th Jun 2013, 09:03
Is a tailwheel differences training sign off by a UK instructor valid for someone flying on their FAA licence?

11th Jun 2013, 09:42
If they are an FAA instructor as well.
You have to have your tailwheel endorsement done by an FAA instructor.

Genghis the Engineer
11th Jun 2013, 11:46
If it's a 61.75 FAA licence, yes, because it's carrying a licence privilege over from the EASA licence.

If it's a separate FAA licence, no - unless as darkroomsource says, that instructor happens to also be an FAA CFI or CFII.

I don't think that the term "differences training" is correct in FAAland either.


11th Jun 2013, 13:27
Further to the above input I should point out that it may be unnecessary for the instructor to have been FAA certificated if recourse can be made to the provision in section 61.41 - unless you logged tail wheel PIC time prior to April 15th, 1991.

Section 61.41 widens the definition of an "authorized instructor" to include flight instructors not certificated by the FAA. I state may instead of shall because a strict reading of 61.41 indicates that this provision is limited to flight training toward the issuance of a certificate or rating. Nevertheless, your tail wheel differences training is of a lesser substance than those two qualification categories so there is a reasonable chance that that training for EASA FCL purposes will be acceptable to the FAA. A simple telephone call ought to resolve the uncertainty. In any event if the instruction was received inside the US from a non-FAA instructor then 61.41 will not permit crediting for FAA purposes.

As an aside, and adding to Genghis's comment, it is a misconception among British pilots that all of the limitations upon an EASA FCL licence are applied to an FAA private pilot certificate issued under section 61.75. In particular, familiarisation training is required prior to a person holding an EASA FCL licence exercising his licence privileges on a listing within the SEP (land) class in which he has never before flown. Notwithstanding the prudence in receiving appropriate familiarisation training (or differences training if applicable) it is not legally required when operating under the authority of an FAA private pilot certificate issued under section 61.75. There is an interpretation available from the Office of the Chief Counsel (FAA) on this specific issue: see interpretation to Krausz (March 22nd, 2012) here (http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2012/krausz-beaumont&son%20-%20(2012)%20legal%20interpretation.pdf).

Genghis the Engineer
11th Jun 2013, 13:46
In particular, familiarisation training is required prior to a person holding an EASA FCL licence exercising his licence privileges on a listing within the SEP (land) class in which he has never before flown.

What do you mean by "listing" ?


11th Jun 2013, 13:46
Thanks for the responses. All very clear and in line with my understanding.

The situation is that I am preparing someone with a stand alone FAA PPL to take their skill test and obtain an EASA PPL. It happens that the aircraft we are flying is tailwheel, so I am giving him tailwheel training at the same time.

AIUI, He cannot fly solo in a tailwheel aircraft using his FAA licence because my sign off is not not valid for FAA. However, he can fly dual with me until he passes his EASA skill test (and the necessary exams) and obtains his EASA PPL. Since he will do the test in a tailwheel aircraft I don't think he actually needs to record any differences training before flying solo on his EASA PPL, but I'll give him a sticker anyway.

If he then wants to use his taildragging skills in the US using his FAA licence he will need to get a tailwheel endorsement from an FAA FI.

Anyone see any flaw with this?

12th Jun 2013, 08:04
Genghis, I have not worded that remark carefully enough. If, in lieu of "familiarisation training" the term "differences training" is inserted, then it ought to be correct. By listing I mean variants within, say, the SEP (land) licence endorsement. That is, the separate lines in column 2 of table 10 of the licence endorsement list in the relevant document located here (http://easa.europa.eu/certification/experts/typeratings-list-licence-endorsement-list.php).

What I meant to state was that the FAA and EASA definitions of variants, for the purpose of what amounts to "differences training," are not identical and one obvious example is the use of EFIS on SEPs for which only EASA requires differences training. A couple of other examples will be apparent from comparing EASA's table 10 and the FAA's section 61.31.


If you are providing the training as a CRI instead of as an FI then it might be worth inquiring with Flight Standards (New York IFU (http://www.faa.gov/about/office_org/field_offices/ifo/nyc_ifu/)) to determine whether section 61.41 can be applied. Tail wheel differences training given by an EASA FI is sufficient for section 61.31(i) on the condition that it is given outside the US. If it is done on a US aircraft in UK airspace then the EASA licence of the instructor must have been granted by the UK CAA.

12th Jun 2013, 16:23
I am an FI. The training is being done in a UK reg aircraft, in the UK.

12th Jun 2013, 17:24
Sounds like good news for your client. You'll find the regulations I've mentioned on the US GPO eCFR site (http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&tpl=/ecfrbrowse/Title14/14tab_02.tpl) in case of any doubts.

In the event the question is raised, a TSA security threat assessment isn't required for that endorsement (source) (https://www.flightschoolcandidates.gov/TSA-2004-19147-0337.pdf).

Lastly, if he uses his FAA certificate outside the US he'll need to ensure he has an FCC Restricted Radiotelephone Operator Permit (type RR (http://wireless.fcc.gov/commoperators/index.htm?job=rr) for US citizens/LPRs or persons with US work authorisation, otherwise type RL (http://wireless.fcc.gov/commoperators/index.htm?job=rl)).