Converting FAA to TC then back again... loophole?

[rudestuff]

As I understand it:

In the US a multi engine rating done at three levels - PPL, CPL and ATPL, so a PPL(ME) taking a SE commercial would end up with commercial SE and private ME (Hence most people do multi only at CPL level)

In EASA: The multi engine is a rating without 'level' so to speak, so a private pilot with a ME rating can do a SE CPL test, and the ME rating upgrades automatically (Hence most people do it as a PPL)

From what I read - the Canadian system is the same as EASA, which leads to the following question:

Could an FAA PPL do a private ME test, convert to TC via an exam to Canadian PPL(ME), then do a Canadian CPL(SE) test - and end up with a CPL(ME)? Because if so, presumably that could be converted back to FAA...

[MarkerInbound]

The TC guidance seems to indicate that Canda issues class ratings for the commercial license.

"Multi-engine Class Rating - Requirements

(a) Skill
An applicant for a multi-engine class rating shall successfully complete a flight test as pilot-in-command of a multi-engine class aeroplane, in accordance with Schedule 7 “Flight Test for the Issuance of a Multi-Engine Class Rating – Aeroplane” of Standard 428 - Conduct of Flight Tests."

[surveytheworld]

The Canadian license has a class rating, but it is separate from if it's a commercial or a private license.

For example, when I first got my Canadian commercial license, I hadn't yet done my multi rating so it had in the "class" section SEL - "single engine land."

After I did my multi rating (which is a stand-alone rating, I did mine in less than 3 hours) my commercial license then said, in the "class" section "SMEL" - single and multi-engine land.

However, if one does their multi rating with just a private license, then gets a commercial license (even if they did not do any extra training or flying on a twin) the class will still remain valid - SMEL.

The only time the class matters for the type of license is the ATPL - the qualifying flight test for that is an IFR ride in a multi-engine airplane.

Hope that helps a bit.

(I actually have a Canadian friend who made use of a loophole to get a TC ATPL faster by converting his TC CPL to an FAA CPL, then getting an FAA ATPL, then converting THAT to a TC ATPL but haven't heard of anyone doing the reverse.)

[peekay4]

It depends on each student's situation I guess. But under Part 141 one can potentially get an FAA commercial cert for much fewer hours than a converted TCCA commercial license.

E.g., it's possible to get an FAA commercial with just 190 hours total, but to get one through Canadian conversion you must have logged 250 total hours (same as Part 61). That 60 hour difference (+/- depending on the student) pays for a ME rating/checkride many times over.

Plus generally speaking, flight training in the US can be much cheaper than in Canada (maybe unless the CAD continues to plunge), so I think one is unlikely to save any money by doing a CPL course in Canada and then converting back to an FAA license.

[surveytheworld]

Do also note that Canada views "solo" time logged towards a commercial license differently than how the US views "solo" (PIC) time. I can't recall the exact details as it's been 15 years since my UND days, but the FAA was a lot more lax in what it counted as solo... I think you could even count it as solo if you were with another student logging it as solo?? Anyhow, in Canada, solo is solo when it comes to logging time for the CPL.

Just something to confirm if you come up to the (not so frozen, this year) north.

[rudestuff]

The FAA PIC is the issue, rather than solo. FARs allow you to log pic time if you are (a) PIC, or (b) sole manipulator of the controls of an aircraft you are rated in. So dual received by a PPL holder can be logged as PIC by both. You can also fly under the hood with a safety pilot (nominated as PIC) and both legally log PIC. Obviously these hours are weeded out by other authorities. What's the score in Canada?

[surveytheworld]

Aha, that's it, rudestuff, thanks.

This kind of stuff would be scrutinized by Transport Canada in the case of a conversion or an application for a higher license.

Only one pilot may log PIC at a time in Canada, no matter what. If I take a PPL holder up for some hood time, I as the instructor would log PIC and the PPL holder would log dual.

(Side note - I could never really comprehend how there logically could be two PICs on board one aircraft...)

[peekay4]

(Side note - I could never really comprehend how there logically could be two PICs on board one aircraft...)
There is only ever one PIC: the person with the final authority over the flight. However, per FAA rules, there is a distinction between being the PIC and logging PIC hours.

I.e., an appropriately rated pilot who is not the PIC may still log PIC hours in some circumstances, most notably when that pilot is "the sole manipulator of the controls of the aircraft". See FAR 61.51(e)(1).

For example, a rated PPL holder receiving dual IR instruction from a CFII may log PIC when s/he is the "sole manipulator" of the aircraft. Here the CFII is the PIC and has the "final authority" over the flight; The PPL pilot is not the PIC but may still log PIC hours as the "sole manipulator".

[+TSRA]

rudestuff,

You'll tend to find any regulator frowns upon converting a license or rating that was itself converted. In your example you could convert to the Canadian ME rating but it is likely that the FAA would not let you "re-convert" it back.

Case in point, I had a Canadian PPL, went to New Zealand to convert it to an NZ PPL. I did my NZ CPL, Instructor Rating and ME-IFR ticket plus a couple hundred hours of flying for a scenic operator. When I came home to Canada, Transport Canada made me re-do the examinations and flight tests for the CPL and ME-IFR (I never re-did my instructor rating). Their rationale was the original NZ license was based on a conversion and even though I held a Canadian PPL, I was trying to convert a foreign CPL based on a foreign PPL that had been obtained via a conversion. Same with the Instructor Rating and ME-IFR - although my Instructor Rating had lapsed in NZ, so Transport Canada was going to make me do every hour all over again. Phew, that is complicated (and expensive) now that I think of it!

Along the same theme, had I gone over to Australia I would not have been qualified for the NZ-AUS open agreement on my PPL because it was a converted license. However, because I obtained a CPL in NZ, my CPL was valid for the conversion - go figure.

License conversions tend to be murky waters with a couple loopholes that are very quickly filled in once discovered. As others have pointed out, countries differ on their application of PIC, Dual, Co-Pilot, Night - you name it. Other times they have the same definition but different requirements - for example NZ needed 5 hours night for the CPL, Canada needed 10 hours - so even though I had an NZ CPL, I had some extra night time building to do.

Where ever possible, I now suggest to anyone that they just do it all with their local regulator. Otherwise, they end up spending more money one way or the other for what will amount to a couple of hours that no one looking at the logbook will really care about.

Good luck! :)