FAA 61.75 'Piggy back' Certificate Validity

[Gustosomerset]

Apologies if this has been covered elsewhere. I've found much discussion about the process of getting this certification based on an EASA PPL(H) and understand that, but remain unclear on one point. I have been told that the FAA 61.75 'restricted' certificate (like the full FAA license) is not based on specific aircraft type ratings. Because of this, in effect, the 61.75 certificate allows the holder to fly any helicopter (up to a certain MTOW) in the UK, without having to go through the EASA process of type conversion involving 5 hours conversion training, exam, etc. On the other hand, I have also been told that: "...the 61.75 certificate covers only the type’s on your UK license." Which is true?

If the FAA certificate does not restrict you to a type, you would, presumably, need to persuade your UK insurer that you were adequately trained to fly any aircraft on which you are not rated on your EASA license - and I'm not sure how you'd do that...

[Gordy]

You are limited to what is on your EASA certificate:

See Here (http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/0/56D0240EC0FE7FA58625768F005C1C7D?OpenDocument) Bold red added by me.


Sec. 61.75

Private pilot certificate issued on the basis of a foreign pilot license.

(a) General. A person who holds a foreign pilot license at the private pilot level or higher that was issued by a contracting State to the Convention on International Civil Aviation may apply for and be issued a U.S. private pilot certificate with the appropriate ratings if the foreign pilot license meets the requirements of this section.
[(b) Certificate issued. A U.S. private pilot certificate issued under this section must specify the person's foreign license number and country of issuance. A person who holds a foreign pilot license issued by a contracting State to the Convention on International Civil Aviation may be issued a U.S. private pilot certificate based on the foreign pilot license without any further showing of proficiency, provided the applicant:]

(1) Meets the requirements of this section;
[(2) Holds a foreign pilot license, at the private pilot license level or higher, that does not contain a limitation stating that the applicant has not met all of the standards of ICAO for that license;

(3) Does not hold a U.S. pilot certificate other than a U.S. student pilot certificate;
(4) Holds a medical certificate issued under part 67 of this chapter or a medical license issued by the country that issued the person's foreign pilot license; and]

(5) Is able to read, speak, write, and understand the English language. If the applicant is unable to meet one of these requirements due to medical reasons, then the Administrator may place such operating limitations on that applicant's pilot certificate as are necessary for the safe operation of the aircraft.

[(c) Aircraft ratings issued. Aircraft ratings listed on a person's foreign pilot license, in addition to any issued after testing under the provisions of this part, may be placed on that person's U.S. pilot certificate for private pilot privileges only.
(d) Instrument ratings issued. A person who holds an instrument rating on the foreign pilot license issued by a contracting State to the Convention on International Civil Aviation may be issued an instrument rating on a U.S. pilot certificate provided:]

(1) The person's foreign pilot license authorizes instrument privileges;
(2) Within 24 months preceding the month in which the person applies for the instrument rating, the person passes the appropriate knowledge test; and
(3) The person is able to read, speak, write, and understand the English language. If the applicant is unable to meet one of these requirements due to medical reasons, then the Administrator may place such operating limitations on that applicant's pilot certificate as are necessary for the safe operation of the aircraft.
(e) Operating privileges and limitations. A person who receives a U.S. private pilot certificate that has been issued under the provisions of this section:
[(1) May act as pilot in command of a civil aircraft of the United States in accordance with the pilot privileges authorized by this part and the limitations placed on that U.S. pilot certificate;]
(2) Is limited to the privileges placed on the certificate by the Administrator;
(3) Is subject to the limitations and restrictions on the person's U.S. certificate and foreign pilot license when exercising the privileges of that U.S. pilot certificate in an aircraft of U.S. registry operating within or outside the United States; and
[(f) Limitation on licenses used as the basis for a U.S. certificate. A person may use only one foreign pilot license as a basis for the issuance of a U.S. pilot certificate. The foreign pilot license and medical certification used as a basis for issuing a U.S. pilot certificate under this section must be written in English or accompanied by an English transcription that has been signed by an official or representative of the foreign aviation authority that issued the foreign pilot license.
(g) Limitation placed on a U.S. pilot certificate. A U.S. pilot certificate issued under this section can only be exercised when the pilot has the foreign pilot license, upon which the issuance of the U.S. pilot certificate was based, in the holder's possession or readily accessible in the aircraft.]

Amdt. 61-124, Eff. 10/20/09

[Gustosomerset]

Gordy. Thanks for this...but I'm not sure that this answers my question. The section you highlight concerns flying 'aircraft of U.S. registry' - I'm talking about flying any aircraft (i.e. in effect G or N reg) in the U.K.
In addition, I think that 'limitations and restrictions' (which are carried across) are different to 'ratings and privileges' as defined on the EASA license. I cannot see any specific mention of 'ratings and privileges' being automatically carried across from the foreign (i.e. UK) license to the FAA certificate. Just above the para you highlighted it says that "(the pilot) ..is limited to the privileges placed on the certificate by the Administrator" - but that's not quite the same thing.

It does seem unlikely to me that this is the case - but the reason I ask is that I am assured that there a significant number of pilots operating in this way - flying helicopters on their FAA certificates for which they are not specifically rated on their EASA licenses - in the UK currently.

[Gordy]

In the US, the license and ratings are considered a privilege. Therefore if you had "Robinson R-22 and Bell 206" on your EASA license, and you used that as the basis to get an FAA license, you are restricted to flying those aircraft types on the FAA license.

Is subject to the limitations and restrictions on the person's U.S. certificate and foreign pilot license when exercising the privileges of that U.S. pilot certificate in an aircraft of U.S. registry operating within or outside the United States; and

Note it states "and foreign pilot license".

The only way to add other types is to get the EASA rating or complete a full FAA checkride---one that is not based on 61.75

[Gustosomerset]

I realise I may be going up a blind alley here...but, as you quote, the US 'restricted' license is subject to the same limitations and restrictions as the foreign (UK) license.
It does not say that it is subject to the same ratings and privileges and I am led to believe that those are differently things.

As I understand it, the FAA licensing system (unlike the EASA system) no longer has type ratings for helicopters under a gross takeoff weight of over 12,500 pounds.
Therefore a full FAA license covers flying any helicopter that meets that requirement (except Robinsons, but that's another issue).
The question is whether the 61.75 piggyback FAA certificate follows that same model.

[havick]

The validation/cornflakes box FAA ppl that you will receive will be based on your foreign license. you need to keep your EASA license and certificate current in every respect in order to exercise the FAA PPL you will receive based on your foreign license.

if you’re planning on flying an N reg in the UK to avoid all the currency and beuracracy requirements that is EASA then you’re best to bite the bullet and spend a week and about 3-5k getting your FAA PPL or CPL and class 1 or 2 medical and be done with it and give EASA the middle finger.

[Gordy]

I am trying to help you dude. You are correct that:

the FAA licensing system (unlike the EASA system) no longer has type ratings for helicopters under a gross takeoff weight of over 12,500 pounds.
Therefore a full FAA license covers flying any helicopter that meets that requirement (except Robinsons, but that's another issue).


I have put the link AND an explaination to this:

The question is whether the 61.75 piggyback FAA certificate follows that same model.
NO IT DOES NOT. 14 CFR 61.75 (e)(3) states:
(e) Operating privileges and limitations. A person who receives a U.S. private pilot certificate that has been issued under the provisions of this section:

(3) Is subject to the limitations and restrictions on the person's U.S. certificate and foreign pilot license when exercising the privileges of that U.S. pilot certificate in an aircraft of U.S. registry operating within or outside the United States;

As an example, if on your EASA license you are limited to flying a Bell 206 as this is the only rating you have, then that is a limitation that is subject to para (3).

Seems pretty black & white & RED to me, but I have never had an EASA license and have no desire to get one.

I second Havic's advice.

[Gustosomerset]

Havick - thanks for that. I agree that, in reality, the only sensible option is probably to get a full FAA license.
Gordy, thanks for trying to help but we seem to keep talking past each other. Your quotes clearly show that the FAA 61.75 certificate is subject to the limitations and restrictions of the foreign (UK) license, but I cannot see where it says that it is also subject to the same ratings and privileges and I continue to believe that these are two separate sets of things. Thanks for your help in any case.

[Gordy]

I guess I have been out of the legal loop for a while---for those who know me, I was pretty active with legal interpretations. Here is the answer to your question, which s the opposite of what I was stating:

grossman-delvag luftfahrtversicherungs - (2014) legal interpretation (https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2014/grossman-delvag%20luftfahrtversicherungs%20-%20(2014)%20legal%20interpretation.pdf)

To add, US law is based upon Juris Prudence. FAA law is technically "Administrative Law" in that the order of precedence for rules is as follows:
1. Public Law/statutes
2. Federal Regulations
3. FAA legal interpretations (for those interpretations that have been updated to conform to the current rules).
4. FAA orders (for those directives/guidance that have been updated to conform to the current rules)
5. FAA notices (for those directives/guidance that have been updated to conform to the current rules)
6. FAA bulletins (for those directives/guidance that have been updated to conform to the current rules)
7. Parts 61 & 141 Frequently Asked Questions, (Q&As)
8. FAA Advisory Circulars

[B2N2]

limitations and restrictions of the foreign (UK) license, but I cannot see where it says that it is also subject to the same ratings and privileges and I continue to believe that these are two separate sets of things.

You are confusing two things.
If your EASA certificate has a limitation that carries over.
it is very common for non-FAA licenses and certificates to carry a maximum take off weight limitation. That carries over.
if your EASA Certificate states that you are rated in a R-22 then that is also a LIMITATION in the eyes of the FAA as under the FAA License/Certificate system such type limitations do not exist.
Another good example is your night rating.
If you do not hold a night rating then you cannot fly at night in an N-reg on a piggy back certificate till you’ve met the FAA night flying requirements.

Now....your EASA certificate does not say ‘No night’
It says VFR day. Follow me on the semantics.

So for the sake of the discussion your EASA certificate states VFR Day R-22.
On your FAA validation you can now only fly VFR day in a R22.

The licensing systems are different so your permission to fly one type becomes a limitation or restriction on the other since no other types are listed.
The fact you have a make/model/type listed becomes the restriction as by default that’s the only one you can fly in Europa land.
Should make sense now.

My background: FAA Flight Instructor full time for 13 years and 80% European customers as our school.
We’ve literally done 100’s of these validations.

[Gustosomerset]

Gordy - Ah! Thanks very much for that reply. That legal judgement is exactly on my point. The critical phrase, it seems to me, is: "the FAA has not considered the absence of a rating as a restriction on a person's pilot certificate." That is the distinction I was searching for and, as you say, shows that the answer to my question seems to be the opposite of a) what one would expect, b) what you were originally stating and c) what B2N2 subsequently says....unless, of course, the FAA interpretation has changed since that judgement.

[Gordy]

The licensing systems are different so your permission to fly one type becomes a limitation or restriction on the other since no other types are listed.
The fact you have a make/model/type listed becomes the restriction as by default that’s the only one you can fly in Europa land.
Should make sense now.

My background: FAA Flight Instructor full time for 13 years and 80% European customers as our school.
We’ve literally done 100’s of these validations.
B2N2:
You may wish to go read the legal interpretation I posted. You are in-correct, as was I initially.
FAA flight instructor 28 years. Trained many Europeans back in the day.

[Gordy]

unless, of course, the FAA interpretation has changed since that judgement.

I did a search of the interpretations and as of today and that search, this one is controlling. Bear in mind it could be superseded by an NTSB law judges finding also, but have done a quick search and found nothing.

[havick]

We’ve literally done 100’s of these validations.

The validation and FAA ppl based on a foreign license is nothing more than a paperwork exercise that does not involve a flight school or instructor in any way shape or form. Only a FSDO gets involved when they review your paperwork. So unless you were unnecessarily taking people’s Money for a paperwork exercise that they can do themselves without any flying required, I have no idea how you would have done 100’s of these validations.

now if your want to switch your license to an FAA certificate which requires a flight test then that’s a different story and then a flight school and DPE would have involvement.

[Gustosomerset]

Gordy - So that legal interpretation is very clear. FAA 61.75 'piggy back' certification, based on a foreign (i.e. EASA) license DOES NOT (contrary to popular belief) restrict the holder to fly only those types for which he or she is rated on their EASA license.
Instead, it confers the FAA privileges of 'an airplane category rating' which, in the case of light helicopters for example is 'any under a gross takeoff weight of over 12,500 pounds'.
I imagine this could be very useful to anyone wishing to fly multiple types without having to go to the expense of gaining multiple type ratings under EASA rules.

However, the FAA go on to say that: "...our interpretation addresses only the requirements to operate a U.S.-registered aircraft under our regulations. Our conclusion in no way limits another country's ability to impose other pilot certification requirements for flights operated within that country's airspace."
So I take that to mean that: a) The interpretation applies only to N reg aircraft (wherever flown) and b) that other countries are at liberty to impose certification restrictions within their own airspace that, in effect, could over-rule the privileges conferred by the FAA certification.
Am I right on both points? The first seems straightforward enough but as to the second, is there any evidence of any country ever having sought to do so - the CAA in the UK, for example?

[Nubian]

Gordy - So that legal interpretation is very clear. FAA 61.75 'piggy back' certification, based on a foreign (i.e. EASA) license DOES NOT (contrary to popular belief) restrict the holder to fly only those types for which he or she is rated on their EASA license.
Instead, it confers the FAA privileges of 'an airplane category rating' which, in the case of light helicopters for example is 'any under a gross takeoff weight of over 12,500 pounds'.
I imagine this could be very useful to anyone wishing to fly multiple types without having to go to the expense of gaining multiple type ratings under EASA rules.

However, the FAA go on to say that: "...our interpretation addresses only the requirements to operate a U.S.-registered aircraft under our regulations. Our conclusion in no way limits another country's ability to impose other pilot certification requirements for flights operated within that country's airspace."
So I take that to mean that: a) The interpretation applies only to N reg aircraft (wherever flown) and b) that other countries are at liberty to impose certification restrictions within their own airspace that, in effect, could over-rule the privileges conferred by the FAA certification.
Am I right on both points? The first seems straightforward enough but as to the second, is there any evidence of any country ever having sought to do so - the CAA in the UK, for example?

Why do I get the feeling that you want to use your FAA piggyback license to fly other than N reg aircrafts in the UK?

[chopjock]

Don't forget if you have a piggy back 61.75 you may want to get it re issued...

​​​​​​FAA certificates for UK licences UK Civil Aviation Authority (http://www.caa.co.uk/Commercial-industry/Pilot-licences/Applications/Jurisdictions/FAA-certificates-for-UK-licences/)

Soon!

[Gustosomerset]

Nubian - I actually don't (I'm perfectly happy with my single rating at the moment) but I was just intrigued by the number of people telling me different things about the validity of the 61.75 FAA license.
In particular the strongly asserted opinions of those that certainly should know the rules but who, it turns out, don't.
That said, if at some unlikely point someone kindly offers me the opportunity to fly their N reg MD500 I'd seriously consider doing the requisite conversion training and the paperwork to get my 61.75 FAA license to be able to do so, rather than spending the time and money to get and then maintain the separate rating via the conventional EASA route. As I said above, I understand a significant number of pilots are already doing this - I just couldn't find the confirmation of how this worked. All credit to Gordy for having done so.

[Gordy]

Am I right on both points? The first seems straightforward enough but as to the second, is there any evidence of any country ever having sought to do so - the CAA in the UK, for example?

I believe you are right on both points yes.

[md 600 driver]

If you obtained your 61.75 licence based on a fixed wing and subsequently added a rotorcraft licence do you need to inform F a to amend your 61.75
also does your FCL licence number change when you add rotorcraft

[nigelh]

That said, if at some unlikely point someone kindly offers me the opportunity to fly their N reg MD500 I'd seriously consider doing the requisite conversion training and the paperwork ..........
why would you need to do any training or paperwork if you have the FAA privileges?

[Gustosomerset]

MD600 - as I understand it, when you apply for your 61.75 certificate, you specify the 'airplane category rating' for which you are applying. Fixed wing and rotorcraft being two separate category ratings, I assume you would need to re-apply for a new certificate to cover a new category on a 'foreign' license.

Nigel H - as specified in the legal judgement letter linked to earlier, in addition to the 61.75 certificate, a pilot is required to have 'an endorsement in his or her logbook as prescribed in 14 CFR 61:31.' You can look up the detail of this requirement here (https://www.law.cornell.edu/cfr/text/14/61.31) but it is, in effect "...to have received training...appropriate to the pilot certification level...and an endorsement for solo flight in that aircraft from an authorised instructor."

[claudia]

Gordy, I am presently flying a squirrel on my UK issued EASA licence (rating with up to date LPC etc). In the event i get a FAA 61.75 based on that licence
do i need to keep the EASA LPC up to date in order to keep 61.75 Ticket valid to fly an N reg squirrel in the UK. Opinions/thoughts would be much appreciated.
Many thanks

[Gordy]

Gordy, I am presently flying a squirrel on my UK issued EASA licence (rating with up to date LPC etc). In the event i get a FAA 61.75 based on that licence
do i need to keep the EASA LPC up to date in order to keep 61.75 Ticket valid to fly an N reg squirrel in the UK. Opinions/thoughts would be much appreciated.
Many thanks
I believe so, yes. Your US certificate is based upon the UK one therefore all limitations and currency would apply.

[claudia]

Gordy, Your prompt reply is much appreciated, Thank you. One further question please, Do i need two LPCs, one for each licence?
The reason i am exploring this is because i have reason to go occasionally to the Republic of Ireland. My squirrel is N-reg.
Thanks again Best Regards.

[Gordy]

Do i need two LPCs, one for each licence?

What is an LPC? I assume a proficiency check?

I am going out on a limb here and say that if you have had an LPC on your foreign license within the preceding 24 months that would cover you for the FAA Flight review.

No-where in 14 CFR 61.56 does it say it has to be in an N reg or by an FAA CFI.

14 CFR 61.56 Flight Review (http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/0/AB8B895828E3309486257C24005B6A14?OpenDocument)

[Gustosomerset]

Again, as per the legal opinion issued by the Office of Chief Counsel for FAA quoted above, "...the FAA has not considered the absence of a rating as a restriction on a person's pilot certificate." So the revalidation of the type ratings in the 'parent' license, via a proficiency check, is therefore irrelevant to the validity of the 61.75 'piggy back' license. The requirement is only that the license itself remains valid (which, being not time limited is not hard to achieve) and that a valid medical supports the license (see note below). So an EASA type rating that has not been revalidated does not constitute a limitation on the EASA license such that it limits the validity of the 61.75 certificate based upon it. Or, to answer Claudia's question directly - ("do i need to keep the EASA LPC up to date in order to keep 61.75 Ticket valid to fly an N reg squirrel in the UK."). No, you do not.

However, to keep your FAA 61.75 certificate valid you do need to ensure that:
a) your logbook endorsement from a U.S. qualified examiner needs to be re-validated every 24 months.
b) you hold an appropriate FAA medical certificate or 'a medical license issued by the country that issued the person's foreign pilot license'.
This second requirement remains, despite the recent introduction of 'self-certification' for some pilot/license/aircraft types in the UK. So, from a medical point of view, the validity requirements of your 61.75 certificate may now be more onerous than for your EASA license.

[claudia]

Gordy/Gusto Thank you both for kindly taking the time to respond with your views,albeit slightly different.
Gusto Im hoping your views are correct.- No EASA LPC needed, just a 24 month flight test with FAA examiner.
and 61.75 is good to go for UK and Ireland in N-reg
Bit of a mine field but guys I appreciate your in-put.
Best Regards

[Gustosomerset]

Claudia, my interpretation is based on the legal opinion of the FAA counsel that Gordy traced above, plus a subsequent discussion with an FAA examiner on the 'revalidation' point. So I believe I'm correct, but am quite happy to be proved wrong. As you say, it's a bit of a minefield....and one that surprisingly few seem to have taken the trouble to navigate, given the benefits.

[Gordy]

Gusto:

However, to keep your FAA 61.75 certificate valid you do need to ensure that:
a) your logbook endorsement from a U.S. qualified examiner needs to be re-validated every 24 months.

Where does it say this----there is no such regulation. You may be referring to the flight review requirement of 14 CFR 61.56 which is conducted by a CFI NOT an examiner.

[Gustosomerset]

Gordy. You're right I'm referring to 14 CFR 61.56 which requires the flight review and logbook endorsement to be carried out by 'an authorised instructor'. That person is presumably usually going to be a Certified Flight Instructor but may also be 'an examiner, an approved pilot check airman, or a U.S. Armed Force' again according to the FAA Chief Counsel.
Worth noting also that the 24 month time limit is very precise with no leeway for extensions, defined as: "... the beginning of the 24th calendar month before the month in which that pilot acts as pilot in command'.

[Gordy]

authorised

"Authorized" please..... When in Rome........ or discussing Rome's rules.... Just ribbing you.

But seriously when you use the word examiner instead of CFI it gives incorrect information.

[claudia]

Guys. Say i go and get my 61.75 or indeed a stand alone FAA ticket, does the CFI conducting the 24 mointh
review need to be specifically rated on the squirrel --- after all his licence being American is not type specific
Just wondering !

[Gustosomerset]

Gordy. You're quite right. I stand corrected - on both points!

Claudia. As you say, the CFI's FAA license is not type specific, so it doesn't matter what aircraft you're in for the endorsement (so long as it's an N reg light helicopter under a gross takeoff weight of 12,500 pounds).

Equally, and on the same principle, once you have done the flight review (presumably in your Squirrel) and have the logbook endorsement you can then fly any N reg light helicopter under a gross takeoff weight of 12,500 pounds for the next 24 months (to revert to my original point), completely irrespective of your EASA type ratings...should you wish to do so...

[claudia]

Gusto. Many thanks for that info. A 61.75 will do my job and i will set the wheels in motion shortly.
Interesting that a CFI who maybe has never even been in a squirrel could be sitting beside me doing my
flight review.!! Best Regards.

[Reely340]

I am going out on a limb here and say that if you have had an LPC on your foreign license within the preceding 24 months that would cover you for the FAA Flight review.
THAT is a very interesting point of view. I was told that an EASA Prof.Check is not substitue for an FAA BFR and of course an FAA BFR is no substitute for the annual EASA Prof.Checks per Type rating. (by someone providing EASA annunal Prof.Checks and type ratings ;) )

Where does it say that, the (more frequent and EASA type oriented) annunal practical EASA Prof.Check can substitute the practical and theoretical FAA BFR?

I'm currently under the impression that my FAA piggyback lic. is only half baked as I never did an FAA BFR as of yet.
However, your interpretation would insinuate, that I'm good to go in any below 12500lbs helo as long as it is N-reg. :8

[Reely340]

as specified in the legal judgement letter linked to earlier, in addition to the 61.75 certificate, a pilot is required to have 'an endorsement in his or her logbook as prescribed in 14 CFR 61:31.' You can look up the detail of this requirement here (https://www.law.cornell.edu/cfr/text/14/61.31) but it is, in effect "...to have received training...appropriate to the pilot certification level...and an endorsement for solo flight in that aircraft from an authorised instructor."

Is that referring to a FAA BFR ?
Is that section saying that piggy back FAA lic w/o BFR + EASA lic + medical is not sufficient to fly N-reg aircraft ?

[Reely340]

Guys. Say i go and get my 61.75 or indeed a stand alone FAA ticket, does the CFI conducting the 24 mointh
review need to be specifically rated on the squirrel --- after all his licence being American is not type specific
Just wondering !Apparently not. The FSDO Officer doing my 61.75 piggy back work in Oahu explained to me that CFIs do not have to be and sometimes are not rated or proficient(!) in flying the a/c the applicant wants to do the review in: In one case the CFI conducting the check ride in a squirrel actually did shut off the engine midflight to indicate he'd like to see the applicant's proficincy in emergency procedures. And off meant off, not ground idle! With stress levels in the cockpit rising considerably the applicant barely manged to land, off airport w/o any damages to a/c or surroundings. => pick your CFI wisely ;)

He (the FDSO officer) said that this rating-less scheme would be the american way: while he was working SAR he frequently rescued off shore skippers who had had the money to buy a capable high sea sail plane but apparently lacked any skills to operate the ship safely out there in heavy weather. Apparently one may legally cross oceans after acquiring proficency sailing a 10ft dingy.

Personally, I do like that idea, of letting darwin sort out the gene pool. That way those with brains do not have to suffer (by excessive bureaucracy) for loonies in their area of conduct.

[Gustosomerset]

Reely - your summary of the 61.75 certificate regulations as 'Darwin sorting out the gene pool' is, IMHO, unimprovable. The fact that so few people appear to understand them only lends weight to your definition.
In answer to your other question: "Is that section saying that piggy back FAA lic w/o BFR + EASA lic + medical is not sufficient to fly N-reg aircraft ?", in my understanding, the answer is, yes, it is not sufficient (if you are hoping to fly the N reg aircraft on the validity of your FAA 61.75 certificate).Or to put it as a string of TLAs (three later acronyms) if you prefer: 61.75 lic (FAA 'piggy back' certificate) without BFR (valid 24 month Bi-annual flight review and logbook endorsement) plus EASA lic (EASA 'foreign' license) + medical (EASA approved medical) = PYL (Pushing Your Luck).

Although the 61.75 certificate is very permissive in terms of the aircraft it allows you to fly, the requirement for the periodic flight review and logbook endorsement is mandatory to preserve its validity, whatever the validity of the EASA license and medical on which it is based.

[Reely340]

Reely - your summary of the 61.75 certificate regulations as 'Darwin sorting out the gene pool' is, IMHO, unimprovable. The fact that so few people appear to understand them only lends weight to your definition.
In answer to your other question: "Is that section saying that piggy back FAA lic w/o BFR + EASA lic + medical is not sufficient to fly N-reg aircraft ?", in my understanding, the answer is, yes, it is not sufficient (if you are hoping to fly the N reg aircraft on the validity of your FAA 61.75 certificate).Or to put it as a string of TLAs (three later acronyms) if you prefer: 61.75 lic (FAA 'piggy back' certificate) without BFR (valid 24 month Bi-annual flight review and logbook endorsement) plus EASA lic (EASA 'foreign' license) + medical (EASA approved medical) = PYL (Pushing Your Luck).

Although the 61.75 certificate is very permissive in terms of the aircraft it allows you to fly, the requirement for the periodic flight review and logbook endorsement is mandatory to preserve its validity, whatever the validity of the EASA license and medical on which it is based.
Thx for the fast response. Your answer is what I had presumed: an FAA piggy back lic has its own renewal scheme, namely the BFR. Nice, simple and relatively cheap.

The final question is what happenes when after acquiring a piggy back lic and maintaining a recent enough BFR
all my EASA TRs have expired, from FAA's point of view? The EASA lic is valid indefinitely, albeit als TRs have expired.

FAA won't care, as long as the BFR is younger than 24 Months, is that true?

[havick]

Have you actually bothered to read 61.75?

(3) Is subject to the limitations and restrictions on the person’s U.S. certificate and foreign pilot license when exercising the privileges of that U.S. pilot certificate in an aircraft of U.S. registry operating within or outside the United States; and

[selfin]

I am going out on a limb here and say that if you have had an LPC on your foreign license within the preceding 24 months that would cover you for the FAA Flight review.

No-where in 14 CFR 61.56 does it say it has to be in an N reg or by an FAA CFI.

The qualifying mechanisms in 14 CFR 61.56 clearly exclude, in the absence of a specific exemption, proficiency checks conducted under a foreign authority. The "examiner" referred to in 14 CFR 61.56(d)(1) for instance is well defined and has been held by the Office of the Chief Counsel as excluding foreign examiners. A relevant opinion was given to John D Collins on 4 Apr 2013 by Mark W Bury, Acting Assistant Chief Counsel for International Law, Legislation and Regulations Division (PDF (https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2013/collins%20-%20(2013)%20legal%20interpretation.pdf)). Besides, non-US personnel have not been found competent to deliver ground training on the relevant rules in 14 CFR 91.

Any reference to "flight training" in part 61 is a reference to training carried out by an "authorized instructor" which, in the absence of a specific exemption, may include foreign flight instructors pursuant to the conditions in 14 CFR 61.41. The conditions for the latter are that the training shall only be credited towards the training requirements of a pilot certificate or rating issued under part 61 and the training has been received outside the US. There is a further condition limiting the purview of the foreign instructor to giving endorsements to show training given which falls short of the requirement in 14 CFR 61.56(c)(2) for an endorsement "from an authorized instructor who gave the review certifying that the person has satisfactorily completed the review."

Instructor conducting flight reviews in the United States may not be remunerated, which includes logging flight time, when foreign (non-leased) aircraft are used. See 14 CFR 375.

[Reely340]

Have you actually bothered to read 61.75?

(3) Is subject to the limitations and restrictions on the person’s U.S. certificate and foreign pilot license when exercising the privileges of that U.S. pilot certificate in an aircraft of U.S. registry operating within or outside the United States; andSure I have, why do you aks? This great thread finally has produced indications that a "missing EASA TR" is not a "limitation" in the FAA's sense of the word.

[Gustosomerset]

Reely - you say: "The final question is what happens when after acquiring a piggy back lic and maintaining a recent enough BFR all my EASA TRs have expired, from FAA's point of view?"

I think that's covered above in response to Claudia's similar question: "As per the legal opinion issued by the Office of Chief Counsel for FAA quoted above, "...the FAA has not considered the absence of a rating as a restriction on a person's pilot certificate." So the revalidation of the type ratings in the 'parent' license, via a proficiency check, is irrelevant to the validity of the 61.75 'piggy back' license. The requirement is only that the license itself remains valid (which, being not time limited is not hard to achieve) and that a valid medical supports the license. So an EASA type rating that has expired (i.e. not been revalidated) does not constitute a limitation on the EASA license such that it limits the validity of the 61.75 certificate based upon it."

So, in short, nothing happens (to your ability to fly an N reg aircraft on your 61.75 certificate) if your EASA type ratings expire, so long as you retain your FAA BFR, logbook endorsement and appropriate medical. Indeed, I suppose nothing would happen either if your EASA type ratings expired before acquiring a 'piggy back' certificate, because, as we know, a "missing EASA TR" is not a "limitation" in the FAA's sense of the word.

As ever, I am no authority, I've just read the legal opinions and talked to some instructors and examiners. Am happy to be proved wrong by any one of the many people that told me and apparently continue to believe that: "...the 61.75 certificate covers only the type’s on your UK license."