Piggyback PPL question

[Banana Joe]

I have a few questions regarding the issue of an FAA piggyback PPL licence based on my EASA licence. I hold a frozen ATPL which is a CPL with ATP written equivalent passed. I currently hold on my EASA licence only a B737 300-900 type rating with an IR CATII/III and in the remarks/restriction section MP is noted, since the 737 is a multi-pilot aircraft. I am going to renew my Single Engine Piston rating very soon.
I understand that in this case, I will get an FAA PPL licence with Single Engine Land privileges, but I intend to obtain also an IR and a Multi-Engine Land privilege.

Will my B737 type rating be credited towards the issue of a Multi-Engine Land privilege? I know type ratings aren't transferred and I am not interested in that.
Will my IR on the 737 count towards the issue of the IR, following the IR written test for foreign pilots?

I am planning on doing some time building in the US and at least 30 hours on a Seneca.

[rudestuff]

If you want to become an MEIR instructor you'll find it much easier to find work if you've got an FI as well.
As for the FAA conversion, how close are you to an ATPL? Or is that on hold right now? If you just want the pic time in a multi, you should consider Canada - no visa issues! Plus you'll effectively get an FAA certificate anyway if you want one (after a 20 question test!)

As for your questions, if you've got SEP and MEP then the feds will give you a 61.75 certificate (Google part 61) and allow you to go flying after a flight review with an instructor - they'll include that in your rental checkout so basically you just make sure he's happy. Can you use your type rating instead of MEP? Possibly - just ring a FSDO in the States and ask, then let us know!
Instrument ratings in the US aren't SP or MP, so you might get away with that as well!

You can also get some really good deals in South Africa.

[Banana Joe]

Thanks for your reply. I will obtain my FI in the future, I just want to get the 30 hours PIC to add on it the CRI privileges later on.
Flying for a cargo outfit with an average of 25 hours per month, it will take me some time to get the required PICUS hours since I am allowed to log them only with LTC or TRI where I work. By coming to North America, I am trying to kill two birds with a stone: get some PIC hours a bit quicker and also satisfy the 30 hours PIC requirement for the CRI add-on.

Did not think about Canada and South Africa. I'll definitely look into Canada. And I'll try to decide which FSDO to get in contact with. I have not found where to go yet. Maybe Florida initially.

[MarkerInbound]

Does your EASA license allow you to fly a Seneca IFR in your home country? Under the FAA system getting a B737 type without any prior ME time would grant you a ME rating valid in any MEL airplane under 12,500 pounds max gross TO weight. The 61.75 certificate requires the holder to obey all restrictions on the underlying license. So for example if it is an Australian license with a CE-172 rating their FAA certificate would say SEL but they would not be able to fly a PA-28 even though there is no FAA limitation.

[Banana Joe]

As of today, no. I can't because my MEP expired and I currently don't have an IR to fly on MEP. What I have is a 737 type rating and an IR down to CATIIIA minima.
I will try to get in contact with a FSDO to confirm that my type rating counts for the MEL. In that case, I would just need to renew my SEP.

[B2N2]

Do NOT contact a FSDO!
They are regional offices where random FAA inspectors get assigned to phone duty and you may very well get the wrong advice as this goes waaaay passed the regular phone questions.
Call the FAA head offfice in Oklahoma and ask to speak to an inspector from Pilot Certification.
Do not be surprised that you may not evt an immediate answer as this needs to be researched. Write down the name and email of the person you’ve spoken with.
Then with any issues down the line you have a name to refer back to.
No offense to the FAA but a regional office or FSDO is nor the right place.

[rudestuff]

Does your EASA license allow you to fly a Seneca IFR in your home country? Under the FAA system getting a B737 type without any prior ME time would grant you a ME rating valid in any MEL airplane under 12,500 pounds max gross TO weight. The 61.75 certificate requires the holder to obey all restrictions on the underlying license. So for example if it is an Australian license with a CE-172 rating their FAA certificate would say SEL but they would not be able to fly a PA-28 even though there is no FAA limitation.
Wrong. You could fly any SEP under 12,500lbs on your 61.75. A type rating on a foreign licence is not considered a limitation by the FAA, it's considered a privilege. (A privilege they automatically give).
The only way they would stop you flying a PA-28 is if your Australian licence specifically stated "PA-28 prohibited"

[Banana Joe]

Do NOT contact a FSDO!

[...]

Call the FAA head offfice in Oklahoma and ask to speak to an inspector from Pilot Certification.


Good to know, thanks!

[B2N2]

Will my B737 type rating be credited towards the issue of a Multi-Engine Land privilege?

This is slightly above my pay grade but I’m going to go with NO.

Under the FAA system a MEL ( Multi Engine Land ) rating is single pilot.
There is no such thing as an MPL in FAA land.

[Banana Joe]

I do not have a MPL, that is a totally different licence from an ATPL or CPL.
​​​​​​The only Multi-Pilot thing I have is a 737 type and its related IR for it. These are ratings.

EASA complicates things.

[MarkerInbound]

Wrong. You could fly any SEP under 12,500lbs on your 61.75. A type rating on a foreign licence is not considered a limitation by the FAA, it's considered a privilege. (A privilege they automatically give).
The only way they would stop you flying a PA-28 is if your Australian licence specifically stated "PA-28 prohibited"

From FSIMS, the guidance a FAA Inspector would use -
“Some foreign CAAs (e.g., New Zealand and Australia) issue PPLs that limit the pilot to a specific make and model of aircraft or limit the pilot from carrying any passengers. Those persons must also comply with the make and model aircraft and passenger carrying restriction of their foreign pilot licenses when exercising the privileges of a § 61.75 U.S. pilot certificate (refer to § 61.75(e)(3)).”

[awair]

If you have a valid foreign license with SEP, B737 and Instrument Rating, you will be issued an FAA 61.75 certificate which includes your Class & Type Ratings ("not for hire"). The addition of the B737 will also give you MEL (MEP equivalent), because the FAA, or is it EASA?, does things differently.

Your 61.75 certificate then becomes "controlling" in FAA airspace, meaning:

You must carry the FAA certificate, medical and ID
You must also carry the original license (which must remain valid)
You must have a current (FAA) Flight Review
You can add Instrument privileges, by taking the short foreigner's FAA Knowledge Test.

Note the FAA difference between valid and current. My understanding, and still waiting for confirmation from FAA legal counsel on this is, as long as you meet the FAA regs (Medical, Flight Review & Recency), you do not need to have a current C of T on the EASA license, for either Class or Instrument.

Unless, specifically stated on the EASA license that it is "Not valid without a current medical", the foreign (EASA) license is still valid for the purposes of "accompanying" the FAA certificate.

Personally, I would still want an EASA medical, just in case the lawyers change their mind, or state that they were referring to different circumstances in their prior legal opinion.

[rudestuff]

From FSIMS, the guidance a FAA Inspector would use -
“Some foreign CAAs (e.g., New Zealand and Australia) issue PPLs that limit the pilot to a specific make and model of aircraft or limit the pilot from carrying any passengers. Those persons must also comply with the make and model aircraft and passenger carrying restriction of their foreign pilot licenses when exercising the privileges of a § 61.75 U.S. pilot certificate (refer to § 61.75(e)(3)).”

https://www.pprune.org/rotorheads/611932-faa-61-75-piggy-back-certificate-validity.html#post10217685

[awair]

rudestuff
Thanks for the link - very useful, especially the Legal Counsel links.
https://www.pprune.org/rotorheads/611932-faa-61-75-piggy-back-certificate-validity.html#post10217685

I forgot to clarify, that your B737 TR would probably need to be a P1/PIC (not SIC) to get the MEL Class on the 61.75 certificate.

[bafanguy]

Do NOT contact a FSDO!

Call the FAA head offfice in Oklahoma and ask to speak to an inspector from Pilot Certification.


Just speaking from my recent personal experience with contacting OKC and the folks from Pilot Certification about a licensing issue , hate to say it but I was essentially blown off and told to contact a local FSDO.

I suspect MarkerInbound is a closet FAA inspector. He's just too knowledgeable on this stuff. ;)

Try them this way and see what happens:

https://www.faa.gov/licenses_certificates/airmen_certification/contact_airmen_certification/

[MarkerInbound]

I am not FAA. But I have 40 years of dealing with them and believe in knowing your enemy. They make everything available with some digging.

[bafanguy]

I am not FAA.

MI,

I was just being a wiseguy ! Your knowledge is appreciated.

[LTCTerry]

Banana Joe - something for you to consider. If you have SEP and MEP you will get both of those on your 61.75 Certificate.

61.75 can give you everything you already have. MarkerInbound knows a lot more about this stuff than me. But I am curious, so did a bunch of quick googling. I get the impression that your type rating would let you fly 737s as a private pilot, but not go rent a Seminole - because there's no Multi-Engine Piston rating on your EASA license. Not meaning to slight Marker, I'm looking forward to learning more.

Here's my suggestion

You are spending a lot of money. A few more dollars won't matter if you come out ahead.

1. Find a flight school/FBO that will let you rent their twin.

2. Study for and pass the private pilot and instrument rating knowledge tests. Pass the commercial airplane pilot knowledge test.

3. Start flight training for the ME commercial certificate. Take the Private Pilot ME checkride. Now now you have a private pilot certificate independent of 61.75 and the rest of your training is PIC under FAA rules.

4. Prepare for the instrument rating in the twin and take a checkride. This is all PIC time under FAA rules.

61.129 has specific requirements including dual and solo cross country flights and IFR training. Work these into the training plan from the beginning.

5. Complete the flight training requirements for the commercial pilot certificate. Take the checkride including IFR approaches. Now, you have an FAA commercial pilot certificate with real instrument rating. (An instrument rating under 61.75 only counts for IFR flights under that certificate.)

6. Continue to fly until you hit 30 hours or are broke.

Depending one where you take them, the written tests are $80-150. Checkrides cost about $600. With an advance plan you spend just a bit more, but leave with credentials in addition to the flight time.

Snags? In EASA-land if you are rated and an instructor is on board it's dual not PIC. Not the case in FAA-land. Ditto for an examiner.

61.129 lists ten very specific hours of required experience that may either all be performed solo (only you in the airplane) or "performing the duties of PIC" with an instructor on board. It's 10 of one or 10 of the other. No mixing of the two. I know 61.129 all too well as I just passed the checkride in March. The place I did my training encouraged me to do the flying solo. I had a private multi rating, but no solo time in a twin. It was a great confidence builder to go do all the solo flights. (You can read about the adventures/misadventures (gear failure, weather, etc) along the way at my blog Terry Pitts | A different take on the world (http://www.terrypitts.com)) Long intro - are you happy with "30 hours" or are you hoping for "30 hours PIC?"

(Private message me if you like and I'm happy to discuss where I did my training - Turbo Seminole $310/hour with dual G5s and ADSB)

Hope this has been helpful. When I spend lots of money on flying I like to maximize the gain(s)!

[rudestuff]

I think the OP wants 30 hours PIC as recognised by EASA - so receiving any flight training although useful, would mean flying extra hours and a lot more money.

It all boils down to what 61.75 certificate the FAA will give: They don't have an MEP rating either, so it's entirely feasible that they will give AMEL based on the fact that a 737 is an AMEL (requiring a type rating)
​

[LTCTerry]

I think the OP wants 30 hours PIC as recognised by EASA - so receiving any flight training although useful, would mean flying extra hours and a lot more money.

It all boils down to what 61.75 certificate the FAA will give: They don't have an MEP rating either, so it's entirely feasible that they will give AMEL based on the fact that a 737 is an AMEL (requiring a type rating)
​

FAA doesn’t have “SEP” either, but fully understands that SEP becomes ASEL in a 61.75 certificate. If the OP’s license doesn’t say MEP...

Would you as a civil servant sign someone off to fly a light twin based on a type rating? I’ll bet my friend at the FSDO wouldn’t, but I’ll ask.

The OP is going to have a hard time finding a place to rent w/o an instructor. Though I know two places that will.

[Banana Joe]

I would love to hear about those two places by PM. So far I know one place in Wisconsin.

[LTCTerry]

I contacted the OP via PM and gave him the names of two places I know from personal experience will rent their twins to low time pilots - with renters' insurance.

I don't want to be a Debbie Downer. As a pilot I want to see other pilots succeed. Based on what Banana Joe has said, he has nothing that allows him to fly a multiengine airplane solo. Perhaps he has taken taken a checkride in something that lets him fly a Seneca, Duchess, Seminole, Twin Comanche, etc solo.

If Banana Joe is currently allowed to log PIC in a MEP under EASA rules, he could simply have someone keep him company who happens to be an instructor and he just fills out his own log book as PIC. Problem solved.

If he's a reasonably current pilot, he can get the FAA ME rating added to his 61.75 certificate in about five hours. After that everything could be PIC with a knowledgeable passenger... Problem solved for just a bit more money. (I had suggested the ratings as a way to get independent FAA credentials instead of just logging flight time.)

[awair]

Would you as a civil servant sign someone off to fly a light twin based on a type rating? I’ll bet my friend at the FSDO wouldn’t, but I’ll ask.


I'm not sure it's a question of a civil servant "thinking about it". It is more of, this is our procedure: OP has the 737, which they can't grant without also granting the MEL, as it is the superior class for the type.

I was just granted MEL on my initial FAA Airplane certificate, check-ride was for a Type Rating, no light twin time demonstrated.

Good luck, and let us know what happens...

[Banana Joe]

Thanks to LTCFerry again for his useful private messages. And to the other users as well! Options are available and I'll consider all of them.

[LTCTerry]

My FAA contact says if the type rating requires being part of a crew - as in the OP’s case - it won’t give AMEL PIC privileges.

Via PM I’ve learned the OP is MEP rated in his EASA license. This should give him a 61.75 certificate with ASEL and AMEL. Any ME flying from an FAA perspective would be PIC.

With a goal of 30 hours of flying Banana Joe could have some great experiences!

[rudestuff]

I might just apply for a 61.75 myself and put this one to rest - I've never had an MEP rating, so it'll be interesting to see what they give me!

[Climb150]

I got an FAA ATP doing a CL65 jet checkride for the licence conversion. Have the jet type and AMEL on the certificate. No restrictions.