Got this statement from the FAA Airmen Branch on FAR 61.75 and 61.56. These is a clear requirement for a BFR when using an FAA license issued on the basis of a foreign license. Copied here verbatim for an email I received.
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In order to exercise the privileges of your FAA pilot certificate you are required to complete a biannual flight review in accordance with 14 CFR Part 61.56.
ANSWER: Ref. § 61.56(c) and § 61.75(b)(1); Yes, the flight review requirement even applies to foreign pilots when exercising their U.S. pilot certificate. It makes no difference whether it was a U.S. pilot certificate that was issued in accordance with § 61.75 or § 61.103. It is still a U.S. pilot certificate. And when a person is exercising that U.S. pilot certificate then as per § 61.56(c) it states, in pertinent part, ". . . no person may act as pilot in command of an aircraft unless, since the beginning of the 24th calendar month before the month in which that pilot acts as pilot in command, that person has-
(1) Accomplished a flight review given in an aircraft for which that pilot is rated by an authorized instructor; and
(2) A logbook endorsed from an authorized instructor who gave the review certifying that the person has satisfactorily completed the review."
There is no difference. If a U.S. pilot is issued a foreign pilot license on the basis of holding a U.S. pilot certificate, that person is expected to comply with that foreign country's pilot certification rules when exercising that foreign pilot certificate. And so, there is no difference when the situation is reversed and a foreign pilot is exercising a U.S. pilot certificate.
As for your comments about § 61.75 (b)(1) which states, in pertinent part ". . . without any further showing of proficiency, provided the applicant:
(1) Meets the requirements of this section;"
What that rule [i.e., § 61.75(b)(1)] is addressing is one of the prerequisite eligibility requirements that govern the issuance of that U.S. private pilot certificate. Once the certificate is issued, there are currency and operational requirements that the pilot must meet and comply with, just like any other pilot certificate that is issued by the FAA.
And as I've said many times in the past, the FAA is a service organization, as well as a regulatory agency, and I agree and fully urge ASIs to take some time with a foreign pilot to explain our recency of experience, instrument currency, VFR rules, air traffic requirements, airspace requirements, etc. to foreign pilots when you all issue one of these § 61.75 private pilot certificates.
And this answer has been coordinated and approved by the FAA's Office of Chief Counsel, AGC 240.
{Q&A-326}
Best regards,
Airmen Certification Branch
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