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FAA License Conversion Advice: Regionals or I Pay by myself??

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FAA License Conversion Advice: Regionals or I Pay by myself??

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Old 5th Sep 2019, 11:51
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What is a "...COP rating" (where it exists) under EASA rules ?
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Old 5th Sep 2019, 19:46
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Originally Posted by bafanguy
What is a "...COP rating" (where it exists) under EASA rules ?
It’s a Copilot/ First Officer rating. As opposed to have a PIC rating. It exists for example in Germany.
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Old 5th Sep 2019, 19:57
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Originally Posted by Sunrig
It’s a Copilot/ First Officer rating. As opposed to have a PIC rating. It exists for example in Germany.
Sunrig,

Thanks for that. Is there a list of which EASA countries have such a rating ? And how would it be indicate on the license ?

On an FAA license it would say, "[airplane type] SIC privileges only", and be listed in the Limitations section of the license. The specific airplane type would be listed under "Ratings".

Last edited by bafanguy; 6th Sep 2019 at 07:43.
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Old 5th Sep 2019, 20:54
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Originally Posted by bafanguy
Sunrig,

Thanks for that. Is there a list of which EASA countries have such a rating ? And how would it be indicate on the license ?

On an FAA license it would say, "[airplane type] SIC privileges only" and be listed in the Limitations section of the license.
You’re very welcome. Unfortunately I have no idea if such a list exists anywhere.
In my EASA license it is indicated with my current Rating saying PIC IR. So for example B737 300-900 PIC IR. I have seen that the First Officers have e.g. B737 300-900 COP IR. As I only know EASA licenses from my previous company, I assumed they were common for all EASA countries. Maybe someone else can chime in on that matter.
On a side note be advised, that you only keep your type rating in EASA if you do your annual LPC. That’s a big difference to the US, where you keep your type ratings displayed on your FAA certificate, regardless if you still fly the specific aircraft type or not. Usually the average European pilot has only the current aircraft type displayed on his license. Unless you choose to renew all previous ratings with a annual checkride out of your own pocket.
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Old 6th Sep 2019, 07:27
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Just for reference, American Airlines has some hiring statistics for 2019:

1 Jan - 1 Aug
593 new hires
318 are flows from Envoy, PSA, Piedmont
275 are off the street of which
- 242 are military trained pilots
- 33 non-military/non flow.

Very small chance of getting hired at AA as a non-military/non-flow pilot.
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Old 7th Sep 2019, 14:01
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Just for grins & giggles, here's the scoop on FAA SIC-only type ratings in the Part 121 world:

C. Part 121 Exclusion. On July 15, 2013, the FAA issued a final rule (78 FR 42323) requiring an SIC (first officer) in domestic, flag, and supplemental operations to hold an ATP Certificate and airplane type rating for the aircraft to be flown. Part 121 requires an aircraft type rating not limited to SIC privileges for all crewmembers exercising SIC privileges (refer to part 121, § 121.436). Since an SIC type rating cannot be used in part 121 operations, a revision to § 61.55(e) removed the ability for a pilot to receive a pilot type rating limited to SIC privileges based on completion of a part 121 air carrier training program.

fsims.faa.gov/PICDetail.aspx?docId=8900.1,Vol.5,Ch2,Sec22

Last edited by bafanguy; 7th Sep 2019 at 14:29.
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Old 8th Sep 2019, 09:41
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Hey guys.
I have recently communicated with a pilot training center in US which specializes in converting foreign licenses. He told me that if your foreign license does not include a specification like PIC/SIC/COP etc. your pilot flying hours as first officer are considered as PIC and I am good to go for license conversion. Thanks to everyone for your comments and insight.
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Old 8th Sep 2019, 22:20
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Originally Posted by amonghtus
Hey guys.
I have recently communicated with a pilot training center in US which specializes in converting foreign licenses. He told me that if your foreign license does not include a specification like PIC/SIC/COP etc. your pilot flying hours as first officer are considered as PIC and I am good to go for license conversion. Thanks to everyone for your comments and insight.


I find this advice hard to believe, I would be verifying with the FAA.
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Old 8th Sep 2019, 22:57
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amonghtus,

I can tell that isnt true. Myself and 4 other people converted our licences to FAA at the same time. Our log books were scrutinized heavily and unless you were the PIC listed on the flight plan or acting in command under supervision for the pupose of upgrade training it isnt PIC.
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Old 9th Sep 2019, 07:18
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Originally Posted by Global Aviator
I find this advice hard to believe, I would be verifying with the FAA.
I sure don't understand Part 61 at the functional level where it gets applied to an individual. I never had to mess with it as that's the job of the training department. But I got curious when amonghtus and IllinoisDavidson began asking about it. So I noodled around and found the following. Is it an explanation ? No idea...I'm just playing jailhouse lawyer:

If FAA recognizes foreign flight time as logable in Part 61:

(j)Aircraft requirements for logging flight time. For a person to log flight time, the time must be acquired in an aircraft that is identified as an aircraft under § 61.5(b), and is -

(1) An aircraft of U.S. registry with either a standard or special airworthiness certificate;


(2) An aircraft of foreign registry with an airworthiness certificate that is approved by the aviation authority of a foreign country that is a Member State to the Convention on International Civil Aviation Organization;

...AND...

c)Logging of pilot time. The pilot time described in this section may be used to:

(1) Apply for a certificate or rating issued under this part or a privilege authorized under this part; or(2) Satisfy the recent flight experience requirements of this part.

https://www.law.cornell.edu/cfr/text/14/61.51

Why can't foreign PICUS flight time be applied toward the 250 hour PIC requirement for an FAA ATP ?



Could his EASA PICUS fill that FAA square ?:

(5) 250 hours of flight time in an airplane as a pilot in command, or when serving as a required second in command flightcrew member performing the duties of pilot in command while under the supervision of a pilot in command, or any combination thereof, which includes at least—
(i) 100 hours of cross-country flight time; and
(ii) 25 hours of night flight time.

§61.159 Aeronautical experience: Airplane category rating. Part 61.159(a)(5)

https://www.ecfr.gov/cgi-bin/retrieveECFR?gp&r=PART&n=14y2.0.1.1.2
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Old 9th Sep 2019, 18:32
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I can't believe this has gone on so long - the FAA allow a pilot to "log" PIC any time they are sole manipulator of the controls of an aircraft for which they are rated. PICUS on an EASA aircraft obviously satisfies that.

The only grey area is if the EASA type rating has a "no pic" endorsement, which could be construed as you can't log PIC. A bit of logical reasoning will conclude that's bollocks: it simply means you can't sit on the left. EASA specifically allow you to log PICUS from the right seat to get the hours for an ATPL so that you CAN sit on the left - which is exactly what the issue is here.
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Old 9th Sep 2019, 19:17
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Originally Posted by rudestuff
PICUS on an EASA aircraft obviously satisfies that.

The only grey area is if the EASA type rating has a "no pic" endorsement, which could be construed as you can't log PIC. A bit of logical reasoning will conclude...
I would assume his EASA PICUS does satisfy the FAA 250 hour PIC requirement (and have tacitly assumed that from the get-go) but that's only an amateur assumption on my part. So, I asked questions in lieu of making definitive statements. And I can tell you "A bit of logical reasoning..." doesn't always work with the FAA and their FARs. That's why there are countless pages of legal interpretations put out by the Chief Counsel of the FAA in DC; logical reasoning failed to actually answer the question.

amonghtus has a big decision to make: whether to cut bait from where he is and come over here assuming he'll proceed to an FAA ATPL with few snags and no deal breakers.

Hope it all goes as it appears it should.

Last edited by bafanguy; 9th Sep 2019 at 19:27.
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Old 9th Sep 2019, 19:29
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The other option is contact a sim centre (Pan Am, Flight Safety etc) and tell them your interested in doing an ICAO to FAA license conversion type rating and check ride.

They will ask to see your flight hours breakdown to decide if your eligible. If your hours satisfy the regs to take the ATP check ride then you are ok.
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Old 10th Sep 2019, 04:01
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Originally Posted by rudestuff
I can't believe this has gone on so long - the FAA allow a pilot to "log" PIC any time they are sole manipulator of the controls of an aircraft for which they are rated. PICUS on an EASA aircraft obviously satisfies that.

The only grey area is if the EASA type rating has a "no pic" endorsement, which could be construed as you can't log PIC. A bit of logical reasoning will conclude that's bollocks: it simply means you can't sit on the left. EASA specifically allow you to log PICUS from the right seat to get the hours for an ATPL so that you CAN sit on the left - which is exactly what the issue is here.
Actually, it's not a grey area. FAA Interpretation to Glenn Counsil dated Apr 13, 2012 specifically outlines that a type rating limited to SIC privileges only is not a "rating" for the purposes of 61.51(e)(1). Thus the only avenue for logging time when the SIC does not hold a full PIC type rating is under 61.159(a)(5) for the purposes of earning an ATP.

The FAA has answered all the questions in the past regarding the "performing the duties of PIC while under the supervision..." in their now discontinued FAQ. The SIC who is "performing the duties of PIC" does not have to be in the left seat, nor does he have to be undergoing any kind of PIC training at the time. He does not have to have a PIC type rating under this provision. The FAA does recommend that the actual PIC sign the logbook of the SIC performing the duties of PIC, but this particular provision does not require such an endorsement. He DOES have to be serving as a REQUIRED second-in-command in order to qualify under this provision.

Mine is a little more than an amateur opinion. I am a former airline Aircrew Program Designee (examiner) responsible for scouring through logbooks and making sure airline pilot trainees met the requirements of the FARs before conducting an ATP/Type Rating check ride and (if all went well!) issuing them a certificate. While we did not see a lot of candidates with foreign experience, there were a few.

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Old 10th Sep 2019, 04:12
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Originally Posted by Global Aviator



I find this advice hard to believe, I would be verifying with the FAA.
Short of requesting a formal letter of interpretation from the Chief Counsel's office, you would be hard pressed to find anyone at a publicly-accessible FAA office (FSDO) with reliable enough information to give an accurate answer. His best bet is the training facility who will issue his ATP/type rating as they employ the designee that will evaluate his qualifications.
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Old 10th Sep 2019, 08:46
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I just wanted to add to this already long conversation about my husband's flight hours. The 'pilot training center' that amonghtus contacted is an accredited 'certificate holder' for Part 61. He got the information for this training center from FAA sources. He is in direct contact with the head of the training center. This person specializes in converting foreign licenses according to FAA protocol. According to him, because my husband's license does not have some kind of SIC limitation on it, when he is pilot flying (PICUS) those hours can be counted as PIC.

Perhaps we are getting wrong information here, but just like raysalmon stated, it seems like answers even from the regulators themselves can be a mixed bag. It may be too much to ask for true clarification from a government agency. Ha!

Not that this makes a big difference, but my husband just received his verification letter from the FAA, for his foreign license. So I guess we are going to keep moving forward with this process. Thanks to everyone for your insight and detailed information.
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Old 10th Sep 2019, 14:59
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A friend of mine had to go back home for an instrument proficiency check after the check airman doing his ATP check ride decided that just having "instrument rating" written on his certificate wasn't enough. He had to be instrument current. There didn't appear to be anything in the regs stipulating this it was just his interpretation.


​​​​​​
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Old 10th Sep 2019, 20:56
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Originally Posted by IllinoisDavidson
Not that this makes a big difference, but my husband just received his verification letter from the FAA, for his foreign license. So I guess we are going to keep moving forward with this process.
Best wishes to your husband in his decision...and you too, of course !

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Old 11th Sep 2019, 19:17
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“(1). Thus the only avenue for logging time when the SIC does not hold a full PIC type rating is under 61.159(a)(5) for the purposes of earning an ATP.”

Thats my recall from decades ago. SIC as PM counts towards the requirements for your ATP.

On your resume it is NOT PIC time. The interview might go down hill, rapidly, if they found out your using SIC time to meet any PIC requirements they have.

Keep a separate entry for SIC/PF time.
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Old 12th Sep 2019, 00:01
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All USA legacies require a minimum of a bachelor degree besides unrestricted ATP and at least 5000 TT. I know this for a fact because i fly for one of them.
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