FAA 61.75 - what happens to addon ratings?

[citabria06g]

Hi all,

I currently hold a UK-JAR PPL and a piggyback FAA private - worked well so far because I was living in Europe. New job is taking me to the sandbox, so any further flying will probably be in the US. I was considering some floatplane training in July and converting to a standalone ticket next year, hence my question: what happens to add-on class ratings endorsed on a 61.75?

I know the IR explicitly says "US test passed" - is it the same for class ratings, and if not does the FAA keep track of which ratings come from the underlying licence and which come from a FAA flight test? Is it possible to have the ratings obtained in the states re-endorsed on a new certificate? Is it any different in the case of:

a) piggyback to piggyback (underlying licence change)
b) piggyback to standalone private
c) piggyback to standalone commercial

Before anyone brings up the "house of cards" argument, I am quite familiar with the implications but a standalone this year just isn't possible due to the new job.

Any written reference greatly appreciated!

06G

[S-Works]

As you will be moving, you will be required to notify the CAA of your new address. That invalidates the 61.75 anyway.

I am not sure you can add a Seaplane rating to a 61.75 but stand to be corrected on that front. If you make any changes to the 61.75 you will have to go through the full process again which will mean paying the money to the CAA waiting for the data to be released and visiting the FSDO.

You would be much better off just converting to an FAA PPL in the circumstances you state.

You can't bury your head in the sand regarding the house of cards scenario as it does rather seem to apply to you....

[citabria06g]

Thanks for the reply.

As you will be moving, you will be required to notify the CAA of your new address. That invalidates the 61.75 anyway.

The address on my licence will remain valid for now (house I own in the UK), however changing address after July 1st would trigger an EASA licence which would indeed invalidate the piggyback.

I am not sure you can add a Seaplane rating to a 61.75 but stand to be corrected on that front. If you make any changes to the 61.75 you will have to go through the full process again which will mean paying the money to the CAA waiting for the data to be released and visiting the FSDO.

You say any changes to the 61.75 - the way I understand it, I have to go through the validation process if the underlying licence changes. Otherwise it would be impossible to add any ratings to the piggyback, and I know the IR is possible. Searched a bit and couldn't find any explicit exclusion of class ratings:

14 CFR 61.75

(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.

Again any clear written reference either way would be awesome.

You would be much better off just converting to an FAA PPL in the circumstances you state.

You can't bury your head in the sand regarding the house of cards scenario as it does rather seem to apply to you.

I'm not trying to escape the standalone, but my thought process is as follows:

a) due to visa issue in the middle-east my passport will be all over the place, not sure I have the time to organise TSA/M1 visa this year;
b) kind of silly to do a standalone private this year and then a standalone commercial next year, hence was trying to ride the piggyback train a bit longer;
c) apart from JB in Florida, which I'm not particularly attracted to, I don't see any part-141 seaplane schools, so even if I were to get a standalone this year it would mean attending two different schools.

Any suggestions welcome.

[NearlyStol]

Seaplane rating.

Florida Seaplanes

Can recommend Rich Hensch and his Maule.
Lake, river anywhere Mid Florida.
Based at Altemonte Springs on private lake.
Best ride for the buck.
Enjoy !

[neilgeddes]

Florida Seaplanes

Yes, recommended

[citabria06g]

Thanks, will look into that.

Still unsure about my original query: assuming you can add an ASES rating to a 61.75 by passing the practical test in FAA-land, will this be re-endorsed on a future standalone private/commercial?

[Mark 1]

I have Instrument and sea (US test passed) on my 61.75.

As I understand it, you can use any address that will reach you. So if you receive mail normally that is sent to your UK address, that will be sufficient.

I suspect that changing any address may invoke the licence verification process again. Not too big a deal.

[B2N2]

All ratings that are US test passed will carry over onto a stand-alone certificate.
With the understanding that people are still involved which means that mistakes can be made and ratings can be dropped unintentionally so check all the paperwork.
If you have the inclination to do so you can look things up here:
Flight Standards Information System (FSIMS)
Volume 5, Chapter 2, Section 7 or 8
Your piggyback has been issued under Section 14

[SunnyDayInWiltshire]

I am not sure you can add a Seaplane rating to a 61.75 but stand to be corrected on that front.

I have a 61.75 with an FAA seaplane rating (ASES). Issued when taking the rating at Jack Brown's without the need to visit the FSDO at all. I've since added ratings to my JAR-PPL which has been reissued, and believe it continues to be valid.

My *assumption* was that the 61.75 would remain valid as long as the underlying UK licence continues to have the same licence number - the text says something like "based on licence XXXX issued by UK CAA". So as along as the licence number doesn't change, then even if you move I don't see why it wouldn't be possible to retain the 61.75 (you also have to tell the FAA that you've moved).

My *hope* is that when my JAR-PPL is replaced by an EASA equivalent, the same licence number might be used. In this case, the 61.75 could continue to be valid after the transition. But until EASA licences start to be printed off in July, we may not know.

If moving to the US, then clearly getting a full FAA licence sounds like a good idea. For those visiting occasionally on business, I can't see that the hassle of arranging an M1 Visa and TSA approval etc. (which must be done long in advance of travel), is worthwhile.

[citabria06g]

Big thanks to everyone for your input, especially B2N2 for the written reference

[Genghis the Engineer]

FAA seemed entirely happy with my UK issued JAA PPL becoming a CPL, and my home address changing several times.

The oddball proviso was that they wouldn't re-issue the plastic card with my new address on, without going through the whole security / FSDO process again. So the FAA have all my current details and are quite happy about it, but my 61.75 licence still has an old address from about 2003 on it.

Seems to work.

I have had an FAA high performance rating added on, using a logbook entry. I'm no expert in FAA procedures, but the FAA CFII who signed it off seemed entirely happy to do so, and then to rent me his aeroplane on the back of it.


No idea about what will happen post EASA. I agree that the licence number looks likely to be the critical factor - if we can keep our numbers, all should hopefully remain peaceful and happy.

G

[S-Works]

Genghis, I would argue that your 61.75 is invalid. Contact the FAA and confirm. But as I understand it any change to the underlying licence requires you to revalidate. Changing from a PPL to CPL or change if address is enough to invalidate.

[Genghis the Engineer]

I did. FAA were happy. Sorry, I didn't keep the correspondence to be able to quote it.

G

[S-Works]

I would like to see the correspondance as I have a statement that is the exact opposite of what you are saying from the Orlando FSDO.

They have stated that any change in the underlying licence renders the 61.75 certificate invalid and the validarion process will need to be completed again in order to update the FAA record. It is a requirement of the the FAA that you notify them of a change of address and that in itself is requires revalidation from the UK CAA.

[BossEyed]

Originally Posted by bose-x

...and that in itself is requires revalidation from the UK CAA.

Where's that written down?

When I changed my address I wrote to the FAA Airman Certification office, and received an acknowledgement. No mention at all of a requirement for CAA validation. My current address is correct on the online database.

[Genghis the Engineer]

From Airmen Certification - Update Your Address

We do not require that you get a new certificate when updating your address and we won't issue one automatically.

And from Airmen Certification - Verify the Authenticity of a Foreign License, Rating, or Medical Certification

.... absolutely nothing about invalidating this if you change address.


Log into their online information and the information you get is that they are happy to be notified of changes of details, BUT if you want the 61.75 card re-issued, THEN you need to go through the process again.

Like Bosseyed, my details are up to date and correct on the FAA database. No statement has been made one way or the other about my licence switching from PP/ to CP/ but it's been accepted in the USA without issue on the basis that my CPL contains PPL privileges. No, I haven't attempted to argue to anybody in FAAland that actually they shouldn't be accepting my licence - I simply presented the paperwork, explained the changes, and invited them to check my details on the FAA website should they wish.

G

[S-Works]

I simply presented the paperwork, explained the changes, and invited them to check my details on the FAA website should they wish.

I got on the bus this morning from Kings Cross to Angel using my travelcard without noticing that the Zones 1-6 had been omitted this morning when it was issued. I got off at Angel without problem, but would have happened if there was a ticket inspector...............

[mad_jock]

genghis I got told the compete oppersite when I asked them.

There is also another ball ache you might encounter to do with the change from PPL to CPL.

If you just continue on your current ratings page it will have your PPL reference on the bottom of it.

Guess what?

If you fly to france this can be an issue. It can also be an issue if you have gone from CPL to ATPL as well. '

So make sure on your next set of sign offs you get them to do it on a fresh CPL ratings sheet.

[Genghis the Engineer]

For no other reason than it looked neater, I did my first class rating renewal after I got my CPL on a new (CPL headed) sheet. Saves explaining to a gendarme in my schoolboy French why the letters "C" and "P" are interchangeable in British English Didn't realise it would save me from having to stage a re-run of Agincourt, but that's obviously an added benefit.

(And then I did my CRI and IMC, both of which are on yet another, CPL headed, sheet. This system really isn't simple is it - hence that my logbook currently shows 7 different expiry dates of assorted privileges, that I need to monitor. Thank heavens for computers!)

Absolutely no risk I think of my upgrading to ATPL this side of the second coming. C I am, and C I shall remain! Used mostly as a P.

G

[Genghis the Engineer]

Originally Posted by bose-x

I got on the bus this morning from Kings Cross to Angel using my travelcard without noticing that the Zones 1-6 had been omitted this morning when it was issued. I got off at Angel without problem, but would have happened if there was a ticket inspector...............

And he could find reference, in any authoritative source (not including a post on the London-Transport-Rumour-Network, or a letter sent by another office, several years ago, to somebody you've never met in person), that you had any access to, of a rule you'd broken.

G