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Part 61.75 & CRI in USA

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Old 25th Sep 2017, 08:32
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Part 61.75 & CRI in USA

Hi All,

Holder of a Part 61.75 based on my licence in the UK, if a CRI is showing on said licences am i able to fly an N Reg in the USA and sign off my friend for his UK SEP revalidation??

UK no issues, just wondering if I can do it when we are both out in the USA doing some flying together?
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Old 25th Sep 2017, 08:36
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I somehow really really doubt that anybody has ever made a rule about this - nor that anybody will ever challenge it if you do do-so, as it'll just be too much of a headache to address.
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Old 25th Sep 2017, 09:46
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Hmmm....

Lots of points to consider.
If you're talking about doing the 'hour training flight' then signing his revalidation page, presuming you have 945 privileges that would be a different ball game to signing him as an examiner if he's revalidation is based on 12 hours flown in the US on an N Reg.

Do you own the aircraft or is it hired?
If hired, does the renter allow instruction other than by a qualified CFI/CFII?
Do you have an FAA CPL with CFI/CFII ?
What's the insurance situation?
Are you charging your friend for his time?
Are you on a visa or under the VWP?
If visa, does it entitle you to work whilst in the US? (VWP won't)

As GTE states - too much of a headache to make sure all of the dots are crossed and eyes teed!

I'm sure it's been done, and I am sure it will be done in the future but to break it down to the full legality would be a bit of work.
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Old 25th Sep 2017, 16:28
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The other question that might come to mind is whether two mates flying together abroad is really going to be a properly constructed instructional flight?
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Old 25th Sep 2017, 18:30
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Really?

Come on........

There is absolutely no reason why 2 mates flying together and between them they make the flight Instructional for the purposes of revalidation and the licence gets signed. Job done.

Why on gods earth do pilots always look for some life sapping reason to find a problem in everything we do.

For the record I have done this many times both as an Instructor and Examiner including for a friend who is an FAA employee DPE to renew his EASA qualifications.

Really guys, I despair.......
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Old 26th Sep 2017, 08:25
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Yeah okay Bose - I think I had something in mind there.

I've had a couple of occasions where, after flying with somebody in their aeroplane - most likely just for a jolly, I've had them ask me afterwards "Genghis, you're an instructor, can we use that flight last Thursday as my biennial".

As in those cases it hadn't been briefed or debriefed as an instructional flight, and it wasn't my understanding at the time that I was flying as an instructor or as Captain, I have invariably said something along the lines of "no, because...., but I can come back and do a proper instructional flight with you next Friday if you want?". Strangely enough I've had no acceptances of that offer. It's possibly just made me a tad over sensitive about people cutting corners on biennials.

The fact that the OP is looking into the issues ahead of time, probably also means he'd do everything properly, and I'm wrong to be concerned on that point.
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Old 26th Sep 2017, 13:04
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It's possibly just made me a tad over sensitive about people cutting corners on biennials.
As there is absolutely no laid down requirement for the biennial flight and quite legally you can fly along straight and level for one hour or (2x flights to make one hour) you may find yourself in danger of Gold Plating........

The simple answer to the original question is there is nothing preventing them doing what they asked. Anything else being thrown into the discussion is just a red herring.
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Old 26th Sep 2017, 13:12
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Originally Posted by bose-x
or (2x flights to make one hour)
3x - don't gold plate it.
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Old 26th Sep 2017, 13:37
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Whilst the wording is sufficiently lax to suggest that 'an hours straight and level' would count as a training flight, I certainly wouldn't accept something so mundane and basic as meeting the 'spirit' of the regulation. The training flight is supposed to be an opportunity to review/practice items that the pilot doesn't undertake often or they consider requires consolidation or perhaps a completely new skill altogether such as VP or RG differences.

In any case, as GTE suggests, it should be properly discussed, briefed, flown and debriefed/critiqued as per good instructional practice - I do not see this as purely a box ticking exercise and would hope that others don't also. How is a properly constructed 'training flight' gold plating?

The OP asked if they could do it when they're out in the US - and as I stated many people do this. I merely raised some other points that perhaps they should consider if they want to be watertight, not just from a UK CAA point of view, but from an FAA standpoint, an insurance issue and the POV of the US Visa system where this could be viewed as 'working'. Maybe those organisations won't care and I really don't care one way or the other either and maybe I am being a tad over the top. But, as I teach my FI candidates, flying and flight training isn't just about jumping in an aeroplane and going (especially in airspace that isn't my usual stomping ground or in an aeroplane that doesn't belong to me) - it's about the proper delivery of structured training and ensuring you adhere to laws/regulations/procedures as you do so.
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Old 26th Sep 2017, 18:26
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How is a properly constructed 'training flight' gold plating?
I am merely pointing out the regulation. How we choose to do it individually is not part of the discussion. I merely post out the answer to the original question as far as the regulation is concerned. As I have said, I do the biennial of an FAA Staff DPE in Florida and he does not have any problem with it. Only the British would look for some way of creating restriction and pain where none needs to exist. The rest of the world is more pragmatic. Reminds me of coming back from Switzerland on Sunday. The Brits were queuing an hour before the gate opened.......
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