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FAA piggyback, keeping it legal

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FAA piggyback, keeping it legal

Old 8th Mar 2019, 01:18
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FAA piggyback, keeping it legal

Got a question.

FAA piggyback licence. Not me (have standalone) but asked by a client...

Have to go to US, have foreign verified - we agree.

Now, I thought that you need do nothing else 'American' except biennial flight review (or whatever it's now called), but client thinks even that not needed.

The correct answer is:
  1. Both wrong
  2. He's right
  3. I'm right
Thanks! Sam.
Sam Rutherford is offline  
Old 8th Mar 2019, 01:57
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The regulation covering the flight review, 14 CFR 61.56, lists acceptable alternatives. Compliance with that section by persons holding a restricted private pilot certificate is mandatory: see interpretation to Collins.

If a US flight instructor is unavailable to complete the review then consider using the WINGS Pilot Proficiency Program. It will require an FAA Safety Team Program Manager (FPM) at a suitable FSDO to manually approve some qualifying flying activity such as a skill test or proficiency check done in connection with the foreign licence.
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Old 8th Mar 2019, 02:55
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Okay, so first reply suggests that my understanding is correct - though will wait in case there are other answers to be sure. Interesting for the second part, though I suspect impractical in reality.
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Old 8th Mar 2019, 06:12
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To get the licence issued all that is required is pre arrange a visit to a FSDO with your appropriate paper work. Licence will be issued end of story.

However before you can exercise the privileges of that licence you must complete a BFR with a US CFI. That last point was stressed to me by the nice gentleman at the FAA.
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Old 8th Mar 2019, 06:42
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Sam, you're right. See FAA Chief Counsel opinion:

https://www.faa.gov/about/office_org...rpretation.pdf

and FAA General Aviation Airman Designee Handbook:

https://www.faa.gov/documentLibrary/...der_8900.2.pdf

Section 21, relevant item found at page 7-162:

Section 21. Accomplish Issuance of a U.S. Pilot Certificate Based on a Foreign Pilot License
...
(6) Advise the applicant about the rules and requirements contained in part 61 and part 91 (e.g., flight review requirements, recency of experience requirements, required logbook entries). As a point emphasis, make clear to the applicant that a flight review (refer to 61.56) must be administered by a holder of an FAA flight instructor certificate with the appropriate ratings before he or she may exercise the privileges of his or her U.S. pilot certificate. The proficiency checks administered by a foreign flight instructor do not count for meeting the flight review requirements of 61.56.
ifitaint...
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Old 8th Mar 2019, 12:10
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Sam - as well as BFR ( truly called Flight Review) which is absolutely required as the above excellent advice states, he'll also have to keep up with US pilot currency requirements which are a bit different as you know He can use his ( presumably) easa /foreign medical to comply with the requirement for a class 3 medical ( and its no extra work to have the med cert verified so suggest you do that)

Most fsdo require an appointment once the verification letter has been issued - the days of walkins are almost gone. . You need to nominate a fsdo to receive the verification letter but if you switch locations the letter can be faxed between fsdos. You could pay around 600 usd to have the verification done in the UK if desperate.

But the 61.75 is not an easy thing these days. The verification process alone is slow. Many people don't know about the rules around medicals etc so renting can be a pain. I'd encourage them to look at the alternative route of doing the private checkride before they decide how to proceed, depending on their long term ambitions. Certainly also consider spending a bit of money to get the FAA class 3 medical done at their next (easa/wherever) renewal with a dual qualified AME.
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Old 8th Mar 2019, 12:15
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And - one more thing - the medical accompanying a 61.75 needs to be a 'real' medical. Not LAPL/AIRMED/self declaration. That is certainly true outside the USA but I cant remember if you can use self declaration in the USA with a 61.75. Those rules are more than convoluted !
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Old 8th Mar 2019, 15:49
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Have to go to US, have foreign verified - we agree.
I’m not certain that’s still the case... for at least 5+ years now. Can’t you go to Tom Hughston or Adam House who are two (the only 2?) DPEs based in the UK who are able to do this?
See here for Tom Hughston
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Old 8th Mar 2019, 18:10
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,Once issued the Certificate under 61.75 functions like any other Pilot Certificate - a current Flight Review* or acceptable alternative is required. This must be done by an "authorized instructor" (AKA FAA CFI). 90-day currency does not have to be N-reg.

I doubt that any FAA Civil Servant would sign off someone's Wings flights without knowing all the people involved, though that would indeed count towards one of 61.56's alternatives. (Wings requires three flight credits and three online training credits, then resets the Flight Review for 24 more calendar months. I think it's a great program!)

This is sort of a moot point anyway. No one is going to rent an airplane to a stranger without a thorough checkout. This will certainly cover the flying portion of a Flight Review. The ground portion is an hour of review of FARs which is valuable for someone about to use their FAA Certificate for the first time.

The FAA's website gives a good overview of the process. Apply, indicating which FSDO you want to use. Have the CAA validate your license. Wait patiently throughout the process. IIRC the webpage suggests allowing 90 days.

In addition to a current Flight Review, a valid Medical is required. I don't believe an EASA Medical is accepted for use with an FAA certificate. I know I was not able to use my Second Class FAA Medical to fly in Germany on my EASA PPL last Autumn. (Although it was acceptable to extend my SEP rating last month with the German Authorities).

It may look like there are a lot of moving parts to make the 61.75 piggy back Certificate work, it's much easier than going the other way! Many, many people have done this and had a great time flying.

Good luck

Terry

Hasn't been a "BFR" since 1997...
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Old 8th Mar 2019, 18:20
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Originally Posted by custardpsc View Post
... self declaration...
There is no "self declaration" for FAA private pilots. This requires at least a Third Class Medical or, for those eligible, Basic Med.

For Light Sport aircraft US residents may use their state-issued drivers license as their "medical" (with some caveats). All Private Pilot Certificates include the privileges of the lesser Light Sport Certificate.

Glider pilots do not have a medical requirement.

Terry
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Old 9th Mar 2019, 07:48
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LTCTerry, a valid EASA medical on an underlying EASA licence is indeed sufficient for a 61.75 Certificate:

Originally Posted by 61.75 (b)(4)
Holds a medical certificate issued under part 67 of this chapter or a medical license issued by the country that issued the person's foreign pilot license; ]
(My bold)

Also, and trivially, whilst the official name is no linger "BFR", the "FR" is still biennial. "bFR", maybe?

Last edited by hoodie; 9th Mar 2019 at 16:56.
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Old 9th Mar 2019, 10:56
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Another thing that might or might not be an issue.
If you are in the UK and after Brexit your EASA licence becomes invalid and you get a UK licence, that will probably render your 61.75 invalid too, especially if the licence number changes.
You might be able to use the quick way to revalidate that was available for the EASA licence change, but who knows.

Of course all of the above is full of "if" as we do know what will happen yet.
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Old 9th Mar 2019, 11:56
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that will probably render your 61.75 invalid too,
Of course the logical thing would be for the CAA to use our old EASA numbers as our new UK reference thus negating the need to go through the FAA verification again.

Have to say I'm not hopeful...
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Old 9th Mar 2019, 19:51
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Unfortunately not quite, I have recently renewed my Fixed Wing Licence and received both EASA and CAA licences and the difference is minor, but the EASA number is GBR.FCL.PP.235272J.A and UK (ICAO) is GBR.PP.235272J.A so they have dropped the FCL part. I thought the same when the last number change came about, as they just added the GBR. bit on the front, so thought the sensible thing would be for the FAA to just recognise it as the same thing, but they didn't and needed everyone to change their 61.75 cert.
Also I have both Fixed wing and Rotary, and the Rotary licence has a H on the end instead of A, i.e. GBR.FCL.PP.235272J.H and my FAA 61.75 lists both Fixed wing and Rotary on the same cert but also says only valid when accompanied by United Kingdom Pilot Licence(s) and lists both licence numbers.
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Old 9th Mar 2019, 20:47
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I have EASA and UK new PPLs. I still have the lifetime licence on which my 61.75 was issued. Is that licence now invalid? It was a lifetime JAR number licence replacing a 1987 lifetime ICAO UK Licence, when I notified the CAA of an address change when I retired.
GBR.FCL.PP######J/A
GBR.PP######J/A both issued 09/01/2018
UK.PP######J/A dated 20/03/2008, (issued on basis of PPL(A), different ######, issued 24/4/1987) on which my 61.75 was issued.
I assume I'll need another CAA validation, but will wait at least until 30/3/2019 to see what new situations transpire.
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Old 10th Mar 2019, 21:35
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He is wrong on both.

One does not have to go to the US to get the 61.75 - but it would speed things along.

One must have a "flight review" (the correct term) every two years so the 61.75 in not valid without the sign off of the review by an FAA CFI.

Not valid either unless the originating licence is valid i.e. one has it, one has a current medical and one has a current flight review for that licence TOO.
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Old 10th Mar 2019, 21:39
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On the is it valid above - NO

You do not have a current originating licence - got to do it again with your new licence.

The lifetime thing is conditioned by the so long as your originating licence is valid i.e. with medical and flight review. Still good for your lifetime, you just can't fly with it
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Old 11th Mar 2019, 08:59
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Ebbie, you are right about the 61.75 and the flight review, but validity in the case of the underlying licence means , valid - ie not withdrawn or suspended. You do not need to meet currency requirements nor flight review requirements for the underlying licence for the FAA to recognise use of a 61.75 based on it . This has been covered elsewhere on here.
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Old 11th Mar 2019, 10:30
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Thank you everyone, very helpful.

I did know about the 'not having to go to the US', but whilst there is lots of "I think it's possible via Tom/Paris/etc. etc.- I've not seen a 'certain' other option.

If anyone does know, perhaps good to post here?

Thank you all, will let client know, and also let my friend know (again) that he's been flying illegally for the last 12 years!
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Old 12th Mar 2019, 19:42
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Originally Posted by Maoraigh1 View Post
I have EASA and UK new PPLs. I still have the lifetime licence on which my 61.75 was issued. Is that licence now invalid? It was a lifetime JAR number licence replacing a 1987 lifetime ICAO UK Licence, when I notified the CAA of an address change when I retired.
...
UK.PP######J/A dated 20/03/2008, (issued on basis of PPL(A), different ######, issued 24/4/1987) on which my 61.75 was issued.
I assume I'll need another CAA validation, but will wait at least until 30/3/2019 to see what new situations transpire.
As mentioned above, your 61.75 is now invalid because your JAR licence expired/was withdrawn the moment your EASA licence starting GBR.FCL was issued. You need a new verification - up to September last year, this could have been accomplished entirely in the UK:

UK CAA -- FAA certificates for UK licences

The irony of it is that many folks, having paid for the privilege of jumping through this paperwork hoop, may end up paying again after 29 March

As custardpsc wrote, your European SEP(land) need not be current (=revalidated), the only thing that counts in FAA-land is the flight review. Also, the requirements for recurring differences training on non-SEPs in FCL.710 do not apply.
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