Removal of 61.64 PIC Limitation
 

14 CFR 61.64 requires a limitation be placed upon a certificate if the flight test was conducted entirely in a simulator, as many of you know (please see the reg). My question is regarding 61.64(g): Can a non-FAA certificated captain/check pilot perform the "direct observation"? Say the first officer did his FAA 737 type entirely in the sim. He flies as a first officer for an Indian airline. The Indian-certificated captain/check airman (with no FAA licenses or ratings) holds an Indian type rating for the 737. They fly for 25 hours together. The captain signs each flight as the reg requires. Can the first officer go to the FAA to have the limitation removed?

Thanks

You can go to the FAA (FSDO Garden City?) and ask. They will give you the answer.