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-   -   FAA 61.75 'Piggy back' Certificate Validity (https://www.pprune.org/rotorheads/611932-faa-61-75-piggy-back-certificate-validity.html)

nigelh 15th Aug 2018 11:36

That said, if at some unlikely point someone kindly offers me the opportunity to fly their N reg MD500 I'd seriously consider doing the requisite conversion training and the paperwork ..........
why would you need to do any training or paperwork if you have the FAA privileges?

Gustosomerset 15th Aug 2018 11:59

MD600 - as I understand it, when you apply for your 61.75 certificate, you specify the 'airplane category rating' for which you are applying. Fixed wing and rotorcraft being two separate category ratings, I assume you would need to re-apply for a new certificate to cover a new category on a 'foreign' license.

Nigel H - as specified in the legal judgement letter linked to earlier, in addition to the 61.75 certificate, a pilot is required to have 'an endorsement in his or her logbook as prescribed in 14 CFR 61:31.' You can look up the detail of this requirement here but it is, in effect "...to have received training...appropriate to the pilot certification level...and an endorsement for solo flight in that aircraft from an authorised instructor."

claudia 25th Aug 2018 11:30

Gordy, I am presently flying a squirrel on my UK issued EASA licence (rating with up to date LPC etc). In the event i get a FAA 61.75 based on that licence
do i need to keep the EASA LPC up to date in order to keep 61.75 Ticket valid to fly an N reg squirrel in the UK. Opinions/thoughts would be much appreciated.
Many thanks

Gordy 25th Aug 2018 16:46


Originally Posted by claudia (Post 10232994)
Gordy, I am presently flying a squirrel on my UK issued EASA licence (rating with up to date LPC etc). In the event i get a FAA 61.75 based on that licence
do i need to keep the EASA LPC up to date in order to keep 61.75 Ticket valid to fly an N reg squirrel in the UK. Opinions/thoughts would be much appreciated.
Many thanks

I believe so, yes. Your US certificate is based upon the UK one therefore all limitations and currency would apply.

claudia 25th Aug 2018 19:20

Gordy, Your prompt reply is much appreciated, Thank you. One further question please, Do i need two LPCs, one for each licence?
The reason i am exploring this is because i have reason to go occasionally to the Republic of Ireland. My squirrel is N-reg.
Thanks again Best Regards.

Gordy 25th Aug 2018 23:48


Originally Posted by claudia (Post 10233203)
Do i need two LPCs, one for each licence?

What is an LPC? I assume a proficiency check?

I am going out on a limb here and say that if you have had an LPC on your foreign license within the preceding 24 months that would cover you for the FAA Flight review.

No-where in 14 CFR 61.56 does it say it has to be in an N reg or by an FAA CFI.

14 CFR 61.56 Flight Review

Gustosomerset 26th Aug 2018 08:36

Again, as per the legal opinion issued by the Office of Chief Counsel for FAA quoted above, "...the FAA has not considered the absence of a rating as a restriction on a person's pilot certificate." So the revalidation of the type ratings in the 'parent' license, via a proficiency check, is therefore irrelevant to the validity of the 61.75 'piggy back' license. The requirement is only that the license itself remains valid (which, being not time limited is not hard to achieve) and that a valid medical supports the license (see note below). So an EASA type rating that has not been revalidated does not constitute a limitation on the EASA license such that it limits the validity of the 61.75 certificate based upon it. Or, to answer Claudia's question directly - ("do i need to keep the EASA LPC up to date in order to keep 61.75 Ticket valid to fly an N reg squirrel in the UK."). No, you do not.

However, to keep your FAA 61.75 certificate valid you do need to ensure that:
a) your logbook endorsement from a U.S. qualified examiner needs to be re-validated every 24 months.
b) you hold an appropriate FAA medical certificate or 'a medical license issued by the country that issued the person's foreign pilot license'.
This second requirement remains, despite the recent introduction of 'self-certification' for some pilot/license/aircraft types in the UK. So, from a medical point of view, the validity requirements of your 61.75 certificate may now be more onerous than for your EASA license.

claudia 26th Aug 2018 10:19

Gordy/Gusto Thank you both for kindly taking the time to respond with your views,albeit slightly different.
Gusto Im hoping your views are correct.- No EASA LPC needed, just a 24 month flight test with FAA examiner.
and 61.75 is good to go for UK and Ireland in N-reg
Bit of a mine field but guys I appreciate your in-put.
Best Regards

Gustosomerset 26th Aug 2018 16:17

Claudia, my interpretation is based on the legal opinion of the FAA counsel that Gordy traced above, plus a subsequent discussion with an FAA examiner on the 'revalidation' point. So I believe I'm correct, but am quite happy to be proved wrong. As you say, it's a bit of a minefield....and one that surprisingly few seem to have taken the trouble to navigate, given the benefits.

Gordy 27th Aug 2018 00:02

Gusto:


However, to keep your FAA 61.75 certificate valid you do need to ensure that:
a) your logbook endorsement from a U.S. qualified examiner needs to be re-validated every 24 months.
Where does it say this----there is no such regulation. You may be referring to the flight review requirement of 14 CFR 61.56 which is conducted by a CFI NOT an examiner.

Gustosomerset 27th Aug 2018 09:13

Gordy. You're right I'm referring to 14 CFR 61.56 which requires the flight review and logbook endorsement to be carried out by 'an authorised instructor'. That person is presumably usually going to be a Certified Flight Instructor but may also be 'an examiner, an approved pilot check airman, or a U.S. Armed Force' again according to the FAA Chief Counsel.
Worth noting also that the 24 month time limit is very precise with no leeway for extensions, defined as: "... the beginning of the 24th calendar month before the month in which that pilot acts as pilot in command'.

Gordy 27th Aug 2018 16:55


Originally Posted by Gustosomerset (Post 10234216)
authorised

"Authorized" please..... When in Rome........ or discussing Rome's rules.... Just ribbing you.

But seriously when you use the word examiner instead of CFI it gives incorrect information.

claudia 27th Aug 2018 19:46

Guys. Say i go and get my 61.75 or indeed a stand alone FAA ticket, does the CFI conducting the 24 mointh
review need to be specifically rated on the squirrel --- after all his licence being American is not type specific
Just wondering !

Gustosomerset 27th Aug 2018 21:27

Gordy. You're quite right. I stand corrected - on both points!

Claudia. As you say, the CFI's FAA license is not type specific, so it doesn't matter what aircraft you're in for the endorsement (so long as it's an N reg light helicopter under a gross takeoff weight of 12,500 pounds).

Equally, and on the same principle, once you have done the flight review (presumably in your Squirrel) and have the logbook endorsement you can then fly any N reg light helicopter under a gross takeoff weight of 12,500 pounds for the next 24 months (to revert to my original point), completely irrespective of your EASA type ratings...should you wish to do so...

claudia 27th Aug 2018 21:52

Gusto. Many thanks for that info. A 61.75 will do my job and i will set the wheels in motion shortly.
Interesting that a CFI who maybe has never even been in a squirrel could be sitting beside me doing my
flight review.!! Best Regards.

Reely340 28th Aug 2018 06:33


Originally Posted by Gordy (Post 10233304)
I am going out on a limb here and say that if you have had an LPC on your foreign license within the preceding 24 months that would cover you for the FAA Flight review.

THAT is a very interesting point of view. I was told that an EASA Prof.Check is not substitue for an FAA BFR and of course an FAA BFR is no substitute for the annual EASA Prof.Checks per Type rating. (by someone providing EASA annunal Prof.Checks and type ratings ;) )

Where does it say that, the (more frequent and EASA type oriented) annunal practical EASA Prof.Check can substitute the practical and theoretical FAA BFR?

I'm currently under the impression that my FAA piggyback lic. is only half baked as I never did an FAA BFR as of yet.
However, your interpretation would insinuate, that I'm good to go in any below 12500lbs helo as long as it is N-reg. :8

Reely340 28th Aug 2018 06:40


Originally Posted by Gustosomerset (Post 10224379)
as specified in the legal judgement letter linked to earlier, in addition to the 61.75 certificate, a pilot is required to have 'an endorsement in his or her logbook as prescribed in 14 CFR 61:31.' You can look up the detail of this requirement here but it is, in effect "...to have received training...appropriate to the pilot certification level...and an endorsement for solo flight in that aircraft from an authorised instructor."

Is that referring to a FAA BFR ?
Is that section saying that piggy back FAA lic w/o BFR + EASA lic + medical is not sufficient to fly N-reg aircraft ?

Reely340 28th Aug 2018 07:05


Originally Posted by claudia (Post 10234714)
Guys. Say i go and get my 61.75 or indeed a stand alone FAA ticket, does the CFI conducting the 24 mointh
review need to be specifically rated on the squirrel --- after all his licence being American is not type specific
Just wondering !

Apparently not. The FSDO Officer doing my 61.75 piggy back work in Oahu explained to me that CFIs do not have to be and sometimes are not rated or proficient(!) in flying the a/c the applicant wants to do the review in: In one case the CFI conducting the check ride in a squirrel actually did shut off the engine midflight to indicate he'd like to see the applicant's proficincy in emergency procedures. And off meant off, not ground idle! With stress levels in the cockpit rising considerably the applicant barely manged to land, off airport w/o any damages to a/c or surroundings. => pick your CFI wisely ;)

He (the FDSO officer) said that this rating-less scheme would be the american way: while he was working SAR he frequently rescued off shore skippers who had had the money to buy a capable high sea sail plane but apparently lacked any skills to operate the ship safely out there in heavy weather. Apparently one may legally cross oceans after acquiring proficency sailing a 10ft dingy.

Personally, I do like that idea, of letting darwin sort out the gene pool. That way those with brains do not have to suffer (by excessive bureaucracy) for loonies in their area of conduct.

Gustosomerset 28th Aug 2018 08:30

Reely - your summary of the 61.75 certificate regulations as 'Darwin sorting out the gene pool' is, IMHO, unimprovable. The fact that so few people appear to understand them only lends weight to your definition.
In answer to your other question: "Is that section saying that piggy back FAA lic w/o BFR + EASA lic + medical is not sufficient to fly N-reg aircraft ?", in my understanding, the answer is, yes, it is not sufficient (if you are hoping to fly the N reg aircraft on the validity of your FAA 61.75 certificate).Or to put it as a string of TLAs (three later acronyms) if you prefer: 61.75 lic (FAA 'piggy back' certificate) without BFR (valid 24 month Bi-annual flight review and logbook endorsement) plus EASA lic (EASA 'foreign' license) + medical (EASA approved medical) = PYL (Pushing Your Luck).

Although the 61.75 certificate is very permissive in terms of the aircraft it allows you to fly, the requirement for the periodic flight review and logbook endorsement is mandatory to preserve its validity, whatever the validity of the EASA license and medical on which it is based.

Reely340 28th Aug 2018 15:38


Originally Posted by Gustosomerset (Post 10235100)
Reely - your summary of the 61.75 certificate regulations as 'Darwin sorting out the gene pool' is, IMHO, unimprovable. The fact that so few people appear to understand them only lends weight to your definition.
In answer to your other question: "Is that section saying that piggy back FAA lic w/o BFR + EASA lic + medical is not sufficient to fly N-reg aircraft ?", in my understanding, the answer is, yes, it is not sufficient (if you are hoping to fly the N reg aircraft on the validity of your FAA 61.75 certificate).Or to put it as a string of TLAs (three later acronyms) if you prefer: 61.75 lic (FAA 'piggy back' certificate) without BFR (valid 24 month Bi-annual flight review and logbook endorsement) plus EASA lic (EASA 'foreign' license) + medical (EASA approved medical) = PYL (Pushing Your Luck).

Although the 61.75 certificate is very permissive in terms of the aircraft it allows you to fly, the requirement for the periodic flight review and logbook endorsement is mandatory to preserve its validity, whatever the validity of the EASA license and medical on which it is based.

Thx for the fast response. Your answer is what I had presumed: an FAA piggy back lic has its own renewal scheme, namely the BFR. Nice, simple and relatively cheap.

The final question is what happenes when after acquiring a piggy back lic and maintaining a recent enough BFR
all my EASA TRs have expired, from FAA's point of view? The EASA lic is valid indefinitely, albeit als TRs have expired.

FAA won't care, as long as the BFR is younger than 24 Months, is that true?


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