If you also hold a valid EASA IR, couldn’t you regain the currency yourself flying the necessary hold, tracking and approaches on the EASA ticket in your home country?
Not if your FAA IR has lapsed past the rolling currency. A flight with an FAA CFII is your only option. Bloody annoying if that happens if say your plane is AOGd for a while…
(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.
I thought I saw that previously – many thanks 
You’ve lost me there
Only that – IF the safety pilot had to be capable of being legally PIC – he’s not awfully likely to be a named insured. In a syndicate where the SP is one of the other members that may be so but rarely otherwise IMHO.
bookworm wrote:
It would seem rather odd if someone meeting 61.3(a)(1)(v) were entitled to be a required pilot flight crewmember, including pilot in command, but not a safety pilot.
Agree, that makes sense. So, I would revise my comment that a US certificate not be required as long as the N number aircraft is operating in the country of the pilot issued non US licence. Outside that country, I would expect a required crew member would need to hold the 61.75 or other US part 61 certificate.
I think you mean “that a US certificate is not required”
bookworm wrote:
Read literally, unless you can reach an alternate in the US, your alternate minima are VFR, not 600-2/800-2.
There are other areas where a literal reading of the definition of an approach does include the broader definition used by ICAO and is limited to part 97 procedures. That would make it near impossible to meet the currency requirements outside the US for IFR. So far the FAA has ducked this inconsistency.
To the OP: just do it and get on with your life. I really don’t think the FAA is going to get riled up if the safety pilot is licensed under EASA as long as it looks like he or she is competent to do the job. It’s one of those cases where you’re maybe better off doing what you want (in a way consistent with the spirit of the regulations), than second guessing what some regulatory pedant might say. To be fair, most of the time, regulators crack down when there is a GOOD REASON to do so. This case doesn’t rise to that level.
The US (along with the UK) differs from Europe in that it has a common law rather than code law legal system. The intent of the law or regulation is critical in the US. In Europe, the focus would be on what the statute says; in the US or UK the issue would be the intent behind the rule (or at least this argument could be made in court).
cactus1549 wrote (#01):
I want to fly my 6HIT in Europe [and] FAR 91.109(c)1 says …
Generally 14 CFR 91.109(c) only applies in the US and within 12 NM of its coast (14 CFR 91.1), and elsewhere to US civil aircraft if an equivalent foreign regulation or ICAO standard is lacking (14 CFR 91.703).
The relevant standard in ICAO Annex 2, tenth edition, which is very similar to SERA.3220, is:
3.2.4 Simulated instrument flights
An aircraft shall not be flown under simulated instrument flight conditions unless:
a) fully functioning dual controls are installed in the aircraft; and
b) a qualified pilot occupies a control seat to act as safety pilot for the person who is flying under simulated instrument conditions. The safety pilot shall have adequate vision forward and to each side of the aircraft, or a competent observer in communication with the safety pilot shall occupy a position in the aircraft from which the observer’s field of vision adequately supplements that of the safety pilot.
Peter wrote (#08):
The problem in this case is that as I wrote earlier the FAA has never defined what is meant by “authorised instructor”.
It is clearly defined in 14 CFR 61.1(b) for the purpose of that part:
Authorized instructor means—
(i) A person who holds a ground instructor certificate issued under part 61 of this chapter and is in compliance with §61.217, when conducting ground training in accordance with the privileges and limitations of his or her ground instructor certificate;
(ii) A person who holds a flight instructor certificate issued under part 61 of this chapter and is in compliance with §61.197, when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate; or
(iii) A person authorized by the Administrator to provide ground training or flight training under part 61, 121, 135, or 142 of this chapter when conducting ground training or flight training in accordance with that authority.
Peter wrote (#08):
Just about every European pilot who travelled to the USA to get additional paperwork had his previous training accepted.
That is typically consistent with 14 CFR 61.41 permitting the crediting of instruction received outside the US from an instructor authorised by an ICAO contracting state.
That is typically consistent with 14 CFR 61.41 permitting the crediting of instruction received outside the US from an instructor authorised by an ICAO contracting state.
Indeed – and that is EXACTLY why the position historically and aggressively adopted by some (nobody on EuroGA AFAIK) is nonsense, because it is exactly this context which operates for European students getting training towards US pilot papers.
The “authorised instructor needs to be an FAA one” argument is irrelevant for another practical reason: few if any instructors of any kind who don’t have the US CFI/CFII rating will be instructing inside the USA
Peter wrote:
The “authorised instructor needs to be an FAA one” argument is irrelevant for another practical reason: few if any instructors of any kind who don’t have the US CFI/CFII rating will be instructing inside the USA
I disagree because pilots trained in the US, by non-FAA instructors, who later seek Part 61 certificates or ratings will be significantly disadvantaged by the territorial restriction imposed in 61.41. As recently as 2016 I met four EASA FIs (without FAA flight instructor certificates) instructing in the US so the breed isn’t extinct. These instructors face the bigger problem because the student instruction and training flight exemptions made in 14 CFR 119.1(e) do not apply to these operations.
Peter wrote:
Not if your FAA IR has lapsed past the rolling currency. A flight with an FAA CFII is your only option. Bloody annoying if that happens if say your plane is AOGd for a while…
Not exactly. Once the rolling currency lapses you have another 6 months to “recover” by meeting the currency requirements. But of course during this time you can’t do it in IMC as PIC, so you need to chose one of the other options such as simulator, IMC/IFR with another IFR current pilot acting as PIC, or VMC under foggles with a safety pilot. Once the 6 months’ “grace” has elapsed, you need the IPC with an FAA CFII.
Yes; that’s correct. Sorry I wasn’t clear. During the second 6 months you need the safety pilot, basically. Can you do it on a sim?
As recently as 2016 I met four EASA FIs (without FAA flight instructor certificates) instructing in the US so the breed isn’t extinct. These instructors face the bigger problem because the student instruction and training flight exemptions made in 14 CFR 119.1(e) do not apply to these operations.
I did wonder whether this happens in the 7 or so US schools which do EASA licenses. Otherwise I can’t see why anyone would want to do it – other than to offer oneself in the USA as an “instructor” under false pretences. This has been done but more often in Europe.
There was an agreement between the FAA and the UK CAA whereby they would accept mutually qualified FIs. This goes back to the days when the above mentioned US schools were operating under the umbrella of the UK CAA. In recent years these schools got moved to EASA supervision, IIRC. @tumbleweed might know more detail. This mutual agreement permitted UK/JAA FIs to train in the USA for both FAA and JAA licenses (the JAA IR could never be trained outside JAA-land but the PPL and I believe the CPL could be). It equally permitted FAA CFIs to train in the UK, but I don’t think this was ever honoured by the UK CAA because in 2005 they famously prosecuted one well known FAA training outfit (the prosecution failed because the guy had a letter from the CAA saying “we hereby confirm we will not take any regulatory interest in your operation and we will not place obstacles in your way” – that’s my recollection of the letter, which he had pinned on his wall – and obviously the CAA never knew that some “junior” wrote that letter).
