EASA -> FAA conversion with expired ratings (and training in Canada)

I don’t think it works that way. The US doesn’t have a “61.75 CPL” (well I heard one exists but it has various restrictions making it usable only for ferrying) and the way they do it is by allowing you to use all your training records, done outside the US with a non-US rated FI, towards a US license or rating.

So when I did my FAA PPL I used my UK PPL training records. Same for the IR (used the IMCR training records, etc, plus flying some 20+hrs in Arizona) and same for the CPL (I never had a Euro CPL but the various x/c requirements were met on European flights, etc).

You have to get signed off by an FAA CFI/CFII as fit for the checkride and this must be done in the 60 days preceeding the checkride, and in practical terms the guy isn’t going to sign you off unless he has flown with you, so you have to do that bit of flying with him. Incidentally that little bit of flying has been done by many Euro pilots in the USA without TSA or Visa.

So whether your current papers are valid doesn’t matter because you are not converting or validating them if you are doing standalone FAA papers.

Renew your EASA SEP PIC rating, get FAA validation, convert EASA CPL to FAA CPL.
Or look into the canada route… @qualupalik is an expert!

Do you even need an FAA PPL/IR? The requirement for the CPL is to “hold an instrument rating”, but does it have to be an FAA IR?

Roger,

The Airmen Certification Branch has given contradicting answers to your question. To muddy the waters there are two relevant interpretations from the Office of the Chief Counsel for FAA: one given to Andrew Krausz on 22 March 2012 by Rebecca B MacPherson, Assistant Chief Counsel for Regulations, and another to Henning Grossman of 6 Aug 2014 by Mark Bury, Assistant Chief Counsel for Regulations.

The verification document provided by UK CAA to the Airmen Certification Branch does not make reference to rating validity periods. If unexpired ratings are truly necessary then the problem should be picked up on during the application process but the several DPEs (and two ASIs) I consulted with on this point were uncertain. A solid answer requires a request for an opinion from the Office of the Chief Counsel for FAA which could take months.

If you decide to wing it without a valid MEP rating, and it has not yet been removed to the rear of your licence, then there are Part-FCL examiners in Arizona and Florida for a proficiency check as a backup. As an alternative simply acquire a US commercial pilot certificate and add an AMEL rating by practical test or do the commercial practical test in an AMEL. UK-granted Part-FCL licence holders may rely on a derogation that allows an expired Part-FCL MEP to be renewed without receiving an evaluation or refresher training at an ATO. No course completion certificate needs to be presented to the examiner. The licence requires UK CAA processing if the rating has been removed to the back. The derogation (applicable also to the IR) will shortly be included in Part-FCL, going by the draft proposed rules annexed to EASA Opinion No. 05/2017, in the event your licence is administered by an EASA Member State that hasn’t adopted the derogation.

If you do not yet have a US restricted foreign-based private pilot certificate (14 CFR 61.75) then an alternative process is to acquire a Canadian CPL with an MEP and group 1 (multi-engine aeroplane) IR. These can be converted to FAA equivalents without further practical tests. You must demonstrate sufficient medical fitness before attempting a Canadian written exam, and must hold a valid appropriate medical certificate before attempting a Canadian flight test, so the process should begin by obtaining a medical. There are 47 Transport Canada Civil Aviation Medical Examiners authorised in Europe (map) and an appointment takes about a fortnight to arrange although some examiners have unpublished slots for the desperate. Transport Canada takes up to 6 weeks to issue the certificate.

On the other hand for US training, assuming you are an alien who is not otherwise admissible under an appropriate visa, the waiting period is broadly similar because it takes several weeks for the Airmen Certification Branch to issue a copy of the verification letter, 2 to 3 weeks for TSA to grant approval to train, about ten days to a week waiting to receive the I-20M-N (certificate of eligibility for a non-academic visa), secure an embassy appointment and receive the passport with visa. The TSA, visa, and miscellaneous costs for the US are about 600 to 700 USD plus 200 USD per additional training event for which a TSA approval is required. Approval is required for an initial standard airman certificate (not for the restricted foreign-based one), which in your case may be a commercial pilot certificate, an instrument rating and an AMEL rating. Canada doesn’t require a study permit unless training for longer than 6 months, assuming you’re a first-world citizen, and no equivalent security assessments or approvals are necessary. The US restrictions limit your choice of training provider to an FAA Part 141 flight school that holds a Student and Exchange Visitor Program certificate whereas any training provider in Canada may be used. In fact not all training for a Canadian licence or rating needs to be done with a flight instructor rating holder (see Canadian Aviation Regulations standard 425.21).

There is no need to first acquire a Canadian PPL to attempt the CPL flight test and no instructor recommendation is required. You need only a valid appropriate medical certificate and a written pass in the CPAER exam. There is a separate short multi-choice paper for the aeronautical radio operator certificate (restricted) issued separately by Industry Canada. If a Canadian PPL is wanted or needed then two choices exist: a foreign-based version, which is fully independent of the parent licence, and a standard one. The former requires a PSTAR written exam and a valid appropriate medical, whereas the standard version requires a flight test and a PPAER written exam. A Transport Canada regional office can issue a foreign-based PPL using a same-day counter service assuming the experience requirements are met. A foreign-based Canadian PPL cannot be converted to a US private pilot certificate. There is no lengthy verification of authenticity procedure for obtaining a Canadian foreign-based PPL. The IR requires a written exam (INRAT, 35 CAD) and a flight test on a multi-engine aeroplane if MEIR privileges are desired. A further MEP test is required for the MEP rating and both tests are done separately. Examiner fees are about half of what FAA DPEs charge and TCCA admin fees are quite low.

The basis for conversion of licences (certificates) and/or ratings is the BASA–IPL (link) between Canada and US. The procedures are detailed in FAA AC 61-135 and TCCA AC 401-001

Transport takes about 90 days to issue an Aviation Document Booklet which is a passport-like booklet containing the licence, ratings, and medical certificate. Once issued you may proceed to the two-fold conversion process starting with a verification of authenticity of the Canadian licence and ratings—and medical certificate unless an appropriate valid FAA one is held—and ending with a physical appearance before either an Aviation Safety Inspector at a FSDO (free) or a DPE (few hundred USD) who completes the application process. At that appointment an appropriate valid FAA medical certificate should be presented together with the Airman Knowledge Test Reports for two FAA written exams (commercial and IR). The exams must, with minor exceptions, be done in the US. No instructor endorsement is needed for the first attempt and there is no need to bother with the Alien Flight Student Program because the TSA security threat assessment is done in the background without your involvement. The ASI/DPE should then issue a temporary airman certificate and the plastic card will follow in the post.

In summary using the Canadian route:

• obtain a Canadian medical certificate,
• fly to Canada and take the PSTAR, CPAER, and INRAT exams (valid for 24 months)
• attend a Transport Canada office for a foreign-based PPL or FLVC (for the IR flight test),
• attempt a flight test for the CPL, IR (on MEP for MEIR privileges), and MEP¹,
• send off application for an Aviation Document Booklet,
• take the ROC-A exam for a radio certificate & submit application to Industry Canada,
• wait up to 90 days to receive the Booklet,
• email form AC 8060-71 to FAA Airmen Certification Branch in Oklahoma when Booklet is in hand,
• wait up to a month for a copy of the verification letter (valid for 6 months),
• take the FAA CPP & ICP written exams in the US (valid for 24 months),
• obtain an FAA medical certificate (or do in conjunction with the Canadian med exam),
• arrange appointment and meet with ASI at FSDO, or DPE.

¹ No MEP flight test is necessary if within the recent 12 months either a foreign MEP has been obtained or 50 hours of PIC flying on MEPs has been logged.

The route is lengthened by awaiting receipt of the Aviation Document Booklet before which it would be imprudent to begin the conversion process. The added expense of making a follow-up trans-Atlantic trip, and of obtaining two medical certificates, is off-set by the savings associated with Canada which does not require a visa, embassy interview, study permit, or security assessments, and Canadian examiner fees are about half what DPEs charge. Canadian training syllabuses are similar to those in use in UK/EU and because no FAA practical tests are done there is no requirement to learn FAA-specific manoeuvres. A Canadian IR is valid for 24 months and the Canadian instrument recency requirements may be met by completing an FAA instrument proficiency check if a US IR is held, or by a foreign pilot proficiency/competency check if “working for hire and reward for a foreign commercial or private air operator” : see AC 401-005.

Peter,

The US restricted foreign-based commercial pilot certificate used to be issued, with territorial restrictions, until late 1997.

You have to get signed off by an FAA CFI/CFII as fit for the checkride

There is no need for an endorsements to attempt a practical test when an equivalent or superior foreign licence is held. See 14 CFR 61.39(e).

Incidentally that little bit of flying has been done by many Euro pilots in the USA without TSA or Visa.

Foregoing the security threat assessment is an irrational choice considering the penalty of being caught especially in light of recently introduced regulations for revoking certificates on national security grounds. The threshold for needing a visa that permits studying is not well defined but several training flights leading to the acquisition of a US certificate or rating most likely constitutes the pursuit of a “course of study” requiring an appropriate visa which excludes the B-class visa and admission under the visa waiver program. The TSA requirement also has an extra-territorial effect.

Cobalt wrote:

The requirement for the CPL is to “hold an instrument rating”, but does it have to be an FAA IR?

The condition given in 14 CFR 61.133(b)(1) for lifting the limitation clearly refers to a US instrument rating.

Roger,

For the CPL and IR the required written exams are the CPAER and INRAT. Preparation takes maybe a week or two.

You do not strictly need to take the PSTAR. It is taken for either a student pilot permit, used typically to meet outstanding PPL recent experience requirements, or for the foreign-based PPL. The standard Canadian PPL requires a PPAER written exam instead (and a flight test).

The need for a Canadian pilot permit, licence, or certificate, is driven by the IR flight test. The CPL flight test requires none of these. Without waiting up to 90 days to receive the Aviation Document Booklet, bearing the CPL and aircraft rating(s) and Canadian medical certificate, the alternative is to acquire either a Canadian PPL or a Canadian FLVC (Foreign Licence Validation Certificate).

The FLVC is available only to non-residents and for a period of 12 months although addition periods may be available. Details are in AC 400-003 (link) or Staff Instruction 400-003 (pdf). Some general information from Transport is published here: https://www.tc.gc.ca/eng/mediaroom/foreign-licence-validation-certificates.html

The FLVC depends on a valid foreign licence, necessarily backed by a valid appropriate foreign medical certificate, and there is no need to attempt a written exam or flight test and no Canadian medical certificate is required. This makes the FLVC an attractive choice for attempting the IR flight test. The FLVC functions like the FAA 61.75. The target turn around time is 2 to 5 days but in practice you should be able to email your documents to a Transport Canada licensing officer ahead of time then turn up in person to collect the certificate. There is no equivalent “verification of authenticity” procedure.

If you are willing to take the PSTAR, meet the recent experience requirement for a PPL, and have a valid appropriate Canadian medical certificate then a better choice may be to acquire a foreign-based Canadian PPL which unlike the FLVC is independent of the foreign licence. The Canadian foreign-based PPL doesn’t require a valid SEP so long as it hasn’t been removed to the rear of the foreign licence. In your case it makes little difference whether a standard or foreign-based Canadian PPL, or an FLVC, is acquired because of the intention to ultimately end up with a CPL. I have mentioned the options for completeness and for the benefit of others who might stop at a PPL/IR.

The PSTAR written exam comprises 50 multi-choice (4 options) questions drawn from a bank of 200 all of which are published by Transport Canada (see TP 11919).