Thanks. So as long as I have the specific easa license (same license number, no ratings) that was used to obtain the us license, and fulfill US currency requirements, i can fly N-reg planes?
Qalupalik wrote:
A US restricted private pilot certificate is not a validation. See post 10 in the thread Initial IPC for a mint FAA based on 61.75? (also EASA IR revalidation for ICAO IR holders). It is subject only to the limitations and privileges made in US regulations apart from limitations if any that are recorded on the face of the parent licence. All other limitations made in the regulations governing the parent licence, such as Part-FCL differences training, are irrelevant.
If you think about it from a practical point of view, it could not be any different. None of the extra layers of government recorded rating expirations, revalidations etc exist in the US so there is no way for FAA officials to understand or respond to them, especially given that many countries have their own unique version of the extra layers. So they give you an FAA certificate based on your foreign license (and what is explicitly written on the back of it) without regard to all that stuff. That FAA certificate then operates like any other FAA certificate, with currency maintained by logbook entries that the FAA does not record and likely never sees.
Back in the 70s my father used a non-expiring foreign license to obtain a ‘based-on’ FAA pilot certificate in the US, then put the foreign license in a file and certainly didn’t maintain the ratings – he never thought about it again. I believe even then he was supposed to carry both when flying, but with the FAA paper in his wallet he didn’t see the point and in reality nobody in the US (e.g. for a FAA BFR) ever asked about it.
A US restricted private pilot certificate is not a validation. See post 10 in the thread Initial IPC for a mint FAA based on 61.75? (also EASA IR revalidation for ICAO IR holders). It is subject only to the limitations and privileges made in US regulations apart from limitations if any that are recorded on the face of the parent licence. All other limitations made in the regulations governing the parent licence, such as Part-FCL differences training, are irrelevant. See interpretation to Krausz.
Ratings included in a restricted certificate other than those acquired by US testing ought to be valid notwithstanding subsequent removal, if relevant, from the face of the parent licence. If you want a firm answer you’ll need to request an interpretation from the Office of the Chief Counsel. Expired ratings are normally removed from the face of a Part-FCL licence when it is reissued following administrative action such as the adding or varying of another rating or certificate.
Part-FCL licences are valid for life but see FCL.040: The exercise of the privileges granted by a licence shall be dependent upon the validity of the ratings contained therein, if applicable, and of the medical certificate as appropriate to the privileges exercised.
If my EASA license has no active ratings (all expired), can I use my FAA validated license if I fulfill FAA currency requirements (Flight Review)?
What happens to the EASA license if it has no more active ratings?
barrysmith wrote:
@mark0505 and anyone! i am trying to figure this whole thing out. i have an expired EASA SEP, and an FAA private based on this. i did the verification process with the orlando FSDO and received a verification letter, but my school is saying that i am not able to fly because my EASA ppl is expired that means my FAA ppl based on my EASA is expired. why would the Orlando FSDO send out a letter saying its valid for life? i am trying to take my FAA commercial but think the school is worried that i am unable to fly, as am i! i dont want anyone to get in trouble.
I was in a similar situation. I requested a verification letter for a §61.75 license sufficiently long in advance that the validity of my SEP at the time the verification letter was issued had expired when I called the local FAA FSDO to arrange for a meeting to get the license. The SEP had been revalidated by then but that of course didn’t show on the verification letter. Also, the statement from the Swedish CAA didn’t mention anything about the license validity, only rating validity
This led to some confusion as the people at the FSDO interpreted the SEP validity as being the same as the license validity and even said the the verification letter had been issued in error. After some back and forth a responsible person at the FAA head office wrote a message stating in no uncertain terms that the validity of the class rating was irrelevant – only the validity of the license mattered and of course EASA licenses are valid indefinitely.
While this discussion was going on I asked for a new verification letter and got one in record time (10 days!) so in the end the issue was moot.
The Airmen Certification Branch in Oklahoma City will issue a verification letter listing foreign ratings even when they have expired. In the case of UK CAA no information about rating validity is transmitted.
If during the application phase you are issued with a restricted US airman certificate listing aircraft or operational ratings then their validity ought to depend only on your fulfilling those currency requirements that are made in US regulations. However nobody has bothered to solicit an interpretation on this from the Office of the Chief Counsel so opinions are bound to vary.
Some options are to:
@mark0505 and anyone! i am trying to figure this whole thing out. i have an expired EASA SEP, and an FAA private based on this. i did the verification process with the orlando FSDO and received a verification letter, but my school is saying that i am not able to fly because my EASA ppl is expired that means my FAA ppl based on my EASA is expired. why would the Orlando FSDO send out a letter saying its valid for life? i am trying to take my FAA commercial but think the school is worried that i am unable to fly, as am i! i dont want anyone to get in trouble.
Ibra, this is addressed in the interpretation given 4 Apr 2013 to John D Collins by Mark W Bury, Acting Assistant Chief Counsel for International Law, Legislation and Regulations Division,
A holder of a U.S. private pilot certificate that is based on a foreign
pilot license as contemplated by § 61.75 would also have to meet the requirements of §
61.56(c). In other words, a person exercising the privileges of a U.S. private pilot certificate
that is based on a foreign pilot certificate and satisfies § 61.75 is required to comply with §
61.56(c) before acting as pilot-in-command of a U.S.-registered aircraft. A person is only
excepted from the § 61.56(c) requirements if the person has (1) within the period specified
in paragraph (c) of § 61.56, passed a pilot proficiency check conducted by an examiner, an
approved pilot check airman, or a U.S. Armed Force, for a pilot certificate, rating, or
operating privilege; (2) within the period specified in paragraph (c) of § 61.56, satisfactorily
accomplished one or more phases of an FAA-sponsored pilot proficiency award program; or
(3) if the person is a student pilot undergoing training for a certificate and has a current solo
flight endorsement as required under § 61.87. See 14 C.F.R. § 61.56 (d), (e), (g).
That was my interpretation both standalone or 61.75 differs in the means used to get a pilot certificate, to maintain the rating you will need a BFR (logical as you don’t have to maintain EASA SEP rating for FAA previleges as per Qalupalik post)
@Ibra: in your home country you can fly the N-registered aircraft on the basis of your EASA license. As soon as you use the FAA privileges, you need to have a valid flight review. I just renewed mine, so good for another 2 years, but without it, you are not legal to fly using your FAA license.
