@Qualupalic, wasn’t aware of that as it doesn’t apply to me (or anyone I know). Sounds like one of the many 61.75 pitfalls.
TSA is supposedly only taking 5 days to process applications right now (I guess they haven’t received many since the pandemic started) so you could do it with a starting date in the future. The only thing is that you would need a training provider for that and get your fingerprints taken but there might be options in Europe.
The TSA fingerprint lady is based in Paris, there may be others, but she had a nice cottage industry going round Europe getting this organised. I can’t remember her details.
Can you do an FAA CPL if you don’t have a standalone FAA PPL?
Can you do an FAA CPL if you don’t have a standalone FAA PPL?
Yes many have done just that with an ICAO PPL.
An alternative route would be to do the FAA CPL training in Europe such as with Orbifly in Cannes. There is no need for a TSA approval to do exams in the US, only for training you need the TSA approval.
You can keep you 61.75 foreign based license, but it will be “frozen” in that after receiving a stand-alone FAA license, you cannot add any additional ratings to your 61.75 based license.
The Instrument Rating on your foreign based license might not be automatically added if you did the theory exam for foreign based pilots instead of the “standard” instrument mating theory exam. I did my theory exam for the 61,75 foreign based FAA license at that time at Le Bourget, Paris, but the theory exams can now only be taken in the US.
As for practical exams, there is this crazy DPE operating from Paris Plages Le Touquet, but this guy is unreliable and is overcharging as well. There is another guy operating as DPE from Midsland Airfield in the UK, but he is not focused on GA and services the US armed forces and air force for all kind of license renewals.
So, if you don’t want to wait going to the US or you just can’t get there at the moment, you could start getting the CPL training done in Europe, study for the theory online, get a certificate either online from the course provider or your FAA CFI in Europe that you are ready and then travel to the US to take the exam(s) and check ride(s).
An FAA CPL certificate is more or less useless without an Instrument Rating as it would limit you to something like 50 NM radius around an airfield for touristic flights. You could not take passengers on a commercial flight beyond that or at night. So, you need to get your instrument rating added to that as well and possibly your mult-engine (MEL).
CPL is just to get stand-alone FAA licence instead of flying N-reg on FAA61.75 with all pitfalls behind (could be standalone FAA PPL to be honest but the incremental work is more fun and I got standalone CPL medical already)
Plan is to get all theory & training in US while there for work, and get more useful flying while there 
An FAA CPL certificate is more or less useless without an Instrument Rating
Any CPL alone is practically useless in Europe, unless you work for an AOC operator, and then unless you just do pleasure flights you need a “Euro” CPL/IR (and the 14 exams). With a CPL/IR you can be a paid “personal pilot” (mostly TPs and bizjets) and that’s a private flight. Or a ferry pilot.
The US scene where you can do stuff like crop spraying, or with a commercial certificate you can go for the CFI and do private certificate training, is practically nonexistent in Europe. Things are pretty tightly stitched up around here. Years ago I did find an ICAO CPL (I have the FAA CPL/IR) to have some obscure value with the max radius of a charity flight but I can’t recall the details, and anyway the one I offered was never taken up, despite me spending ages getting the DfT permission etc.
Yes many have done just that with an ICAO PPL.
I am amazed. I recall from my FAA IR training in Arizona and my FAA CPL training in the UK (before the UK option was closed off, reportedly by “a well known individual” reporting the visiting DPEs to the Home Office for an alleged breach of working visa regulations) that you needed the FAA private certificate to do the FAA commercial certificate.
AeroPlus wrote:
An FAA CPL certificate is more or less useless without an Instrument Rating as it would limit you to something like 50 NM radius around an airfield for touristic flights. You could not take passengers on a commercial flight beyond that or at night.
It’s a banner tow rating
Peter wrote:
I recall from my FAA IR training in Arizona and my FAA CPL training in the UK (…) that you needed the FAA private certificate to do the FAA commercial certificate.
Well OK, you need to go through the 61.75 validation process of your ICAO PPL as well before being able to use it as a basis for meeting the qualification requirements for the FAA CPL. But yes, you don’t need a standalone FAA PPL.
