And in terms of the PIFR....it is modular starting with enroute privileges only...exactly as the proposed EIR...the difference is that it is possible to add instrument approaches and departures one-by-one to effectively end up with the same privilges as a full IR...and revalidation/renewal is by way of biennial flight review (AFR) AQ
I have no argument with you, Awqward 
FWIW, I think you do need an FAA CFI/CFII to do a BFR, but I have no reference to support that. I would be quite suprised if it was not the case, simply because there are a few thousand private pilots in Europe (not to mention many more thousands elsewhere outside the USA) who run FAA papers, and they have a big incentive to find a local solution. I have been in touch with so many of them over the years, and I have never heard of anybody in Europe getting their BFRs done by any "local" instructor.
Fortunately there are plenty of freelance FAA CFI/CFIIs around. I know several myself, and one of them is an A&P/IA too (very handy).
The "problem" with US regs is that they are nearly wholly written for the US context, with almost no allowance for how they might map onto foreign regs. One can understand why that is (US pilots have little need to fly abroad, for a start) but it creates a lot of what appear to be grey areas.
My take on it is that everything is permitted unless prohibited (fairly obviously that has to be the case because it's impossible to have a permission for everything) and that means a lot of stuff is legal even though many say it isn't.
One common bone of contention is the famous "authorised instructor" often referred to in the FARs... I am not going to start on that one
If you feel idle you can start a discussion of "known icing conditions"
It must be time for that one again. I believe bookworm was a key player in the good olde days of Usenet
to effectively end up with the same privilges as a full IR
Correct me if I am wrong but that is still not the full ICAO IR, is it? It is probably close to the UK IMCR except that Australia is not covered in Class A so an "Australian IMCR" is a full IR in all but name.
This is interesting. The JAR license without VFR night qualification doesn't say that you can't fly VFR night, does it? Only if you have the night qualification it mentions it. So based on the FAA letter you could do VFR at night unless your JAR license had written on it that you can't. Right?
Peter,
I don't know what the argument would be about regarding an "authorized instructor". To me it is pretty clear that the authorized instructor required by the 61.56 flight review must hold a US CFI certificate.
61.1 (2) defines the term authorized instructor as follows:
(2) Authorized instructor means--
(i) A person who holds a ground instructor certificate issued under part 61 of this chapter and is in compliance with Sec. 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 Sec. 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 SFAR No. 58, or part 61, 121, 135, or 142 of this chapter when conducting ground training or flight training in accordance with that authority.
There are provisions for a non US instructor to provide training that counts towards meeting a US rating in 61.41 quoted below, but the instruction is limited to providing instruction towards the requirements of a pilot certificate or rating and may only provide endorsements to show training given. The flight review required in 61.56 is not training towards the requirements for a pilot certificate or rating and it requires a specific endorsement by the authorized instructor.
Sec. 61.41
Flight training received from flight instructors not certificated by the FAA
(a) A person may credit flight training toward the requirements of a pilot certificate or rating issued under this part, if that person received the training from:
(1) A flight instructor of an Armed Force in a program for training military pilots of either--
(i) The United States; or
(ii) A foreign contracting State to the Convention on International Civil Aviation.
(2) A flight instructor who is authorized to give such training by the licensing authority of a foreign contracting State to the Convention on International Civil Aviation, and the flight training is given outside the United States.
(b) A flight instructor described in paragraph (a) of this section is only authorized to give endorsements to show training given.
Sec. 61.56
Flight review.
(a) Except as provided in paragraphs (b) and (f) of this section, a flight review consists of a minimum of 1 hour of flight training and 1 hour of ground training. The review must include:
(1) A review of the current general operating and flight rules of part 91 of this chapter; and
(2) A review of those maneuvers and procedures that, at the discretion of the person giving the review, are necessary for the pilot to demonstrate the safe exercise of the privileges of the pilot certificate.
(b) Glider pilots may substitute a minimum of three instructional flights in a glider, each of which includes a flight to traffic pattern altitude, in lieu of the 1 hour of flight training required in paragraph (a) of this section.
(c) Except as provided in paragraphs (d), (e), and (g) of this section, no person may act as pilot in command of an aircraft unless, since the beginning of the 24th calendar month before the month in which that pilot acts as pilot in command, that person has--
(1) Accomplished a flight review given in an aircraft for which that pilot is rated by an authorized instructor; and
(2) A logbook endorsed from an authorized instructor who gave the review certifying that the person has satisfactorily completed the review.
Note that when recording the flight in the pilot logbook according to 61.51, a clear distinction is made between training towards a certificate and a flight review. If they were considered the same thing, the clause "or flight review" would not be necessary.
Sec. 61.51
Pilot logbooks.
(a) Training time and aeronautical experience. Each person must document and record the following time in a manner acceptable to the Administrator:
(1) Training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review of this part.
(2) The aeronautical experience required for meeting the recent flight experience requirements of this part.
Many thanks for that post, NC-Yankee. I agree, of course. Now that I see this, I remember it well from years ago
One issue we get here in Europe is that the foreign training dispensation in 61.41 (which is very clear on the acceptance by the FAA of all foreign training, done by non US rated instructors) often gets joined up with the "authorised instructor" bit, to achieve a "business enhancing" result that an "authorised instructor" is required for all training required for a particular FAA license or a rating.
The PIFR is like the IMCR only in that it is retricted to Australian airspace. However there is no distinction in terms of training standards or privileges...unlike the IMCR...(Although I am not denegrating the IMCr...I find it very useful! AQ
MM_flynn, when I said it was loosing time flying night in the USA I meant that unfortunately, I won't be able to see the country by air, only dark. And IFR hours do count for finding a job, sometimes requirements ask for a number of IFR flight hours, but I've never seen a job offer asking to have XXX hours of night visual. That's why, if possible, I would prefer to do those night hours IFR instead of visual. But as I would have to pay them from my pocket, I would like, if possible, that those hours can serve me as to find a job.
Thank you everybody for your help, my doubts are no more. The conversation has become a little too tecnical for me, as I'm not an english speaker. So I read everything carefully but excuse me if I do not enter to participate in it.
I am not familiar with professional pilot logging requirements, but "IFR time" would most easily be logged in daylight (safest) and, to make it unquestionable, on a formally filed IFR flight plan.
You don't need to touch IMC (cloud) to log IFR time.
My view of these points is below:
While piloting N-registered aircraft in the US under the authority of my "piggy-back" FAA certificate, that includes "instrument airplane" privileges, ......
...... I am not authorised to conduct an ILS approach unless I had performed at least one such approach during the last 35 days (in flight under actual or simulated IMC, or in an approved flight simulator). This currency requirement is imposed by Australian regulations that, in this case, also restrict exercising instrument privileges of my "FAR 61.75" Pilot Certificate.
I think that for an N-registered aircraft, the FAA doesn't care about the Australian currency regime. All they care about is the normal FAA IA currency. Of course Australia could care (but probably not in an N-reg unless it was operated in Australia)
As in my first example, any restriction on the use of a particular approach procedure would also apply to me while flying under the authority of my "FAR 61.75" certificate (but not when flying under the authority of my other, "stand-alone" FAA Pilot Certificate that I could only use after obtaining a separate medical certification from an FAA-accredited medical examiner).
This is a problem as the specific approach approvals are on the face of your Australian licence (well they are on mine). If you are not approved for GPS approaches in Australia, I do not think you could do them under your 61.75.
This is why I got US test passed on my 61.75 to avoid the interactions with the Australian IR regime. Too messy. The basic PPL is fine but beyond that I think it is easier to rely on a US IR.
Quoting from VOLUME 5 AIRMAN CERTIFICATION CHAPTER 2 TITLE 14 CFR PART 61 CERTIFICATION OF PILOTS AND FLIGHT INSTRUCTORS Section 14 Issue a Title 14 CFR Part 61 U.S. Pilot Certificate on the Basis of a Foreign Pilot License
….A person may be issued a § 61.75 private pilot certificate based on a foreign pilot license as follows: a) With no instrument privileges, for which neither a knowledge nor a practical test is required. b) With instrument privileges, provided the applicant has passed the Instrument Foreign Pilot knowledge test and the applicant’s foreign pilot license has the equivalent Instrument [Aircraft] rating. The applicant is required to pass the Instrument Foreign Pilot knowledge test versus the Instrument [Aircraft: Airplane, Helicopter, or Powered-lift, as appropriate] knowledge test because the Instrument Foreign Pilot knowledge test’s focus on 14 CFR part 91, subpart B that relates to instrument flight rules (IFR)/operational procedures tests the applicant’s knowledge on operating safely in the National Airspace System. c) With a standard instrument rating, provided the applicant has passed the Instrument[Aircraft: Airplane, Helicopter, or Powered lift, as appropriate] knowledge test and practical test. The U.S. pilot certificate will be issued with the notation “U.S. TEST PASSED”…
My “61.75” FAA certificate has been issued on the basis of my Australian (CASA) licence and my Australian instrument rating (as per (b) above). Thus, I am unable to fly under IMC using this FAA licence unless my Australian instrument rating (CID) is valid (to be renewed every 12 months) and I satisfy both Australian and American recency/currency requirements.
JasonC said: This is why I got US test passed on my 61.75 to avoid the interactions with the Australian IR regime. Too messy. The basic PPL is fine but beyond that I think it is easier to rely on a US IR.
Thus, you must have gained your instrument rating on your “61.75” FAA pilot certificate after passing the FAA’s “Instrument – Aircaft” knowledge test, followed by a practical flight test with an FAA examiner (as per (c) above).
Cheers, A
