Menu Sign In Contact FAQ
Banner
Welcome to our forums

Downgrading an FAA standalone PPL to a 61.75 - possible? (EASA v. FAA medicals)

Reference this medical thread and this mad UK DFT/CAA attack on N-regs

I had a conversation with somebody today which raised an interesting point.

You can fly an N-reg on an EASA PPL + 61.75 + FAA IR + EASA medical.

But if you have a standalone FAA PPL (not 61.75) you need an FAA medical.

Now, what if somebody can’t get an FAA Class 2, or even the Class 3, but can get an EASA medical, is it possible to downgrade an FAA PPL to a 61.75?

There are certain things which prevent you getting an FAA Class 1 or 2. For example any heart procedure like a stent requires a repeat angiogram, which is medically mad – only a masochist would do an angiogram twice, apart from it costing some 5k-10k. But some people cannot get even the FAA Class 3 on any practical timescale or without spending thousands on medical practitioners. This is due to very strict FAA requirements for the format of the consultant’s reports, for Special Issuance medicals. They have to contain just the right phrases, and it is not unknown for the reports to bounce back and forth for 6 months or more. Very few European AMEs have any experience in this area and it appears most don’t really want to get involved with them. And many consultants over here are not contactable in a useful way; certainly the way the medical profession is set up here in the UK they do all possible to prevent any direct communication (even with a private patient, and of course this type of work has to be paid privately) and the only form of contact is with his secretary, and most of them don’t reply to correspondence. The medical profession seems to live in a bubble of its own and this and the 4-digit costs causes quite a lot of people to give up flying rather than go for a Special Issuance. In the US of course they now have Basic Med which is a bit like the UK NPPL except (a) you can fly IFR and (b) the NPPL will be killed by Brussels in April 2018 for most aircraft.

Whereas an EASA medical doesn’t involve this stuff, and you don’t need to get the reports translated into English for the FAA.

This may also be relevant. You can hold a standalone and a 61.75 but only if the 61.75 was done first.

The next Q would be: which exact law would be broken in Europe if a standalone FAA PPL holder flew an N-reg without an FAA medical but with an EASA Class 2?

The interaction of Part 61, Part 91 and non US airspace is complex.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Now, what if somebody can’t get an FAA Class 2, or even the Class 3, but can get an EASA medical, is it possible to downgrade an FAA PPL to a 61.75?

No, as you say, if you hold a standalone you can’t get a 61.75. The reverse is not true in that you can keep a 61.75 if you get a standalone.

Edited: I guess you could surrender your certificate voluntarily and then apply. If you do not hold a US standalone certificate you are able to apply for a 61.75. Not sure the FAA would approve of that course of action however.

Last Edited by JasonC at 15 May 21:21
EGTK Oxford

Peter wrote:

The next Q would be: which exact law would be broken in Europe if a standalone FAA PPL holder flew an N-reg without an FAA medical but with an EASA Class 2?

When flying N-reg in Europe, as long as you have valid EASA papers, I don’t think the europeans actually care whether you do have a FAA certificate or not. That’s a matter for the FAA. And to the FAA, if you have a 61.75 you are legal to fly if you have either the medical that goes with your foreign license, or a FAA medical.

So that makes everyone happy.

LFPT, LFPN

Peter wrote:

The next Q would be: which exact law would be broken in Europe if a standalone FAA PPL holder flew an N-reg without an FAA medical but with an EASA Class 2?

14 CFR 61.23 (a) (3) (i)

Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section, a person … Must hold at least a third-class medical certificate … When exercising the privileges of a private pilot certificate, recreational pilot certificate, or student pilot certificate, except when operating under the conditions and limitations set forth in § 61.113(i);

With “medical certificate” being defined as (according to 14 CFR § 1.1)

Medical certificate means acceptable evidence of physical fitness on a form prescribed by the Administrator.

I doubt that an EASA medical satisfies that requirement.

Aviathor wrote:

And to the FAA, if you have a 61.75 you are legal to fly if you have either the medical that goes with your foreign license, or a FAA medical.

But flying on a standalone FAA PPL, you will not have had a valid medical as required by the law cited above, so you might have an issue getting an insurance payout if you need it.

Last Edited by Rwy20 at 16 May 20:33

I recall @bookworm once posting the opposite view

However if the FAA Chief Counsel pronounced on this topic, they would most likely support Rwy20’s view. They supported the word “issued” literally on the “is an EASA license valid for an N-reg all over the EU” issue.

Administrator
Shoreham EGKA, United Kingdom

You can even fly an N-reg in the UK with a UK-issued ICAO license – whether a national license or an EASA license. In that case you would not need any US airman certificate or medical. A UK medical would suffice.

LFPT, LFPN

In the UK you can fly an N-reg with the NPPL or the LAPL.

Administrator
Shoreham EGKA, United Kingdom

But that was not the question.

8 Posts
Sign in to add your message

Back to Top