There is no security threat assessment needed for a flight review, or instrument proficiency check, any training flight done to meet recent experience requirements, training for endorsements such as for a tail-wheel airplane, and the like, because TSA has exempted these activities. See Docket No. TSA-2004-19147 dated 19 Oct 2004 under subject “Interpretation of Certain Definitions and Exemptions from Certain Requirements Contained in 49 CFR 1552” (pdf link):
What is flight training?
“Flight training” is defined in 49 CFR 1552.1(b) as “instruction received from a flight school in an
aircraft or aircraft simulator.” TSA interprets this definition to include only that training that a
candidate could use toward a new airman’s certificate or rating.What is recurrent training?
“Recurrent training” is defined in 49 CFR 1552.1(b) as “periodic training required under 14 CFR
part 61, 121, 125, 135, or Subpart K of part 91.” TSA interprets this definition to not include any
flight review, proficiency check, or other check whose purpose is to review rules, maneuvers, or
procedures, or to demonstrate a pilot’s existing skills on aircraft with a maximum certificated takeoff
weight (MTOW) of 12,500 pounds or less, such as the flight review required under 14 CFR 61.56 or
the recent flight experience requirements in 14 CFR 61.57.
A student visa should not be required for attempting a written exam or practical test. Neither of these events on their own constitutes a “course of study.”
If you then fly with a flight instructor to … prepare for a checkride legally that isn’t training.
Of course it’s flight training although, if not mandatory, it might be better characterised as an extended rental checkout or flight review. Foreign licence holders seeking a US pilot certificate may make use of the exemption at 14 CFR 61.39(e) which together with 14 CFR 61.41 allows the preparatory training required by 14 CFR 61.109(a)(4) and 61.129(a)(3)(v), etc, to be done with a foreign flight instructor outside the US.
Qalupalik wrote:
14 CFR 61.41(e)
14 CFR 61.39(e) requires me to hold at least the privileges sought, which doesn’t work for me if I want a FAA IR without having an EASA one first. Getting a Canadian IR (to get the initial rating) to get the FAA IR (to be able to fly N-reg planes) to get the EASA CB-IR (just in case) sounds like a very roundabout way to get things done…
If I understand correctly, I can do the training with a non-FAA (so, in my case, EASA) IRI, outside of the US based on 14 CFR 61.41 (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) – correct?
If so, now for the “authorized instructor” question, which I believe was discussed here, but I can’t find it. In short, does the above mentioned EASA IRI satisfy the “person authorized by the Administrator” part of 14 CFR 61.1(b) – required for both the theoretical and practical exams. Reading Qalupalik’s post above gives me hope this works, but it does sound “to good to be true”.
The FAA indeed accepts training done by non US instructors.
It is the last 3 hours before the checkride (which IIRC need to be flown within 60 days preceeding the checkride) which for practical reasons need to be done with an FAA instructor – because he has to sign you off as ready for the checkride.
The above assumes you are doing the checkride in the US. If you are looking at doing it in Europe, with the one guy who has exclusive rights, then everything changes, and last time I looked at his website he refused to accept any non US instruction. I have just looked it up and it has dramatically changed; it has been totally stripped down and even contact details have gone…
@tmo, check this out: http://euram.at/flight/
The exception at 14 CFR 61.39(e) applies to pilot certificates (licences) rather than ratings.
The meaning applied to “authorized instructor” by 14 CFR 61.1(b) enables section 61.41.
“Authorized instructor means …[a] person authorized by the Administrator to provide … flight training under part 61 … of this chapter when conducting … flight training in accordance with that authority.”
Any reference to an “authorized instructor” in respect of an instrument flight training requirement made in part 61 is a reference to a Part-FCL IRI to the extent permitted in section 61.41. An IRI certificate conforms to ICAO Annex 1 section 2.8 (standards on flight instructor ratings). The scope of the authority conferred by section 61.41 is flight training and I would construe the limitation in paragraph (b) accordingly. That is, I do not read section 61.41 as authorising a non-US flight instructor to give the endorsement required by 61.35(a)(1), 61.49(a)(2), or 61.65(a)(4) etc for an aeronautical knowledge test. Perhaps your examiner will come up with a different interpretation.
The Canadian IR experience requirements are essentially the same however only 5 hours of instrument time needs to be received from a flight instructor rating holder. The remainder may be received from a sufficiently experienced CPL/ATPL holder as described in paragraph (9) of standard 425.21 (link) of the Canadian Aviation Regulations.
On 18 May 2018 the TSA, directed by executive orders on regulatory reform, reopened the comment period on the interim final rule—69 FR 56324 of 20 Sep 2004 (Federal Register link, govinfo link) —which established the Alien Flight Student Program. See 83 FR 23238 of 18 May 2018 (Federal Register link, govinfo link). Comments were sought on, among others, the following issue (supplementary information, section III, para 2):
Impact of modifying STA [security threat assessment] requirements for alien flight training
candidates from an event-based requirement to a time-based requirement.
Currently, TSA requires individuals to be vetted before each training
event. This requires payment of fees for each training event to
complete the STA process. With the expansion of recurrent vetting
programs, it may be possible to allow for a time-based STA requirement
(such as once every three years) rather than an STA for each training
event.
The TSA docket (2004-19147) for these rules, where comment responses may be found, is available at https://www.regulations.gov/docket?D=TSA-2004-19147
See for example the comprehensive recommendations from GAMA’s Aviation Security Advisory Committee (comment ID TSA-2004-19147-0417, link). Currently TSA approvals are tied to the nominated flight training provider. One of ASAC’s recommendations to TSA is that the approval be tied to the flight training candidate instead. If adopted this change would benefit candidates receiving relevant training from multiple freelance US instructors in Europe.
If adopted this change would benefit candidates receiving relevant training from multiple freelance US instructors in Europe.
Interesting developments.
The US must have been losing out to Europe for airline pilot training. For many years, EASA officials have been touring the world (most of which is the “3rd World”) and selling them EASA FCL and component certification. I was at one seminar, Greece, where one EASA official was off to Venezuela, right after his speech. How successful they actually are I don’t know but this is obviously in competition with the FAA which has always enjoyed a de facto worldwide monopoly in these areas (Europe is a very small place geographically).
172driver wrote:
http://euram.at/flight/
Thanks, I am aware of this option; there are also options with Aero Poznań – they are a Cirrus shop, but can be persuaded to do training in one’s own aircraft, CB-IR validations based on experience, and so on. FWIW they sounded very professional on the phone and have a “yes, we can” attitude. The reason for my (possibly overly obsessive-compulsive) digging into the subject is I really want to combine “business” (of getting an IR) with pleasure (experience flying in the US) and if I can do that while burning the same pile of cash, yay.
Plus, maybe, a little bit, “you don’t tell me it cannot be done” towards my local naysayers… And, if I pave a reasonable way, perhaps others (from that local crowd) will follow… Airfield of dreams, eh?
Qalupalik, thank you, again, for pointing out my lack of idea of what I’m even reading. I truly appreciate it. So, basically, if I have a PPL(A) with a SEP(L) I can use it to train for an IR, tailwheel, HPA, complex, with a non-FAA instructor; I just need a FAA one to sign me off. Same for the theoretical and practical exams in case of the IR. The world is starting to make sense now!
Only an appropriate US-certificated flight instructor may give the endorsements required by 14 CFR 61.31 for tailwheel, complex, and high performance airplanes.
The additional training required for these operations may be given by a foreign instructor, under the provision of section 61.41, but only a US-certificated flight instructor (or other person specifically authorised by the administrator) may give an endorsement after finding the candidate proficient. For example paragraph 61.31(i)(1) for tailwheels states “… no person may act as pilot in command of a tailwheel airplane unless that person has … received an endorsement from an authorized instructor who found the person proficient in the operation of a tailwheel airplane.” See also paragraph 61.41(b).
Peter wrote:
The US must have been losing out to Europe for airline pilot training.
You gotta be joking. Nobody here gives a flying f*ck about EU training. Rightly or wrongly.
