FAA PPL/IR

This article, originally written in 2005 and since updated, describes the procedure used by a JAA PPL/IMC-R holder to get an FAA PPL/IR.

After 2013 or so, references to JAA will mostly today be referring to EASA.

Being an aircraft owner, the original objective was to do it all (including the FAA checkrides) in the UK. However, various changes which started in 2004 reduced the availability of FAA examiners outside the USA. Only the FAA PPL was done wholly in the UK, in 2004, but I managed to squeeze in the CPL in 2007 just months before the FAA NY IFO permanently terminated visiting examiners. The IR was done in the USA in 2006. It is still just possible (2010) to do it all in Europe but with considerable hassle and risk, and nowadays most people choose to train as far as possible at home and then go to the USA to finish off.

To obtain worldwide privileges of the FAA IR, one needs a US (N-) registered aircraft. There are plenty of them on the market in Europe, and this article describes the process of placing a G-reg aircraft on the US (N-) register.

An FAA PPL has some privileges in aircraft which are not US-registered. Currently (pre-EASA FCL "Euro protectionist" changes which are threatened for 2012) a G-reg aircraft can be flown worldwide on it, VFR, and no paperwork is involved as the ICAO PPL is automatically validated by the ANO. Other European countries have different rules, but a US license is widely recognised around the world, either for direct use or for validations/conversions to local papers. Additional information is here.

 

Step by step details of how to obtain the M-1 Visa and TSA Permission - updated

 

Why an IR?

I wanted the full instrument rating (IR) so I could fly IFR outside the UK. One can easily get stuck for days under a low cloudbase. Under ICAO, there is a minimum cloudbase requirement for VFR operations at most controlled-airspace airports; typically 1000-1500ft. This can be very frustrating because not only I could probably depart VFR but also if this was in the UK, I could fly IFR perfectly well; the clouds are just the same.

For IFR flight outside the UK, a full IR is required. Also the unique UK privilege of being able to fly IFR practically anywhere (with the IMC Rating or an IR) is missing, and IFR flight usually means filing an IFR flight plan which has to be validated by the Eurocontrol system. One cannot do what is normal in the UK for IFR, which is to pick a list of waypoints (VORs, airways intersections, etc) and just fly, telling ATC stations on route where one is going, or even flying in IMC non-radio which is legal in Class G.

The other reason for an IR is for an aircraft whose performance and/or fuel efficiency requires flight high up in the airways e.g. a jet or a turboprop.

For UK-only flying, if one has an aircraft which is suited to flying at low levels (below say 15,000ft) there is a lot less need for an IR because of the IMC Rating. This is a unique UK-only privilege, allowing one to go practically anywhere IFR except into Class A airspace, so long as departure and arrival visibility is at least 1800m.

I never found the Class A restriction of the IMC Rating to be an obvious problem because, in the UK, one can get about adequately IFR below Class A. One benefit of Class A would be better access to VMC on top; UK weather is generally worst in the winter and, of the flights that have been planned some days ahead and that get scrapped on the day, many got scrapped because the icing level is below the MSA and there is Class A not far above. Access to Class A would enable VMC on top during much of the year, and at say FL150 one would be VMC on most days, around Europe and well away from fronts. Obviously the layer needs to be not too thick to climb through - this is primarily a de-ice consideration.

The major benefit of an IR and flight on a Eurocontrol flight plan is the IFR clearance; in effect one is cleared for the entire route from the start. This avoids the possibility of a refusal to enter CAS which risks last-minute doglegs or even a turn back. While in the UK one could file an IFR flight plan (outside Class A) and fly it on the IMC Rating, such a flight plan is pointless (except for search & rescue purposes) because one doesn't get any whole-route IFR clearance and nobody en route has received a copy of it

So, my main reason for the IR: European touring.

But, make no mistake about this, doing the IR is hard. It is far harder than the IMC Rating, not just in terms of the pressure and workload during the training and checkride but also in how much of your life will be wasted on seemingly pointless trivia. Don't even think about it unless you are pretty determined to fly around Europe, and you are able to get your hands on a suitable IFR aircraft.

 

Why FAA?

There are two options for an IR: a JAA (European) IR and an FAA (American) IR.

The JAA IR is tailored towards commercial airline (CPL/ATPL) operations and comes with an extensive ground school comprising of 7 exams (7 for the PPL/IR; 14 for the CPL/IR) which - for a pilot with no instrument experience - takes several months' work. In reality, for people with serious jobs and family commitments, it seems to work out nearer to 1-2 years. There is also a mandatory ground school attendance of about 1 week (though this may be waived - if doing the IR in the UK - if one is upgrading from an FAA IR to a JAA IR, reference). The ground school contains a lot of material that's either irrelevant to light aircraft operations and contains a lot of theory which is hard to make use of. The JAA IR involves a minimum of 50hrs (55 for multi engine) training time. Very few private pilots are doing the JAA IR today. Moreover, none of one's IMC Rating training counts towards the JAA IR but it all counts towards the FAA IR. Around 2008, matters improved when the JAA IR question bank appeared in the public domain and this enabled candidates to operate a significantly more effective revision method: memorise as many answers as one can. Also, questions relating purely to jet airliners were removed. Update 8/2011: I did later tackle the JAA IR also; the notes on it are here.

The aircraft also needs to be CAA approved and for UK checkrides needs to be fitted with special custom-made window screens.

On the positive side, the UK appears to be the only JAA country in which one can do the IR in a foreign (e.g. N) registered aircraft.

The FAA IR was designed with the correct assumption that jet aircraft specific knowledge belongs into a jet Type Rating and is thus more practical and more suitable for the private pilot. It requires 40 hours of instrument experience which includes 15 hrs of training. In practice only very competent IMC Rated pilots could reach the practical test standard (PTS) in 15hrs. The FAA IR ground school is substantial and, in the light aircraft context, very practical and thorough. It is a single exam which is likely to involve several weeks' full-time study even for a relatively experienced IFR pilot, and an experienced UK IFR pilot with a job etc can probably do it in a few months. Flying in the USA is very different (airspace, services, etc) and one gets examined on it (in the written exam, and in the oral) even if one never uses this knowledge afterwards, and learning this stuff represents a major proportion of the theory work for the FAA IR.

All the flight training towards the FAA IR can be done by any ICAO "authorised" instructor, in any ICAO state, and American flying schools accept logged dual instrument time even if the instructor himself had only an IMC Rating (common on the UK PPL scene). There is some dissent on this but in most practical cases it is moot - more details here. The last 3 hours must be done within 60 days of the checkride and since an an FAA instructor is needed to sign off the candidate as ready for the checkride, this more or less implies than the same FAA instructor is needed for the last few hours. This paragraph is true for both the FAA IR and the FAA PPL.

The training can be done in any registration aircraft. It is only the checkride for which some FAA examiners operating in Europe have required an N-reg aircraft, though this rule has varied over the years and it's worth checking with the examiner what his preferences are. The FAA itself is not concerned about the aircraft registration.

A Rating can be attached only to a License so an FAA IR needs an FAA PPL which can be either a "piggyback" one (61.75 "based on", and requiring the continued validity of, one's UK PPL and medical) or a standalone one. I decided to go for the standalone version which is a bit more work but it avoids building a "house of cards" where a lot depends on one original piece of paper.

It is an international convention that for the IR to be valid, its country of issue has to match the country in which the aircraft is registered. This means that an FAA IR requires an American registered (N-reg) aircraft. Some notes on the privileges of an FAA PPL/IR in non-US aircraft are here.

There are four distinct parts to doing the FAA IR:

1. Getting an FAA medical
2. Getting an FAA PPL
3. Getting an FAA IR
4. Placing the aircraft on the N register

 

1. FAA medical

This can be done in the UK, and is considerably cheaper than a CAA medical which appears to cover similar ground. One can do FAA Class 1, 2 or 3. The last one is the simplest and most popular for private flying. All three are ICAO compliant (if no special conditions are attached) but the Class 3 has been subject to some controversy; the Irish CAA have banned (2006) Irish-resident Class 3 holders from flying; they state it is not ICAO compliant which is false, but in Ireland "anything goes" and under ICAO it is legal for a member state to impose its own medical requirements onto its citizens. So I went for the Class 2 which turned out to be slightly more strict in the eyesight department than the CAA Class 2 which I had passed a few weeks before. The enduring myth that FAA medicals are "easy" isn't true; they still check everything that is relevant to pilot incapacitation.

The FAA medical requirements are a little easier than the JAA ones in the ECG requirement for a given age and in the approach to some marginal situations. However FAA is much easier than JAA in one crucial area: the audiogram. A JAA PPL/IR requires the JAA Class 1 audiogram, even though a Class 1 medical is required only for a CPL/ATPL. It's not uncommon to have one good ear and one which is fails the JAA audiogram, and then you can never do a JAA IR... This is a stupid restriction which is not based on any evidence because general aviation headsets are monaural and having one bad ear is no handicap. It has its roots in an ICAO recommendation but JAA gold plated it into an absolute requirement for any IR.

The JAA audiogram requirement is also described on this CAA page. However there is a CAA proposal to make the limits a little easier: Hearing (Proposal by the UK) Audiogram standards for the initial class 1 and initial instrument rating for class 2. There will be no difference between initial and revalidation/renewal class 1 audiogram requirements i.e. the requirement is now that there shall be no hearing loss in either ear tested separately of >35db in the 500-2000Hz range, and 50db at 3000Hz. This will also be the requirement for the issue of an instrument rating to a class 2 holder. Another interesting angle is that - unless the audiogram is done professionally, using special equipment which injects masking noise into the opposite ear - the amount of bone conduction from one ear to the other makes the -35db limit rather meaningless; this is of course an interesting plus for pilots who are after the JAA IR but could not have done it previously because one of their ears is below the limit. Update 2007: it appears that this proposal is now the regulation i.e. the old renewal limits have become the same as the initial limits.

 

2. FAA PPL

This can be done entirely in the USA, and there is where most UK FAA holders do it. Flying in the USA is cheaper but one has to find the time to go there for a few days (or about 6 weeks if doing it from scratch) plus the hassle of the TSA and Visa process.

The minimum training requirement is about 40 hours (similar to the JAA PPL) but a UK/JAA PPL holder needs just a few hours' training to cover the extra items in the FAA syllabus.

There is a single ground exam which has less content than the seven JAA exams but it covers the same practical ground and more. A reasonable package for revision includes

FAA Oral Exam Guides - Private Exam Guide
FAR/AIM Book
ASA Private Pilot Prepware

The above can be bought at Transair and Pilot Warehouse although their FAA study material may not be on their websites. There are other texts which are preferred by some e.g. Gleim.

There are also free websites that contain FAA question databases, e.g. http://www.exams4pilots.org

It is often claimed in the press, in the anti-FAA articles that frequently appear, that there is a way to cheat through the FAA written exams. It might have been possible at some time in the past but isn't anymore. There are too many questions to memorise a significant portion - unless one spent a year going through the question bank over and over. Also the FAA periodically change the order in which the multiple choices appear, so pure memorisation would be of limited value. The JAA ATPL question bank has recently (2008) been released, too, and is widely used as a study aid by would-be airline pilots.

A piggyback (61.75 "based on") FAA PPL isn't discussed here because I didn't do one. In my view there isn't a lot of point unless one is sure one will maintain one's UK license and medical. There is a further gotcha for pilots who had the old UK PPL, got an FAA piggyback PPL on that, and then converted their UK PPL to a JAA PPL. Not only do they have to reapply for the FAA endorsement again (which nowadays is a trip to the USA) but also the JAA PPL expires every 5 years and when it expires the FAA one expires also. There is an article on piggyback FAA PPLs at the PPL/IR website. Personally I think a piggyback PPL is a waste of time because the whole context is the PPL/IR objective and one may as well go to the USA and do the whole lot there as standalone licenses. Also, piggybacks have recently (2008) got caught up in weird rules which may involve going to the USA to get things like the ICAO English language proficiency words added to it.

Your UK PPL training is fully credited towards the FAA PPL training requirement. There are a few gotchas however. One is a 100nm night cross country flight (the FAA PPL has night privileges as standard) which must be either between two airports >100nm apart, or with a full stop landing at an airport which is >50nm away. Then there are 10 night takeoffs and 10 landings. All of these are after the FAA Civil Twilight which is one hour after official sunset. All these are described in the FAR/AIM book (the official book) as "training" which implies that an instructor must be present. Most UK PPLs with the Night Rating or the more recent Night Qualification won't have met these requirements in the course of their night training.

An FAA instructor is required for the last 3 hours within the 60 days preceeding the checkride, and this instructor needs to sign you off as ready for the checkride.

The FAA PPL Written Exam

Outside the USA, this can be done at several locations; one of which is Flight Safety at Farnborough UK. I did mine at a long-gone outfit in Norwich. The single FAA PPL written is a lot more practical and in some respects harder that the seven JAA PPL exams together. There is no way that the average fresh successful JAA PPL exam graduate would pass this paper without revision. Luckily there is a lot of material one can buy to assist with the revision, because the question bank is largely in the public domain, like the PPL Confuser is for the CAA exams. For an existing CAA/JAA PPL holder, the most notable areas of difficulty are

a) There is a lot of US-specific stuff which is completely alien to a European pilot, e.g. concerning weather services, frequency usage, and airspace rules. Irritatingly, the exam paper occassionally refers to e.g. "Michigan" but you aren't allowed to take in a map of the USA, so you have to know where the state of Michigan is relative to some weather chart provided. This is the area which even the most experienced UK pilots need to revise thoroughly.

b) There is a lot more practical stuff; e.g. mixture leaning and engine management generally. An experienced UK pilot should have no problem with this and every PPL should know it.

c) There is a chunk of instrument flight knowledge, e.g. VOR tracking, with some of the questions right out of the UK IMC Rating exam paper. Again, in my view, every PPL should know this and someone with current instrument skills will be fine.

The exam is preceeded with a brief oral exam with an instructor who then signs you off as ready to sit the written exam. This "signing off as ready for the next bit" is typical of the FAA process, and makes it very hard for a candidate to somehow cheat.

The FAA PPL Training and Checkride

I managed to do this wholly in the UK, but it took a while to home-in on an establishment who could deliver the FAA examiner. Prior to the final total termination of visiting examiners in 2007, this was a recurring theme in European FAA training - the training was (and remains) easy but examiners were hard to come by, and quite a lot of pilots did the training only to find they could not get a checkride, and had to go to the USA to finish off.

Historically, a lot of UK based FAA training establishments have operated revenue raising schemes, claiming that e.g. all training has to be done with an FAA (CFI/CFII) instructor.

For me, the cost of the standalone FAA PPL (done at a long-defunct UK outfit) worked out around £3000, plus a slice of the visiting U.S. examiner's expenses (a chap from the Middle East) which depended on how many checkrides he did during that visit. The oral was hard due to his fiery temper and impenetrable accent. The checkride was thorough and considerably harder than the JAA PPL checkride I did a few years previously. I did pass OK but had problems with the examiner's aggressive manner who, in his own words, was trying to distract the pilot. This kind of thing would not have happened in the USA where the whole process is much more controlled.

Incidentally, I think that an FAA PPL is not possible to train ab initio (i.e. a pilot who has never done any flight training at all) in the UK because the student cannot legally do the solo portion in UK airspace; this is because he would be flying on the US Student Pilot Certificate which is invalid outside the USA. This isn't going to affect many people, since most people doing the FAA PPL in Europe already have a PPL under which they can be PIC in the aircraft concerned. It would affect only someone who has bought an N-reg plane and wanted to do the whole ab initio PPL in it. The only way I can think of would be to ostensibly commence training towards a JAA PPL, with a JAA instructor in a G-reg at any UK school, and then when all the solo requirements have been met finish off with an FAA instructor who would have to be capable of being PIC.

 

3. FAA IR

As with the FAA PPL, this can be done in the USA, or in the UK with the same system of examiners coming over from the USA - IF you can find an examiner.

For a UK PPL holder with a current IMC Rating, the FAA IR will require a lot more extra training than the FAA PPL. The pilot will need a good 10hrs to cover general areas like STARs/SIDs and other airways procedures, plus specific stuff like a partial panel (AI and DI obscured) nonprecision approach, and this assumes that he already flies regular IFR. There are also some specific items e.g. a 250nm cross country flight with some procedures. Some JAA IR holders like to knock the FAA IR route but the FAA IR doesn't come on the back of a cereal packet. It is designed for a pilot who is going to use it and who has long term access to a suitable aircraft.

As for the FAA PPL, there is a single ground exam which obviously has less content than the 7 (14 exams if doing a CPL/ATPL) JAA IR exams but it covers the practical ground for private IFR flight. A good package for revision includes

FAR/AIM Book
ASA Instrument Rating Prepware
ASA Instrument Rating Test Prep
Instrument Oral Exam Guide
Practical Test Standards book

The above can be obtained in the UK in the usual pilot shops. Again, a book by Gleim is liked by some.

As with the FAA PPL which can be done as a piggyback (61.75 "based on"; not recommended for reasons given above) it is also possible to do a piggyback FAA IR - using the Foreign Pilot Exam route. This is available to holders of a 61.75 FAA PPL and any ICAO IR. You just sit the FP exam and that's it. Unfortunately there is a big catch: the resulting IR has to be completely re-done if the pilot later gets a standalone FAA certificate (PPL or CPL). If you have a 61.75 "based on" US certificate, and did the full FAA IR, the FAA will add "Instrument Airplane US Test Passed" to that certificate. If you then get a full FAA PPL or CPL, the IR you have transfers over. If however you do the "Foreign Pilot" IR, for which there is no checkride, you get an IR based on your "foreign" IR. That IR does not transfer over to a standalone certificate! If you later get an unrestricted FAA PPL or CPL, you have to do the full FAA IR to add it to that.

The FAA IR Written Exam

July 2005: Finally, after some 8 months of revision broken up by other commitments, I have been over the material enough times to get a consistent pass mark (over 70% is required) on the computer exam. I used the ASA book and the ASA computer mock exam; the latter I sat at least 50 times! A friend also lent me the complete set of about 13 videotapes by John and Martha King, which I watched right through; they are good material but I found the retention was poor and I forgot most of the details within days. Martha King laboriously explains even the most trivial issues and there is no doubt which of those two runs their household! On balance, I think it's more effective to spend the last few days before the exam on the computer mock exam and do it over and over.

I did the written exam at a now-defunct firm in Norwich; cost about £230.

I spent two days immediately before the exam going over the material over and over, using the computer exam and looking up the correct answers for anything I was unsure of. During the actual exam I recognised a few of the questions and it was readily apparent that the FAA has changed the order of the multiple choice answers, to prevent people learning the answers by rota! I can't see how such a cheat would have worked anyway, given the number of possible questions (2000 or so). There were also a number of questions which I had never seen in the ASA material; possibly these were new questions. A number of the questions were ambiguous, and there was one really hard one that would have involved an hour's worth of cross-country fuel consumption calculations, with plenty of opportunity for getting something wrong. Most of the questions were good practical IFR stuff.

I did not consider the exam difficult but then I knew more than half of the material already, from my IFR flying in the UK. It is however certain that articles that have appeared in the UK press claiming that one can do the FAA IR in the USA, from scratch, in two weeks including the written exam, is rubbish. One could work through the written material in 2-3 weeks, well enough to pass, assuming a heavy full-time residential course. To get over 90% would probably take a good month or two.

There are many things in the FAA rules which are completely wrong for UK or European airspace. For example, in the USA one can enter Class D with just a two-way radio contact; there is no need to get an explicit clearance. One has to watch out for this. However, 99% of FAA PPL/IR holders will never go anywhere near the USA and will quickly forget any rules like this. This could be a problem for a particularly stupid pilot who did all his flight training in the USA and then turned up in the UK not realising that he needs an explicit clearance to enter Class D.

The FAA IR Training

There won't be a lot under this heading as I already have the required logbook entries except the 250nm cross-country flight under ATC direction. In fact, I did do the flight, from the UK to Prague (600nm each way) but due to poor weather we did not complete the requirement of three different instrument approaches. If I have to go to the USA, I may as well do that flight over there - will be flying an unfamiliar aircraft anyway so will need to to get used to it. Otherwise, it can be done wholly in Europe, and doing it outside the UK FIR neatly sidesteps all the DfT conditions if that happens to be a requirement. I did get the DfT permission, but in the end didn't make much use of it.

The FAA IR Checkride

This section is going to read more like a diary, as I work through the options. The full procedure for organising training in the USA, getting the TSA stuff, getting the visa, etc, has been compiled into a long list which has been verified by several people who have done it during 2005; details here.

I chose Arizona over Florida, for the much better weather and the possibility of much nicer sight-seeing (Grand Canyon, Bryce Canyon, Monument Valley, etc) if I get the IR done before the 2 weeks is up.

In Dec 2004 I telephoned the well-known Robert Lynch (who is normally impossible to catch) at the FAA IFO in NY who is in charge of authorising FAA examiners working in Europe and he was completely unconcerned about getting an examiner sent out to the UK. Around this time, however, the system was changed to require all examiners to register with the FAA and their supply dried up. At that point Mr Lynch did not return calls and could not be contacted in any other way.

In Dec 2005, a few more phone calls to other known UK based FAA training outfits showed that nobody had seen an examiner since early in 2005 so they sent people to Florida or Arizona for the checkride. This is an unattractive option because a certain minimum amount of familiarisation will be needed in the USA, and with the flying costs out there being so much lower one may as well do any required flight training out there.

November 2005: I booked with a school in Arizona called Scottsdale Flight Academy. They sounded ideal but after a couple of weeks of messing around I discovered that they are not approved under SEVIS (basically, a scheme for US educational establishments, which incidentally requires the school to be Part 141 approved which this one wasn't) and cannot issue an I-20 form which is required for the M-1 visa. (There may be a way to do flight training under a J-1 visa which can be obtained without an I-20 but I didn't continue the very slow correspondence with the US Embassy for long enough to find out). This was $130 (TSA fee) wasted. It is poor procedure that the TSA website allows one to start a training request with a school which can never deliver an I-20.

I went to the next contact, CRM, which was recommended by a UK JAA/FAA instructor who I had known about for a year or two. CRM used this instructor as their sole point of contact for the UK business and would not reply to my emails, and much of the time there was nobody on the phone either, and I often could not get hold of the UK instructor either. They did claim to issue the I-20 and despatch it by Fedex (to the instructor, inexplicably) but a week later there was no sign of it. So, CRM was abandoned after 2 weeks and another $130 wasted. Unfortunately CRM opened up a "training request" with the TSA and never closed it, resulting in me getting a long interrogation by U.S. Immigration on a trip to the USA 2 years later (and probably on any subsequent trip) due to the appearance that I did not complete my training and therefore must be a hijacker. Repeated attempts by me in the following years to get CRM to clear this up with U.S. Immigration were unsuccessful.

I did the fingerprinting at Flight Safety in Farnborough. At the time, there was no fee; they appeared to be paid by TSA. This is a big company which runs a number of big flight simulators, and they do the fingerprinting as a little job on the side, using their IT manager working out of his tiny office; quite amusing... One can do fingerprinting at the larger US schools too but it does narrow down the options, and it's a good policy to minimise risk of delays by doing all one can before getting on the plane to the USA.

December 2005: I booked for the IR with Chandler Air Service. Another $130 to the TSA. Third time lucky? They are a much better outfit, well organised, they reply to emails, so far there is always somebody on the phone who can deal with queries, and they have in-house fingerprinting and I-20 facilities. They charged $250 for the I-20 form issue... some schools refund this at the end but this one doesn't.

February 2006: IR FINISHED. The full writeup is here. It was extremely hard work; all the rubbish that is written all over the place about the FAA IR being easy, etc, is just that: rubbish.

This is the end. After about 5 years of dabbling at it, the objective is finally completed.

However I am now doing the FAA CPL; this isn't terribly hard and I have already passed the CPL written exam (while in the USA) so I have two years to do the additional training and the checkride. The reason for this is rather theoretical. A technically competent pilot who has done all the written exams while still in the UKand who has most of the logbook requirements should be able to do the FAA CPL/IR in around 4 weeks and that represents the practical pinnacle of flight training for pilots who don't have commercial ambitions. In any event, a commercial license is close to worthless for commercial work in Europe; unless one gets a job in an organisation with an AOC, they are practically limited to: being a paid pilot for a company or an individual who provides you with an aircraft; being a ferry pilot, and that's about it.....

October 2007: I have done the FAA CPL, wholly in the UK, during a period spanning a number of months during which an FAA DPE examiner was visiting the UK but as of 10/2007 this has all been stopped by the FAA (NY IFO), so I got mine done just in time. It was done through a very nice instructor based in the UK. This is as far as I want to go; the ATPL needs a lot of night hours and I rarely fly at night.

 

4. Placing the aircraft on the N register.

This is described here

 

11/2007: The best order of doing things

In the past this could have been played in different ways, if one is flying a G-reg aircraft destined to go N-reg. However, as of late 2005, with the persistent difficulties of getting a UK-based checkride, my recommendation is simply this:

1) Get your FAA medical, all logbook requirements, written exams done in the UK.
2) Find a suitable U.S. school (I recommend Arizona for the safe-bet weather)
3) Send them a copy of your logbook and get them to confirm that all the specific required flights are acceptable
4) Go out there and do the standalone PPL and the IR, and perhaps the CPL too, all in one go
5) Place the aircraft on the N register

For a competent IMC Rated pilot, the total U.S. time should be 2-3 weeks for the PPL/IR and maybe 1 more week for the CPL. This assumes a simple aircraft; if you choose a school with glass cockpit equipped aircraft then not only it will take you another week but you will also have wasted a lot of time if the one you are flying back home is not glass cockpit equipped.

It's very important to realise that there has never been a problem in the UK in finding freelance instructors to fly with, to pick up skills, to meet specific training or logbook requirements, and this is true for JAA and FAA instructors and for flying in G-reg and N-reg aircraft. It is the sporadic FAA checkride availability in the UK that drops a spanner in the works and forces the pilot to go to the USA. And once going to the USA, it makes sense to do an intense flight training package out there, close to the checkride and in the same aircraft that will be used for the checkride.

Flying the entire FAA IR dual training requirement (15hrs) in the USA also sidesteps any possibility of hassle through somebody alleging that your IMC Rating training is not acceptable towards the FAA IR - more info here. In 2008 I was subjected to a vicious attack along those lines, in the form of a widely circulated email from a well known individual on the FAA checkride scene but he or his informant did not realise that I flew a lot more than the 15hr FAA requirement while in the USA, which made the acceptability of my IMC Rating training irrelevant.

 

Is the FAA IR suitable for European IFR?

The short answer is that it is every bit as good as the JAA IR. Neither IR teaches a lot of the operational details e.g. constructing Eurocontrol-acceptable IFR routings, flight plan filing strategies that ensure one gets a continuous IFR clearance, etc.

The FAA IR appears to be fully adequate for private IFR flying around the USA, whereas the JAA IR is designed as the first stepping stone for ATPL students and is certainly not adequate for private flight around Europe.

New holders of either IR ought to do some flying with an experienced IFR pilot, to pick up the many small operational details. Some information is here.

One EuroGA discussion on the differences is here.

 

2/2009: ICAO English Language Proficiency Requirement

A compliance statement to this effect needs to appear on the pilot's license.

The FAA has provided a very straightforward online process for obtaining a replacement license for a mere $2 and this license will carry the appropriate statement. Details are here local copy.

The above link is for standalone FAA PPL holders only. If the pilot holds an FAA piggyback (61.75) license then things get more complicated and at time of writing (8/2009) the matter remains somewhat unclear. A UK resident FAA Designated Pilot Examiner, Adam House, has been processing these statements for a fee and thus making it unnecessary for the holders to visit the USA.

 

The Future, and Conversion Routes

The "EASA threat" is currently wholly contained in its latest FCL proposal on regulating foreign (essentially meaning: FAA) licensed pilots is here (pages 159-161). This can be interpreted in different ways but it looks like FAA licensed pilots will be forced to obtain EASA licenses. The proposal is rather bizzare because the pilot does not get the slightest credit for previous ICAO training or qualifications! The official deadline for implementation is 2012.

During 2009 it emerged that EASA does not propose to attack N-reg airframes but instead may give the national CAAs the power to fine owners who do not maintain their aircraft. Possible attacks would have been long term parking restrictions, or a requirement to maintain to EASA Part M rules, but both of these appear to have been dropped. The latter one would have been particularly difficult in terms of equipment certification..

EASA claims to be working towards signing up reciprocal treaties with other countries (outside the EU) for mutual document recognition. This reciprocity concept is a very "European approach", as morally hard to criticise as telling Bob Geldof to stop doing pop concerts to end poverty, but is a high risk strategy because the chief player (the US FAA) is not going to modify its own regulations to suit Europe.

My own opinion is that EASA's current highly aggressive FCL proposal is going to hit the rocks before 2012, because of the political difficulties in forcing it through. And if it does not meltdown completely, more acceptable FAA to JAA conversion routes should emerge at the last minute. It would therefore be foolish, in my view, for FAA licensed N-reg owners to panic.

Pilots who wish to pre-empt the risk of future EU regulatory action, or who need to fly a G-reg under IFR in Europe, will need to look at the JAA/EASA IR options. This involves a lot more work but it avoids the travel to the USA and the Visa/TSA hassles. There is no clear cut argument on the costs because so much depends on the value one attaches to one's time, time spent with family, general hassle, etc.

There is also an FAA to JAA IR conversion option. You still have to sit all the exams but can avoid the ground school attendance. The UK CAA requires a minimum of 15hrs' flight training on top. Some other countries do not have this 15hr requirement and you could just turn up for the checkride; however, there are further rumours (very likely false) that the UK CAA is not happy about adding a non-UK JAA IR to a CAA issued PPL. For good weather, there are "professional" schools in Spain and Greece which offer conversion courses and some of these have a reputation for "less than onerous" checkrides, but they all seem to suffer from poor communication which makes it hard to establish the options. Most European IR schools operate written exams from the UK CAA, and even an IR done in Greece involves sitting the CAA exams in Athens, for a mere 5 euros each. Update 1/2012: I did the JAA IR conversion route here.

More esoteric options are countries which are not yet JAR-FCL compliant but can be expected to become so (whether or not they are or will be EU members) - any national licenses obtained there are going to get grandfathered into full EASA ones. Hungary used to more or less directly validate FAA licenses until they stopped around August 2009. Unfortunately, research in this area is complicated because the national CAAs do not readily discuss such options and one needs a good local connection to check them out.

Most countries around the world will validate any ICAO CPL/IR if you have a "relationship" with a commercial operator flying aircraft registered in that country. Sometimes you get just a validation but in some cases you get a whole separate national CPL/IR. If that country later becomes JAR-FCL compliant, this can offer a route to a JAA CPL/IR which will in most cases side-step sitting the 14 JAA CPL/IR exams, but this is a very long shot and one could get stuck with a near-useless national license.

Nevertheless it is clear that a rather efficient route has emerged for those who wish to cover all the bases:

1) Get the FAA PPL/IR - this entitles you to fly an N-reg worldwide IFR or a G-reg worldwide VFR; best done wholly in the USA

2) After 100 hours total time, get a UK JAA PPL - the 100hrs TT gives you credit for about half the CAA exams and most of the flying.

3) Get a JAA IR using the FAA IR conversion route - this does require all the ground exams but there is a huge credit on the flying requirement. However, the above EASA proposal contains what amounts to a conversion route, comprising of only a few of the ATPL exams and no additional training, so this is actually a better option that doing an FAA to JAA conversion today.

The above route gives you a JAA PPL/IR and the FAA PPL/IR - both completely independent sets of licenses. This route is a lot more attractive if you can get your hands on an N-reg aircraft early on, of course.

An alternative approach, which is what I did and which is more applicable to a UK pilot who is initially flying a G-reg aircraft:

1) Get a JAA PPL and the IMC Rating, making sure the training meets all the FAA PPL/IR specific logbook requirements; this can all be done in the UK or at certain CAA-approved schools in the USA

2) Get the FAA standalone PPL using the JAA PPL training as a full credit; this is just the FAA exam, a few hours' flying, and a checkride

3) Get the FAA IR using the IMC Rating training as a full credit (but see this). The aircraft can be transferred to N-reg at this point.

4) If this proves necessary, get a JAA IR using the FAA IR conversion route. And if something happened suddenly, you can always renew the JAA PPL and IMC-R.

I am adding notes on the current EASA threat to FAA licensed pilots here.

Update 5/11/2016: It is no longer possible to sit the FAA exams outside the USA. A good discussion is here.

 

Last edited 18th March 2017

 

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