• Facebook
  • Twitter
  • LinkedIn
  • Instagram
  • Youtube
Helicopter Flight Training Sponsors


All Entries


Added Ratings and Foreign Pilots…Revisited

Posted 3 years 340 days ago ago by Randy Rowles

Within the past few months, the number of pilot applicant’s ineligible for a pilot certificate practical test has increased because their instructor misunderstood the requirements for an additional certificate or rating. Additionally, the number of ineligible applicants when using a foreign pilot certificate as the basis for FAA certification has increased as well. Let us review each of the problem areas directly.

An issue exists regarding properly endorsing a pilot for solo flight when that pilot already holds an FAA pilot certificate above the Student Pilot level seeking new certification in accordance with 14 CFR 61.63. Specifically, the misunderstanding within our flight instructor cadre relates to an existing pilots 14 CFR 61.56 Flight Review currency when receiving instruction for a new category/class of aircraft.

Does a pilot need to have a current Flight Review prior to receiving a solo endorsement when receiving training for a new category/class of aircraft? This topic has been debated between flight instructors for years, however you can find the answer in FAA Legal Interpretation issued to Daniel Beard on January 9th, 2015.

In a letter to the FAA dated July 27th, 2014, Mr. Beard asked FAA whether a person operating in solo flight under a 14 CFR 61.31(d) endorsement must comply with the flight review requirements in 61.56(c). The FAA responded stating “…a pilot who holds a higher level pilot certificate and has an endorsement for solo flight under 61.31(d) must comply with the flight review requirements in 61.56 before acting as pilot-in-command of ANY aircraft”.

The answer is YES! A pilot that holds a pilot certificate above a Student Pilot certificate must have a current flight review before conducting solo flight on a 14 CFR 61.31(d) endorsement.  

The US flight training market is supported in a large part with pilots from other countries desiring FAA certification. For pilots that obtained their pilot certification from countries other than the US, provisions within our regulations to accept the experience and certification to obtain FAA certification exist.

The are many reasons that a foreign pilot would desire an FAA pilot certificate. Many aviation regulators accept FAA certification as a full or partial equivalent to their own aviation certification. They may use their FAA certificate for the purpose of bypassing costly and time-consuming processes within their home countries pilot certification process, or to simply to fly an N registered aircraft as pilot-in-command.

No matter the reason for desiring FAA certification, the pilot must have their foreign pilot certificate validated if being utilized for any portion of eligibility when applying for an FAA pilot certificate or rating. This is not limited to the issuance of a 14 CFR 61.75 (Private Pilot certificate issued based on a foreign pilot license). The requirement to validate a foreign pilot certificate also applies to 14 CFR 61.77 (Special Purpose Pilot Authorization), 61.123(h) (Commercial Pilot), and 61.153(d)(3) (Airline Transportation Pilot).

Remember, your student trusts your guidance and experience dealing with such matters. In many cases, these are financially sensitive and time-limited career decisions for these foreign pilot applicants. Let’s get it right the first time!

For more information on Foreign Pilot validation, please visit the following link:


For more information on Endorsement for FAA Pilot Certification, please visit the following link:


About Randy:  Randy Rowles has been a FAA pilot examiner for 20 years for all helicopter certificates and ratings. He holds a FAA Gold Seal Flight Instructor Certificate, NAFI Master Flight Instructor designation, and was the 2013 recipient of the HAI Flight Instructor of the Year Award. Rowles is the owner/president of Helicopter Institute.