Ibra wrote:
So you will need an FAA PPL even if you hold a French PPL and UK PPL, one is valid to fly the aircraft in Cherbourg and the other in Bournemouth?
Peter wrote:
My view is that the FAA wording doesn’t say you “cannot cross a border”.
At some point on that route the aircraft will not be in the airspace above the territorial waters of any state, conservatively taking the limit as 12 miles, so 61.3(a)(1)(vii) will not apply and a US pilot certificate will be needed.
tmo wrote:
The q is: with a current FAA Flight Review, does the SEP(L) rating on the EASA license need to be valid, or not. IOW, does one need both a FAA Flight Review and an EASA one, or just the FAA one?
The requirement for the flight review or substitute activity was confirmed in the interpretation given on 04 Apr 2013 to John D Collins by Mark W Bury, Acting Assistant Chief Counsel for International Law, Legislation and Regulations Division. The interpretation is supported by 14 CFR 61.2(b) which applies equally to your question on the exercising of IR privileges.
—
§61.2 Exercise of Privilege.
..
(b) Currency. No person may:
(1) Exercise privileges of an airman certificate, rating, endorsement, or
authorization issued under this part unless that person meets the
appropriate airman and medical recency requirements of this part,
specific to the operation or activity.
—
Needing to maintain the validity of a foreign rating will depend on whether FAA regards the rating expiration date endorsed in the foreign licence or certificate of revalidation as a limitation or restriction for the purpose of 14 CFR 61.75(e)(3) or 61.2(a)(4). You could request an opinion from the Office of the Chief Counsel for the FAA. The rule in FCL.040 (exercise of the privileges of licences) does not apply when exercising the privileges of a restricted US private pilot certificate.
The closest interpretation is in the opinion given on 22 Mar 2012 to Andrew Krausz by Rebecca B MacPherson, Assistant Chief Counsel for Regulations:
While 14 C.F.R. 61.75 does incorporate the limitations and restriction
“on the person’s US certificate and foreign pilot license,” (emphasis
added) that language refers to the scope of the authority reflected by
the certificate itself. In other words, the pilot is subject to the
restrictions and limitations that appear on the face of the US
certificate or foreign pilot license. The language does not include
the entirety of regulatory requirements of the foreign State since the
holder of the §61.75 certificate is bound by the US regulatory
requirements to exercise the privileges of the US certificate. The FAA
views that language as addressing the limitations of the sort FAA
uses, e.g., “not valid for night operation,” where the individual has
not completed the night training requirements.
The night operations example was about the least helpful example imaginable because there is nothing written on a Part-FCL PPL indicating the absence of a night rating, eg taking this interpretation literally means the restricted US private pilot certificate is not compliant with ICAO Annex 1 (requirement for dual night flying instruction before exercising privileges at night).
That’s interesting indeed.
Does the FAA define the boundary as the 3mile or 12 mile one, or as the airspace boundary?
France to Germany, there is no issue with this, but UK to France there could be a problem unless it was the 12 mile one and one flew Dover to France 
Going forward it’s 24 miles (nautical) water crossings for me
Qalupalik wrote:
The night operations example was about the least helpful example imaginable because there is nothing written on a Part-FCL PPL indicating the absence of a night rating, eg taking this interpretation literally means the restricted US private pilot certificate is not compliant with ICAO Annex 1 (requirement for dual night flying instruction before exercising privileges at night).
I think it is very helpful, it makes sense from a USA perspective. After all the 61.75 IS a form of a USA license, it may not be ICAO Annex 1 (requirement for dual night flying instruction before exercising privileges at night) compliant as a result, however the FAA could easily make it ICAO compliant by putting the necessary restriction ON the 61.75 but have either chosen not too or they don’t realise… Of course from the other side of the fence it makes no sense at all. 
Of course IMHO you would have to be very stupid to ignore how your national CAA might view this if you never had any of the appropriate dual training.
Am I right to assume that a pilot can fly on 61.75 license in the UK using a Pilot Medical Declaration?
The closest interpretation is in the opinion given on 22 Mar 2021 to Andrew Krausz by Rebecca B MacPherson, Assistant Chief Counsel for Regulations:
The Grossman opinion is perhaps more helpful. It confirms that a 61.75 (strangely not described as that in the text) allows a pilot to fly an aircraft that would require a type rating on the underlying licence by meeting only the FAA requirements even if they do not hold the type rating on the underlying licence.
Still not exactly what you need, but close.
bookworm wrote:
It confirms that a 61.75 (strangely not described as that in the text) allows a pilot to fly an aircraft that would require a type rating on the underlying licence by meeting only the FAA requirements even if they do not hold the type rating on the underlying licence.
Thank you. And they do reference 61.75(e) in the footnote, which should clear any doubt.
