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According to FAR 61.153(d), a pilot may use a foreign commercial or ATP certificate as a prerequisite for getting a US ATP.

To do so, an applicant must:

Meet at least one of the following requirements:
...
(3) Holds either a foreign airline transport pilot license with instrument privileges, or a foreign commercial pilot license with an instrument rating, that... (emphasis added)

What's the difference between "instrument privileges" and "Instrument rating"?

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The short answer is that the privileges are what the rating confers, and there are ways to get those privileges other than having the rating.

A commercial pilot licensee in most jurisdictions that follow ICAO certification guidelines may fly small planes for hire, doing service as a courier, air taxi, crop duster, etc. These do not necessarily require flying in IMC or in Class A airspace, and so a CPL holder must also have a separate "instrument rating certification" in order to fly IFR.

ATPL licensees fly in Class A as a matter of course, and that also often requires ascending and descending through the cloud ceiling which is IMC by definition. Therefore, the requirements for an ATPL in ICAO-compliant jurisdictions inherently include those required for the "instrument rating" applied separately to lower certification levels (private/commercial), and the resulting license for an airline pilot confers the same "instrument privileges" that the rating would.

Thus the difference in terminology; an ATPL holder in another country has "instrument privileges" as a consequence of his basic license and so does not need a specific "instrument rating". The same is not true for CPLs and so the law specifically requires the instrument rating as a prereq for a foreign CPL seeking an FAA ATPL.

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    $\begingroup$ That was a great answer last week, but it took the weekend thinking about something else entirely for it to make sense this morning. $\endgroup$ – FreeMan Jul 20 '15 at 12:30
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This arises from a difference in how instrument privileges are granted by the FAA. Private and commercial ratings do not include instrument privileges but the ATP rating does.

This means that for a commercial pilot to have instrument privileges the pilot must also have an instrument rating. To apply for an ATP rating the pilot must have instrument privileges (from an instrument rating) and once the ATP is passed, the pilot no longer has an instrument rating, just an ATP rating. The ATP rating itself grants instrument privileges.

The wording in the regs you post account for this. The applicant must have instrument privileges and this can either be from a foreign commercial+instrument rating or just a foreign ATP rating (that grants instrument privileges).


Instrument privileges allow you do instrument things and an instrument rating is something that confers instrument privileges.

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