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I hold an FAA private license with ASEL and AMEL class ratings and with an instrument add-on rating. [I'm trying to be precise but, basically, I've an FAA multi/IFR PPL.]

I'd like to add a Rotorcraft-Helicopter class rating to my PPL. [I.e., get rated in an R44.]

I did my fixed-wing training with AFSP approval. (I'm a permanent resident.)

Do I need to obtain AFSP approval for my helicopter training?

According to the AFSP FAQ,

Category 3 Clarification - For flight training in the operation of aircraft with a maximum certificated takeoff weight of 12,500 lbs. or less, Candidates must obtain AFSP approval for the following three training events:

Single Engine Land (SEL)

-- Includes initial Airman's Certificate, including a private, recreational, or sport pilot certificate. If a private and/or commercial license is the candidate's initial FAA license, it is considered an initial airman's certificate and is not exempt.

Instrument Rating (IR)

Multi Engine Land (MEL)

Each of these three events requires a separate training request.

All other training events on aircraft with MTOW of 12,500 lbs. or less are exempt from AFSP regulations, including Commercial Pilot License (CPL), Airline Transport Pilot License (ATPL), and Certified Flight Instructor (CFI). These events are exempt only if the candidate holds an FAA stand-alone pilot certificate.

But, when asked, the AFSP said that I do need to get AFSP approval. (Citing no rule.) I've asked for clarification but does anyone know for sure?

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  • $\begingroup$ What the AFSP said is directly contradictory to the FAQ, but if they say you need it, you need it. I'd work on getting my citizenship asap if I was you, then you won't have to deal with this kind of stuff nearly as often. $\endgroup$ – Noah Wood Jan 31 '18 at 9:11
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The problem is that person writing the FAQ seems to not understand the category and class system for pilot certification. The interim final rule (the actual regulation) does not make the distinctions you have discussed from the FAQ. See https://www.flightschoolcandidates.gov/IFR_Alien_Pilot.pdf as Category 3 does not specify an FAA pilot certificate category or class, just MTOW of 12,500 pounds or less, which means a R-22, R-44, Sikorski/Schweizer 300, seaplanes, gyrocopters, gliders, lighter than air, etc. unless specifically exempt elsewhere.

According to https://www.flightschoolcandidates.gov/TSA-2004-19147-0337.pdf the measure that they use with regards to whether or not you are subject to the "threat assessment" is whether you are taking training that will "substantially enhance piloting skills" but then it further states that the requirements are for the "initial pilot certificate, including a private, recreational, or sport pilot certificate."

It would be very hard to argue that training towards a certificate in RH is not going to "substantially enhance piloting skills". However, when they came up with the FAQ it appears that they have ignored that there is any category of aircraft outside of that of airplane (and any class outside of land airplanes).

Adding on RH (or Instrument-Helicopter) to ASEL/ AMEL/ Instrument-Airplane would be your "initial pilot certificate" in the rotorcraft category, helicopter class, or your "instrument rating" for that category.

For the sake of not getting yourself or your flight school in potential serious trouble, you should probably apply under the Category 3. If I were in your position I would omit the "probably" of the last sentence, but I am not a government regulator and I am not an attorney, so there is always a degree of uncertainty with regards to my personal interpretation of this material.

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