I hold a FAA private certificate that is issued based on 61.75. I have single engine land and instrument ratings on the foreign license (EASA). My FAA certificate also has these ratings listed.
My question now is: What are the currency requirements to execute the privileges of the FAA certificate to fly in the US?
61.75 (e) states:
(3) Is subject to the limitations and restrictions on the person's U.S. certificate and foreign pilot license when exercising the privileges of that U.S. pilot certificate in an aircraft of U.S. registry operating within or outside the United States; and
This can be interpreted two ways:
a) The currency of a rating on the foreign license is a limitation or restriction and therefore the pilot needs to be current for both the foreign license (e.g. EASA 2 year check for SE land rating, and EASA 1 year check for instrument rating) in addition to the FAA required BFR and IPC/IR currency based on approaches etc.
b) The limitations and restrictions mean explicitly mentioned limitations (e.g. EASA PPL does not include night flying, so the US cert would have "VFR day only" listed as a restriction). The EASA license itself does not expire on its own and is valid as long as the pilot holds a valid medical. Therefore only the BFR and FAA instrument currency requirements apply to fly legally in the US.
So which interpretation is correct? Is there some other regulation which makes it more clear?
Practically "to be safe" I could just fulfill the EASA requirements every year/two years, but that is quite an effort (this can only be done by an EASA ATO which there are few in the US). It also adds additional costs.
I could also take the test(s) to get a FAA private and IR independently and everything would be FAA based only. That's an option but also requires time and effort.