Do I have to prove my flight training time abroad when applying for a standalone FAA license?

Question

I have done flight training in Germany and hence hold a German EASA Private Pilot License. For this I did the appropriate flight training which is documented in my logbook. But in Germany these logbook entries are not endorsed by an Instructor, it is the flight school sending the paperwork to the CAA that confirms you fulfilled all requirements.

Now I am in the situation, that I want to get a stand-alone FAA license. The two Part 61 flight schools I enquired so far both stated, that without logbook endorsement, non of the flown hours could be credited for the requirements of 61.109. But I also have German pilot friends that claim they also had no endorsements and that this was no problem while getting the license.

Is there maybe an official position paper of the FAA or something that states in more detail, what a foreign pilot needs to bring to prove being eligible?

And of course I know, that I will need additional training, but hopefully not 45 hours again. Therefore if the assumption of StephenS in the first answer is correct and I can use my logbook to prove part of the 20h DUAL (later night training is endorsed and 2.5h flying with CFIs in the US), then maybe I can reduce the requirement to about 15h. But where does the interpretation of only the 20h DUAL must be endorsed come from and not the SOLO or the rest to 40h? And what about the specific requirements in the section below in 61.109? If I have a cross country which is not endorsed, does it fulfill the requirement or not?

To keep this topic straight on this point, I am aware of all the necessities to start flight training: Regarding medical, I have a Class 3. Regarding student license, I have a 61.75 validation of my German license with ASEL and Instrument. Regarding Visa I am already staying in the US and working legally on a visa, the flight training is just part time.

Answer 1

I've been in exactly the same position as you: I had an FAA foreign-based (61.75) private certificate based on a South African PPL and then got a regular, standalone FAA private certificate. As you described, SA instructors don't have to endorse each lesson, they only endorse specific permissions like "authorized for solo flight in the circuit".

To answer your main question, no one cared much about the contents of my logbook. The FBO I (re-)trained at didn't look at it and the DPE didn't either apart from glancing over a few entries and saying "huh, that's different". However, he did check the US pre-checkride endorsements from my CFI in detail (more on that below). So I feel very confident saying that foreign endorsements for individual lessons are simply not required.

If you want an official source, see 14 CFR 61.41:

§61.41 Flight training received from flight instructors not certificated by the FAA.

(a) A person may credit flight training toward the requirements of a pilot certificate or rating issued under this part, if that person received the training from:

[...]

(2) A flight instructor who is authorized to give such training by the licensing authority of a foreign contracting State to the Convention on International Civil Aviation, and the flight training is given outside the United States.

Since Germany is an ICAO state, all your training there counts and asking for endorsements is a little pointless because you have a German PPL. That means it's obvious that you did actually receive the training :-)

Furthermore, the FAA's instructions to DPEs don't require them to check that every lesson was endorsed, they only require them to check a list of specific pre-checkride endorsements (see section 5-375). And you'll get those endorsements from your US CFI before your checkride anyway.

That's because the wider answer to your question is that getting a standalone FAA certificate requires you to do everything as if you were a student: get an FAA medical, get a student certificate, pass the written test, meet the requirements for the checkride (experience plus endorsements) and then do the checkride. And since you're not a US citizen, you'll need TSA approval for flight training. But all your experience logged outside the US counts towards the FAA's requirements, where applicable.

That might seem like a lot of effort but I highly recommend doing it. FAA certificates never expire, whereas licenses from other countries do. Once you have an FAA certificate, you never have to worry about keeping your German license and medical current.

Answer 2

You can find the detailed requirements for a FAA PPL in Part 61 Subpart E.

The total time of 40 hours can be met by any flight time you have logged, either DUAL or PIC. (In theory, SIC should qualify too, but I can't think of any legal way for a student pilot to have that.)

DUAL time can only be logged when you are receiving "training" from a CFI, who must endorse each such log entry along with a description of said training (maneuvers, procedures, etc.) in the remarks. This endorsement is what allows those hours to count toward the 20 hours of "flight training" required for your PPL.

The "solo" time of 10 hours can only be met by flight time where you are the only person in the plane, meaning that it can only be logged as PIC time. PIC time does not need to be endorsed--ever.

Where I think you're getting hung up is that a student pilot cannot legally act as PIC without getting an endorsement before the flight, and those endorsements have limitations. For instance, my first endorsement only allowed me to fly around the pattern at my home airport, the second allowed me to fly between my home airport and a neighboring airport, and the third was for a specific cross-country trip that I'd previously flown with my CFI. However, the resulting PIC time was not endorsed by my CFI after those dozen or so flights.

In your specific (and unusual) case, you were able to legally meet the solo time and cross-country time requirements without an endorsement before those flights. Still, like me, you don't need any endorsements after the flights. Just logging the PIC time yourself was enough for it to count.

Your records and history will undoubtedly look strange to your CFI (and eventually your DPE), so it's best that you make it easy for them to see which specific log entries you're using to meet each requirement. I'd suggest marking those entries with sticky flags, noting which FAR(s) they fulfill, and including a translation of the remarks if they're not in English. Don't note or translate your entire logbook, though; they don't care about anything beyond seeing that you've met the minimum requirements. And, while it shouldn't matter according to a literal reading of the regs, common sense suggests a preference for time logged in US aircraft (N reg) at US airports (Kxxx).

Finally, FAR 61.103(j) says that any applicant for a US PPL must "Hold a U.S. student pilot certificate, sport pilot certificate, or recreational pilot certificate." There's nothing in the regs that says a validated foreign PPL qualifies, so you'll need to discuss with your local FSDO; if they say it does, it's best to get that in writing so there's no paperwork problems with the DPE on the day of your checkride.