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6 Answers

Commercial SEL add-on (No private privilege *expired foreign based PPL)

Asked by: 3000 views , ,
Commercial Pilot, FAA Regulations, General Aviation

Good day,

I recently had my Commercial AMEL and am Instrument rated as well. I wish to do the Commercial ASEL add-on but my problem is I don’t have Private privileges under my Commercial license as my Private license is “foreign based” and separate. Being my country’s PPL license expired, my foreign based FAA PPL also expires. Do you guys have an idea if I can take a Commercial ASEL add-on based on my Commercial AMEL alone ? 

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6 Answers

  1. Best Answer


    Russ Roslewski on Dec 04, 2020

    If I follow you correctly, you have a U.S Commercial AMEL certificate that is NOT foreign-based, correct? In this case, the expired foreign Private ASEL is irrelevant, it may as well not exist.

    So you have a standard U.S. Commercial AMEL but no Private-ASEL privileges. This is not that unusual, it happens somewhat regularly with military pilots who have never flown a single-engine aircraft (fewer any more, but they used to start off in twin-engine jets).

    This poses no problem for a single-engine add-on. You will just need to meet the experience and training requirements in 61.129a and pass the checkride. This is exactly the same situation as someone who has their Commercial – ASEL certificate and wants to add on a Commercial AMEL. They don’t have a Private AMEL, but that doesn’t matter. I do this kind of training routinely.

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  2. awair on Dec 04, 2020

    Subject to verification, but read carefully the Legal Counsel letters:

    Is your foreign ASEL expired, or just not current?
    For example, an EASA license does not expire.
    If you have an EASA license, on which your 61.75 certificate is based, and your SEP is not current, the FAA certificate is still valid.

    You must comply with the FAA regs for Flight Review, medical & recency…

    …as long as the foreign certificate is not “surrendered, suspended, or revoked”, the FAA 61.75 is still OK.

    (I\’ll search for the reference, but perhaps Mr Collins has this at hand…)

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  3. kyle on Dec 04, 2020

    Hello all, I currently hold an FAA Commercial AMEL-IR so it’s a stand alone license. I just don’t have Private ASEL privilege on my FAA Commercial license. Foreign PPL-ASEL is expired since it’s issued in Philippines in which in our country, the licenses around expires. As I read the 61.129(A) I currently meet all the requirements, does most CFI’s know about this kind of instance for the Commercial add-on ? I’m only concerned because this might cause an issue with the CFI who’ll train me and the DPE who will conduct my checkride.

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  4. KDS on Dec 04, 2020

    Reference FAR 61.123(h), which says:

    (h) Hold at least a private pilot certificate issued under this part or meet the requirements of § 61.73; and (that second part after the word OR is for military pilots).

    Note that there is no requirement for you to hold a private ASEL, but rather only to hold “at least” a private pilot certificate. A commercial certificate, such as you hold in AMEL, is at least a private pilot certificate.

    It is not even necessary for you to mention your foreign based private pilot certificate and it might just confuse them if you did.

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  5. Mark Kolber on Dec 05, 2020

    Kyle, read Russ’s answer again.

    Since you hold an FAA commercial pilot certificate with a multi-engine rating, adding a single engine rating is straightforward. You do not need to have a single engine private rating. As he said, it is no different than the extremely common situation of a commercial pilot with only an ASEL rating adding a multi rating to his commercial certificate.

    You ask whether most CFI’s know how this works. Well, like anything else, there are CFIs who are not very good at understanding the rules, but this is simple, very basic stuff. I’d say you can be pretty sure that any multi instructor knows it because he does it in reverse all the time.

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  6. kyle on Dec 06, 2020

    Hello all, thanks for your helpful insights about this. I’ve already talked with my previous MEI and confirmed everything with me and said it’s pretty straightforward and an easy process for me to add a SE add-on on my current CPL in my situation. Have a good day captains

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