Can a pilot with an ICAO Multi-Crew Pilot License fly an airliner into the U.S.?

Question

In the question How do non-US pilots get the hours necessary for an ATP?, the question was raised of whether we have 250 or 500 hour foreign pilots flying airliners into major U.S. airports. DeltaLima's answer mentioned the ICAO Multi-Crew Pilot License (MPL), which

allows a pilot to exercise the privileges of a co-pilot in a commercial air transportation on multi-crew aeroplanes.

Of particular interest is the large gap in the minimum experience requirement between this license and an ATP license that would normally be required to fly an airliner in the U.S. While the FAA normally requires airline pilots to have at least 1,000 flight hours (or 1,500 if they don't have a degree in aviation,) the requirement for the ICAO MPL standard is much less. According to ICAO:

The ICAO Standard for the MPL specifies 240 hours as the minimum number of actual and simulated flight hours performing the functions of the pilot flying and the pilot non-flying.

While the U.S. has no such pilot certificate, what I'm wondering is:

1. Is a pilot who receives an MPL from another country allowed by the FAA to fly an airliner on normal scheduled passenger service routes into major U.S. airports?

2. If so, are there any further restrictions on doing so? For instance:

   • Can they fly a route subject to ETOPS regulations into the U.S.?
   • Can they fly a 777 into the U.S. or are they limited to smaller aircraft (e.g. turboprops and the like?)

What is required for a pilot to fly in another country? and I have a European EASA license - what do I need to do to be allowed to fly in the US? cover some general points about the certification requirements to fly an aircraft in a country other than the one where the pilot obtained their license, but they don't address issues specific to flying airline routes.

Interestingly, ICAO seems to suggest that pilots with an MPL would indeed be able to fly in the right seat of an airliner into any ICAO country:

International recognition of flight crew licenses

The Convention on International Civil Aviation, often called the Chicago Convention, provides for worldwide recognition of flight crew licences issued by any member State of the International Civil Aviation Organization (ICAO) provided that:

1.the licence meets or exceeds the ICAO licensing Standards of Annex 1 – Personnel Licensing to the Convention on International Civil Aviation; and

2.the licence is used on an aircraft which is registered in the State which has issued or validated the licence.

If the licence is to be used on an aircraft which is not registered in the issuing State, the licence holder must obtain a validation of the licence from the State of Registry or alternatively obtain a new licence issued by the State of Registry.

Can someone provide a reference to the FARs (or something of similar authority) or cite personal experience to confirm whether this is indeed allowed and, if so, what restrictions are placed on such operations?

Answer 1

The MPL doesn't allow the holder to fly as Pilot-in-Command, although in a pinch he probably could do it. It's a basic ticket to allow a non-ATPL pilot to fly as a fully qualified crew-member of an aircraft that otherwise requires the full ATPL ticket. Elsewhere the pilot would likely be accumulating only solo experience, and he won't be much use when transitioning to a multi-crew airplane. The MPL only allows the holder to act as copilot, 2nd officer (flight engineer) or cruise pilot, not as PIC, on any flight including to the USA. Where it's used, the MPL holder will be granted his ATPL when he completes any additional regulatory requirements and has accumulated the required hours. The MPL pilot is entitled to fly in his aircraft as co-pilot from anywhere outside the USA into the USA, although not in a USA-registered aircraft. Some pilots start their MPL training after completing A PPL or CPL beforehand.

Answer 2

Yes. Remarkable to think that the FAA permits the foreign-operated airplane off your wingtip on a simultaneous approach into JFK to have a MPL FO with as little as 258 hours (8 hours gained while on current flight) while the same FAA requires 1500 hours for the FO in your U.S. operated airplane of the same type.

Note the odd situation when your initial training is for multi-crew ops: Per ICAO, MPL is equivalent to CPL endorsed with an instrument rating and a type rating on a multi-crew aircraft. But ... an MPL pilot cannot generally fly a single pilot aeroplane without meeting additional requirements. (!) IDK what happens if the Captain becomes incapacitated during a flight with a MPL FO.

The Ethiopian 737 MAX that crashed March 2019 had a MPL FO with a total of 361 hours. He had 207 hours in type, all of them accrued within the 90 days prior to the accident but was certified to fly as a 737 FO 88 days prior to the accident. (?!)

The Final Report of the Lion Air 737 MAX crash investigation noted that in establishing the pilot type rating, training, checking and currency requirements for a new airplane, Boeing uses a group of pilots who have an operational flying background, and the group includes airline line pilots "to help ensure the requirements are operationally representative." The Safety Recommendation: "The FAA and OEMs should re-evaluate their assumptions for what constitutes an average flight crew’s basic skill and what level of systems knowledge a ‘properly trained average flight crew’ has when encountering failures."

My thoughts: The FAA should add to their intrepid Glossary of terms: Properly Trained Average Flight Crew — The lowest common denominator of pilot competency found in the worldwide pilot pool; used as the best case design standard for human factors.

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14 CFR Part 129 — OPERATIONS: FOREIGN AIR CARRIERS AND FOREIGN OPERATORS OF U.S.-REGISTERED AIRCRAFT ENGAGED IN COMMON CARRIAGE

§ 129.15 Flightcrew member certificates Each person acting as a flightcrew member must hold a certificate or license that shows the person's ability to perform duties in connection with the operation of the aircraft. The certificate or license must have been issued or rendered valid by:

(a) The State in which the aircraft is registered; or

(b) The State of the Operator, provided that the State of the Operator and the State of Registry have entered into an agreement under Article 83bis of the Convention on International Civil Aviation that covers the aircraft.

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Answer 3

A pilot with an MPL licence here. I've been flying in and out of the US for the past year with an MPL licence. In all fairness I've been flying around the rest of the world and amassed 2000hrs before I flew to the US for the first time.