FAA ATPL holder seeking a New Zealand command
An airline pilot with New Zealand citizenship has just returned from 12 years flying in the United States. She holds an FAA ATPL(A) with type ratings on the Beech 1900 and Cessna 208, 2,150 total hours, 1,100 hours as PIC, 300 hours night and 150 hours instrument. Her FAA first-class medical is current. Her last flight was seven months ago. A New Zealand Part 135 operator wants to employ her as a single-pilot IFR captain on a Cessna 208 Caravan from next month. She has never held a New Zealand licence and has no New Zealand medical certificate. The company's operations manual requires 90-day recency and an instrument rating. She asks whether she can start flying passengers while her NZ ATPL application is processed, and what she must complete before commanding the Caravan.
1. Can she act as PIC of the New Zealand Part 135 Caravan before her NZ ATPL is issued?
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No, not on the strength of her FAA ATPL alone. A foreign licence does not automatically authorise commercial passenger operations in New Zealand. She must hold a New Zealand licence with the appropriate privileges, or a specific CAA validation or authorisation. The normal route is an application to the CAA under Part 61 for an NZ ATPL(A), with assessment of her overseas licence and logbooks against the NZ experience requirements. That process will normally include NZ air law and other examinations, a flight test, and evidence of the required experience and type/class ratings. She also needs a New Zealand Class 1 medical certificate issued under Part 67. The operator must complete its own Part 135 induction, training and checking, and the CAA must be satisfied that she is competent for single-pilot IFR command. Until those steps are complete, she cannot be used as a passenger-carrying PIC. She could possibly act as a student, observer or under supervision only if the rules and the operator's approvals permit it.
2. What medical, recency and instrument requirements must she satisfy?
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She needs a current New Zealand Class 1 medical certificate. The FAA first-class medical is evidence of her US status, not a substitute for the NZ certificate. For recency, the usual NZ requirement is at least three take-offs and three landings in the preceding 90 days, and for passenger-carrying operations the take-offs and landings must be in the same type or class. Her seven-month gap means she is not recent. She will need refresher training and the required take-offs and landings before carrying passengers. Because the proposed operation is single-pilot IFR, she must also satisfy instrument recency and the operator's instrument proficiency requirements. The company's 90-day recency rule is an additional contractual requirement, not a substitute for the regulatory rule. Her night hours and instrument hours are relevant to the ATPL experience assessment, but they do not cure the recent-experience gap. The operator should document the refresher, checking and recency before she is released to the line.
3. If she only wanted to fly private VFR in New Zealand, would she still need a New Zealand licence?
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Yes, in practice she would still need a New Zealand licence or a CAA validation. A foreign private licence is not a general permission to fly in New Zealand. The CAA must assess her licence, medical and experience, and she would need to meet the relevant NZ private pilot or higher licence requirements, including any air law examination, flight review or conversion training. Her FAA medical would not replace a NZ medical certificate. If she later wants to use the privileges commercially, she must hold the appropriate NZ commercial or airline transport licence and ratings, not merely a private licence. The fact that the flight is VFR and non-commercial reduces the operational complexity, but it does not remove the licensing and medical requirements.