I am trying to find an ‘official’ concise explanation, preferably generated by the CAA, which provides justification for my obtaining an EASA licence by April 2014 in order to continue to work as a commercial pilot of a privately owned N reg aircraft.
I am aware of the subsequent derogations, but am looking for something which explains why I had to obtain the EASA licence, to be sure of being able to continue to work.
I appreciate the information is out there but I just haven’t been able to find it – any help much appreciated.
http://www.caa.co.uk/docs/33/Information%20Notice%202014171.pdf
http://www.caa.co.uk/docs/224/IR%20conversions%20QA%2020140811.pdf
Thanks very much Neil,
That’s is what I came up with, but I am after something more like the original Information Notice (If there was one, I can’t find it), which may make more sense to a layman unaware of the issues and subsequent derogations. In addition the reference to ‘non-commercial’ and 2016 aren’t helpful to the point I’m trying to make.
I think the second document is fairly explicit when it says
As from 8 April 2015, holders of ‘Third country’ ICAO-compliant licences will no longer be entitled to exercise the privileges of the licences and associated ratings on aircraft registered in an EASA country, even if the flight is for private purposes only.
There are references to the Basic Regulation in the first derogation document, I suspect if you google that you will find it chapter and verse.
It’s real and it caused me no little trouble but I have done IR and Type Rating now, so I’m good to go.
Thanks again Neil,
Your addition while I was typing my reply is helpful.
I’m definitely getting there, although ideally I’m after something which references the fact that if I don’t get an EASA licence, I will no longer be able to ply my trade after the original April 2014 deadline on N registered aircraft.
ATB
Nick
I get a lot of emails from pilots asking me for a clear reference to the EASA FCL requirement for EASA papers from April 2016.
It is harder than it looks.
It is not hard to find the very short passage in EASA FCL. Starting here you find
and AFAIK this is all there is. I think that everything else (including anything published by the UK CAA or any other CAA) is just a locally interpreted paraphrase of that very short statement.
A year or so ago I spoke face to face to a UK CAA guy, head of licensing or something similar, and I asked him whether they have any clarification of the above words, what “operator” means, etc, and his reply was NO.
preferably generated by the CAA
The problem is that no local CAA has the right to create law by paraphrasing an EU directive. What you do potentially get, however, in a civilised country like say the UK, is that if the local CAA wording is more permissive than the EASA wording, is protection from a local prosecution if you complied with the CAA wording but not with the EASA wording. A criminal prosecution is done based on locally worded law. But I doubt any local CAA wording is more permissive than the EASA wording 
However -
to continue to work as a commercial pilot of a privately owned N reg aircraft.
talks about commercial work, and that’s a different thing.
If it is an AOC operation, then different rules apply. The pilot(s) will probably still require EASA papers (licenses ratings medicals). But the AOC permission will implicitly authorise whatever the operation is and what pilot papers are required. The interpretation of what “operator” etc means will be irrelevant. You have the AOC and you can fly in accordance with it. PROB99 an N-reg will be required to be maintained under Part M, not Part 91, otherwise you get unfair competition complaints from local-reg operators who are forced to use an EASA 145 company, etc
If it is a Part 91 operation, non AOC, e.g. an FAA CPL/IR working as a paid pilot for the owner of an N-reg bizjet/PC12/etc, then if the “operator” meets the EASA FCL wording above the pilot(s) will need the EASA papers. Such a Part 91 operation is a “private flight”, everywhere in the world, otherwise “bizjet aviation” would mostly collapse.
The above is obviously the strictest interpretation of EASA FCL. This topic has taken up gigabytes of internet bandwidth and whoever drafted it (possibly in a Cologne bar; a sentiment suggested by a couple of barristers I have spoken to) is rolling on the floor laughing at how much great havoc they have achieved. Multiple threads here too – search for e.g. Morocco.
Another problem is that the derogation to 2016 is not EU-wide. Some countries have not implemented it, possibly because their national CAA could not understand the 1000 page EASA docs 
This leads to more endless debates whether the April 2016 date applies to pilots based in the country which did apply the derogation, and/or doesn’t apply if overflying countries which didn’t apply it. Straight out of Kafka. There is one guy who works inside the system who sometimes drops in here…
Hi Peter,
I did the whole EASA CPL/IR thing prior to April 2014 to ensure I could continue to work as an FO on a privately owned N reg bizjet.
I may now be asked to prove that I had every reason to believe the additional training / qualifications were required in order for me to continue in that role….
ATB
Nick
Another, in my opinion bigger issue facing operators of all nationalities is Part-NCC, which imposes the requirement for an AOC style ops manual and management system on every operator of a jet or multi engine turboprop. There will be audits and all that stuff, which will cost the operator.
The UK CAA has carefully avoided changing the EASA FCL wording, and in fact they just copy/paste it.
So no “interpretation” has been added, from what I can see, in the above (year 2012) doc, @neil
I probably spoke to the guy who wrote that. The CAA doesn’t know what it means either.
