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Some subtle changes in the UK process for non UK ICAO licence validation for G-reg aircraft - ICAO IR is now valid for CAS

There has been an unpublicised change in the UK regs on this.

For many years, a G-reg could be flown on any ICAO PPL, noncommercial, VFR. It could also be flown IFR (if the pilot had an IR) but only OCAS e.g. Class F/G only.

This meant, for example, that an FAA PPL/IR holder, flying a G-reg, could fly an ILS (in actual IMC, so we avoid the debate of flying an IAP in VMC ) into Biggin EGKB (Class G) but not into Southend EGMC (Class D).

This “OCAS” restriction has disappeared.

This is valid worldwide which is highly significant because while one “can” hack around the UK fairly well in Class G, including IAPs, IFR outside the UK is mostly (not wholly, I know…) impossible without getting into CAS. This, for decades, made the validation practically worthless.

A more subtle change is that the “noncommercial” restriction (which also means no paid training) has also disappeared, but only for non-Part 21 aircraft (basically Annex 1).

And as we know from the brexit outcome, an EASA Part-FCL licence is also valid for 2 more years in a G-reg, and it is valid for commercial operations so is valid for flying instruction.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

And as we know from the brexit outcome, an EASA Part-FCL licence is also valid for 2 more years in a G-reg, and it is valid for commercial operations so is valid for flying instruction.

By the way, an EASA Part-66 license is also valid for G-reg for 2 more years, which comes quite handy for G-regs based in the EU.

LKBU (near Prague), Czech Republic

Peter wrote:

There has been an unpublicised change in the UK regs on this.

It was published in the ANO in 2016. I’ve mentioned it here before (although while in EASA, it only applied to Annex 1 aircraft e.g. PtF).

What would be new would it be applying to “former EASA products” on G-reg.

Last Edited by alioth at 15 Jan 09:50
Andreas IOM

Yes; G-reg Annex 1 always had the ability to be flown on any ICAO PPL. Didn’t realise IFR was too, but then the number of Annex 1 planes IFR certified under the LAA IFR programme is reportedly miniscule.

This is probably a good example of where some well chosen and not too provocative “misalignment with EASA” is really beneficial.

Administrator
Shoreham EGKA, United Kingdom

G-ARJU, a very well maintained Piper Apache with IFR kit and non EASA, seems to deserve to benefit from this rule change, if I understand it correctly. The previous owner sadly passed away.

Oxford (EGTK), United Kingdom

I just started the process to bring my RV7A under G-reg, possibly with IFR approval.
I have an IR on my piggybacked FAA PPL, and a IR(R) (I think equivalent to IMC) on my UK-Issued (ex-)EASA PPL (it was automatically included without my consent when I switched to UK-EASA PPL few years ago, based on the FAA IR). Questions for the UK regulation gurus:
1) do I understand correctly that I can fly an IFR-approvel G-reg RV7A under IFR within CAS thanks to my FAA IR?
2) did my FAA PPL lose the piggyback “support” on 1st Jan when my UK ppl lost its EASA status? I remember I had to renew the piggyback when I switched to UK-EASA ppl few years ago, but then the license number changed slightly (few letters changed), while now I think(?) my UK license number didn’t change on 1st Jan.

Last Edited by mancival at 17 Jan 12:14
United Kingdom

1. Yes. Arts 137 & 150 of the UK ANO 2016 as amended.

Art 137(1) […] a person must not act as a member of the flight crew of
[a non-Part-21 aircraft registered in the United Kingdom other than an
excepted aircraft] without holding an appropriate licence granted or
rendered valid under this Order.

Art 150(3) […] a licence [granted under the law of a Contracting
State other than the United Kingdom] is, unless the CAA gives a
direction to the contrary, deemed to be a licence rendered valid under
this Order in respect of a non-Part-21 aircraft registered in the
United Kingdom.

Art 150(4) […] the privileges of a licence deemed valid under
paragraph (3) are restricted so that it does not entitle the holder to
act as a member of the flight crew of any aircraft flying for the
purpose of public transport or commercial air transport.

2. No. The foreign licence number must match what is recorded in section XIII of the US certificate.

FAA Order 8900.1 (FSIMS), 5-596F (link):

F. Duration. A § 61.75 U.S. pilot certificate issued on the basis
of a foreign pilot license remains in effect as long as the foreign
pilot license used to obtain the U.S. pilot certificate is valid.

NOTE: A prefix or suffix change in a foreign pilot license does
require the reissuance of a U.S. pilot certificate issued on the basis
of a foreign pilot license. Some examples of countries that issue
prefixes and suffixes on their pilot licenses are Canada, Germany, and
Great Britain. For example, on a foreign pilot license issued by Great
Britain, the prefix codes the grade level of the pilot license. In
Germany, the suffix codes the grade level of the pilot license. For
the U.S. pilot certificate to correctly identify the person’s foreign
pilot license, if the person’s foreign pilot license has a change in
its prefix or suffix code, the U.S. pilot certificate must be reissued
to reflect the person’s most current foreign pilot license number. All
requests for reissuances of U.S. pilot certificates that require
prefix or suffix changes must be made by application on an FAA Form
8710-1. The applicant must request verification of the authenticity of
the foreign pilot license before making application.

London, United Kingdom

Thanks Qalupalik. For answer n.1 you proved I can fly a G-ref RV7 with my FAA license, in UK airspace: am I legal to fly also in European Countries airspace (assuming experimentals are welcome there)? When 1) license, 2) plane and 3) airspace have 3 different countries respectively, I’ve always heard that legality must be double-checked…

United Kingdom

It would be nice if the CAA would issue some guidance on this.

Using an FAA Licence and IR to fly IFR worldwide in a G-Reg aircraft would solve so many problems.

LFMD - Cannes Mandelieu, EGLL - London Heathrow, France

It is clear that is exactly what you can do. Other countries have done similar things e.g. the FAA does the 61.3 but the UK CAA is unique in doing this validation automatically.

I’ve always heard that legality must be double-checked…

Not heard of that one.

would solve so many problems.

AFAICT it would “solve problems” only in the UK, where they have continued to implement the “Brussels attack on N-regs” If it wasn’t for that, being N-reg would be ideal for most (not all, due to A&P etc issues).

Administrator
Shoreham EGKA, United Kingdom
18 Posts
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