What will FAA IRs / N-reg pilots do in the UK after 21 December 2021?

Now that is really interesting.

SRG2141

The wording states:

Declaration of a Flight Crew Licence Issued by an ICAO Contracting State for
use in UK Airspace in Non-Commercial Activities for under 28 days per calendar
year, under Annex III of Regulation (EU) 1178/2011 (the EASA Aircrew
Regulation)

That to me says I can do 28 IFR (FAA papers only) operations in a calendar year. It doesn’t say all the year’s flying has to be done in one 28-day block. That should cover all my foreign flying easily, given that I can do the Shoreham-BILGO under VFR on any even remotely ok day.

It needs a flight with an FI or presumably even a CRI, who certifies your FAA papers and logbooks.

No mention of a charge, which is weird given that the CAA applies to the FAA for validation of this stuff!

Strangely, the form contains the same stupid confusion as the CAA did a year or two ago:

It took them 4 weeks to climb down and accept the FAA Class 3 is just fine.

Also, digging around online, this text appears: A CAA form SRG2142 has also to be submitted nowadays, in order to let the UK CAA check that the licence has not been suspended or conditions attached in the home country. This adds time (and a little cost) to the validation process, so should be done as soon as possible. So this is how the CAA collects some money. And of course many of us have done this 2141+2142 stuff before.

So actually one comes around full-circle with this. It basically means the derogation ending Dec 2021 doesn’t mean anything – if I read it right. It never did mean anything – from the day the CAA moved to the 2141+2142 route annually. N-reg pilots in the UK just send the CAA 40-something quid every year, and carry on.

Maybe the one difference is the “acclimatisation flight”. I don’t recall seeing that bit previously.

Are we taking about 28 days using FAA papers in G-reg or N-reg?

Those 28 days can be spent throughout the calendar year howsoever it suits. The regulation for the SRG2141 route is art 8(3) in Commission Delegated Regulation (EU) 2020/723. The validation would allow a foreign-registered aircraft whose aircraft operator resides, or is principally established, in the UK, to be flown in the UK without holding a licence granted or accepted under the Aircrew Regulation, etc.

For whatever it is worth, another avenue might be to obtain a UK schedule 8 pilot’s licence iaw art 152 in the ANO. To the extent that the licence confers SSEA, SLMG, TMG, or SEP privileges, the licence is acceptable in lieu of a UK Part-FCL licence for Part-NCO operations, art 3(3) in the UK Aircrew Regulation. Although the conditions for the conversion of an ICAO PPL, or higher, to a UK Part-FCL PPL are fixed by art 9(2) in the above delegated act, there is to the best of my knowledge no equivalent requirement for 100 hours of pilot experience for a UK sch 8 PPL.

I must be missing something but I find it amazing how the SRG2141+2142 route has been turned around and has come back as a 28-day workaround for the derogations we used to get, say 4+ years ago.

Except, on a closer look, it used to be SRG2140+2142; not quite the same.

Since 2140+2142 has had to be submitted for the UK derogation for the last few years, that derogation (which few could quite understand what it said) appears to have been meaningless all along.

Anyway, thanks to Qalupalik, we have a very viable route, because together with the VFR-OCAS option, I am sure 28 days a year will do most people, if they reserve it for really deserving days.

Peter wrote:

N-reg pilots in the UK just send the CAA 40-something quid every year, and carry on.

But does it have to be re-applied for annually? The wording on the application form seems to suggest it is a one off application to fly less than 28 days per calendar year – (Implying that the permission will be on-going as long as the licence is valid?). And it would be a nonsense to have to do an acclimatisation flight more than once…

I declare that:
a. My Third country ICAO compliant Licence, medical and Ratings are current and valid
b. I do not hold a validation issued under European Commission Regulation (EU) 1178/2011, Annex III, granted by the United
Kingdom or any other Member State of the European Aviation Safety Agency (EASA).
c. I have not had a validation refused, suspended or revoked by an EASA Member State
d. I will be flying for no more than 28 days per calendar year in UK Airspace on the basis of this declaration.

Also all of us affected people have done SRG2142 recently… several times

Spoiler Alert for UK Based FAA I/R’s – looks like this doesn’t help us…

Qalupalik wrote:

Those 28 days can be spent throughout the calendar year howsoever it suits. The regulation for the SRG2141 route is art 8(3) in Commission Delegated Regulation (EU) 2020/723. The validation would allow a foreign-registered aircraft whose aircraft operator resides, or is principally established, in the UK, to be flown in the UK without holding a licence granted or accepted under the Aircrew Regulation, etc.

It looks like the Validation is, under the EU Regs, for one year and can only be extended by a further year, and in that case only if the applicant is working towards a Part FCL ticket – so it is not a silver bullet for FAA I/R holders to fly 28 days per year in perpetuity:

“3.The validation of a licence shall have a validity period, which does not exceed one year, and its privileges shall only be exercised as long as the licence remains valid. The competent authority that validated the licence may extend the validity only once and only by a maximum of one year, if during the validity period the pilot has applied for a licence in accordance with Annex I (Part-FCL) ":https://www.easa.europa.eu/document-library/regulations/commission-delegated-regulation-eu-2020723

Furthermore, it looks as though this route is not available at all after 21st December for UK Based FAA I/R holders, only foreign based pilots:

Getting permission from the CAA before flying
Permission is required and must be retained. Your ICAO licence/certificate needs to be validated for a limited duration. You will need to make a “declaration” following one of the processes below.

PS: same thing is happening in France but deadline is way down the road to bother…

I thought the French deadline was May 2022?

Good news if not.

Pilot-H wrote:

It looks like the Validation is, under the EU Regs, for one year and can only be extended by a further year, and in that case only if the applicant is working towards a Part FCL ticket – so it is not a silver bullet for FAA I/R holders to fly 28 days per year in perpetuity:

No, that time limit does not apply. Read the first clause in art 8(3) again: “By way of derogation from the provisions of Articles 4 to 7 …”