Peters recent posting on the logbook thread has reminded me of a statement made which suggests it is in the UK.
The site is here but the “point of interest” is copied below
“UK IMC Rating – This is NOT an instrument rating and is highly illegal in any aircraft that is not UK registered. Most importantly, to be absolutely clear, YOU MAY NOT EVER EXERCISE THE PRIVILEGES OF A UK IMC RATING IN A US REGISTERED AIRCRAFT, NOT EVEN IN THE UK. While doing so, you are not only operating illegally but you are not insured either!”
I know this has been debated to death probably elsewhere, but I wonder what the current opinion is. From my point of view, when I fly my N reg in the UK, I do so using my JAR PPL and the attached IMCr. When I fly outside of the UK, I fly on my FAA license and have no instrument privileged whatsoever. That seems to be the general consensus of people I know, and those who have tried to get advice from the CAA have not had any strong direction from them either way.
I think you have this wrong. You fly your N-reg in the UK on your FAA ticket.
It’s the other way round, i.e. that you can fly G-reg on an FAA license. Furthermore the IMCr is not an ICAO rating. That you can fly your G-reg in the UK on an FAA license is based upon the CAA recognizing ICAO licenses.
You can fly an N reg in the UK without an FAA license if you have a valid UK licence…however if you have an FAA Licence I doubt you could claim you are not using it while flying an N-reg….I don’t think the FAA would see it that way….and your FAA license obviously does not have the IMCR….I think this is where said examiner is coming from…..ironically if you did not have an FAA cert in the first place you MAY have an argument…(although said examiner would dispute this as well)
If you fly an N-reg outside the USA, you have two potential ways to be legal as the pilot
Moreover any Ratings you are making use of must be on the Certificate (US-speak for License) on which you are then flying. So e.g. you cannot fly on a UK PPL and a US IR, or a US PPL and a UK/JAA/EASA IR.
Since the IMC Rating cannot be on a US PPL, the IMC Rating question applies entirely to the 2nd case above i.e. a UK issued PPL with the IMCR.
I wrote to the FAA some years ago and got the affirmative reply quoted here.
While certain individuals disagree with that FAA reply, I have never seen such a disagreeing opinion received by anybody from any part of the FAA.
It’s a tricky subject. In a civilised society, with normal rules of justice, the individual who receives such a reply can obviously rely on it.
I am not a lawyer but one UK barrister explained to me that, under UK law, such an opinion from an official body does not modify the law (create an estoppel) which means that others reading it (e.g. here) are not necessarily able to rely on it. But you (the individual who received the opinion directly) can – in so far as that a prosecution against you will fail. But only the one prosecution will fail. After that, you can no longer rely on it. The principle is that if an official body gives you an opinion and it is incorrect in law then you (the member of the public) are entitled to receive a correction.
I have no idea how the law works in the USA (which is what presumably determines the applicability of FAR 61.3) but fairly obviously an opinion from a branch of the US Govt must be valid to some extent. There is a view that only the FAA Chief Counsel matters, and I am sure that’s the ultimate authority, but if no other part of the FAA had any authority on stuff on which there are no Chief Counsel opinions then every FAA FSDO would be completely pointless which is obviously not the case. There are CC rulings on interesting stuff like the applicability of the JAA mutual validation scheme to 61.3 (it isn’t applicable and the word “issued” is interpreted strictly – see my link above) but there are no rulings I know of on the IMC Rating.
if you have an FAA Licence I doubt you could claim you are not using it while flying an N-reg
I think you can do exactly that.
You can fly an N-reg on your European papers, subject to 61.3, if say your FAA BFR or FAA medical have lapsed.
Therefore, if a person who owns and flies an N registered aircraft is trained for the IMC rating and is tested for the IMC rating in his own N registered aircraft and the CAA then issue an IMC rating in the knowledge that the IMC rating training and examination was undertaken on an N registered aircraft, I think that might give sufficient comfort that flying N reg on an IMC is legal as far as the CAA are concerned.
But surely anyone with an EASA licence no longer has an IMC rating because the EASA licence will now say “instrument rating”. Therefore, being in possession of an “instrument rating” (restricted or otherwise), the holder is complying with the FARs when flying under IFR?
[no edits – just testing]
And a UK issued licence probably doesn’t allow you to fly all over Europe in an N-reg.
Therefore, if a person who owns and flies an N registered aircraft is trained for the IMC rating and is tested for the IMC rating in his own N registered aircraft and the CAA then issue an IMC rating in the knowledge that the IMC rating training and examination was undertaken on an N registered aircraft, I think that might give sufficient comfort that flying N reg on an IMC is legal as far as the CAA are concerned.
Thats a good point, but I am not sure if a instructor would give that the necessary thought. I’m not sure as the CAA dont record the reg of the aircraft on their paperwork, it would only be listed in your logbook. I have renewed my IMC in my N reg before, but latterly I have done it in a G reg, as my ADF isnt good enough to be used properly. It seems like it is still debatable, but most thought trails seems to suggest it is OK, so I shall continue. And our insurers know the plane is an N reg, and all of the group owners are given an discount (or at least they are aware) as we all have IMCr, so it would be rough if they wouldnt pay out.
And a UK issued licence probably doesn’t allow you to fly all over Europe in an N-reg.
That is true. Outside of the UK I fly using only my FAA license. But that means potentially that any Enroute IR I was awarded on my EASA license, would have no use for me as a N reg pilot. My options would be to go for the full CB IR, and do the FAA foreign instrument rating exam and apply to have an IR endorsed on my FAA certificate, or just fly VFR. The latter isnt a huge issue for me given how much flying I do outside of the UK anyhow.
But that means potentially that any Enroute IR I was awarded on my EASA license, would have no use for me as a N reg pilot.
That’s a really good point – the EIR won’t be of any use to N-reg pilots, except in the airspace of the country which issued their PPL.
I have renewed my IMC in my N reg before
Loads of people have done. For example when I renew my JAA/EASA IR (£150 every year) I get the UK/JAA PPL and IMCR signed off at the same time.
I just need to get the DfT permission for that flight.
But if n-reg you would just get it added to your 61.75 by doing the IFP exam. Pretty straightforward.
Can you do the FAA Foreign Pilot IR exam if your only instrument qualification is the EIR and perhaps the IMCR?
I don’t think so. It has to be a full ICAO IR. The CB IR would do but not the EIR.
I am not saying you could not hoodwink an FSDO into falling for it, but you could do that equally with the IMCR now that it is called “instrument rating” 
But then nothing in the FARs – AFAIK – defines their use of the term “instrument rating” as an ICAO IR. Or does it? In the absence of such a definition, nothing stops you doing the FP IR exam on the basis of your IMCR!
