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Anti N-reg provisions - EASA FCL and post-brexit UK FCL

Not that I really need the FAA medical.

You do need an FAA medical to fly an N-reg, anywhere. But as far as the FAA is concerned, the Class 3 is 100% valid regardless of what any other country says.

Administrator
Shoreham EGKA, United Kingdom

http://www.easa.europa.eu/system/files/dfu/Derogation%20TABLE_23.07.15%20version%2030.xlsx

A new derogations table is online. This seems to be updated to April 8th, 17

LSZH

Hmmm, so the UK has gone for it… so what is this DfT/CAA measure about?

Maybe somebody should point Croatia, Cyprus and Italy to this thread

Administrator
Shoreham EGKA, United Kingdom

To my mind it has the hallmarks of the Foreign Aircraft Operating Permit (eg for revalidation flights) for which they charge. Did they intend to do so but then realised that the Amiercans don’t charge for piggybacks etc? By which time all the paerwork was in place, so why not roll out anyway….?

To my mind, this U.K. DfT edict is objectionable on the following grounds (in no particular order):

It has been introduced without stakeholder consultation;
It has been introduced with insufficient warning for stakeholders to comply;
It misclassifies the FAA Class 3 medical as somehow inferior to EASA Class 2 (the FAA Class 3 vision requirements are arguably stricter);
It prejudges a Brexit issue;
It discriminates against Commonwealth and other non-US citizens;
In the absence of evidence that holders of FAA and Commonwealth ICAO certificates are a present danger to third parties in U.K. airspace, it infringes the spirit of the CAA’s GA red-tape challenge;

Can anyone refine or add to that list?

If Members of Parliament receive reasoned objections, there is every chance that DfT may think again.

Glenswinton, SW Scotland, United Kingdom

Isn’t it the case that the problem is not actually what the CAA have done, but really lies with the original EU regulation 1178/2011. Everyone seems to have expected the 8th April deadline to be extended to 2019, that hasn’t happened for some reason.The stuff from the CAA this week, whilst being very disorganized is at least a favourable exemption from the EU ruling for UK airspace. Arguably the CAA could have gone further with regard to medicals or in requiring the examiner theory-knowledge sign-off, but at least it is something to work with. I must admit it’s all a bit uncomfortable when you start from an anti-brexit viewpoint like mine.

I also posted a comment on here yesterday evening, wondering whether a UK based pilot with an FAA licence can fly outside the UK in another EASA member state. I was trying to interpret Aviathor’s comments. Having thought and read further, I think the answer to my own question is probably NO. In my own case I can probably fly VFR in France, because I have a CAA PPL satisfying the Part-FCL requirements as well as the FAA 61.75 satisfying the FAA requirements. But I suspect I could not fly IFR in France, since my EASA licence only has IMC privileges which are not recognised outside the UK. And the SRG2140 self-declaration form only relates to UK airspace. I suppose I could pursue the more onerous licence validation route using CAA form SRG2139 at some stage but that requires 100 instrument hours and I’m only up to 75!

Liverpool, Barton

Peter wrote:

You do need an FAA medical to fly an N-reg, anywhere.

Wrong. Not on a 61.75.

LFPT, LFPN

placido wrote:

A new derogations table is online. This seems to be updated to April 8th, 17

I do not think that table is new. It lists the countries that applied the last derogation that was voted a year ago and expires 8th April 2017

I believe a copy of this very table was posted earlier in this thread.

Last Edited by Aviathor at 09 Apr 12:09
LFPT, LFPN

Isn’t it the case that the problem is not actually what the CAA have done, but really lies with the original EU regulation 1178/2011. Everyone seems to have expected the 8th April deadline to be extended to 2019, that hasn’t happened for some reason.

It hasn’t happened yet. But in the past, through all the derogations going all the way back to the April 2012 date delayed to April 2014, they never did publish anything till the last moment anyway – presumably to maximise the FUD factor.

I also posted a comment on here yesterday evening, wondering whether a UK based pilot with an FAA licence can fly outside the UK in another EASA member state.

In the countries which have gone for the 2019 derogation, AIUI, the list posted by Placido above and my table extracted from it, you can. In say Italy you cannot unless you have the full EASA papers. But this has been the case potentially ever since April 2012, because there were always some countries which didn’t derogate (why I have no idea; IMHO most likely because they have nobody who can read the EASA regs). I say “potentially” since there are two points of view:

  • a pilot based in a country which did derogate can fly all over the EU (this view is also from one person deeply involved in EASA)
  • a pilot without the EASA papers cannot even overfly a country which didn’t derogate

The 1st option is not too bad because the countries where most GA is based have derogated. Well, Italy never did but, hey… Italy is the country of creative solutions

Obviously the 2nd option is much more draconian. You would have a complicated matrix of countries to avoid when developing the Eurocontrol route. It would have killed most international GA including most privately owned (non AOC) bizjet ops!

I do not think that table is new. It lists the countries that apply the last derogation that was voted a year ago and expires 8th April 2017

Oh well, that interesting scenario is gone then… it has the UK on it which would have over-ruled this mad DfT/CAA move (the UK is in the EU for a couple more years).

But my comment above about flying abroad applies to the extent that you can fly to the countries which have (or will) derogate – and on the FAA Class 3 which is 100% ICAO compliant (despite a dubious move by the Irish CAA c. 2012). Unless somebody else implements the same stuff as the UK seems to be doing…

What this means, for example, is that you could get yourself the NPPL (takes about 8 weeks) which you do on the back of an EASA PPL or the FAA PPL training, and do the medical declaration, and fly VFR to the UK border (Z flight plan) and then change to IFR and fly as normal. And same on the way back (Y flight plan). The NPPL is valid for an N-reg but only in UK airspace (it is AFAIK valid for a G-reg in France too). IMHO everybody should apply for the NPPL anyway – one day it might be the best £150 you ever spent!

EDIT: got this from a German pilot

Germany has derogated to April 2018.

Administrator
Shoreham EGKA, United Kingdom

Last time I looked up this excel on the EASA page the date was from a year ago at least so it must be new.

LSZH
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