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

SRG2140 is not the form it says to use in the IN. It is 2139.

It seems utterly bizarre they are putting N-reg owners through this rigmarole, especially with less than 48 hours notice — when for nationally-regulated Annex II aircraft any ICAO license will do with no need to pay fees, see an examiner, sit oral exams, or anything else. I really don’t understand why they didn’t just extend the current arrangement to 2019, especially as Brexit may make the whole thing irrelevant anyway.

Peter wrote:

In somewhat of a surprise (and very late!) move, the Department for Transport has chosen NOT to extend the Article 12(4) opt-out to 8th April 2019 (which was what was expected).

This for me confirms that EU residents are the ones concerned. The derogation is not applied and residents of the Union that have 3rd country licenses can no longer use their privileges unless they also have the appropriate EASA qualifications. As far as FAA certificate holders are concerned I suppose they are applying the terms of the current draft if the IP. Maybe it means that the BASA is closer than we think.

I received a link to this form SRG2140 in an email from my trustee (SAC). However in a further email they referred me to the forms directory on the CAA website which reveals the following link which actually now works. It appears the CAA are moving things around on the website as we speak.

http://publicapps.caa.co.uk/docs/33/SRG2140Issue1.pdf

Aviathor wrote:

The derogation is not applied and residents of the Union that have 3rd country licenses can no longer use their privileges unless they also have the appropriate EASA qualifications

Just like driving licences. I Haven’t fully grasped what’s the big fuss about it.

I got just the same email from SAC. It followed a question from me to them asking which of these three different forms is appropriate, (2139/2140/2141). I think what they mean is that FAA licenced pilots should not submit SRG2141 or SRG2139, but that the SRG2140 in in fact the appropriate one.

In my case it’s a FAA IR on a 61.75 private pilot certificate, which in turn is based on a CAA PPL. I am making the assumption that my IR privileges are caught by this new declaration requirement in just the same way as anyone who has a natively FAA private certificate, but I’d welcome anyone else’s views on that aspect.

The concerning thing to me is the elapsed time it will take for the CAA to process this form. Especially since it may involve them validating my licence with the FAA.
Having been through the rigmarole in the other direction, i.e. getting the CAA to validate my PPL to the FAA in order to begin FAA training, and then waiting for the FAA to finally issue the IR certificate when I’d finally passed the flight test, I know that both organisations are very slow. I could envisage it taking 2 or 3 months for any conclusion once this SRG2140 declaration is submitted.

Then there’s the question of who can endorse the theoretical knowledge. I have asked an EASA examiner who does PPL and UK IMC, but I am half-expecting him to say that since the privileges of the FAA IR go somewhat further, he is unable to do so. I’d be interested to hear what anyone else finds on the willingness of other EASA examiners to sign that part of the declaration.

Then there’s the question of what’s the status of FAA licences in the meantime. No use? Am I really expected to stop filing IFR and simply fly VFR until all this works through.

And finally there’s the question of other European countries and what they do, and whether or not one is expected to go through the same process with each country one flies into.

I wonder if it’s a case of the CAA being overly keen to apply the EASA position, or perhaps just giving a heads of what to expect when and if the BASA agreement is finally in place.