Apparently, UK AOPA sent out an email sometime in March 2017 saying
So I wonder what brought about this change of mind by (obviously) the DfT.
There is another angle here:
One CAA doc says FAA Class 2 or EASA Class 2, whereas one of the forms, SRG2140, says ICAO Class 2.
And the FAA Class 3 is equivalent to an ICAO Class 2, if you look at the privileges (non commercial flight).
It has also been confirmed this is a DfT move, not a CAA one.
Germany has derogated to April 2018.
That’s not what it says in that text. Quite to the contrary actually. It says that they intend to derogate, but can only do it once the European Commission has published an according regulatory change.
So, what will happen in the UK when EASA does publish it? One EASA insider has posted on a UK site that this remains the intention – if I understood him right. The UK is still in the EU so won’t an EASA derogation make this UK DfT move irrelevant?
Peter wrote:
The UK is still in the EU so won’t an EASA derogation make this UK DfT move irrelevant?
I still don’t see how it can be relevant regardless until the UK leaves EASA if that ever happens.
It is in the same category as say Germany passing a reg requiring an ADF for all flight above 2000ft. What is the EU going to do about it? It’s not going to implement a military takeover of Germany (the only way to force an international dispute). Or ban export of BMW cars. In practice, it isn’t going to do anything. Politics is the art of the possible.
Without a derogation published in the EU, all N-reg pilots without EASA papers are grounded. Everybody has always known this, but we have had constant derogations since 2012, and each of them was published only at the 11th hour, so everybody got used to it. And the April 2019 derogation was known to be in the EU lawmaking pipeline….
This UK measure appears to offer the pilots an intermediate way around the lack of an EU derogation, although it does have aggressive, bizzare and poorly written requirements.
OTOH doesn’t each country have to opt into the EU derogation? The UK always has done so, but if it chooses to not do so now, what then? Under EU law, the UK doesn’t have the right to offer any other route. It comes back to my 1st para above.
I bet the other EU countries are watching this situation.
Peter wrote:
OTOH doesn’t each country have to opt into the EU derogation?
That’s how it is phrased in 1178/2011 chapter 12(4) as well as the other items where derivations were offered.
Is it a stupid question to ask whether 61.75 holders need to fill in SRG2140?
Timothy wrote:
Is it a stupid question to ask whether 61.75 holders need to fill in SRG2140?
If the 61.75 and the Easa Licence have equivalent ratings, then (apparently) it is not needed….
If the FAA certificate has had further ratings added which are not reflected in the underlying EASA licence, and you wish to exercise those extended privileges in an N-Reg, in UK airspace, then (apparently) it is needed…
This Transport Canada page ( local copy ) shows that as far as they are concerned the FAA Class 3 is equivalent to the EASA Class 2
Timothy wrote:
Is it a stupid question to ask whether 61.75 holders need to fill in SRG2140?
Timothy, I have a CAA PPL with the UK IMC rating, plus a 61.75 with an FAA IR added to it. I presumed that I must get submit the SRG2140 form on the same basis as Peter’s comment above. For 61.75 holders I think the only point requiring any effort on your part is the EASA examiner’s signature. If you look at that section of the SRG2140 which requires an EASA examiner’s signature, it has some text which says that the EASA examiner is certifying you have a knowledge of air law etc appropriate to the ratings you intend to exercise. I was able to get an EASA examiner to sign this declaration for me on Saturday, and have now sent the form off to the CAA. The examiner in question runs the flying school where I did my PPL, so on the basis that I passed all the requisite CAA exams with him only a couple of years ago, he was happy to sign the form for me. However, beforehand it occurred to me he could have an issue regarding the wording “appropriate to the ratings being exercised”. I intend to exercise my full FAA IFR privileges which go beyond the UK IMC rating, and it could perhaps be argued that the theoretical knowledge required is more extensive. Some individuals might well have said “how should I know if your theoretical knowledge is appropriate or not to your IR rating” but as it was, the gentleman I approached was quite accommodating. I know there isn’t much time to get this form submitted, but if you are in the same boat with an IR rating to protect, my advice would be to approach someone who you know fairly well for the examiner’s signature.
