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

OK… here we go.

All the CAA links in the foregoing posts concerning those CAA documents have gone dead. The forms have been revised and were found elsewhere. I am not going to bother posting the URLs as they will go dead before this ink is dry, so here are local copies

SRG2139 Issue 2
SRG2140 Issue 2

I don’t think SRG2139 is applicable to “us”.

Both have been revised in July 2017. The FAA Class 3 is now acceptable as per this which also details the delay until April 2019.

SRG2142 Issue 2

It’s been suggested that SRG2142 is not applicable to “us”.

Administrator
Shoreham EGKA, United Kingdom

Update, in case anyone is interested:

I sent in SRG2140 with school-certified copies of all the stuff – license, medical, logbook pages showing a valid BFR and valid IR.

They replied after a week or two, saying the application doesn’t meet their standards and they also want SRG2142 and £45, as well as certified copies of the other stuff. So I phoned them up saying I had already sent them the certified copies of the docs and indeed I am looking at the scans of what I sent them (obviously I scanned it, before sending it in Special Delivery!). A lady went to get my file and admitted they had the certified copies and that the email is just a standard email they send to everyone. So they just want the SRG2142 and the £45.

SRG2142 has some odd stuff in it which doesn’t apply (application for a license validation). You can put N/A through that. All they want is the bit to send to the FAA to get the FAA to confirm I am real, and the £45.

I explained that they can get this by going to faa.gov, and in conjunction with a certified copy of the logbook showing the BFR and (for IR holders) the IR currency this will confirm the license is valid. She said she will pass this information back.

Speaking to others who have done this submission when this requirement first hit the UK pilot scene and heard nothing, this looks like a change of tactic, either to get the £45 or for some other reason.

Administrator
Shoreham EGKA, United Kingdom

Why did you have to pay?

EGTK Oxford

Because SRG2142 asks for £45. Verified with a phone call. As to the wider question of “why SRG2142”, I have no idea.

Administrator
Shoreham EGKA, United Kingdom

I’m currently ignoring this completely – is anyone else following this strategy?

Wondering if I’m part of the flock or a lone sheep (wolf?). :-)

In a statement by the CAA posted on another forum, it explicitly says that the UK requirement for US certificate validation concerns pilots flying in the UK airspace. This tells me that the CAA interprets the Article 12(4) opt-out as an airspace requirement as opposed to a license requirement.

That would mean that EU residents with US certificates cannot fly into the airspace of countries that have not opted out without meeting the requirements of Article 12(4) i.e. having the required EASA paperwork.

Conversely, no US certified pilot being residents of the EU cannot fly in UK airspace without having validated meeting the UK license validation requirement?

Hypothetically, do I as a resident of France (which has opted out), having a US PPL/IR, need to do anything prior to flying in UK airspace on N-reg?

LFPT, LFPN

Sam – two or more lone wolves make a pack :)

p.s. Met the Vintage Flyers in Lokichoggio last November and wish I’d said hello. That was a good party!

NeilC
EGPT, LMML

I’m currently ignoring this completely

It is an interesting Q whether the requirement for the SRG2140/2142 stuff is within the CAA’s powers to create legislation under its delegated powers. If so, not complying voids your insurance.

One CAA insider I know reckons this whole thing is outside the CAA’s delegated powers (it requires a change to the ANO) but who wants to test it after an insurance claim? IOW, it’s the same old story…

In any case, the SRG2142 (the CAA getting the FAA validation of your FAA papers) thing is interesting in terms of what triggers it after you send them the 2140. It could be that people who sent in the SRG2140 before a certain date got processed, and everyone afterwards has to do the 2142 and pay £45. Or it could be some other thing that triggers the 2142 requirement. But frankly who is going to be flying on photoshopped FAA papers and have the balls to send certified copies of them with the 2140? I would be amazed if the FAA validation would ever turn up anything new. So this could be a random “let’s harrass some % of UK based N-reg pilots” kind of thing.

Administrator
Shoreham EGKA, United Kingdom

I to have today received an email from the CAA saying, ‘Please fill in SRG2142 and send £45 so we can verify your licence’. I suspect this might be for those of us late to the party.

EGTF

Has anyone heard anything back after sending in SRG2142?

It is fairly obvious that when the FAA gets hundreds or thousands of these, they are going to fall over backwards laughing and probably won’t respond to the requests, especially as all the info can be obtained from faa.gov in conjunction with a certified copy of the logbook pages showing the BFR and (if applicable) the IR rolling currency.

Administrator
Shoreham EGKA, United Kingdom
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