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

Hi all,

Sorry to resurrect an old subject. I have read through the last 20 or so pages and I’m not sure I understand if someone with an FAA IR is able to use the full privileges of that IR flying a G-reg aircraft in UK airspace.

I have an FAA CPL IR, an FAA Class 3 Medical and an EASA PPL IR(R)/IMCR which I have been using to fly a G-reg aircraft IFR OCAS in the UK. I didn’t have access to an airways equipped aircraft while it was possible to use the FAA papers (before all this kicked off last year) but now I do. Having sent SRG2140 to the CAA I received a reply stating that, while using the FAA papers, I am restricted to Day VFR Only regardless of the medical held, as stated in ORS no 1228: ORS4… . I let the FAA Class 2 drop to a third class as I only fly privately.

After reading with interest this conversation I find some are being told something different. Is that the case or have I got the wrong end of the stick!? Might it be that as my medical is Class 3 that the restrains in place?

Regards,

Rob

EGMC, United Kingdom

Rob, ORS no 1228: ORS4 seems very clear. I do however think this would restrict you to flying G-reg day VFR within the UK. You would not be able to exercise your FAA privileges on G-reg outside the UK.

Since you do have an EASA PPL and a FAA IR, why don’t you just take the IR skill test IAW the provisions of CB-IR and obtain an EASA IR? This supposes that you do have at least 50 hrs of documented PIC time under IFR.

Last Edited by Aviathor at 16 Jul 19:49
LFPT, LFPN

Might it be that as my medical is Class 3 that the restrains in place?

Yes. ORS4 1228 [ local copy ] is quite explicit:

2.1.2 Medical fitness
(a) The applicant shall either meet the relevant EU medical requirements stipulated in
Commission Regulation (EU) No 1178/2011 for the privileges sought by them or hold
an FAA Class I, II or III medical, to take full advantage of this exemption. However,
applicants with a FAA Class III medical, may operate Day, Visual Flight Rules only
when operating G registered aircraft, or in compliance with the privileges permitted by
the FAA Airman Certificate when operating N- registered aircraft.

There is no restriction to Day VFR if you hold a Class II.

Since you have an EASA license, I assume you have a valid EASA medical. In that case you should be able to use you EASA Class 2 medical, to which you add an audiogram , and then exercise your FAA IR privileges on G-reg, within the UK.

But again an EASA IR would allow you to fly also to the continent.

LFPT, LFPN

I wonder what the reasoning was that limits FAA Class 3 to day VFR in a G-reg. ORS1228 does state that the FAA Class 3 is equivalent to ICAO Class 2.

There was a temporary “business” last year where the FAA Class 3 was no good even for an N-reg based in the UK (loosely speaking). This was madness and fortunately was sorted out by ORS1228 a few weeks later. Much discussion in this thread.

Administrator
Shoreham EGKA, United Kingdom

Thanks for the speedy replies Aviathor, Bookworm and Peter.

I did question the CAA at the time (about a year ago) but they insisted the Class 3 would restrict to Day VFR Only, but they didn’t mention that the EASA Class 2, with an audiogram, would be sufficient to use the FAA as if they were EASA issued like before.

So the trick here is to upgrade the FAA medical to Class 2, get the IFR PIC time up to the required 50 hours and do the EASA CBIR. I have 38 logged so not far to go, but it’ll be a lot more interesting building them using the FAA IR up in Class A rather than down outside CAS. I don’t remember the FAA Class 2 having an audiogram which is odd if they require an EASA Class 2 plus audiogram or FAA Class 2.

Thanks again guys, much appreciated. Peter your trip reports on your website have been excellent inspiration!

Rob

EGMC, United Kingdom

But of course, forgive me if I’m stating something you already know, regardless of what medical you have, AFAIK you cannot use your FAA IR in a G-reg aircraft anyway…although with a valid IR(R) you can at least maintain rolling currency providing you stay out of Class A…

YPJT, United Arab Emirates

Historically you could fly a G-reg on ICAO papers, day or night VFR, worldwide, and even IFR (if you had an ICAO IR) but only IFR OCAS which made that bit almost useless around Europe (it was quite useful in UK Class G).

I did a quick search and found this. Some reading around there…

This is the old “can I fly a G-reg on ICAO papers” debate. That “automatic validation” of ICAO papers disappeared c. 2012, then came back somehow, then disappeared, but remained for “non EASA” aircraft (basically, uncertificated aircraft) and possibly only in UK airspace.

So if you have an FAA PPL/IR you can jump into a G-reg RV and fly it VFR and (if the RV is thus approved) IFR but the IFR is doable only in countries which allow IFR in homebuilts.

But really I don’t know the current status of this whole thing for certified aircraft. I asked an ex CAA licensing specialist and he is not clear about it either. Wasn’t there something with an April 2018 date on it?

Administrator
Shoreham EGKA, United Kingdom

Thanks Peter, there was something in CAP804 I was referred to once years ago that allowed this use of ICAO papers in G-reg in UK airspace as though it was CAA issued (I have “Cap804 part I section 4 part q subpoint 1 Page 589” as a note on this) but as that’s longer current.

So really I need to stay flying on my EASA PPL IRR, build those hours to the required 50 while remaining OCAS then convert to EASA CBIR.

Thanks again,

Rob

EGMC, United Kingdom

Does anyone know what the status/latest political environment is with respect to the derogation until April 2019? Is there an expectation that ability for countries to apply the derogation will be extended again?

Ignoring for a moment that in the UK’s case April 2019 is just after the Brexit deadline but assuming that the UK will stay in EASA, what would that mean for the UK as the CAA stated on their webpage http://www.caa.co.uk/News/New-Guidance-on-Third-Country-Licences/:

Pending final agreement of the terms of the EU-US bi-lateral aviation safety agreement (BASA), currently under negotiation, an exemption from this requirement will apply to pilots holding FAA licences who wish to exercise only private licence privileges within UK Airspace.

I presume that the EASA derogation question for other countries is also linked to agreeing the EU-US BASA. Has there been any news/progress on this, especially in the current EU-US environment?

Selfish question is thus whether I should start worrying about getting my IR on the EASA-FCL licence…

EGTF, EGLK, United Kingdom
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