That is not how EASA FCL is worded, but we pretty well exhausted that one on the FCL thread. No enforcement to date and no insurer interpretation… Nobody knows what the situation is.
EASA FCL has been changed or interpreted by some authorities to make it fit for their own purpose and written and adopted accordingly by them to become more limiting than the original EASA text. The lack of insurer interpretation is because nobody has explained it to them. They still think that a registry validation is all that’s required and takes precedence over national requirements. Who can blame them ? Registry validations are not well defined for the best of people so what chance have the insurers got ?
EASA FCL has been changed or interpreted by some authorities to make it fit for their own purpose and written and adopted accordingly by them to become more limiting than the original EASA text.
Alioth, FAA 61.75 does allow you to fly N registered plane in Europe, and also registries have and continue to accept 61.75 FAA issued plastic card certificates. You are correct though that the existing licence it is based on also needs to be valid, Australian or whatever. 61.75 issued is still actually a certificate or licence in its own right, not classified as a validation.
Dictionary meaning of validation – the action of making or declaring something legally acceptable.
I don’t understand what you are so outraged about. The IoM Validation says that you can fly the particular IoM registered frame, i.e. your licence to fly it is rendered valid by the Isle of Man in accordance with Isle of Man Law. Not European Law, or Spanish Law, or US Law. You are still (and always will be) obliged to keep the underlying licence and ratings up to date. Just like the FAA 61.75 licence discussed above requires you to keep the underlying licence up to date.
You are moaning away about regulations put in place by other authorities, primarily EASA. Everywhere else in the world except EASA land you need your underlying licence and the Validation; that’s all.
Have you had a specific problem???
Why would you only need your underlying licence for example Australian and the validation outside of Europe ? Does the requirement to comply with national regulations not exist there ? I genuinely don’t know so you must know something more about it. No outrage here or moaning but just looking at the situation as it seems to be. Again for about the 8th time 61.75 isn’t the same thing as we are discussing. Different points of view are good for healthy discussion, last I heard we live in a democracy.
I was asked to get a Geurnsey A&P Licence based on my FAA A&P licence which was just a couple of forms and a small fee.
That said, I was surprised when about 6 months after having performed an Annual Inspection I received a call from a Dutch national that was “renewing the C of A”.
It turns out that only a “state appointed” Inspector can renew the C of A, for a fee,
Presumably the Guernsey registry will have a list of CofA inspectors who they have authorised.
You still need an FAA A&P/IA to sign any 337. Does Guernsey need their CofA inspector to sign off any mods too? In fact what is the 2-reg position on acceptance of FAA approved mods after the plane has gone onto the 2-reg?
Yes indeed the key Q is whether an FAA A&P can continue to maintain a 2-reg, and do so fully using Part 91 rules, with the only “non US” bit being the Guernsey inspection for the ARC issue.
Form the conversations I have had with an owner operating on the 2-register, I understand that the inspector from the 2-reg needs to inspect it every year so the 2-reg can re-issue the C of A every year.
It used to be that IOM would not accept any light aircraft unless owned by a resident of the IOM and I thought that was still true of the Guernsey register. If a UK citizen can put a PA-28 on the 2-register direct from the N without an export C of A, what is stopping the 2-register from being huge? I am intrigued.
Again for about the 8th time 61.75 isn’t the same thing as we are discussing
I disagree. There’s nothing materially different about it. 61.75 is just a validation. Sure, they send you a plastic card, but it’s not a standalone FAA license and depends on the validity of the underlying one and the moment the underlying one is not valid, for whatever reason, the 61.75 is no longer valid. The only material difference with 61.75 and what the IOM CAA are doing is the FAA doesn’t require periodic renewals (and IIRC, you need to also do an FAA BFR, but I could be wrong on that count – personally I have a standalone FAA one).
There’s some more differences such as a registry validation is specific to aircraft registration and also company, 61.75 doesn’t have that. 14 CFR 61.75 states that it is a certificate issued on the basis of a foreign licence, so not a validation. Yes the original licence has to remain valid too but that’s as similar as it gets. I see your point, but don’t necessarily agree that the two can be compared.
@Hurricane, i am struggling to understand your agenda in this thread. What exactly is your issue? Validations are not the same as a 61.75 even though in practice they have the same result. But what is your point? You seem to be unhappy with something but I can’t, for the life of me, work out what it is.
No agenda Jason, just discussion. There’s many points of view in this thread, Alios has a view that a validation means that the registry saw an ICAO licence applicable to an aircraft, Neil says that everywhere else in the world bar Europe you need your underlying licence and validation, that’s all. I still don’t know why the requirement to comply with the national regulations outside Europe would possibly be dropped in this case, unless I misunderstood the post.
Originally we were discussing why some registries are continuing to issue validations for European based pilots and aircraft, without having an EASA licence. One can put the onus on the pilot but then again the registry does know where the aircraft and pilot are based. For many of you on this forum you will have either started or completed your studies for an EASA licence or at the very least an EASA IR. If it is the case that some pilots are still being allowed to fly in Europe without an EASA licence, then one might feel slightly deflated by the expense taken to obtain EASA qualifications.
I’ll leave everyone to chew that over.