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Flight instruction or training in third country aircraft

I’d be very interested in an actual case of eg a non EASA registered MEP is used in an EASA ATO.
The above EASA Guidance Material doesn’t restrict it, but can a national authority veto it?

always learning
LO__, Austria

In the UK, you certainly can. I did my FAA IR to JAA IR conversion in my N-reg. Also the traditional permission is no longer needed.

How it works elsewhere I don’t know, but we have many N-reg owners here.

The local CAA can veto it because each country “owns” its airspace totally. If there is anything smelling like a “commercial” operation, all hell breaks loose, starting with AOC holders complaining to their CAA.

You can see virtually no schools/FTOs operating 3rd country aircraft, for this reason, and freelance training involving multiple clients needs to keep a low profile.

How exactly do the CAAs block schools operating N-reg fleets I don’t know but the most obvious is the under the table one of simply not renewing their training license

Then there is the debate whether the FI needs to be PIC. With most N-reg flight training/revalidation, he doesn’t have to be PIC, but if say he was doing an IR renewal and the candidate’s papers have expired, or just the IR has and the flight will be in actual IMC or filed as IFR, then he does have to be PIC. FAR 61.3 enables locally issued papers to cover the FI but only in the airspace of the issuing country.

I also recall EASA requiring an EASA CPL for any paid instruction in Euro-land, regardless of aircraft reg or license/rating being trained. No reference, and it may have been a UK CAA (ANO) rule. It was used to bust an FAA training operation running out of Norwich, in 2005. Methods used to sidestep this were (a) charging for the ground school only (b) flying out of UK airspace (the candidate needs a valid PPL for that, to cover the UK part of the flight) (c) not telling anybody.

Administrator
Shoreham EGKA, United Kingdom

I don’t know anyone operating a non-EASA reg plane for training in Germany, so I can’t comment on that.
However, receiving renumeration for training given by a PPL-FI/CRI is explicitly mentioned as one of the privileges of a PPL in FCL.205.A

FCL.205.A PPL(A) — Privileges

(a) The privileges of the holder of a PPL(A) are to act without remuneration as PIC or co-pilot on aeroplanes or TMGs engaged in non-commercial operations.

(b) Notwithstanding the paragraph above, the holder of a PPL(A) with instructor or examiner privileges may receive remuneration for:

(1) the provision of flight instruction for the LAPL(A) or PPL(A);

(2) the conduct of skill tests and proficiency checks for these licences;

(3) the ratings and certificates attached to these licences.

Last Edited by CharlieRomeo at 27 Oct 11:29
EDXN, ETMN, Germany

If training towards EASA papers, and the client is paying, it seems clear that you need EASA CPL theory. If done standalone, it is 13 exams and you can just let them expire.

If training towards non EASA papers, e.g. FAA, I reckon this varies per country, and some may even have no regs on the topic.

All the above is irrespective of the aircraft reg.

Administrator
Shoreham EGKA, United Kingdom

My question is only about training for EASA SEP/MEP ratings (not licenses) and in a non EASA registered (not necessarily N-reg) aircraft.

always learning
LO__, Austria

@Snoopy

AMC2 ORA.ATO.135 Training aircraft and FSTDs.

London, United Kingdom

Snoopy wrote:

According to the above, it seems it is up to the national aviation authority?

Indeed it seems up to ATO & NAA, after all that is what matters? if ATO don’t fly non-EASA reg, you better have your own ATO?

I think it’s better list examples of ATO that do PPL/SEP/MEP/CBIR in non-EASA regs than talking about the rules, which as far as I am concerned Qalupalik has covered in all details and facets?

I know one ATO in UK that does EASA IFR training in N-reg SR22 Cirrus (I am not sure if they do 10h CBIR ATO tough?) and one ATO in France where you can do EASA Aerobatics rating in N-reg T28 Trojan (obviously non-ATO hours so probably non-relevant)

For EASA PPL/SEP in non-EASA regs, I doubt you can do any, but I know someone who did his PPL & SEP & MEP in his privately owned vintages (G-reg Harvard and N-reg Beech 18 Twin Expeditor), I am not sure what were the arrangements but like everything it’s always possible when you throw lot of money on it or maybe ATO/NAA are likely to approve as those aircraft were “privately owned & special” (well the client as well ) but highly unlikely ATO/NAA will accept for someone who is tight on budget on a regular GA type, say doing ATO training in N-reg Mooney or C172 (don’t ask me how I know )

Last Edited by Ibra at 27 Oct 19:18
Paris/Essex, France/UK, United Kingdom

@Snoopy

Thanks, I quoted it on the previous page

AMC 2.

London, United Kingdom

Humblest thanks @qalupalik

AMC2
ORA.ATO.135 Training aircraft and FSTDs
EVALUATION PROCESS
Two cases for the evaluation process of Annex-I aircraft are distinguished:
(a) Annex-I aircraft that hold an ICAO-level certificate of airworthiness (CoA)
(1) To support the evaluation process performed by the competent authority and provide
the competent authority with sufficient data related to the aircraft in question, an
instructor who is qualified in accordance with Annex I (Part-FCL) to Regulation (EU)
No 1187/2011 and nominated by the head of training (HT) of the ATO should assess that
the aircraft is appropriately equipped and suitable for the training courses provided. The
result of this assessment should be submitted to the competent authority and may be
included already in the application for the authorisation.
(2) During the evaluation process, the competent authority should consider aircraft that hold
a CoA issued in accordance with Annex 8 to the Chicago Convention to provide a level of
safety comparable to that required by Annex II to the Basic Regulation, unless the
competent authority determines that the airworthiness requirements used for
certification of the aircraft, or the service experience, or the safety system of the State of
design, do not provide for a comparable level of safety.
(b) Annex-I aircraft that do not hold an ICAO-level CoA
(1) Initial assessment by the competent authority and criteria taken into consideration
The competent authority should take into account the following criteria (non-exhaustive
list):
(i) national airworthiness requirements based on which the aircraft CoA was issued;
(ii) aircraft similarities to a certified variant;
(iii) aircraft with a satisfactory in-service experience as training aircraft;
(iv) simple and conventional aircraft design;
(2) Additional assessment by a qualified instructor
Before the inclusion of these aircraft in the fleet of an ATO and their use in training to obtain
Part-FCL licences and ratings, the ATO should apply for the authorisation to the competent
authority that should perform the evaluation process in the following order:
(v) aircraft that does not have hazardous design features or details, judging by
experience; and
(vi) operable aircraft systems, equipment, and appliances that do not require
exceptional skills or strength.
Page 3 of 5

(i) the aircraft should be safely controllable and manoeuvrable under all anticipated
any probable operating conditions;
Annex III to ED Decision 2020/005/R
To support the evaluation process performed by the competent authority and provide
the competent authority with sufficient data related to the aircraft in question, after the
positive initial assessment by the competent authority as per point (1), an instructor who
is qualified in accordance with Part-FCL and nominated by the HT of the ATO should show
through an evaluation report that the aircraft is appropriately equipped and suitable for
the training courses provided. That evaluation report should consider all of the following
criteria:
operating conditions, including after failure of one or more propulsion systems;
(ii) the aircraft should allow for a smooth transition from one flight phase to another
without requiring exceptional piloting skills, alertness, strength, or workload under
(iii) the aircraft should have sufficient stability to ensure that the demands made on
the pilot are not excessive, considering the phase and duration of flight; and
(iv) the assessment should take into account control forces, flight deck environment,
pilot workload, and other human factors (HF) considerations, depending on the
phase and duration of flight.
Subject to a positive evaluation report as per point (2), the competent authority should
issue the authorisation

Last Edited by Snoopy at 27 Oct 21:54
always learning
LO__, Austria
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