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N-reg in DTO?

I’ve tried searching, but didn’t really find anything. Anyone know if N-reg in EASA DTO is kosher?

Norway, where a gallon of avgas is ch...
ENEG

Yes, you can do anything in basic training in an N-reg, except the solo. Which is annoying .

I don’t know the regs, but I know someone who created a DTO with an N-reg plane. He does more IR training than PPL.

DTOs can’t do IR training, can they? Asking for a friend…

tmo
EPKP - Kraków, Poland

The ability to do commercial work in foreign reg planes is country specific.

AFAIK there is no EASA regulation on this topic.

Administrator
Shoreham EGKA, United Kingdom

tmo wrote:

DTOs can’t do IR training, can they? Asking for a friend…

No.

ESKC (Uppsala/Sundbro), Sweden

Sorry, the plane is used for making IR hours, then the student goes to an ATO to finish as a CB IR.

NorFlyer wrote:

Anyone know if N-reg in EASA DTO is kosher?

That question ought to be directed to the Norwegian competent authority if the training will take place in Norway because the amendment to the Aircrew Regulation creating Part-DTO has not yet been incorporated into the EEA Agreement. Neither of the Commission (Implementing) Regulations amending article 10a of the Aircrew Regulation nor the Basic EASA Regulation has been incorporated into the EEA Agreement. See EEA-Lex.

The EU position is clearer. Para 1 of article 10a includes non-Annex I third-country aircraft when operated in EU by an operator resident, established, or with a principal place of business there.

Economic regulation as Peter mentions will be dealt with separately. For example a commercial operation in UK involving an aircraft registered outside the EEA, the British Crown dependencies, or the 14 British Overseas Territories, must only be done with a UK CAA-granted permission. Training given to the owner is however a non-commercial operation under UK law although although the law of the state of registry may impose further restrictions.

In the case of a US-registered (and controlled) aircraft the status of the instructed person ought to be clarified. This is because the Part 119 exemptions for “student instruction” and “training flights” have been narrowly interpreted by the Office of the Chief Counsel as meaning training for the purpose of Part 61 and other title 14 parts. See interpretation given 3 Aug 2017 to William W Grannis by Lorelei Peter, Assistant Chief Counsel for Regulations. Compliance with TSA rules will be required if that narrow interpretation holds outside US.

London

Para 1 of article 10a includes non-Annex I third-country aircraft when operated in EU by an operator resident, established, or with a principal place of business there.

That just means the instructor would need EASA FCL papers, in addition to the FAA ones he needs for ICAO compliance. This is probably not a problem. Given the FAA 61.3 concession, training confined to just the one country (of license issue) would sidestep the need for FAA papers.

For example a commercial operation in UK involving an aircraft registered outside the EEA, the British Crown dependencies, or the 14 British Overseas Territories, must only be done with a UK CAA-granted permission.

Looking at the total absence of this activity I am sure you would never get this permission for a “school”. Somebody must have tried it… the advantages of N-reg are significant.

Compliance with TSA rules will be required if that narrow interpretation holds outside US.

That sounds like a can of worms, and IMHO would not hold up to a closer examination by the OCC once they realise it would shut down the entire N-reg community outside the US It would not be possible to do even a BFR…

FWIW, there is a more basic point: one cannot train for an ab initio FAA PPL (if not holding any other licenses) outside the US in an N-reg because the US Student Pilot Certificate is valid within the US only. This was looked at in the past and the conclusion was that you would have to embark on an EASA (or similar) PPL, get the solo sections done under that (on a rented local-reg plane) and then you could complete the FAA PPL (in the same local-reg plane perhaps; the FAA doesn’t care about that). More in various posts – example.

Administrator
Shoreham EGKA, United Kingdom

Article 10a of the Aircrew Regulation covers pilot training organisations. The requirement for a valid Part-FCL licence or certificate is made elsewhere. The details are in the thread: Flight instruction or training in third country aircraft.

Peter wrote:

the US Student Pilot Certificate is valid within the US only.

There is an exception in 14 CFR 61.89(a)(5) for some routes in Canada. It’s unclear whether international flight means flight in the airspace of more than one territory, which is the meaning given to an international air service in article 96 of the Chicago Convention and the meaning adopted in the Tokyo Convention in 1963 (at the insistence of the US representative), or any flight outside the US including those wholly in the airspace of one territory.

A US civil aircraft may be used for flight training in Canada under the NAFTA and the training may include solo flying, under the direction and supervision of a flight instructor, so a US student pilot certificate is clearly not necessary for a student pilot to perform solo flying outside the US. The ICAO Annex 1 standard simply requires, before a student pilot flies solo in an aircraft on an international flight, that an agreement exists between the contracting states concerned. The Canadian student pilot permit must therefore satisfy the requirement made in 14 CFR 61.3(a)(1)(vii): When operating an aircraft within a foreign country, a pilot license issued by that country may be used. The Office of the Chief Counsel might very well deem a student pilot solo authorisation made under Part-FCL as sufficient but to meet the ICAO standard a general agreement would still be necessary.

London

Qalupalik wrote:

The EU position is clearer. Para 1 of article 10a includes non-Annex I third-country aircraft when operated in EU by an operator resident, established, or with a principal place of business there.

Would this also apply for a G-reg plane and its use in an EASA ATO in case of a hard brexit?

Thank you Qualu!

Indiv. CBIR Instruction
LOWG, LEBL
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