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Need for Complex Endorsement N-reg

NOPE.

Im staying with my license for the moment.
I will probably do the ATP later this year, so I can do the full paper exercise then.

To be honest I don’t really feel/think that the new certificate nr makes my FAA license invalid. Its only a different start. Number remains the same. That nr is me.
Yes if you read the small text. In court of law. Naahh, don’t think so.

spirit49
LOIH

@spirit49 I was in Bodø last Friday to do the certificate number change for the FAA and was told that one other Norwegian license holder had done the same in December (?). Would that happen to be you?

Last Edited by Aviathor at 23 Feb 19:28
LFPT, LFPN

once Part-FCL operator provision derogations expire, to fly an N reg in Europe if your operator is based here will require you to have both licences valid and current.

That’s right – that’s why I said “EASA FCL”. The current start is April 2016, which for practical purposes (moving the plane to N-reg etc) is right now.

BTW that writeup I did in 2005 on moving G-reg to N-reg is still largely accurate. I ended up bent over a barrel when I did that, due to a number of strategic mistakes, the biggest of which was getting the company where I was hangared to do the move. That company has now gone; I could not write this bit before now. NEVER get the company where you are hangared to do anything that could be “complicated” unless you have other hangarage options. They just left the plane sitting there for about 8 weeks. “Their” IA (actually a guy who was working for another company and was moonlighting for this one) walked away from it because there were some issues he did not want to get into (e.g. it needed an ELT installed) and he didn’t want his “second job” exposed. It was only when I brought in “my” IA (who worked closely with a DAR) that it got done. In 3 days!

then the FAA should really regard all states in EASA-land as a unit since the national CAAs are de facto issuing licenses on behalf of EASA. But I guess they don’t bother.

I am sure it’s not a case of not bothering.

Firstly the USA is entitled to regard a sovereign country as a sovereign country. That is how the world has run for centuries. Well, disregarding the odd war or two, and let’s face it, Europe hardly holds the moral high ground when it comes to killing millions of people to shift national borders Just because some countries over this side of the water have done a treaty between themselves for mutual license recognition / validation is not necessarily of concern to the USA and is no reason why they should rewrite their laws to account for each such treaty.

That’s just my opinion of course but I do think that is how the USA really sees it. They draft their regs in the knowledge that most of the world’s aviation (inside and outside the USA) de facto runs directly or indirectly on FAA pilot qualifications (and validations thereof) and FAA airframe and component certification and they – in the words of one FAA lawyer whose presentation I went to a few years ago – are very careful to avoid unexpected side effects of regulatory changes. They draft their regs to last decades, and change them only when there is a real pressing reason – unlike Europe where every new wagon-load of self proclaimed world class intellectuals / gravy train riders has to make its mark as it passes through Brussels – with another 10,000 pages of new laws which virtually nobody can read, let alone understand, and which are often so badly drafted that any UK lawyer halfway through his training wonders which of the ~1000 Cologne pole dancing bars they were drafted in. Take the (to us pilots) the most notorious piece of totally in-your-face politically motivated and ambiguous piece of FUD – the EASA FCL attack on N-reg pilots as one fine example. The Americans just fall over laughing when they see this crap.

And Europe is just a tiny little piece of the earth’s political map, after all.

The fact that every country in Europe has a large % of its population (probably more than 50% in many cases, if people got a free vote, which they will never get precisely for that reason) in favour of leaving the EU, just plays into the hands of the US lawmakers who are well aware of what goes on in Europe and who are even less keen to consider the EU countries as some kind of a special case.

The FAA has no more reason to redraft 61.3 to take into account EASA than it has a reason to redraft 61.3 to take into account a deal between Botswana and the Belgian Congo to recognise each other’s PPLs.

Another factor is that, historically, most relevant countries in the world have done bilateral treaties with the USA. As far as the USA is concerned, these stand no matter what war or whatever takes place in (say) Europe. So if Europeans decide to give up their sovereignity to Brussels (which they have done to a large degree) and Brussels then rules that these existing treaties are void, that is like me owing you 5 quid and you owe 5 quid to Fred so “therefore” I owe 5 quid to Fred. In time this will sort itself out (there is an FAA-EASA treaty now, quite limited but it’s a start) but a big reason for that shift in US policy is due to EASA trying to sell its Part M regime to every gold plating bureaucrat around the globe, and a proper gold plater with no life will always prefer Part M to the FAA version. And we pilots know just how the 3rd World loves paperwork! This has resulted in a reduction in US influence in foreign lands so they decided to work more with the EU.

Administrator
Shoreham EGKA, United Kingdom

Outside of the single country exemption allowed by the FAA if flying in the issuing state of your licence where you would not need an FAA licence at all.

If that is the case, then the FAA should really regard all states in EASA-land as a unit since the national CAAs are de facto issuing licenses on behalf of EASA. But I guess they don’t bother.

ESKC (Uppsala/Sundbro), Sweden

It is only those European pilots who are flying an N-reg on the “based on” 61.75 PPL who don’t have to maintain their EASA papers current. Those flying an N-reg on a full FAA PPL or PPL/IR need to maintain both their FAA and EASA papers current.

Peter, I don’t see any difference between your two cases here. The European operator provisions when they take effect apply to both sets of FAA certificate holders. Could you please explain how they apply differently?

I am not sure my statement was wrong (although you correctly identify it as being shorter than yours!) :)

Achim is of course right that once Part-FCL operator provision derogations expire, to fly an N reg in Europe if your operator is based here will require you to have both licences valid and current. Outside of the single country exemption allowed by the FAA if flying in the issuing state of your licence where you would not need an FAA licence at all.

Last Edited by JasonC at 03 Dec 07:10
EGTK Oxford

There are two contexts here.

One is the one picked up by NCYankee in his detailed post above which refers to the 61.75 “based on” PPL and possibly the Foreign Pilot Exam IR. This I agree with and IIRC there have been FAA Chief Counsel rulings confirming the position – even though many would find this surprising.

The other is the one posted by Achim

N-reg in Europe requires me to maintain my EASA FCL license current so the FAA currency requirements come on top of the EASA requirements

where he doesn’t say he will be getting the “based on” PPL.

It is only those European pilots who are flying an N-reg on the “based on” 61.75 PPL who don’t have to maintain their EASA papers current. Those flying an N-reg on a full FAA PPL or PPL/IR need to maintain both their FAA and EASA papers current. They still need to do their 2-yearly EASA PPL revalidation flight and if they have an EASA IR they still need to revalidate that every year. This is simply EASA FCL which, on an “as written” interpretation, requires every pilot whose operator is EU based to have valid and current EASA papers regardless of aircraft reg.

This illustrates the peril of posting a context-devoid one-liner in a thread which is of potential legal interest to the casual EuroGA visitor and which I therefore don’t just want to leave as-is in case it misleads The other option would be to simply delete the one-line post…

The other problem is that your EASA IR will be lost totally after 7 years if you never revalidate it… and there are similar gotchas for an EASA PPL. So in practice you do have to keep those papers revalidated to some degree even if you are flying an N-reg on a 61.75.

Administrator
Shoreham EGKA, United Kingdom

I agree with Jason. Anytime the FAA doesn’t restrict something it can be interpreted as being permitted. You are required to have the EASA license in your possession and it has to be valid, that is it is not expired or revoked and must match the ratings required for the category and class of aircraft. The FAA has issued an opinion that limitations not written on the foreign license are not binding on the US license. The opinion was explaining that differences training that is required for the UK license did not apply to the FAA license as it is not written on the UK license. Currency would fall into a similar category as it does not determine if the UK license is valid or not, just whether or not a pilot may exercise the privileges granted by the UK license. On the other hand, the Flight Review requirement and the Complex and High Performance endorsements may be required to act as a PIC using the FAA license, but are irrelevant to the UK licence. You can work thru the FAA regulations and determine that in the case of a safety pilot, a pilot with at least a private pilot rating for an aircraft must have a current medical, but does not have to be current in terms of takeoffs and landings or night, or have various endorsements, but may still act as the safety pilot.

KUZA, United States

That’s an interesting line of argument. Is there a reference somewhere, Jason?

No, it is clear from the FAA 61.75 rules. If you have a 61.75 FAA licence based on your EASA one whether you are current on your EASA is irrelevant. Why do you think it matters?

EGTK Oxford

If you are not located at an airfield with an IAP, why not do your regular “currency flight” over to the one next door that has an IAP? One should fly every few weeks, or more often. I know many pilots fly much less than that but are they really instrument pilots?

If they have 10,000+ hours of IFR time, and fly VFR twice a week, possibly so.

Last Edited by Silvaire at 02 Dec 21:31

For me, it would be rather difficult and a lot of hassle to comply with the FAA 90 day currency requirement for IFR.

What 90 day currency requirement for IFR do you refer to?

You could always obtain a US private pilot certificate based on part 61 requirements, most of which you will already have met by your previous training and experience.

KUZA, United States
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