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FAA IR time, and IMCR time, and whatever other time, towards "50hrs IFR PIC" for the CB-IR or BIR

When I started this thread I assumed that these 50h IFR PIC should be recognized as long as they were done in any ICAO environment. I didn’t think that I had to go back through my logbook and find “EASA time”.
To clarify, I could only count hours that I did after my FAA IR skill test and since it was more than 25h it was sufficient for the EIR. The IFR PIC time before the skill test did not count. It does make sense in a way, because the definitions are different between FAA and EASA.

One thing that bugs me is that most people seem to know that SPIC time only counts in integrated courses, even though the definitions/FCL suggest otherwise (in my humble opinion). I think something was forgotten while copy-pasting law from JAR to EASA. But I’ve given up trying to understand this topic. ;-)

ArcticChiller wrote:

The IFR PIC time before the skill test did not count. It does make sense in a way, because the definitions are different between FAA and EASA.

The definitions are the same. The credits are different. This funny FAA PIC logging causes headaches in Canada also so it isn’t only an EASA problem. A simple cure is to record experience in separate logbooks according to the rubrics for the licences you hold or intend to hold. This approach catches other odd differences such as not using correcting fluid in logbooks for US/Canadian purposes, etc.

London, United Kingdom

@mktime
I hear you. But it desn’t matter how many rnav approaches in the USA you flew.
PBN is an EASA requirement. You need PBN privileges on your licence if you want to use GPS during an IFR flight.
And in order to get PBN privileges, you need a training in an ATO and skill validated during a check ride. This is what the DGAC requires. Might be a little different in other EASA country.

BTW, you might get to fly a NDB approache during your EASA IR checkride. Also, NCO is in effect so learn it and ignore French decret while you prepare your checkride.

LFBR

If i need 50h instrument ( not IMC but instrument log flight plan) after the FAA exam, i don’t plan to convert it now.

Is it still possible to fly N-Reg plane IFR in Europe with my FAA IR licence ?
It it’s the case i need to fly on N-Reg for this 50h and then i can convert.

If it’s not the case, i need to do 50h in USA, i plan to do anyways but was not sure about 50h on instrument flight plan soon.

Thanks

LFMD, France

The situation is ambiguous to some extent. Nobody has a clear answer; I suggest a review of that thread, perhaps working backwards.

Administrator
Shoreham EGKA, United Kingdom

Manu wrote:

PBN is an EASA requirement. You need PBN privileges on your licence if you want to use GPS during an IFR flight.
And in order to get PBN privileges, you need a training in an ATO and skill validated during a check ride. This is what the DGAC requires. Might be a little different in other EASA country.
Sounds like national gold plating. EASA doesn’t require training at an ATO if you already have PBN experience. Also, the validation is to be done during a PC — not a check ride.
ESKC (Uppsala/Sundbro), Sweden

Peter the answer is quite clear. Articles 20 and 23 of the Basic Regulation require pilots of third-country aircraft, when they are operated in EU by an operator established or residing there, to comply with the Aircrew Regulation. Article 3 of that regulation requires such pilots to comply with the annexed technical requirements, ie to hold a licence granted converted or validated under the regulation or converted under a BASA–IPL, except to the extent that a member state derogates or makes an exemption.

Member states may derogate until 20 JUN 2020 as discussed near the end of your linked thread. The derogation allows member states to opt-out of the article 3 requirement in respect of non-commercial flights in aircraft registered either in a third-country or in a member state. In the case of third-country aircraft operated by non-resident operators the derogation isn’t necessary because pilot in these operations aren’t brought under the Aircrew Regulation or the essential requirements in annex IV to the Basic Regulation.

For non-commercial flights in UK there is an exemption in respect of US pilot certificates until 8 APR 2019 or earlier if rescinded or superseded. The exemption, made prior to the recent Aircrew Regulation amendment enabling an opt-out, covers the aircraft mentioned in the previous paragraph. Again, non-resident operators are not bound by the Aircrew Regulation and therefore do not need the exemption. See UK General Exemptions E 4433 and E 4474 notified in ORS 4 No. 1220 of 5 APR 2017 and No. 1228 of 27 JUN 2017 (link). The explanatory notes to these exemptions summarises the present situation clearly.

Without prejudice to the primacy of EU law there is a general provision in the UK Air Navigation Order 2016, at art 148(3)(b) (link), allowing a US-registered civil aircraft to be operated in UK by a pilot whose licence (certificate) was granted or rendered valid under either the US regulations or the ANO—so long as UK CAA has not given a direction to the contrary. However, UK will continue to bind itself by EU law throughout the transition period following withdrawal from EU so an opt-out pursuant to article 12(4) of the Aircrew Regulation will be necessary from 8 APR 2019 when exemptions E 4433 and E4474 expire.

London, United Kingdom

Indeed; perhaps the main bit which is not clear is whether the UK’s exemption (the one expiring 8 APR 2019) means a UK based N-reg pilot can fly just in the UK (which appears clear) or all over Europe (which is how the derogations are understood by most, otherwise they are largely meaningless, since so many countries never applied them, in some cases prob99 because they never read the EASA reg ).

Administrator
Shoreham EGKA, United Kingdom

Qalupalik wrote:

Peter the answer is quite clear.

Indeed, your explanation is crystal clear. The only thing I’d mention is that the DfT suggested to me that the exemptions would be renewed rather than the UK derogating under 12(4), but it may be that your information is more accurate or more recent than mine. It makes little difference apart from the paperwork.

No I simply assumed a derogation would be the preferred method based on the justification given in the explanatory note to the existing exemption.

London, United Kingdom
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