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

Hmm, ok so by means of that new regulation, after April 2016 the only way do to IFR PIC hours on an FAA IR would be in the US, unless the local CAA allows flights in an N-reg on a FAA IR. Lets hope the BASA comes out with a GA-friendly solution….

The EASA FCL duplicate pilot papers requirement (some notes here) is due to come in April 2016, but it applies only to “EASA airspace” (the EU, plus Switzerland and Norway) and only if the “operator” (this term is not defined – much discussion here… e.g. do a search on “Morocco”) is based in the EU.

So you will be able to fly a non-EASA-reg plane (e.g. an N-reg), on the State of Registry pilot papers (e.g. FAA PPL/IR if N-reg) indefinitely, if

  • the “operator” is not based in the EU, or
  • the flying is outside “EASA-owned” airspace

So you don’t have to do the 50hrs IFR in the USA, though that is likely to be the simplest way if you are already there. You will be able to do it in say the Middle East.

I am not 100% sure about my above comments on Switzerland and Norway, because it seems that if the UK left the EU, all UK based N-reg pilots will not need the duplicate papers, and that ought to be true for Switzerland and Norway too. Can anyone from there confirm whether these countries implement EASA FCL totally?

I also think that if you borrow/rent a plane from say a US citizen who is temporarily visiting Europe, and he retains control over where it flies, manages the maintenance, etc, then the “operator” will not be EU resident.

A load of fun

It is obvious this anti N-reg provision of EASA FCL is going to be very difficult to enforce unless you piss somebody off in a big way, or you have a big accident and the insurer walks away from it because you did not clear your situation with him first.

Administrator
Shoreham EGKA, United Kingdom

Although it also seems possible that you could do the 50 IFR hours in the UK. For example, if you have a recent ICAO IR, the UK will grant you a PPL (with three written tests and a skills test) and you can apply to have an IMCR (IR-R) added (on the basis of having an ICAO IR). With this you should be able to fly the 50 IFR hours in the UK (Avoiding Class A airspace); then do the CB-IR skills test. I am in this position, but haven’t done it yet, so your mileage may vary…

Sans aircraft at the moment :-(, United Kingdom

I agree, and this highlights another possible issue: flying in UK Class G, with the IMCR, you can log what you want and nobody will know whether the conditions at your flying level were VFR or IFR.

What is almost impossible is flying “Eurocontrol IFR” on the IMCR, because it usually takes you straight into Class A. I don’t know if anybody can think of a useful Class D route which could be flown on a Eurocontrol flight plan. I suppose you could do EGHH-EGHI (Bournemouth to Southampton)

Administrator
Shoreham EGKA, United Kingdom

Norway and Switzerland and members of EEC and hence EASA. If GB were to leave the EU, it does not mean that they automatically step out of EASA.

Edit: and I doubt it will happen overnight.

Last Edited by Aviathor at 15 May 18:32
LFPT, LFPN

It is obvious this anti N-reg provision of EASA FCL is going to be very difficult to enforce

Not so sure about that. You will need to submit your logbook to prove your experience, and they will see it was acquired in the EU. They may have some objections to that.

Last Edited by Aviathor at 15 May 18:28
LFPT, LFPN

They may have some objections to that.

You are IMHO right about collecting some necessary logbook entries towards some EASA entitlement, but I was thinking more along the lines of getting stopped at some airport, with just your FAA papers on you. The policeman will need to be seriously clued-up on the regs. Today, the average airport policeman doesn’t even know what a pilot’s license looks like and finds it hard to believe the FAA one is a bit of plastic, and certainly cannot read anything printed on it. I know we have done this to death many times but I think insurance would be the biggest issue for anyone wishing to run some kind of “non EU operator” structure. That said, a year or so ago I spoke to a multi bizjet operator who got his insurer’s formal OK for his structure, which was an operating company in the USA. Actually it’s easy to arrange for corporate ops. And impossible for the simple private owner pilot living in Brighton

Administrator
Shoreham EGKA, United Kingdom

I can confirm Switzerland is in EASA-land and we have the same issues with the acceptance of FAA credentials.

LSGG, LFEY, Switzerland

Good evening

My goal is the CB-IR, which requires 50h PIC under IFR in order to skip the theory exams and other requirements. I am just shy of 50h PIC time under IFR, which I logged in the USA. However, this time includes dual instruction towards my initial FAA IR. Simple question: Can I count all my FAA PIC hours, or only the hours after I got my IR? I heard rumors that I can’t, but of course I like my opinion better and this is my reasoning:

EASA definition of PIC according to FCL.015: “Pilot-in-command” (PIC) means the pilot designated as being in command and charged with the safe conduct of the flight.
- I was indeed designated as PIC and charged with those duties.

AMC1 FCL.050 Recording of flight time: (b) Logging of time: (1) PIC flight time: (i) (ii) the holder of a licence may log as PIC time all of the fligh time during which he or she is the PIC;
- I was holder of a licence and I was PIC. The instrument rating is not a licence so it can’t be a requirement in order to log PIC under IFR according to this rule.

Am I correct or did I miss something?

Thank you! :-)

Last Edited by ArcticChiller at 20 Sep 17:08

For what it’s worth, I (and probably almost everyone who went CB-IR route) used the time logged with the IR(R) for CBIR.
Also, I don’t think when something asks PIC time, you differentiate between PIC time after you had your licence or not. Your first solo would count.

Bolded what I think is relevant. Whether you have a licence or not is irrelevant I would claim. If you are PIC, you log and count PIC, but you can only be PIC under certain conditions. I think alone in the plane is always PIC.

Logging of time:
(1) PIC flight time:
(i) the holder of a licence may log as PIC time all of the flight time during which he or she is the PIC;
(ii) the applicant for or the holder of a pilot licence may log as PIC time all solo flight time, flight time as SPIC and flight time under supervision provided that such SPIC time and flight time under supervision are countersigned by the instructor;

For those converting from an FAA IR, EASA won’t recognise IFR PIC time before you have qualified – it needs to be after the FAA IR checkride. This is different from those taking the normal CB-IR route with theory exams, where time learning towards IR(R) and subsequent solo IFR time will count.

FlyerDavidUK, PPL & IR Instructor
EGBJ, United Kingdom
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