More CAA (or EASA?) Bureaucratic Idiocy

[QDMQDMQDM]

I have a UK PPL. Very occasionally I would like to rent aircraft in Switzerland. To do that I have to convert to a JAR PPL. That counts as a new issue, which is £159 (gasp) and they need an original birth certificate or passport or -- and get this -- a photocopy certified as true by my flying instructor. A lawyer isn't allowed.

What utter bollox.

QDM

[IO540]

Perhaps they consider an instructor to be more trustworthy than a lawyer :O

Now there is an interesting topic!

As to charges, £159 for a piece of paper probably doesn't cover their costs. If you look at a typical business which is buying-in materials, and you take the annual cost of their Purchasing Dept and divide it by the number of purchase orders they issued that year, you will find the cost per purchase order is into 3 figures.

The question really should be whether they should be doing this at all.

[Adrian N]

QDM, given that they manage to make such simple things so complicated, you can imagine how I am looking forward to the task of getting skis approved for my aeroplane which is (from next week) on an EASA C of A. The fact that dozens of identical aeroplanes operate on skis on French domestic C of As will matter not one jot, and I can sense an expensive major mod fee and months of hassle. :*

[IO540]

Surely certification is now done by EASA, and if something has been approved by another EASA member (even at any time before EASA came into being) then you should have automatic approval.

The obvious difficulty with the process is locating aircraft owners who have had something fitted previously. There is no central database for Europe. A starting point for research would be contacting the manufacturer of the said equipment and see if they will disclose contact details of somebody in the EU who bought the product - this is likely to fail if it was a non-cooperating maintenance firm or some other dead end.

The CAA have a database of AANs (on their website) but it's obvious, looking at a few cases which I happen to know about, that a lot of stuff got fitted to G planes over the years without anybody obtaining an AAN - largely because "everybody" thought that if something has a US STC it could be screwed to a G without formality. This was true under the now-defunct CAA-FAA treaty but you were still supposed to get an AAN, and the CAA could have refused (and often did) on major mods.

In your case, you will need to find somebody on F who has the skis fitted and get the DGAC reference from him.

I hope the above is correct; I don't work in the business and now I am on N it doesn't affect me anyway.

[Adrian N]

For most aeroplanes you would be correct. Mine's a Jodel, and all the ski-equipped ones that I know are on the French register. An F-reg Jodel (D140) has to have a national permit to fly (CDNR or CDNS), and can't have an EASA C of A. An identical G-reg example can have an EASA C of A.....

The French mod, that was approved by the DGAC when these aeroplanes were on full French C of As is therefore unknown to EASA.

I'm about to embark on the process, and maybe I'll be lucky.... but I'm not optimistic.

[Squadgy]

I have a UK PPL.

By that do you mean a UK NPPL or a UK CAA PPL issued pre-JAR? If it's the UK CAA PPL then it should be acceptable in all ICAO states without a JAR style licence.

[QDMQDMQDM]

I mean the latter. A UK PPL, issued pre-JAR. I thought you had to have a JAR PPL to fly other countries' registered aircraft?

[Squadgy]

No, I'm sure you can use your pre-JAR one. I'd double check with CAA FCLD, you may well save yourself some beer tokens. May be wrong though - please let me know if I am :)

From LASORS:

A6 FLIGHT CREW LICENCES (JAR
AND UK NATIONAL)
Flight crew licences issued in accordance with
JAR–FCL will conform to JAR-FCL specifications and
may only be replaced with a JAR-FCL licence. Licences
issued in accordance with UK National arrangements
will, where applicable, remain valid until their date of
expiry and may be renewed after this date. The UK
National Licence will continue to be available to those
who have previously held the licence. There is no
necessity for UK national licence holders to convert to
a JAR-FCL equivalent licence unless they wish to do
so. The only circumstance in which all holders of a UK
national licence would need to obtain a JAR-FCL
licence would be if the EU mandated such a move. Until
such time as EC Directive 91/670/EEC is withdrawn, a
UK National licence can still be validated in other EU
States.Holders of UK national licences do not need to
surrender their licence upon issuance of a JAR-FCL
equivalent.

[IO540]

This subject comes up all the time and normally I don't get into it (doesn't affect me).

However, isn't a fair summary this:

A JAA PPL allows you to fly any JAA-reg plane, and the country of registration has no power to veto that.

A non-JAA PPL (i.e. any ICAO PPL, and this description unfortunately includes the old UK CAA PPL) needs validation by the country of the aircraft registration, and they can refuse, or attach entirely arbitrary conditions. In this case, the UK PPL might be more acceptable to a European country than say a Russian PPL, though strictly speaking they both have the same rank.

The UK CAA validates ICAO PPLs (VFR, noncommercial, etc) automatically, through an ANO article, for G-reg planes, but this is on the whole very unusual. Other countries have a more onerous procesure. Some don't like it at all, because it would allow people to fly their national reg planes on the FAA PPL which is much cheaper (done in the USA) to get than a JAA one, and this damages the domestic flight training business. I give the CAA credit for this generosity; it's a rare gem in an otherwise largely protectionist regulatory regime.

[Squadgy]

non-JAA PPL (i.e. any ICAO PPL, and this description unfortunately includes the old UK CAA PPL) needs validation by the country of the aircraft registration, and they can refuse, or attach entirely arbitrary conditions. In this case, the UK PPL might be more acceptable to a European country than say a Russian PPL, though strictly speaking they both have the same rank.

This may be true outside of the JAA states however EEC directive 91/670/EEC (http://http://europa.eu.int/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc=391L0670&model=guichett) states:

This Directive shall apply to procedures for mutual acceptance of licences issued by Member States to civil aviation cockpit personnel.

Any person holding a private pilot's licence issued by a Member State shall be permitted to fly aircraft registered in another Member State. This recognition shall be limited to the exercise of the privileges of the holder of a private pilot's licence and of associated aircraft ratings under visual flight rules (VFR) by day only in an aircraft certificated for single-pilot operations.

These rules have been in place since 1992, well before the introduction of JAR style licences.

[IO540]

[Switzerland] it is/was the only country to grant the UK IMC privileges in their airspace

Do you have a reference for this?

It's pretty amazing.

Not worth anything now though because the present-day ANO restricts IFR privileges of the IMCR to UK only. This change of wording was put in within the last few years.

Switzerland is the only place in Europe (that I know of) which permits a BRNAV GPS to substitute for an ADF, for en route IFR in CAS. That is pretty amazing in itself, by European standards.