Important explanation from the European Commission to my letter
I accept your apologies.
Let me try to set out what the issue is about.
Regulation 216/2008 on common EU air safety rules sets out, amongst others, basic requirements for pilot licences. These basis reqirements will have to be followed up by more detailing implementing rules defining such requirements in much more detail. These more detailed requirements will have to be adopted by Commission and Member States (so-called Comitology) and confirmed by the European Parliament. The proposals for these more detailed implementing rules have to be developed by EASA (so-called opinions).
Last week the EASA Committee was looking at EASA's opinion on requirements for Flight Crew Licences (FCL). These proposals would, if adopted, imply that holders of Foreign Pilot Licences will have to undergo a validation process. On the basis of the assumption that the whole legislative package will come into force , as requested by the European legislator , in April 2012, the validation process would have to be terminated by April 2013. Accordingly , there is no immediate risk to the validity of your licence even if the EASA opinion is adopted without changes.
Last week, the Committee did not yet take a decision on this matter. The issue will again be looked at in December.
I take this opportunity to inform you that there is a preferable alternative to regulating the issue under Regulation 216/2008. Since 2008 already, a draft bilateral air safety agreement between the USA and the EU is technically ready. It foresees settlement of such issues through a mutual recognition mechanism. Unfortunately, the entry-into-force of this agreement has been delayed by political complications stemming from draft Congressional law (FAA Re-Authorization Act) which is inspired by protectionist elements on a number of points which are unacceptable for the EU.
Since recently, FAA officials tell us that they are optimistic to solve these political complications once a new Congress has been elected. We have to see what will happen by then.
In other words: The key for solving this issue in the most efficient way is located in WashingtonDC, not in Brussels.
I trust this mail clarifies the matter.
Yours Sincerely
Eckard SEEBOHM
Head of unit aviation policy
European Commission