Originally Posted by
mad_jock
Although on the license transfer side of things I would be in exactly the same situation going the other way.
Still the principle of the loophole I disagree with and think it should be stopped. The method of shutting it and shall we say grandfather rights need to be worked on.
Mad_jock,
At a high level the licence transfer is the same, it as always is in the detail. I know nothing about ATPL level transfer. However, at the PPLIR rating level level we have the
JAA ->FAA process is
1 - Take and pass 60 question knowledge test (probably 2 weeks of study for the FAA differences), exam available online and inexpensive
2 - Present oneself and ones JAA licence and medical to demonstrate can speak English
3 - Take BFR checkride (in this case likely to be a combined IPC and general hour with an instructor)
FAA-> JAA process
1 - Minimum of 15 hours training in a FTO
2 - Take and pass 7 exams (in the UK given in a very limited number of places and dates)
3 - Pass an initial flight test
4 - Get a class 2 (but with class 1 audio)
FAA->EASA process (as currently documented)
1 - 50/5 hours training in a FTO
2 - Pass all exams
3 - Pass an initial flight test
4 - Get a class 2 (but with class 1 audio)
The steps are broadly similar, yes. However, the cost and reasonableness are grossly disproportionate.
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You clearly have a bee in your bonnet about N-reg ops. Unfortunately, to the extent your concerns involve Jets, the EASA proposals will not help you in the slightest to close your perceived loop hole.
There is no attack on N-reg as such, it is an attack on pilots, as well as some bonkers drafting - by targeting the law on where the operator is based rather than on where the aircraft or the pilot is based.
So for example, a UK company that operates an N-Reg and has the operating entity in Oxford will clearly be effected. This will mean that if this company is operating their jet in New York, they will be required to have crew with EASA licences to be legal in the eyes of EASA and FAA licences to be legal in the eyes of everyone else. It is very strange EASA is going to force all EU (and other EASA member states) to file a difference that they are going to define the FCL requirements for foreign aircraft operating outside the EASA area. This company will either fire its current pilots, help them retrain, or go for the following option.
My UK company now changes its organisation, its ultimate holding company is listed on whatever exchange they feel provides best access to capital, they consolidate through a NV based Co (for obvious tax flexibility), they have a Delaware sub that owns, flight plans, manages the maintenance, etc. for several jets and despatches the particular aircraft (which lives at Oxford). Who is this aircraft's operator and where are they resident.
Now at the PPL level this is just too big a PITA to get involved with.
So the summary of the current EASA proposal is
1 - EASA is attempting, through a flawed leverage logic, to open up US commercial markets and poke the US Congress in the eye for disrespecting the EU
2 - EASA may be attempting to force N-Reg jet operators into the EASA regulatory structure. In this class of aircraft, the EASA/JAA structure of small AOC jet ops is statistically significantly more dangerous than the FAA private jet structure.
3 - EASA is attempting to do this by introducing the undefined term of [residence of operator]
4 - For Jet operators, they have many advantages (in terms of maintaining market value, legal global maintenance, selection, modifications, better safety) for operating N, so they will continue
5 - Jet pilots will either be screwed or their companies will by pass the rules through a small change in corporate structures.
6 - PPLIRs (as it stands) have to go back to ground zero for the IR (or lobby hard, or quickly go for JAA transition training)