CAA proposal for ANO amendments for EASA

[mm_flynn]

Originally Posted by robin

I'm still not clear here.

Where are the transitional arrangements??

It is an interesting document.

1. there are clearly no transitional arrangements in the document
2. there isn't a definition of an EASA aircraft in the document and my recollection is the EU reg defined this as all aircraft other than a specified group, registered in an EASA country or operated by an entity established in an EASA country.
3. the addition of pilot residency in 61 may or may not be relevant. If the aircraft is non-EASA by virtue of it being operated by an overseas operator, then this overriding fact makes the residency of the pilot a subsidiary issue (although slightly different than the EU principle in that it would appear to allow a non EU resident to operate a non UK but locally operated aircraft on any licence acceptable to the state of registry). If on the other hand the intent is to require any aircraft type that is not specifically on the non-EASA list where either the operator or the pilot is resident in the EU to have EASA licences this will come as something of a shock to any foreign aircrew who might be resident in EASA (I.e. A Delta pilot who has chosen to live in the UK)
4. The language specifically removes IMCr privileges rather than the previously muted 'can't take away an existing privilege' logic. (Worth AOPA taking up the 'WTF you guys promised us that you would address this issue in implementation!!' campaign)