A couple of further points on the FAA IR conversion.
- I think it is an excellent thing for FAA IR pilots who might want to occassionally fly EASA-registered aircraft (or who in the future might want to buy one on the EASA-register and keep it there).
- Clearly any conversion is unwelcome for FAA IRs who want to stick with flying N-reg.
I think it is important to seperate the two! I don't think the conversion to a
full EASA IR useable on any EASA aircraft is going to be any easier than the one proposed (until and unless we get a Bilateral treaty), except for the issue of TK where I think we should push for the less onerous options I mention above.
However, for the FAA IR sticking to N-reg aircraft, there is a precedent
already in EASA FCL. Article 7.4 says
Aeroplane or helicopter type ratings may be issued to holders of Part-FCL licences that comply with the requirements for the issue of those ratings established by a third country. Such ratings will be restricted to aircraft registered in that third country.
The entire FRA problem could be solved with the insertion of the following 3 words at the start of the existing FCL Art 7.4: "Instrument Ratings and"
A lot of the push back on the FRA topic from EASA and EC stakeholders has been a bunch of nonsense about the EU "Basic Regulation" law of 2008. This certainly allows EASA to restrict FRA, but it doesn't make them. At least that is what is clear to me from the fact the Type Rating exemption is there in 7.4. I would suggest that FRA stakeholders lobby for this specific change.