Having just discussed this issue further at this week's EASA Part-FCL Implementation Forum, I elicited the following from the UK CAA:
- They don't know whether FAR 61.3 applies to sub-ICAO licences - so they've asked the FAA...
- ...who said they didn't know either, so will now seek legal advice.
- Several NAAs merely consider that N-reg aircraft may NOT be flown using sub-ICAO licences.
Until this is resolved, anyone who chances flying an N-reg aircraft on a sub-ICAO licence does so at their own not inconsiderable risk. Prudent advice is NOT to do so; a fully-compliant ICAO PPL is the minimum licence which should be used.
But hey, you barrack room lawyers who think otherwise, feel free to go ahead and risk being deemed complicit in any subsequent claim for damages should an N-reg aircraft flown by a sub-ICAO licence holder be involved in an accident.....
