Working in scandinavia with a UK ATPL

[leftofloc]

Hi Folks
Is there anyone out there that has worked in Scandinavia(Danish, Swedish or Norwegian registered aircraft, OY,SE,LN) with a UK issued JAR-FCL ATPL license. Have you encountered any problems/difficulties.

Cheers

[Moonwalker]

Interesting question you ask! It hasn't been possible up to now at least if you ask the Swedish, Norwegian and Danish CAA. Dunno what's happening now with EASA etc.. might change. I don't think that many operators has been aware of this rule though but if you get a ramp check... :ooh:

[leftofloc]

Thanks moonwalker

Well I have been told (in writing) by the swedish transportstyrelsen that I can work as a First Officer, but need a skill test to work as a skipper. The Danes have a slightly different opinion, and according to them you need a skill test to work as a pilot ( what is the definition of pilot, PIC or FO or both, I know ICAO says the pilot is the one responsible for the safety of the aircraft) on a scandinavian registered aircraft.
I am a little bit confused as I am sure that both Thomas Cook and Viking (when they existed) had people with UK licenses working for them.

[aloha1985]

Hmm, according to the reqs they are obliged to recognise any licence issued according to JAR-FCL by any other contracting state – at least, that is what they (NCAA) have told me. I suppose, as far as working on LN reg aircraft is concerned, it should (with a lot of emphasis on the should) only be a matter of having the UK ATPL re-issued by the NCAA – even though I am not sure they should even be demanding that. Isn't there some list out there somewhere detailing which countries practice mutual recognition of each other's JAR licences? I'm sure I've seen one somewhere...

[Moonwalker]

aloha1985: The problem with the UK issued ATPL is that it's not a JAR FCL ATPL and doesn't reach up to a the JAR FCL standard I've been told. In UK you can or could at least sit in the RHS and act as a FO and get your ATPL issued. I think JAR FCL state that you need a command/ATPL skill test where your command skills are assessed. If I remember correct it was more countries than the Scandinavian ones that rejected UK ATPL as the UK CAA refused or forgot(?) to change the directions. I know UK operators that nowadays do a proper skill test when they issue an ATPL so the regulations might have changed?

If TC flew with UK skippers then I can see three options. Either they weren't aware of it. They operated a non Scandi-registrated aircraft that recognized a UK ATPL or they had made a skill test according to the required level and had shown the relevant paper work to the CAA.

[aloha1985]

Moonwalker: my bad. I read it as a UK issued JAR licence. As for UK national licences I'm sure they would have an issue with it. However, is there any way to exchange your national ATPL for a JAR ATPL? They've been doing the switch in Norway for some time, but I figure the differences between a UK national and a UK issue JAR are a little less defined..? :hmm: As an example all of our licences now have the ICAO language level stated, but as far as I know, UK licences simply read "English proficient"..?

[CaptainProp]

Yes, you can get your UK issued ATPL exchanged for a JAR one. When I changed mine I was given I think a 6 months or so waiver to complete the language proficiency test and then that was added to my license.

In the TC case I am pretty sure they did had to do an OPC before flying on the Scandinavian AOC(-s) and would therefore have satisfied the requirement you are talking about.

CP

[Kilo-club SNA]

Assuming it is a JAR ATPL issued by UK there really is no issue and if it's a national ATPL uk will transfer it to a JAA ATPL.

The issue lies in the fact that there a two interpretation of the JAR. Sweden interprets that you can only get an ATPL if you have a skill test in the LHS and the UK (as well as most other JAA nations) doesn't care. If flying is performed to ATPL standard then an ATPL can be issued. You need an ATPL as a first officer to act as relief captain on long haul for example.
With EASA this becomes more specified and it clearly states that the skill test can be done in either seat as long as the pilot can perform all duties ie the aircraft has to be equipped with identical controls on both sides. ( the issue then becomes how much focus you put on the taxi....)
Remember, the ATPL is a license and a prerequisite for being a commander in multi pilot ops, not a qualification in itself.

Sweden insists on its interpretation and Denmark goes along for solidarity reasons. The only time this should really be an issue is if you convert from uk license to se or dk license where you have to show that you either have time as a captain or have performed a pc in the left seat.

[leftofloc]

Thanks kilo-club

The problem is that I have been with two very big uk operators flying scheduled flights out of LGW and LHR the last 8 years and have got a UK JAR-FCL ATPL license.
I am now, due to personal reasons, to fly for a scandinavian airline as a copilot and I have been cleared by the swedish CAA to fly on swedish, danish and norwegian registered A/C:s as a copilot only with my UK license. All well, at least until the danish CAA stepped in and told me that I am under no circumstances to fly on a danish registered A/C with a UK ATPL, not even as a copilot. I will be allowed to fly if I change it back to a UK CPL license.. . This is absolutely ridiculous and I do not for obvious reasons want to give up my ATPL license as all my other type ratings would become more or less useless.

[Upper Medium]

leftofloc,

Just to be clear they do realise you have a JAR-FCL ATPL issued by the UK CAA, not a UK ATPL? They are two completely different licenses.
I would be interested to know on what grounds they are refusing you to operate on Danish reg as I'd be very surprised if they have a remit to do so.

In about two weeks time EASA FCL kicks in and they will have even less of a leg to stand on as the new regulations are designed exactly with this in mind, it might be worth looking into. There are some knowledgeable FCL gurus at the CAA personnel licensing dept down in Crawley, I'd suggest phoning them up, explain your predicament and ask if they can give any advice - they might be able to help.

If you can't get anywhere it might be worth exploring whether two hours in the sim with a UK TRE doing an LST in the left seat is acceptable to them. If it is, it could be worth the money not having to go nine rounds with these imbeciles.



UM

[SR-22]

With a UK issued JAA licence it should not be a problem at all no

[Moonwalker]

I think all this comes down to a cultural thing. In Scandinavia you generally get your ATPL when you get your first command upgrade that requires an ATPL certificate. Probably due to the extra cost involved in holding an ATPL compared to a CPL in Scandiland. In UK, generally an ATPL is a trigger for the SFO salary increment and also a left over from the time where you had a time limit to unfrozen your ATPL. All that is gone now but as many other things the mind set hasn't changed. To be fair the issue process in UK has been lousy and I've been on several LPCs where the FO basically just been given an APTL. I don't know the exact wording in JAR FCL but why have an ATPL certificate if someone just give it to you? I think that is what the Nordic CAAs has had an issue with. As someone else said, I hope EASA will sort this out so your "problem" won't be an issue in a month time.

[Upper Medium]

Moonwalker,

There is nothing lousy about it at all, in fact it is highly regulated, and you need to do a LST as opposed to a LPC for ATPL issue if you have the required hours as specified. Not much difference I grant you but one is certainly not just given a new license.
In this day and age why should your ability to command an aircraft from a regulatory point of view depend on which seat you sit in? It just shows how hopelessly out of touch some of these people are.

Culture shouldn't dictate which set of laws and regulations a state decides to disregard, the "because we've always done it like this" attitude just doesn't fly anymore.

[leftofloc]

Seems to make no sense at all. You can fly on a danish registered A/C with a UK CPL (in the right seat obviously) but to fly the same A/C in the right seat with a UK JAR-FCL ATPL you need a check, in the LEFT seat. . . .Where is the logic in this ?

[aloha1985]

*sigh* :ugh:

[Instinct]

I've been operating outside of EU the past few years on a local ATPL, still keping my UK (f)ATPL current. Having been offered a job in Scandinavia I considered unfreezing my UK ATPL before tranferring it to Scandinavia in order to enjoy the benefits of having a Scandinavian ATPL and so have been in contact with the UK, Swedish and Danish Authorities regarding this matter.
To sum up, theoretically I could've had it done but it would've involved the CAA of two states and an instructor from a third country to execute the check in a fourth (non JAA) state. Let's just say I chose not to go down that road...

If one day - before I become captain - I need an ATPL one of three tings will happen; I'll find myself a left seat in a simulator, I'll find myself an adress in the UK to move my license back there, OR the rules will have changed. In fact, it's my understanding that they will, shortly. In the future again as I've understood things, they will be more in line with the Scandinavian way, hence there won't be an almost global demand of an ATPL to apply for a First Officer job (Which in itself is a bit weird...).

The issue - as some have stated - is that Scandinavia is more strict (strict as in doing exactly what it says instead of using a natinal application) in it's interpretation of JAR FCL, the key difference being that they require a LHS check for the ATPL to be issued.
I agree and don't agree with you Upper Medium. Legislation should not be a result of culture and "the way it's always been", which is what UK and most other JAA countries are doing. However, I also think that authorities should work for compability and transborder cooperation, which is the whole point of JAA and ICAO. Therefore I think the Scandinavia states at an early stage should've realised the difference and changed their procedures in order not to handicap Scandinavian license holders on a global market.
There's no right or wrong neccessarily, as long as things work and the safety levels are achieved. What I think Moonwalker is referring to, and I hope we can agree on, is that an ATPL is a commanders license and that the check to get that license in UK is no where near the level of check I would find suitable to get your command.

Just to clarify leftofloc, you should most definitely be able to fly RHS in a DK-registered aircraft on a UK ATPL, I currently am! Sure, my company have applied for change of state of issue but I'm yet to recieve my Danish license, hence I'm still flying on a UK one.
The only thing that should happen when/if you transfer your license to Denmark is that it changes back to a CPL. When/if you move it back to UK, it'll default back to a UK ATPL, as it's already been in their data base. Furthermore, your current (in the validity section) states that the holder may operate "...Aircraft registered in any Member State of the Joint Aviation Authorities".

Hope that helps,

[leftofloc]

Thanks for info. I have got it black on white from the danish CAA. UK ATPL licenses are not valid in denmark ! It is however legal to fly with a UK CPL license.
Are you sure that it is that easy to convert back to a UK ATPL once EASA comes into place, I am not that sure as it seems that no one can tell exactly what is going to happen.
One solution is of course to convert my UK ATPL to an irish ATPL, they are valid in denmark . . . .

[Trolle]

What about changing your UK ATPL to a JAR FCL ATPL? Which should be accepted in DK.

[leftofloc]

Trolle, my license is a JAR-FCL ATPL. Issuing country is United Kingdom, that is the problem. The danes obviously know better than the rest of the world . . .

[Northern_Driver]

Nääh, the Danes just have higher standards :E