JAA or EASA should I wait?

[JAJW]

Hi everyone,

Yesterday I passed my skills test and am absolutely chuffed to bits.:)
Before I send all of my information off to the CAA, I thought I should check to see whether or not I should wait. If I send it off now, will I get a JAA PPL or an EASA PPL? If I get the JAA PPL, will I then have to pay to get it converted to an EASA PPL?

I would really appreciate any advice anyone can give me on this.

Thank you

JAJW

[gijoe]

Ring up the CAA licensing dept and find out - they won't mind and are as confused about EASA as we are.

It may be worth the wait so that you don't have to renew in 5 years time.

Well done!

[nick14]

The CAA will not issue any EASA licences until the changeover date which I believe is in November so if you send it now it will be a JAA PPL assuming that you took the training according to the JAA syllabus.

The Benefit is that as of 8th April all JAA licences became EASA licences. So your shiny new PPL will have JAA stamped on it but be acceptable under EASA. That means that you will not have to do anything until you licence is up for renewal and then you will be issued with an EASA licence.

Hope that helps

[BillieBob]

The UK will begin issuing (non-expiring) EASA licences on 17 September. Any licence issued before that date, although being deemed to be an EASA licence, will be issued in accordance with JAA requirements for a period of 5 years, after which it will be replaced with a non-expiring EASA licence. The currently published fee for the replacement of a JAR PPL with an EASA PPL is £73, which can be expected to increase at least by inflation over the 5 year life of the JAR licence.

The decision is simple - is a 4-6 week delay in receiving your licence worth £73 to you?

[I Love Flying]

Can't answer your question for you, but congratulations on gaining your PPL JAJW:D

[Kolossi]

Hi JAJW,

Congratulations on passing, I got my JAA PPL just over a month ago.

I mulled over the same question as you, but being a month further back it was looking at a longer wait for me - and there's already been one postponement of the date for start of EASA licence issue, who's to say there won't be another.

One final factor you may wish to consider is the following, though I couldn't get any definitive answer from anybody about whether it's true or not (even from CAA). With a JAA licence, you can still add on the IMCr, which when the licence is converted to EASA will be noted as IR(R). It's my understanding that if you get a straight EASA licence, you do not have any route to tack on an IR(R), so your only route to fly in anything other than VMC would be to do a full IR. Now THAT might be worth £73 to you :ok:

HTH

Kolossi

[Kolossi]

Oh and another thing, although the JAA licence is a "5 year" licence, I believe they will all have to be converted to EASA by Sep 2014, so you are looking at having to pay £73 in 2 years time, not 5.

[riverrock83]

Hi JAJW,

Congratulations on passing, I got my JAA PPL just over a month ago.

I mulled over the same question as you, but being a month further back it was looking at a longer wait for me - and there's already been one postponement of the date for start of EASA licence issue, who's to say there won't be another.

One final factor you may wish to consider is the following, though I couldn't get any definitive answer from anybody about whether it's true or not (even from CAA). With a JAA licence, you can still add on the IMCr, which when the licence is converted to EASA will be noted as IR(R). It's my understanding that if you get a straight EASA licence, you do not have any route to tack on an IR(R), so your only route to fly in anything other than VMC would be to do a full IR. Now THAT might be worth £73 to you :ok:

HTH

Kolossi

Tis a question I've also sked on here before without a definitive answer. Beagle thinks it will be OK but he never answered this precise question.



CAP 804 says it can can only be endorsed onto a UK aeroplane licence (and it doesn't differentiate between former JAR Part-FCL versions, pure Part-FCL licences and Pre-JAR versions).
We know that you will always be able to add it to a UK (non-EASA) licence (but these will only be valid on Annex 2 aircraft after April 2014).
The CAA briefing doc (http://www.caa.co.uk/docs/2330/Revised%20Statement%20UK%20IMC%20RATING%20May%202012%20_v3.p df) says if your licence is a JAR licence (which is considered a Part-FCL licence until converted...) has a valid IMC when it is converted to a licence that looks like a Part-FCL licence, then you will get an IR(restricted) endorsement on the Part-FCL EASA licence.
We also know that you can still add an IMC rating to a licence that looks like a JAR licence before it is converted.
According to Part-FCL you aren't supposed to be able to add a national rating to an EASA licence.
There is still ongoing representation to EASA to allow the ongoing adding of what will be an IR(r) to a part FCL licence after the conversion period


Would seem logical that you can add an IR(R) onto a pure Part-FCL licence at least until the end of the conversion period (2014?) and thats my hope. Doesn't mean it will happen though :(

[Kolossi]

What (s)he (riverrock83) said!

My decision was based on the fact that if I got the JAA licence now, not only would I not have to wait any longer for my licence, but there appeared to be some situations in which an IMCr could still be added to it and would result in an IR(R) on conversion to EASA, whereas with a straight EASA licence nobody had come up with any scenario where it was known that the IR(R) could be added to it.

Welcome to aviation !:(

[JAJW]

Thanks for all the replies everyone.

So let me get this straight, and please correct me if I'm wrong, but if I do what Kolossi says and get my JAA PPL now, I could do the IMC, get it attached on and convert my license to EASA, after which I will never have to renew it again. Right?

Or if I get the JAA PPL now, will I still have to renew it after 5 years (even after converting it to EASA), as it was originally a JAA license?

Talk about the wrong time to pass haha.

JAJW

[BillieBob]

I believe they will all have to be converted to EASA by Sep 2014Where did that little gem of misinformation come from?Or if I get the JAA PPL now, will I still have to renew it after 5 years (even after converting it to EASA), as it was originally a JAA license?If you get a JAA licence now you will have to replace it with an EASA licence at some point in the next 5 years. Whether you do that at the end of its life or sooner is entirely your choice. Once you have the EASA licence, it will never need to be re-issued.

[exeng]

Out of interest I have a very old PPL, the privileges of which have not been used for at least 22 years.

Many years after the PPL thing I actually did the ATPL course and then flew as an F/O and have been (still am) a Capt on various medium sized jets (757, A320, 737).

I would never dream of jumping into a light aircraft unsupervised but wonder what gates I have to jump through (licence wise) in order to start the light aircraft flying again.

Apologies again for my ignorance but for the last 'x' years I've just been jumping through the many hoops to earn a living.


Regards
Exeng

[riverrock83]

I suggest that you will have upgraded your PPL to CPL then ATPL so first question is whether it really is a stand alone PPL.
If you are currently flying commercially then I'm guessing your single engine piston (SEP) rating will just have expired, in which case you probably need refresher training and test with an examiner. In UK see CAP804 which will soon become the best place to get the info.

[JW411]

exeng:

I did exactly this. I went back to single-engines after an absence of over 20 years. I bought a PA-28 and found a friendly instructor to ease me back into PPL thinking. I did five hours dual (which I thought was about right) while things came flooding back and then did a check ride with the local examiner.

The CAA issued a separate "Rating-Certificate of Revalidation" form endorsed "SEP (land)" which I kept in my JAR ATPL as a separate page.

[riverrock83]

JAJW
Yes however next time you would send your licence into CAA it will get converted from JAR to EASA. So its a risk and it means you can't get a night rating or change your address...
As I said, the CAA haven't said you can't add a new IR (r), but they also haven't said you can.

[Kolossi]

I believe they will all have to be converted to EASA by Sep 2014Where did that little gem of misinformation come from?

Well actually BillyBob, since you've asked - albeit in a way that I feel was a little unnecessarily aggressive - I'll tell you the whole story, which I've now read back from the notes I made at the time.

It was the CAA "helpline". When I realised that I would probably pass my GFT during the transition period and be in the position described by JAJW, I phoned them up to ask whether I should apply during the transition period or wait until EASA licences were issued.

They were less than helpful and said it was up to me. I kept asking questions though and was eventually told if I applied during the transition period for a JAA licence, I'd have to convert it later to an EASA one. I was told at the time that the price for this conversion had not yet been determined and no-one in the CAA would know, but it would probably be around £150, and that although the JAA licence was 5 years it would need to be converted by Sep 2014.

Unsatisfied with the quality of the response I asked to speak to a manager and was told none were available. I was eventually rung back by the head of Engineering licencing who basically said she hadn't really a clue about this as it was pilot licencing. I asked to speak to the head of Pilot Licencing and was told no-one was currently in that post. I asked in turn to talk to their superior who i was told was the head of licencing, but was told that they were on holiday. I pointed out the absurdity of there being no-one in authority regarding pilot licencing in possibly the most critical period in that area for decades, and that it really wasn't acceptable that no-one knew what was going on. (I may even have said that "if I behaved so incompetently in the cockpit, they'd take my licence away!" :oh:).

I was told the head of licencing would ring me back on his return from leave. In the end someone saying they were the acting or former licencing manager rang me back and tried to have a go at me for saying the department was incompetent. (note the wording of what I said, I didn't say they were incompetent, though clearly that was the sentiment behind my politically-correct self-criticising simile). Eventually he calmed down enough to tell me it would cost £73 to convert the 3 year JAA licence, and if it wasn't done for change of address/new ratings, it would need to be done by 7 Apr 2015 (I'd forgotten this later "update" when I made my post yesterday, but the point was that according to what I was told by the CAA, the JAA licence will not be valid for the full 5 years). He told me that they knew exactly what they were doing and had plenty of resource to cope with the transition. About a week later they publicly announced the revised and delayed end of the transition period.

I do have the names of the individuals concerned, but as I'm sure you'll understand I won't give them here.

So make of that what you will. To be honest I wouldn't put much weight of any of what the CAA said to me in person, that's why I didn't even mention that it had come from them. The docs referred to by riverrock83 at least give some confidence, but as he and I have said it's far from clear. For me the clear *possibility* of IMCr on the JAA as opposed to adding IR(R) to an immediate EASA licence means that for me it was the way to go despite the knowledge of at least an extra £73 (no doubt that will go up in the months and years ahead) being hoovered from my wallet by the CAA at a time and amount of their choosing.

HTH

[Prop swinger]

Kolossi,

From the CAA (http://www.caa.co.uk/default.aspx?catid=2330&pagetype=90):

New European Pilot Licensing Regulations: A Quick Guide (http://www.caa.co.uk/default.aspx?catid=2330&pagetype=90&pageid=13059), see page 7.
Frequently Asked Questions concerning the new European rules for pilot licensing (http://www.caa.co.uk/default.aspx?catid=2330&pagetype=90&pageid=12231), see question 7.

[Kolossi]

Thanks for posting the links here PropSwinger. Yes I've read those, many times, and at least the "Quick Guide" was out before I had the conversation with the CAA (I can't remember if the FAQ was, but I suspect at least one version of it was). When I was phoning up to clarify my confusion, I was referring to the quick quide when I was given the information I mentioned in my post. The trouble is it talks about if you have a JAA licence from before the transition or an EASA one after, but it does not explain the situation if you actually obtain a JAA licence DURING the transition period*.

Another thing is that if I look at FAQ 7 or P7 of the quick quide as you suggest it says things like
If your JAA licence is not marked "Valid for United Kingdom registered aircraft" ...

But if you are considering whether to apply for one or not, you don't actually have one so you don't know which would apply do you!? (So that JAJW knows, the one I got doesn't say that so is in fact a JAR-FCL licence!)

I'm sure somebody somewhere knows, but I'm afraid the situation for those applying during the (extended) transition period is very far from clear in the information sources available - apparently including even CAA senior management.

Regarding IMCr/IR(R) I'm reasonably confident that nobody anywhere has a definite answer as it's still being haggled with Brussels.


*BTW as an aside I don't see the merit in the transition period, why not just chop over from issuing JAA one day, then EASA the next? Questions like these wouldn't than arise, although to be fair then I'd have HAD to have an EASA licence with no immediate prospect or an IMCr/IR(R).

[UV]

Sorry, but you can never trust CAA advice about any FUTURE rules/timescales.

Past history shows that the Goal Posts are continually changed so, to avoid any unseen traps, you should never, ever, rely on what they say will happen in future or on predicted dates they publish.

Your best option is to go on what is CURRENTLY published and act NOW. The alternative is wait until the future rules are published and then act, but you take a huge risk.

Another bit of advice. Never do anything on the phone, always get it in writing.

From personal experience it is the only way to avoid the dreaded CAA question "Who told you that?" (when in fact they did) followed by backpedaling, denials, claimed misunderstandings, etc., etc.

[BillieBob]

It doesn't matter what the UK CAA says or doesn't say, it no longer has control over the law. Article 4 of EU Regulation 1178/2011 states that JAA licences are to be deemed EASA licences and all are to be replaced by 8 April 2017 - 5 years after the law came into effect. Therefore, a JAA licence issued prior to 8 April is replaced at the end of its 5 year life. So far as those licences issued during the transition period are concerned, all must be replaced by April 2017 and so a JAA licence issued today will have a life of a little over 4 years and 7 months. The maximum period by which a JAA licence's life could be shortened would be 5 months (assuming that it were issued on 7 April 2012), which is hardly significant in the great scheme of things.

There is nothing in law that requires JAA licences to be replaced by Sep 2014 (unless they were issued before Sep 2009). In fact, there is nothing at all significant about Sep 2014. The UK's decision to delay implementation of Part-FCL until Sep 2012 did nothing more than shorten the transition period, which still ends on 8 April 2014 and by which time all non-JAA compliant licences must have been converted.

[Kolossi]

Hi BillieBob,

Thanks for those updates. Bizarre though it is I find myself preferring an anonymous internet poster over a senior management in a relevant regulator body - though with of course caveats in my own mind of wanting it in writing from CAA/EASA/whoever as mentioned in UV's post.

But perhaps then you could spare your opinion on the 7 April 2015 date mentioned by the CAA Manager? I'll accept what you said about the pilot licences and the EASA rules (until somebody proves otherwise :)). But could it not be akin to the visibility requirements in VFR - the rules of the air specify one thing, but then your licence limits it further? What I mean is in this case could it be that the JAA licence itself is indeed valid for the full 5 years, but it won't actually be permitted to fly EASA-registered aircraft after 7 April 2015 on a JAA licence or something like that? I'm sure the man from CAA gave some explanation of that date at the time but I didn't note and can't recall what it was.

BTW, just out of interest (for me, as I'm sure for others here), where did you pick up the info BillieBob? I see that many of your posts on PPrune relate to regulation and are backed up with references - do you work in the field with CAA/EASA, or are you just good at finding and dissecting the docs? Unfortunately as in the visibility example above, in aviation it's often a case a a referencable document says something explicit, seeming to give a definitve answer, but another somewhere else contradicts or refines it - but it would be nice to know the provenance of the opinions that you are helpfully providing. Not meaning to doubt, just to understand. Thanks :ok:

[peterh337]

I don't know who Billiebob is but I think he is ex CAA and perhaps working as an aviation consultant.

The problem with the CAA is that so many smart people have left in the last 1-2 years. The contrast between now and say 10 years ago is staggering. It is virtually impossible to get a decent answer out of the CAA on anything now - unless you know somebody on the inside who happens to understand the stuff. The people on the public interface don't seem to know anything.

Also, the CAA is maneuvering carefully on anything to do with EASA so as to protect the various historical UK GA entitlements such as the IMCR.

[BEagle]

One final factor you may wish to consider is the following, though I couldn't get any definitive answer from anybody about whether it's true or not (even from CAA). With a JAA licence, you can still add on the IMCr, which when the licence is converted to EASA will be noted as IR(R). It's my understanding that if you get a straight EASA licence, you do not have any route to tack on an IR(R), so your only route to fly in anything other than VMC would be to do a full IR.

I will try to keep this simple and comment only on the issue of new IMCr / IR(R)s to those JAR-FCL PPL(A) holders who currently do not hold one, for use on EASA aeroplanes.

Please also note that the CAA will not be processing any applications between 13 and 16 Sep 2012 whilst they change over to the new licensing system.

1. If your application is processed before 13 Sep 2012, it will be issued as an IMC rating for inclusion in your JAR-FCL PPL(A).

2. If your application is processed after 16 Sep 2012, but before 8 Apr 2014, it will be issued as an IR(R), to be included in a part-FCL PPL(A).

3. The situation regarding issue of new IR(R)s after 8 Apr 2014 is still under debate.

4. You must convert any existing IMCr into an IR(R) if you wish to use it from 8 Apr 2014. The conversion is purely administrative. If you fail to do so, you won't be able to use the IMCr privileges on EASA aeroplanes until you do convert.

The IR(R) is identical to the IMCr as regards privileges, revalidation and renewal requirements!

[BillieBob]

But perhaps then you could spare your opinion on the 7 April 2015 date mentioned by the CAA Manager?In relation to your specific query, I can see no significance in that date. A JAA licence is deemed to have been issued in accordance with Part-FCL and so there is no limit to its validity other than the final date of 7 April 2017 (now 2018) by which all JAA licences must have been replaced.

The derogations from Part-FCL that are allowed until 8 April 2015 by Article 12 of Regulation 1178/2011 are:


All provisions related to licences for powered-lift aircraft, airships, balloons and sailplanes

The provisions of subpart B (the LAPL)

Introduction of the aerobatic, towing, mountain and flight test ratings

The helicopter MCCI

The mountain instructor and flight test instructor

None of these has anything to do with the validity of JAA licences.

As to knowing my way around the regulations - it is what I am paid to do. When I stopped flying commercially a few years ago, my employer kept me on with a brief to monitor the development of EU regulation and how it was going to affect the industry in general and the Company in particular. Up until recently, that has been focussed on the Aircrew Regulation but, increasingly, is now including the forthcoming Air Ops Regulation. I am also still active in my local flying club and so extend my interest to the effect on flight training generally. Contrary to Peter's assumption, I have never been employed by either the CAA or EASA, although I was involved as an industry representative in the early days of development of the Essential Requirements.

I might also say that, having grown up in a farming family, I have seen the dead hand of European bureaucracy, coupled with an incompetent government department (DEFRA in that case) all but destroy an entire industry. I can now see a repeat of that destruction in the making and the best (only) way of preventing it is to keep one step ahead of the bureacrats and maintain pressure on the appropriate government department (the CAA as an agency of the DfT) to avert the worst excesses.

Edited to add the following quote from CAP 804JAR licences issued before 17 September 2012, that are fully compliant with JAR-FCL, automatically become Part-FCL licences. The legislation requires the physical replacement of JAR licences with their Part-FCL equivalents on calendar expiry (so that all are replaced before 8 April 2018).I had missed the line in Article 1 of Regulation 290/2012 that amended the final replacement date in Article 4 of Regulation 1178/2011 from 2017 to 2018.

[Kolossi]

Thanks for all your replies, most interesting and very helpful to me, and hopefully to JAJW too as he started the thread :ok:

[BEagle]

I had missed the line in Article 1 of Regulation 290/2012 that amended the final replacement date in Article 4 of Regulation 1178/2011 from 2017 to 2018.


That was sneaked in when it was obvious that no-one else (apart from the UK) was going to be ready to issue part-FCL licences until Apr 2013, so Apr 2018 was the last valid date for a 5-year licence issued immediately prior to the EASA changeover date.

Incidentally, a non-JAR compliant pilot licence may still be used for flying EASA aeroplanes after Apr 2014, but only within the scope of the LAPL(A) and only until Apr 2015.

The CAA has already had to come up with 2 x 2 month deferments regarding Flight Examiners (1 refers to seminar requirements, the other to non-UK Flight Examiner briefing) - are we really sure that there won't be other issues too - such as the situation regarding PPL exams / mandatory 'groundschool'?

[JAJW]

Thanks for all of the replies. I have to admit, I got a little confused by some though. My impatience got the better of me and I have sent off for my PPL before the EASA transition.

Fingers crossed I get it soon, I'm bored of being on the ground. :ok:

[luckyllama]

So if I have a JAA PPL with four years to renewal, and intend to do an IMCr for the first time before April 2014, does it make sense to get an EASA now (first), get the IMCr first and then convert to EASA, or simply add the IMC to the JAA and wait until 2017 comes around to convert?

As a separate Q presumably an FAA piggy back becomes invalidated by the change to EASA and needs to be applied for again?

[iblackfin]

When you send all your paperwork to CAA in order to add your fresh IMCR the CAA will send you EASA licence back with IR(R) in it.

[Whopity]

In order to add the IMC to your JAA licence it will have to be converted as they cannot amend a JAA licence. Do it all at the same time. As you retain the same licence number it should not affect your FAA licence.

[S-Works]

You don't retain the same licence number and your FAA 61.75 will be invalid.

As an example my licence number changed to

GBF.FCL.CP.xxxxxxx.A

This has been confirmed by the FAA to invalidate a 61.75. There are steps being put in place at the moment to sort out reissue of these certificates.