N-Reg aircraft based in UK

[PJ500]

Up until recently I was able to work in the UK on a UK based N registered aircraft on the basis of my FAA licence and rating. I also hold an EASA licence but without a rating on that aircraft type. Because of the passing of the recent August deadline regarding the use of non-EASA crew licences or validations (CAA IN 2016075) the operator of this aircraft now requires flight crew to be dual licenced and rated (i.e. FAA and EASA).

I contacted the CAA regarding this and had a couple of email exchanges, however, despite this, it is still not completely clear to me if I can continue legitimately flying the N-Reg aircraft without having to hold an EASA type rating. Understandably the aircraft operator does not want to risk the embarrassment of an awkward ramp check.

This has now resulted in my losing significant work, and I was wondering if there are other people in a similar position - and if there is any clear guidance anywhere on this that has enabled them to continue without having to repeat a type rating course (required if < 500hours on type).

The FAA are completely uninterested except to say that they will not co-operate with any attempt at enforcement.

I'd be grateful for any views or experience. I'm aware of a few recent posts but these tended to lean toward part NCC ops.

Thanks,

[rudestuff]

Unfortunately the regulation contains the word 'may'. I've heard the CAA are unlikely to play ball with that one, but the IAA are supposed to be very helpful. Perhaps a change of state of issue would solve your problem if the CAA say no.

[Jonnyknoxville]

Get an address in America . Can't force us pilots to an easa licence

[BizJetJock]

Sadly not correct. It is where the operator is based that matters, not the aircraft or the pilot.

[Jonnyknoxville]

Ah , I assumed it was a US operator

[CL300]

this is irrelevant as far as part NCC is concerned, if the aircraft has its main base of operations in Europe then part NCC applies

[noneya]

CL300,

Please post the document that supports your post.

this is not troll bait, I am truly interested to see this written somewhere. As of now everything I have read, refers to only the operators base or offices.

Thanks
j

[CL300]

we are talking complex airplanes ok ?? i could have quote 800/2013 it is the same

EC N° 216/2008 Article 3 (h) 'operator' shall mean any legal or natural person, operating or proposing to operate one or more aircraft
Article 4
(c) registered in a third country and used by an operator established or residing in the community
(d) registered in a third country, and used by a third country operator into, within or out of the community

For N registered airplanes in Europe, mainly registered by trustees, they are de-facto controlled by european operators, they have been imported in Europe, they have adresses for fees to be sent in europe, etc...

If the aircraft commutes in and out , no issues, if the aircraft stays with a subsidiary or the real owner, or whatever, part NCC applies

one might escape the scheme, but by and large.... no way out..

my initial wording was cutting short airplane / operator, NCC for third countries registered planes really address the owner/operator/pilot, therefore the aircraft base.

[g450cpt]

CL300,

This is straight from the horses mouth.

EASA-NCC.eu - NCC 800 (http://www.easa-ncc.eu)
NCC/NCO Check
1. Is your aircraft registered in a EU State?
Yes/No (N registered will check NO)
2. Are you a private operator with a principle place of business inside of any EASA State?
Yes/No (if the operator is not based in the EU, they will check NO)

Result: No EASA documentation required.

In conclusion, according to the EASA website, if the operator is based somewhere other than the EU (i.e. the US, Asia, Canada, etc..) NCC does not apply. It does not matter where the owner lives, nor does it matter where the airplane spends it's time. All that they are concerned about is where the operator's principle base of business is.

g450cpt

[BBJ-Captain]

So let's put it into really simple terms.

You have a Falcon on the N-reg requiring FAA licence.
The aircraft is owned (on the registration plate) but a person financed through Wells Fargo in the USA.
The 'owner' is actually a man who lives in the EU predominantly (but we all know that wherever the sunshine and the boat are.....)
The aircraft has permanent crew, who are pay rolled through a management company.
This management company is (for argument sake) Tag based in Farmborough. All invoices and flight planning services go through here.

Do the crew require the EASA licence endorsement?

[noneya]

BBJ Captain,

In your scenario the answer is yes, you have to comply with NCC, because the operator is based in Europe.

j

[CL300]

G450

Along the manuals i had done, i encountered all versions of the story, however, and bottom line, EASA people are not idiots, and a plane sitting in europe for the last two years or more, sending Eurocontrol invoices to whoever in Europe is considered as have it's principal place of operation in Europe.
Now , i cannot say that you cannot try to cheat the system or slip through it, if genuine, this is fine. Most of the time after a thorough audit, it was found most of the time that NCC was indeed applicable.
Again this is not a pain, as for N reg for example, one that operates outside USofA needs a proper MEL and an international procedures manual ( among other things), transition to NCC is painless.

The most impacted are and were the owner/pilot in its CJ or equivalent thing, that has NO clue about an escape route, a W&B or any form of paperwork and storage of it. The rest of the crowd is having a less steeper learning curve.

Part SPO are the next to suffer, and depending on the country of residence, the transition is sometimes quite tough.

[g450cpt]

CL300,

As I stated earlier (if the management company is based somewhere other than the EU), then why would a Eurocontrol invoice be mailed to someone inside of Europe when the management company (the operator responsible for paying that bill) is based outside of Europe. Lets take for example a N registered airplane being operated by a US based management company under FAA part 91 rules for an owner that has homes in different areas of the world. Let's say the owner wants to spend the summer in Spain. Under your scenario that aircraft would fall under NCC, which would also require the pilots to have EASA licenses. Using the web link that I previously posted, one can clearly see that is not the case. I agree that they should have proper MEL, IOM, SMS (most upstanding management companies have these) but the requirement for EASA licenses is not mandatory. BTW trying to obtain an EASA license for a FAA pilot is indeed painful.

g450cpt

[CL300]

If the owner spends the summer in Spain, he is not based there is he ? he had not imported the airframe did he ?
Part NCC assess planes / operators based Europe, even though they are N or what else registered.
In your case , if the airplane does not sit in its hangar in FAB or CEQ or anywhere else in Europe all year long , no worries, else NCC applies.
You can deny some facts or answer wrongly to the question, and i say again, one might slip through the net, for a while, usually insurance claim is the wake up call..

[Hawker125]

Hi all,

this conversation is very interesting and people is pulling out very good matters and example. My personal believe is that we are here talking about Part 91 operations for N-reg. as such, all the problems are from the holder of the LOA, as this is the main operator, if the LOA holder is not one of the pilots but it's a mgmt company that's quite simple. If the mgmt company is european part NCC applies. If the LOA Responsible person is EU/UK Resident Part NCC applies, if he is not EU/EK resident and there is no European/UK mgmt Company then Part-NCC does not apply.

As a very humble and personal consideration, if you have a job in Europe on an N-reg airplane you should know this amendment to EASA is 2 years old, you should have start your conversion way before as you are working in a country with the wrong licences, you know it could not be forever...nothing personal to anybody. I dream an aviation world in which there is not such painful conversion and problems, just one world license (probably it will remain a dream) but An American pilot flying in Europe any day is NOT different from an European pilot flying in US, regulations and procedures are NOT the same, hence my statement of the WRONG LICENCES for the country your are working in. one thing it to overfly or just make a single trip or landing, another story is to work permanently in a country without having a clue of a background of the country regulations and not complying to the very expensive and strict legal requirements we all have to follow in Europe or in US or anywhere we want to bring this example in.
Safe flights

[CL300]

You cannot imagine the number of people operating a "complex" airplane and being completely ignorant about the applicable regulations. The number of LOA being signed by the seller ( yes by the seller, or broker or whatever you call them), and not being updated. You cannot imagine the state of some AFM. The list is VERY long.
As far as safety is concerned ( if i read along your lines), one trip a year is safer than being based without the 'proper' licenses, this i doubt very much.
EASA and FAA have been talking about this for years, and the base line being taken is the fact that if you are paid to fly, then you should get a valid license for your operation area.
Will it make the flights safer ? hell no ! but it will tackle here and then some operations. by an large it is not very significant ( except for the individuals concerned of course).
I have 3 exemptions (or waivers) going on for clarification of documentation (2 regarding the use of LOA 95 vs 195, and one regarding the requested ground training on a specific case) planes are flying, legally although not having a definitive answer on these matters, and the 45 days waivers are edited since August.....
Good case to come i believe, will se..

[mad2fly]

Hi all,

this conversation is very interesting and people is pulling out very good matters and example. My personal believe is that we are here talking about Part 91 operations for N-reg. as such, all the problems are from the holder of the LOA, as this is the main operator, if the LOA holder is not one of the pilots but it's a mgmt company that's quite simple. If the mgmt company is european part NCC applies. If the LOA Responsible person is EU/UK Resident Part NCC applies, if he is not EU/EK resident and there is no European/UK mgmt Company then Part-NCC does not apply.

As a very humble and personal consideration, if you have a job in Europe on an N-reg airplane you should know this amendment to EASA is 2 years old, you should have start your conversion way before as you are working in a country with the wrong licences, you know it could not be forever...nothing personal to anybody. I dream an aviation world in which there is not such painful conversion and problems, just one world license (probably it will remain a dream) but An American pilot flying in Europe any day is NOT different from an European pilot flying in US, regulations and procedures are NOT the same, hence my statement of the WRONG LICENCES for the country your are working in. one thing it to overfly or just make a single trip or landing, another story is to work permanently in a country without having a clue of a background of the country regulations and not complying to the very expensive and strict legal requirements we all have to follow in Europe or in US or anywhere we want to bring this example in.
Safe flights

I am not a national of any EASA state. So according to ICAO, EASA has no right to require me to have any other licence than the one required by the aircraft's state of registry.

I've brought this up several times and no one has ever commented on how I am wrong in believing this.

[CL300]

@mad2fly This is correct, however EASA can say that in order to operate an aircraft for compensation or for hire within EASA, you need to have an EASA license..

[mad2fly]

@mad2fly This is correct, however EASA can say that in order to operate an aircraft for compensation or for hire within EASA, you need to have an EASA license..
The only ICAO rule that allows a state to not recognise a license issued by the state of aircraft registry is:

1.2.4.2 Licences of Personnel - Article 32
The pilot of every aircraft and the other members of the operating crew of every aircraft engaged in
international navigation shall be provided with certificates of competency and licences issued or rendered
valid by the State in which the aircraft is registered. Each Contracting State reserves the right to refuse to
recognise, for the purpose of flight above its own territory, certificates of competency and licences granted to
any of its nationals by another Contracting State.

What ICAO rule allows this to apply to a national of a non-EASA state if they are flying for hire.

[CL300]

ICAO has desires, EASA rules...
The article you quote is for a flight arriving or departing, not doing A to A within EASALand.

The spirit of the regulation is to have people with EASA licenses IF the aircraft is based in EASA Land. All countries are sovereign over their territory, as a consequence, IF you are paid for driving a plane, and that you are based in EASA, THEN you need an EASA License, ELSE you are not in the scope of law.

[BizJetJock]

Nobody is forcing you, as an individual, to get an EASA licence. These rules apply to operators, and say that if the operator is based in EASA-land they are not permitted to use any pilots that don't have an EASA licence. It then becomes a purely commercial decision on your part whether you invest the time and effort to get one.
Incidentally, this is not an EASA invention. All they are doing is implementing the requirements of ICAO Annexe VI. Bermuda and the Cayman islands (and other UK Overseas Territories) have had these requirements for years. But since they will validate anyone else's licence then the issue doesn't have the same obvious effect.

[ChickenHouse]

Who invented the term "operator" in this context and what the heck does it mean? Did anybody have found a clear definition to check if an when one is an "operator" by means of EASA private flying?

[Harriko]

In the title it says "in UK" but this pretty much is same for all the EASA countries...

Do you have any idea of N-registered planes that has different rating requirements in FAA and EASA?
Like Beech King Air 90s...They have to have type rating in EASA but no rating required in FAA. And same is with Cessna turboprops which require only "SE Land" in FAA but would require Cessna SET in EASA.

If I operate an US-registered Caravan in EASA-country with EASA-licence do I need ratings according to EASA or FAA?

[CL300]

In the title it says "in UK" but this pretty much is same for all the EASA countries...

Do you have any idea of N-registered planes that has different rating requirements in FAA and EASA?
Like Beech King Air 90s...They have to have type rating in EASA but no rating required in FAA. And same is with Cessna turboprops which require only "SE Land" in FAA but would require Cessna SET in EASA.

If I operate an US-registered Caravan in EASA-country with EASA-licence do I need ratings according to EASA or FAA?
This is an easy answer, you can fly on the N aircraft with your EASA licence ONLY in the country of your licence ( not over EASA territory)
If you fly you Caravan for compensation or for hire ( sounds familiar ?? ) THEN you need a part.NCO AND an EASA rating on it.
If you own a N register caravan, and are not paid to do so ( pleasure), then your FAA ticket is enough, however if operated from EASA land, then part.NCO

[Harriko]

Oh be damned. It will be a Cessna SET rating then :* Well I could have used that 8000 euros for something else too...

[deefer dog]

The spirit of the regulation is to have people with EASA licenses IF the aircraft is based in EASA Land. All countries are sovereign over their territory, as a consequence, IF you are paid for driving a plane, and that you are based in EASA, THEN you need an EASA License, ELSE you are not in the scope of law.

What a load of tosh! Why do you keep referring to the word "base" when it does not appear in the legislative text? Concentrate on the facts which concern the operator and the principle place of business of the operator. It has nothing to do with where pilots are based either, or are you suggesting that all those who drive planes for AA, and who may be based in the UK, need to get EASA licences?

[CL300]

AFAIK American Airlines does not fly London to Birmingham nor has its operation and pilots based in UK. Fifth right prevents this. AA does USofA to wherever and back. Like anyone else, on top AA is NOT a part NCC ops, it is a FAR part 121 operator, as such its business lies from/to USA.
Now it is very simple, you can shout and cry, BUT at the end of the day Ramp checks have started, fines are already levied. Regardless of the trustee ( USA case), the aircraft operated mainly in Europe is/was imported, it was imported in the EU ( whatever state), and it flies from somewhere, this somewhere is where the Part.NCC has to be located. I have customer's addresses in Belgium/Luxembourg/San Marino, aircrafts registered everywhere, BUT located in France as their main base of operations, France is competent. Period.

The first two countries where EXTENSIVES ramp checks have been performed lately are Netherlands and Romania. Extensive goes to the point of the SPA for EFB was requested where an LOA was issued in lieu of... Requesting clarification within 45 days.

So the SIPRIT of the LAW is this, it is not me who wrote or vote for it .... LoL

[Hawker 800]

I fly mostly for a UK AOC holder, but do a little private (corporate) flying in a Hawker on the Isle of Man register. The aircraft is EU VAT paid, and rightly enough in Rotterdam we were ramp checked last month.

They asked the question (to which I could not answer/chose not to answer) as to why the aircraft was EU VAT paid but the operator was registered in a non EU country. I didn't know SAFA inspectors were concerned about aircraft VAT, when checked in LBG it is always customs.

Is this a new gotcha to catch out third country crews operating in Europe? (I'm UK licenced and F/O was FAA certified, both with IOM validations of course, both British passport holders)

This operator keeps a trip folder to give to the SAFA inspectors. I'm wondering if the VAT certificate was not in that folder, would they even have asked?

[deefer dog]

CL300,

I am not going to get involved in a p@ss@ng contest with you, and if you wish to put yourself up on the forum as the resident expert it's fine by me. However when you keep trotting out nonsense, and try to disguise it with misplaced and completely irrelevant references to VAT and "Fifth Rights," it demonstrates that you have not even bothered to read the legislation. Had you done so, and in this respect let's concentrate on the licencing issue and TCO's, you would know that the word "base" does not feature in it.

It matters not one iota where the aircraft is based, and neither does it make a scrap of difference where the crew may be based, live or even reside. What DOES matter is where the operator resides, and this has been clarified in the guidance material. Operator IS defined, and so too is how one determines where the operator really does reside. Read it CL300 and then by all means get back to me if you think I am crying or shouting.


Now it is very simple, you can shout and cry, BUT at the end of the day Ramp checks have started, fines are already levied.

Oh yes? Fined by whom precisely? You obviously know that SAFA produce records of inspections carried out and such fines are a matter of public record. With that in mind pray tell who has been fined and for what offense in this context they were prosecuted for? I question this because I really don't believe you, especially because of the recent announcement made by SAFA relating to how this matter will be treated...something I guess you may not have read.

If you wish to respond please be kind enough to restrict your answers to the matter in hand, show me where you believe the word "base" is referenced and in what context, and try not to cloud the matter with VAT, importation, Part 121 or any other fancy terms that you think may help improve your credentials.

If that's too complicated for you, and if you don't manage to find details of who got fined and where, perhaps you could answer me one very simple question:

ABC company is the operator of an M registered GLEX. ABC company has its principle place of business in Canada, but bases its GLEX at Linate in Italy for most of the year. The GLEX is crewed by Italian pilots who live in Milan, and they only have American licences which are validated by the Isle of Man. Are you suggesting that they are flying illegally, and if so please explain your logic.

[CL300]

ABC company is the operator of an M registered GLEX. ABC company has its principle place of business in Canada, but bases its GLEX at Linate in Italy for most of the year. The GLEX is crewed by Italian pilots who live in Milan, and they only have American licences which are validated by the Isle of Man. Are you suggesting that they are flying illegally, and if so please explain your logic.

Me I cannot care less..And I agree for the term operator place of residence; and if you just blank read the Annex VI of AIROPS 965/2012; you can live happy ever after. But, there is a but. And this is where **** hit the fan.
If your GLEX spends more than 185 days per year or one year with three years on the italian soil, it will have to be imported in the EU.The place you imported your GLEX in can be considered as place of operation ( but this is in the last resort, ask people whom import their plane in Denmark years ago) Your IOM company (even though not EASA but ICAO if i am not wrong) set for the purpose of owning an asset outside Canada will be considered the operator. An aircraft, you like it or not has a base, you will find this information generally on the insurance contract. This base can be considered as the place of normal operations. Your crew base ( where they are resting or domiciled normally and are taking their duty from) can be considered as a base of operation ( ask RYR).
Your case is a bit short-cut and not thorough enough for me to give a definitive answer, and i charge 1000€ per day for auditing these things.
I can speak only from the cases i have, customers that are coming to me having been bitten by the system . Two recent examples:

CJ1 ( N registered, plane in Cannes, Operator/Owner in Belgium) Part.NCC being made in France in AMS having accepted the PRNAV approach and not having the proper SPA was fined "on spot" for 2500€, the owner came to me with the "invoice " in hand.
Falcon T7 registered,(French Crew, T7 validation, operator in San-Marino based in France Part.NCC french based) being Ramped checked in Romania, aircraft impounded for 24 hours waiting for a Fax to confirm that the EFB usage was operating under the proper LOA .

I have a lot of these, and honestly , i'am just fixing things. I do not want to be right or wrong , i just tell you that this is what is happening NOW. The audits are set to happen from february ( this is at the place of business, and i have already dates set from various countries agencies to operator, to check the archives, the manual, the crew records etc...)
So, this is how it is, and one more i am not judging if it is ok or not ok.

To come back to your GLEX, a second advice would be nice....

[deefer dog]

And I agree for the term operator place of residence; and if you just blank read the Annex VI of AIROPS 965/2012; you can live happy ever after.

Good, I'm pleased you have that straight now so hopefully you will drop the word "base" when dishing out your free advice.

Of course you couldn't leave it at that could you? Now you introduce more red herrings that have nothing whatsoever to do with the subject matter. What has EFB's or operating approvals (PRNAV in your example) got to do with TCO's and the licences that TCO crew should have? Absolutely NOTHING.

I wouldn't let you fix anything more complex than a food mixer, let alone let you get near to the paperwork of my airplane, but hey ho if you have happy customers good for you. I hope that the time you spend here every day posting drivel doesn't impinge on getting your clients out of the trouble that you probably got them into.

I'm out of here!

[CL300]

i hope to meet you face to face one day, it will be interesting discussion. Well , you know , since i spend a lot of time in front of a computer ( for obvious reasons lol) I have some breaks during my days, and i am always interested in what is written here and there.

I am not a counselor, what i just say is there is regulations, the spirit of regulations, and what the enforcement in countries are. Period.
The broader view on my examples above is the fact that authorities are indeed looking deeply into NCC, much deeper than they use to. My advice is not based solely on what i think is the best, it is backed by law firms, various DGCA or CAA or LBA or whatever authority you can think of, and what they will ultimately choose as an option fi they do not find suitable material.
You need to open your mind a bit more...
The thing is that you will not come back here telling your curse, on the other hand, i know that the operations that i set up for my customers are at time of issue bulletproof; now they have to follow the book, but this is not of my responsibility.
I audited them, WE produced the paperwork, I trained them, now they have to do it...
And I will quit this discussion as well, since my last two manuals are in the final stage, and i am moving to new stuff.
You have my deepest sympathy

[Harriko]

Well regarding my previous question about requiring a CessnaSET...If my Cessna is N-registered can an EASA ATO do the SET-training with an N-registered aircraft? ORA.ATO.135 just states that

ORA.ATO.135 Training aircraft and FSTDs
(a) The ATO shall use an adequate fleet of training aircraft or FSTDs appropriately equipped for the training courses provided..

I can not locate any requirements that the aircraft must have CofA or ARC issued by an EASA-country. So is it possible to do the training with N-reg in EASA-country? Atleast the EASA-ATOs in the USA seems to do their training with N-registered planes...

-Harri

[Journey Man]

Deefer,

Your input to this forum would be more valuable if it featured less personal insults and snide remarks, and focussed more on the discussion.

[CL300]

Harriko, yes you can, but you need an EASA CRI/TRI. there is some limitations depending on the country, like the flight can only be done within the country of issuance of the TRI, etc.. but again, this is not cast in concrete.
Your issue will be to find an ATO with the actual plane and program approved.
I do not know about Finland, and a call to you authority is sometimes faster than gathering informations here..

[Harriko]

Harriko, yes you can, but you need an EASA CRI/TRI. there is some limitations depending on the country, like the flight can only be done within the country of issuance of the TRI, etc.. but again, this is not cast in concrete.
Your issue will be to find an ATO with the actual plane and program approved.
I do not know about Finland, and a call to you authority is sometimes faster than gathering informations here..
ATO is not a problem. Buying a plane will require just a couple of euros...

Just wanted to hear if someone knows a specific rule that prohibits the usage of third country registered. I read through the Commission regulation 1178/2011 and wasn't able to find anything that would deny this.

And Finnish CAA is on weekend leave and I am about to contact them tomorrow and ask if they would approve the training.

[CL300]

What i can tell you is that there is an ATO in France doing its EASA rating on N registered CJ. Not only for the "bounces" but as well for a part of the syllabus, since the sim is only a fixed based one.

[jtelling]

The requirements regarding validations for those flying non EASA aircraft for remuneration have been in the making for sometime. Policy at the CAA is
taking a very simple approach within the UK. If you fly a non EASA aircraft within Europe on a non EASA license (not just N reg but M and others) and are remunerated for doing so you must have applied and obtained a validation by last August. The validation is in essence an LST carried out by a TRE/SFE and the 1158 has to be submitted to the CAA to obtain the validation. You then have a year in which to obtain an EASA license, however in some cases the CAA "may" extend the validation for a further year if the applicant can demonstrate that they are completing their exams. The regulations only apply to those who live in Europe and the aircraft is based in Europe. If the aircraft is registered outside Europe but actually spends its time within you are not exempt the validation rules. Simply if the pilot has an address outside Europe but actually lives in Europe this also does not exempt you from the requirements.This has nothing to do with Part NCC. If you fly a non EASA aircraft but are not remunerated that is only fine until next April when the rules will apply to all. So any PPLs flying a SEP on a N reg based in Europe for example will need to obtain an EASA PPL. As for type ratings you can have a type rating put on to your EASA license and are exempt from a type rating only if you have 500 hours on type and pass an LST. You may also only have one validation so if you fly two types on an FAA license for example you have to have dropped one. As you would expect the UK CAA is strictly applying the rules and a ramp check can prove very embarrassing as some have already discovered. The rest of Europe appears not to be enforcing the requirements with such vigour. As a TRE who has completed a number of validations I am also aware that the authorities have been looking at where aircraft are really based a opposed to where the operator says that are based.

[mrangryofwarlingham]

When someone stoops to personal insult and being rude, I often think it is a cover up for a lack of knowledge.
Deefer.....does this resonate with you ?

[Beaver100]

I left the industry so I really don't care, but I see no examples in your posting of where this supposed rule is derived from ? It's not NCC as you say but if someone is relating it to another European law then I would be very careful. One good court case and win for the pilot or operator is highly likely in this scenario, and would have far reaching repercussions. Aircrew Reg 1178/2011 specifically relates the location of the operator as to which type of licence they should hold. If it's outside of Europe then it doesn't need to be an EASA licence or validation. Now, you or others can come back at me with a poorly worded version of something hastily written which is totally different from 1178/2011, but to rely on that in court when a pilot or operator is suing and has the specific wording of the European law means you will lose.

I doubt your examples above, same as CL300 postings, a friend of a friend down the pub told me such and such has been fined etc doesn't really add up. Or could there be a financial motivation for you to post ? Only asking.

If we ever leave the EU I would also suggest that it's highly unlikely that 1178/2011 could be enshrined into U.K. Law. I mean how ? The wording specifically relates to an operator based in the EU, and as we won't be then I fail to see how they can impose NCC or licence rules on European operators, and operators based outside of the EU will continue to be not affected by all of this mess.

[PSF2J]

Not entirely right jtelling, before you start panicking the light aircraft pilots. Released by the CAA in their EASA workings update today:

"The Agency (EASA) also explained that there is likely to be a further extension to the opt out period for pilots holding third country licences used in non- commercial operation, to allow additional time to agree changes to the bilateral agreement with the USA."

Remaining rules are entirely to do with where the "operator" is based, and provided it (aircraft) is not in EASA-land for half the year or greater, then fantastic, a validation is not required.

Beaver 100 sums it up quite succinctly.