EASA Lic for N Reg pilots domiciled EU.
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TN8B
This is an extract from a CAA letter to me which explains and rectifies an error re the 1500 hrs you mention. That is only for a Public transport validation see below
Yours below
And as posted by U and M
Just to get this clear re validations 1500 hrs multi crew only applies to validations for Public transport
This is an extract from a CAA letter to me which explains and rectifies an error re the 1500 hrs you mention. That is only for a Public transport validation see below
“The table is explicit for ATPL conversions where the holder has more than 1500 hours in multi-pilot aeroplanes may be granted a validation for multi-pilot operations in commercial operations. It also says that an ATPL holder with more than 700 hours may be granted PPL privileges. These requirements are the same as those that previously applied under JAR-FCL and we continue to interpret them as we did prior to 2012. The CAA view is that as the ATPL(A) includes the privileges of the CPL(A), the validation terms for CPL holders as specified in the table are also available to ATPL holders and will result in a validation with the privileges that would be granted to a CPL holder.”
This is not correct. What Annex III to the Aircrew Regulation actually says is that the holder of an ATPL(A) with more than 700 hours may be granted a validation that allows:
“Exercise of privileges in aeroplanes in operations other than Commercial Air Transport”
So such a validation would include ATPL(A) privileges - including being remunerated to act as flight crew - but only for flights that are not Commercial Air Transport (as defined in EU regulations).
I apologise for this error and the confusion it has caused.
This is not correct. What Annex III to the Aircrew Regulation actually says is that the holder of an ATPL(A) with more than 700 hours may be granted a validation that allows:
“Exercise of privileges in aeroplanes in operations other than Commercial Air Transport”
So such a validation would include ATPL(A) privileges - including being remunerated to act as flight crew - but only for flights that are not Commercial Air Transport (as defined in EU regulations).
I apologise for this error and the confusion it has caused.
Because then you would need to add a restricted IR to the restricted CPL wouldn't you and, also, to be a pilot in command (on the validation at least), they require not only an ATP from the ICAO nation....but ALSO, they want you to have 1500 hours multi crew and 500 hours on type (lmfao.....re the validation, because if you had done the EASA licence, that requirement doesn't exist??? One rule for one....etc etc)
The validation involves proving you have an FAA ticket, demonstrating 1500 hours of multi crew time, a Class 1 EASA Medical being issued and also, an LST, on the type you want to fly if you want it added to your validation. I meet all this criteria, but have to do the LST (still planned for today unless I see a doc confirming the delay until 2017 from the CAA), which is valid for 6 months and would add my current type to my licence.
Last edited by Pace; 11th Apr 2016 at 20:27.
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Czech CAA
For the past eight years I've been flying G550-Nreg and a 737BBJ- P4reg out of Czech rep. With the new EASA plan to dismiss me, validation of my FAA ATPL license seems like a good idea to gain time to sit the freaking 14 exams, should I decide to go that route. Yet, the Czech CAA will only validate my FAA license to fly aircraft registered in the Czech rep! OK reg! How is that suppose to work? How valid is that validation if at all? And again, I can't get a strait answer from any authority, as of when I'll be flying illegally.
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All,
Thanks a lot for a very informative thread....
But it is a LOT of info to digest...
So... in order to understand my own case :
Flying a Part 23 Biz Jet on a VP-xx ticket based on a FAA ATPL License, in a European country.
Private operation, NOT Charter (Part 91, NOT Part 135, in FAA language...)
I also have an EASA CPL-IR, MCC, but I have not sat the dreaded 14 exams... hence I do NOT have a TR on the EASA licence.
What will happen ? When ? What can I do to continue flying ? (Do I need to sit the 14 exams or just part of them ?) Does the answer depend upon the number of flight hours I have on type (or total) ? Would the answer also differ if it was N-reg or M-reg ?
Thanks a million !
Leo.
Thanks a lot for a very informative thread....
But it is a LOT of info to digest...
So... in order to understand my own case :
Flying a Part 23 Biz Jet on a VP-xx ticket based on a FAA ATPL License, in a European country.
Private operation, NOT Charter (Part 91, NOT Part 135, in FAA language...)
I also have an EASA CPL-IR, MCC, but I have not sat the dreaded 14 exams... hence I do NOT have a TR on the EASA licence.
What will happen ? When ? What can I do to continue flying ? (Do I need to sit the 14 exams or just part of them ?) Does the answer depend upon the number of flight hours I have on type (or total) ? Would the answer also differ if it was N-reg or M-reg ?
Thanks a million !
Leo.
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Hi the answer is we don't know yet what is going on rumour has it that there has been a big legal challenge against the EASA regs by believe it or not the french and the chaos that has caused has meant the month delay in formalising the april 2017 extension.
EASA promised a BASA for both FAA PPL stuff and then would move onto FAA Commercial stuff.
There are 8000 FAA Pilots based in the EU so its EASAs priority to make a transition pain free. My guess is the vast majority are PPLs
What I am not sure of is the number of non EASA rated pilots flying commercial in the EU a much smaller and maybe insignificant number so maybe the motivation to sort something for us in a transition isn't great
The french shout when they don't like something and usually get it fixed us lot we also have a case but will slip through the net uncomplaining and unnoticed if EASA have their way
Again will keep you posted soon on a possible move for us which I don't want to mention if its a dead end
Pace
EASA promised a BASA for both FAA PPL stuff and then would move onto FAA Commercial stuff.
There are 8000 FAA Pilots based in the EU so its EASAs priority to make a transition pain free. My guess is the vast majority are PPLs
What I am not sure of is the number of non EASA rated pilots flying commercial in the EU a much smaller and maybe insignificant number so maybe the motivation to sort something for us in a transition isn't great
The french shout when they don't like something and usually get it fixed us lot we also have a case but will slip through the net uncomplaining and unnoticed if EASA have their way
Again will keep you posted soon on a possible move for us which I don't want to mention if its a dead end
Pace
Last edited by Pace; 13th Apr 2016 at 07:10.
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I was made aware several years ago that there was going to be a change of licensing regulations in Europe, so I completed my EASA studies and earned my EASA ATPL.
Many colleagues also did this too.
I sympathise with everyone who is concerned for their career, but this has been on the cards for a long time. I understand both sides of the argument but to me, European job = EASA licence, Worldwide job = FAA licence.
When I spoke to the UK CAA, they said the regulation change will come into effect sooner or later.
Many colleagues also did this too.
I sympathise with everyone who is concerned for their career, but this has been on the cards for a long time. I understand both sides of the argument but to me, European job = EASA licence, Worldwide job = FAA licence.
When I spoke to the UK CAA, they said the regulation change will come into effect sooner or later.
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Spacecadet
I fully understand your position and why you did the EASA ATPL exams I can also understand the EU and elements within the EU regretting the huge numbers of mainly FAA aircraft which have developed over 40 years legally within the EU.
Who is at fault the pilots and aircraft owners or the regulators over all those years.
As stated EASA had a clean sheet could have saved the EU a pack of money by incorporating the FAA tried and tested as well as universally accepted system and adjusted that for EU specific needs
Instead they chose to create their own regulations doing exactly what forced so many towards FAA in the first place.
Aviation knows no boundaries and the world is a shrinking place which will mean that in the future it will become more important for pilots to work in one or other country or even another continent.
Safety is about standardisation less scope for mistakes and I see EASA as a huge missed opportunity to reduce costs and really support aviation world wide
The market place rules only a stick works in communism or dictatorships and had the EU put something equally attractive and cost effective in place the problem would have died naturally.
Nevertheless we have EU laws on rights to work and discrimination laws and not everyone can trundle off to a full time school for six months and have a job at the end of it or because of family commitments don't suit 1 to 2 years distance learning. That is not even looking at the costs of getting and maintaining those licenses for 2 registers
the EU have a moral obligation to those people to make sure they can continue working till retirement age.
If I was 40 I would do the same as you with maybe 27 years flying ahead, plenty of earning time to draw back the large costs of achieving and maintaining dual licenses with an option to work public transport in Europe
But in my case I don't have that time
Others are happy flying private aircraft and do not want to fly public transport
Grandfather righting was always an accepted practice to protect pilots from legislation damage which through no fault of their own would severely damage their livelihoods and occupation
I see NO reason why EASA and the commission could not meet their moral human right obligations by issuing these pilots with restricted ATPLs ? restricted to NON public transport with at most a pass in Air Law. That would save any back door entry to an EASA unrestricted ATP and would help a lot to a steady transition over time without damaging the pilots Pilots caught up in this
Pace
I fully understand your position and why you did the EASA ATPL exams I can also understand the EU and elements within the EU regretting the huge numbers of mainly FAA aircraft which have developed over 40 years legally within the EU.
Who is at fault the pilots and aircraft owners or the regulators over all those years.
As stated EASA had a clean sheet could have saved the EU a pack of money by incorporating the FAA tried and tested as well as universally accepted system and adjusted that for EU specific needs
Instead they chose to create their own regulations doing exactly what forced so many towards FAA in the first place.
Aviation knows no boundaries and the world is a shrinking place which will mean that in the future it will become more important for pilots to work in one or other country or even another continent.
Safety is about standardisation less scope for mistakes and I see EASA as a huge missed opportunity to reduce costs and really support aviation world wide
The market place rules only a stick works in communism or dictatorships and had the EU put something equally attractive and cost effective in place the problem would have died naturally.
Nevertheless we have EU laws on rights to work and discrimination laws and not everyone can trundle off to a full time school for six months and have a job at the end of it or because of family commitments don't suit 1 to 2 years distance learning. That is not even looking at the costs of getting and maintaining those licenses for 2 registers
the EU have a moral obligation to those people to make sure they can continue working till retirement age.
If I was 40 I would do the same as you with maybe 27 years flying ahead, plenty of earning time to draw back the large costs of achieving and maintaining dual licenses with an option to work public transport in Europe
But in my case I don't have that time
Others are happy flying private aircraft and do not want to fly public transport
Grandfather righting was always an accepted practice to protect pilots from legislation damage which through no fault of their own would severely damage their livelihoods and occupation
I see NO reason why EASA and the commission could not meet their moral human right obligations by issuing these pilots with restricted ATPLs ? restricted to NON public transport with at most a pass in Air Law. That would save any back door entry to an EASA unrestricted ATP and would help a lot to a steady transition over time without damaging the pilots Pilots caught up in this
Pace
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"Riddle me this.....if I get a Part FCL....which one am I flying on? Both? Do I take off in France on my Part FCL and land in Teterboro on my FAA?? Or vice versa? At which point in flight am I swapping???"
TN8B posted this and i didn't see any reply yet.....so I will have a punt....
You take off in France using your British Television licence (as it's an EASA state( and land in Teterboro on your "Fishing licence". The point at which you swap licences will be your ETP over the Atlantic I think, or it may have to be the exact Lat/Long equal distance point in the NAT's.....I'm not sure?!!
It's a good point. You can't fly on TWO licences....so why make people hold two that don't need them? This is where so many people on here are getting their knickers in a twist. Don't offer a back door to an FAA ATP holder, that will allow that holder to fly for easyJet or NetJets or whoever, by getting a validation.....but by the same token, don't then also say that their licence cant be used to fly private ops, simply because the operation is EU based. It makes no sense. The Status Quo would remain if they just issued a restricted ATP (or whatever ticket that person needs to hold, to carry on doing what they are doing now) with the restriction being that their Third Country Licence has to be valid (medical s in place etc) in order for the ATP (Restricted) to be valid!! Easy! That way, if you want to do an EASA ATP (full), or do an EASA one and an FAA one to open up more jobs....hell, even an Aussie one, a Canadian one and a blinking Russian one, they can do.....the only limits would be where the HOLDER decides to set them....not EASA, with ZERO JUSTIFICATION!!!!!!
I think, somebody also mentioned, the M reg based in the USA regulation and that those aircraft have to leave at some point, even for a day, so that they are not U.S based. That's exactly how it is for the N/VP/A6/P4 etc etc in Europe, unless they want to pay the local VAT/Taxes etc.....which MANY light aircraft do pay (because its a ball ache flying out of the EU due time and distance etc....puddle jumpers struggle with that) but, most foreign reg' aircraft don't....because escaping the EU is easy and done regularly....which is why these people own the sodding things in the first place!! I know of several EU operators now that specifically own N registered, in the EU, so that their frequent visits to the U.S, don't have the added complexity of having to pre-notify the TSA/Immigration lot about every place they intend on visiting and who is on board etc, which you have to do if you're M reg or EU reg. So, these guys fly on their N reg licences and I know of two that have let their EASA licences lapse because they don't need to use them.
TN8B posted this and i didn't see any reply yet.....so I will have a punt....
You take off in France using your British Television licence (as it's an EASA state( and land in Teterboro on your "Fishing licence". The point at which you swap licences will be your ETP over the Atlantic I think, or it may have to be the exact Lat/Long equal distance point in the NAT's.....I'm not sure?!!
It's a good point. You can't fly on TWO licences....so why make people hold two that don't need them? This is where so many people on here are getting their knickers in a twist. Don't offer a back door to an FAA ATP holder, that will allow that holder to fly for easyJet or NetJets or whoever, by getting a validation.....but by the same token, don't then also say that their licence cant be used to fly private ops, simply because the operation is EU based. It makes no sense. The Status Quo would remain if they just issued a restricted ATP (or whatever ticket that person needs to hold, to carry on doing what they are doing now) with the restriction being that their Third Country Licence has to be valid (medical s in place etc) in order for the ATP (Restricted) to be valid!! Easy! That way, if you want to do an EASA ATP (full), or do an EASA one and an FAA one to open up more jobs....hell, even an Aussie one, a Canadian one and a blinking Russian one, they can do.....the only limits would be where the HOLDER decides to set them....not EASA, with ZERO JUSTIFICATION!!!!!!
I think, somebody also mentioned, the M reg based in the USA regulation and that those aircraft have to leave at some point, even for a day, so that they are not U.S based. That's exactly how it is for the N/VP/A6/P4 etc etc in Europe, unless they want to pay the local VAT/Taxes etc.....which MANY light aircraft do pay (because its a ball ache flying out of the EU due time and distance etc....puddle jumpers struggle with that) but, most foreign reg' aircraft don't....because escaping the EU is easy and done regularly....which is why these people own the sodding things in the first place!! I know of several EU operators now that specifically own N registered, in the EU, so that their frequent visits to the U.S, don't have the added complexity of having to pre-notify the TSA/Immigration lot about every place they intend on visiting and who is on board etc, which you have to do if you're M reg or EU reg. So, these guys fly on their N reg licences and I know of two that have let their EASA licences lapse because they don't need to use them.
Last edited by Underrated and Moderated; 14th Apr 2016 at 22:50. Reason: Irrelevant
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Just to clear up the point of which license do you start and end the flight with ? It's one! the FAA license
Your EASA license has NO legal bearing on an FAA aircraft other than itself an excemption
This is purely a legal stipulation concocted to say our licenses are harder to get, more expensive but not better
For that reason if we make you get our licenses too their is no benefit to getting your licenses in the first place
If we force you to get our licenses we don't have to compete in the market by offering something better or more attractive than the FAA system and what's more we can give more of your cash to training organisations to get licenses that hold no validity on your aircraft and that you have no practical need for
Pace
Pace
Your EASA license has NO legal bearing on an FAA aircraft other than itself an excemption
This is purely a legal stipulation concocted to say our licenses are harder to get, more expensive but not better
For that reason if we make you get our licenses too their is no benefit to getting your licenses in the first place
If we force you to get our licenses we don't have to compete in the market by offering something better or more attractive than the FAA system and what's more we can give more of your cash to training organisations to get licenses that hold no validity on your aircraft and that you have no practical need for
Pace
Pace
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Old thread..... What the hell is going on now?! I had a "battle" with the CAA earlier this year....
I am now, unemployed...jobless (not really because of the reg's changed...more from the ex CP being a complete pile of chicken sh**...long and unbelievable story)....anyway....I cant get another job in the EU, because I only have an FAA ticket. I have looked everywhere...unless an aircraft is OPERATED outside the EU/UK/EASA States....then the FAA ticket is useless.
It feels like EASA killed my career!
SO.....who do I sue? Seriously though....what do I do beyond the 14 exams (have started, but fitting in the study around family life (8 year old and 2 year old) and a wife who has this year, been diagnosed and is being treated for cancer, is fu**ing difficult
I am now, unemployed...jobless (not really because of the reg's changed...more from the ex CP being a complete pile of chicken sh**...long and unbelievable story)....anyway....I cant get another job in the EU, because I only have an FAA ticket. I have looked everywhere...unless an aircraft is OPERATED outside the EU/UK/EASA States....then the FAA ticket is useless.
It feels like EASA killed my career!
SO.....who do I sue? Seriously though....what do I do beyond the 14 exams (have started, but fitting in the study around family life (8 year old and 2 year old) and a wife who has this year, been diagnosed and is being treated for cancer, is fu**ing difficult
U A M,
I'm not an expert, but I don't think your correct with regards to "..unless an aircraft is OPERATED outside the EU..". I believe the requirement is that the OPERATOR is based outside the EU/EASA countries. In other words; a N reg, or any other non-EASA reg, aircraft can be operated on the respective states (in your case the FAA ticket) national license within the EU, provided that the operators head office/domicile is NOT in the EU. Again, I'm not an expert, but you may want to try and have this confirmed and perhaps what you are looking for, to get a job within the EU (on your FAA ticket), but with an operator that does not have it's domicile in the EU. Hope this helps somewhat.
I'm not an expert, but I don't think your correct with regards to "..unless an aircraft is OPERATED outside the EU..". I believe the requirement is that the OPERATOR is based outside the EU/EASA countries. In other words; a N reg, or any other non-EASA reg, aircraft can be operated on the respective states (in your case the FAA ticket) national license within the EU, provided that the operators head office/domicile is NOT in the EU. Again, I'm not an expert, but you may want to try and have this confirmed and perhaps what you are looking for, to get a job within the EU (on your FAA ticket), but with an operator that does not have it's domicile in the EU. Hope this helps somewhat.
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[QUOTE=Klimax;9885547]U A M,
I'm not an expert, but I don't think your correct with regards to "..unless an aircraft is OPERATED outside the EU..".
Hey Pal....Yes ...you are EXACTLY correct....
.....however, I worded my post poorly. The Operator has to be outside of the EU....for example, my last "Employer" is based in Luton...maintained in EGHH and OPERATED, from Guernsey (well, Stansted, but they have paperwork trail, phone number and email going via Guernsey)....!
This is, obviously, utter tripe and of course, as illustrated above, is a joke, as the OPERATOR in this case, is very clearly, really, physically, based in the UK. It's like meeting the Wizard of Oz behind the curtain, pulling levers when you go to their office and phone the "Guernsey based" dispatcher/planner...and all the green screen, fake backdrop magic falls away..!! Thats great....but if it's such an obvious loophole, why even bother with it? Why not just issue an FAA ATP holder, with a validation, for a specific aircraft, as long as his licence, 61.58, insurance blah blah is all current for the type, just the same as the IOM do?? This way, people like me (professional, 4000+ hour pilot with 4 jet types and multiple thousands of hours as PIC on them), keep their jobs and can find others if one private op goes down the swan....and the weekend warriors in their N reg King Airs, have to get themselves up to a higher level (with approved courses being attended etc). It's clearly not Public Transport and Private Jet Ops has a better (proven/fact) safety record than AOC companies anyway (I am lead to believe....I can probably find the fact somewhere). It makes no sense.
Lets face it....the likes of GAMA, TAG, JET et al are just after stamping out the little man and adding more aircraft to their managed fleet.....and, by utilising the loophole, the Fred in a Shed Operators, can continue to "Get around" the regs. Can "Get around" improving their fatigue management, their SMS and their SOP's.....its
useless. I'm currently
I'm not an expert, but I don't think your correct with regards to "..unless an aircraft is OPERATED outside the EU..".
Hey Pal....Yes ...you are EXACTLY correct....
.....however, I worded my post poorly. The Operator has to be outside of the EU....for example, my last "Employer" is based in Luton...maintained in EGHH and OPERATED, from Guernsey (well, Stansted, but they have paperwork trail, phone number and email going via Guernsey)....! This is, obviously, utter tripe and of course, as illustrated above, is a joke, as the OPERATOR in this case, is very clearly, really, physically, based in the UK. It's like meeting the Wizard of Oz behind the curtain, pulling levers when you go to their office and phone the "Guernsey based" dispatcher/planner...and all the green screen, fake backdrop magic falls away..!! Thats great....but if it's such an obvious loophole, why even bother with it? Why not just issue an FAA ATP holder, with a validation, for a specific aircraft, as long as his licence, 61.58, insurance blah blah is all current for the type, just the same as the IOM do?? This way, people like me (professional, 4000+ hour pilot with 4 jet types and multiple thousands of hours as PIC on them), keep their jobs and can find others if one private op goes down the swan....and the weekend warriors in their N reg King Airs, have to get themselves up to a higher level (with approved courses being attended etc). It's clearly not Public Transport and Private Jet Ops has a better (proven/fact) safety record than AOC companies anyway (I am lead to believe....I can probably find the fact somewhere). It makes no sense.
Lets face it....the likes of GAMA, TAG, JET et al are just after stamping out the little man and adding more aircraft to their managed fleet.....and, by utilising the loophole, the Fred in a Shed Operators, can continue to "Get around" the regs. Can "Get around" improving their fatigue management, their SMS and their SOP's.....its
useless. I'm currently
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Just wanted to bump this thread up....as some of the old names that were commenting and making a worthwhile contribution, have failed to comment or give their latest findings and I wondered if there was any new news. There are so many unanswered questions and I would like to try to establish if anyone has made any progress??
As a Brit with FAA licenses, I am stuck between volunteering my pilot/instructor time in the UK/EU (cannot earn without EASA licenses) and the same in the US (visa requirement).
I have focused on ground school and there is a small niche in defence where the civilian regulator does not exist. It gets to me that EASA schools can operate in the US with non-qualified (only validated) personnel, and the reverse is not allowed.
I have focused on ground school and there is a small niche in defence where the civilian regulator does not exist. It gets to me that EASA schools can operate in the US with non-qualified (only validated) personnel, and the reverse is not allowed.
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Yes....Instructing is another biased area. I have and have been, looking into the possibility of CFI/CFII....as there is a market for FAA training still (for the private owners), however, it's expensive and needs dedicated time. Are you (^^) a CFII?? If so, I may be able to put you in touch with an organisation that can give you some work...though, you still have the problem of being paid for your services!!
Everyone else seems rather quiet on here....I wonder if they are keeping their heads down on what has otherwise been, a thread with a lot of worthwhile contribution in the past
Everyone else seems rather quiet on here....I wonder if they are keeping their heads down on what has otherwise been, a thread with a lot of worthwhile contribution in the past
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[quote=Underrated and Moderated;9887970]
If the aircraft is based inside EASA land then the operation is governed by EASA. Here is extract from the rules:
GM1 ORO.GEN.105 Competent authority
NON-COMMERCIAL OPERATIONS
(a) For the determination of the principal place of business ‘activities referred to in this Part’ means
those activities to which Part-ORO, Part-NCC or Part-SPO apply. For organisations that also
exercise activities that are not subject to Part-ORO, Part-NCC or Part-SPO, the determination of
the principal place of business should consider that part of the organisation that is responsible
for the operation of aircraft subject to Part-ORO, Part-NCC or Part-SPO. For non-commercial
operations, this is usually the home base of the aircraft concerned, or the location of the flight
department.
U A M,
I'm not an expert, but I don't think your correct with regards to "..unless an aircraft is OPERATED outside the EU..".
Hey Pal....Yes ...you are EXACTLY correct.... .....however, I worded my post poorly. The Operator has to be outside of the EU....for example, my last "Employer" is based in Luton...maintained in EGHH and OPERATED, from Guernsey (well, Stansted, but they have paperwork trail, phone number and email going via Guernsey)....!
This is, obviously, utter tripe and of course, as illustrated above, is a joke, as the OPERATOR in this case, is very clearly, really, physically, based in the UK. It's like meeting the Wizard of Oz behind the curtain, pulling levers when you go to their office and phone the "Guernsey based" dispatcher/planner...and all the green screen, fake backdrop magic falls away..!! Thats great....but if it's such an obvious loophole, why even bother with it? Why not just issue an FAA ATP holder, with a validation, for a specific aircraft, as long as his licence, 61.58, insurance blah blah is all current for the type, just the same as the IOM do?? This way, people like me (professional, 4000+ hour pilot with 4 jet types and multiple thousands of hours as PIC on them), keep their jobs and can find others if one private op goes down the swan....and the weekend warriors in their N reg King Airs, have to get themselves up to a higher level (with approved courses being attended etc). It's clearly not Public Transport and Private Jet Ops has a better (proven/fact) safety record than AOC companies anyway (I am lead to believe....I can probably find the fact somewhere). It makes no sense.
Lets face it....the likes of GAMA, TAG, JET et al are just after stamping out the little man and adding more aircraft to their managed fleet.....and, by utilising the loophole, the Fred in a Shed Operators, can continue to "Get around" the regs. Can "Get around" improving their fatigue management, their SMS and their SOP's.....its useless. I'm currently
I'm not an expert, but I don't think your correct with regards to "..unless an aircraft is OPERATED outside the EU..".
Hey Pal....Yes ...you are EXACTLY correct....
.....however, I worded my post poorly. The Operator has to be outside of the EU....for example, my last "Employer" is based in Luton...maintained in EGHH and OPERATED, from Guernsey (well, Stansted, but they have paperwork trail, phone number and email going via Guernsey)....! This is, obviously, utter tripe and of course, as illustrated above, is a joke, as the OPERATOR in this case, is very clearly, really, physically, based in the UK. It's like meeting the Wizard of Oz behind the curtain, pulling levers when you go to their office and phone the "Guernsey based" dispatcher/planner...and all the green screen, fake backdrop magic falls away..!! Thats great....but if it's such an obvious loophole, why even bother with it? Why not just issue an FAA ATP holder, with a validation, for a specific aircraft, as long as his licence, 61.58, insurance blah blah is all current for the type, just the same as the IOM do?? This way, people like me (professional, 4000+ hour pilot with 4 jet types and multiple thousands of hours as PIC on them), keep their jobs and can find others if one private op goes down the swan....and the weekend warriors in their N reg King Airs, have to get themselves up to a higher level (with approved courses being attended etc). It's clearly not Public Transport and Private Jet Ops has a better (proven/fact) safety record than AOC companies anyway (I am lead to believe....I can probably find the fact somewhere). It makes no sense.
Lets face it....the likes of GAMA, TAG, JET et al are just after stamping out the little man and adding more aircraft to their managed fleet.....and, by utilising the loophole, the Fred in a Shed Operators, can continue to "Get around" the regs. Can "Get around" improving their fatigue management, their SMS and their SOP's.....its
useless. I'm currently GM1 ORO.GEN.105 Competent authority
NON-COMMERCIAL OPERATIONS
(a) For the determination of the principal place of business ‘activities referred to in this Part’ means
those activities to which Part-ORO, Part-NCC or Part-SPO apply. For organisations that also
exercise activities that are not subject to Part-ORO, Part-NCC or Part-SPO, the determination of
the principal place of business should consider that part of the organisation that is responsible
for the operation of aircraft subject to Part-ORO, Part-NCC or Part-SPO. For non-commercial
operations, this is usually the home base of the aircraft concerned, or the location of the flight
department.
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Some of my customers on part NCC have been audited.
When I advised them I played safe with the authorities.
If the aircraft was permanently in Europe EASA Land, Part NCC applies, full stop.
Then : If the owner flies as Single Pilot --> N Licence is enough ( "safety pilot" is not paid anyway)
IF the owner flies with a "Captain" or a "Crew" whom is(are) paid for the job this pilot(s) has to have both licences.(EASA + FAA)
In part NCC, you have to maintain the list of the pilots that are allowed to fly, as well as their training records.
So far, in both cases, the findings were not on this issue.
For the one interested, one of the finding was that a copy of the manual was not physically at the "home base" of the aircraft, and one training certificate was not updated ( even though the pilot had performed the said training), in the relevant part of the manual.
The other main one was the record keeping for a customer whom did not want an integrated solution ( and stick with paper), some flights were missing as well as W&B records for over flights.
As you can see, these were not great issues and have been corrected easily.
When I advised them I played safe with the authorities.
If the aircraft was permanently in Europe EASA Land, Part NCC applies, full stop.
Then : If the owner flies as Single Pilot --> N Licence is enough ( "safety pilot" is not paid anyway)
IF the owner flies with a "Captain" or a "Crew" whom is(are) paid for the job this pilot(s) has to have both licences.(EASA + FAA)
In part NCC, you have to maintain the list of the pilots that are allowed to fly, as well as their training records.
So far, in both cases, the findings were not on this issue.
For the one interested, one of the finding was that a copy of the manual was not physically at the "home base" of the aircraft, and one training certificate was not updated ( even though the pilot had performed the said training), in the relevant part of the manual.
The other main one was the record keeping for a customer whom did not want an integrated solution ( and stick with paper), some flights were missing as well as W&B records for over flights.
As you can see, these were not great issues and have been corrected easily.
Yes....Instructing is another biased area. I have and have been, looking into the possibility of CFI/CFII....as there is a market for FAA training still (for the private owners), however, it's expensive and needs dedicated time. Are you (^^) a CFII?? If so, I may be able to put you in touch with an organisation that can give you some work...though, you still have the problem of being paid for your services!!
Everyone else seems rather quiet on here....I wonder if they are keeping their heads down on what has otherwise been, a thread with a lot of worthwhile contribution in the past
Everyone else seems rather quiet on here....I wonder if they are keeping their heads down on what has otherwise been, a thread with a lot of worthwhile contribution in the past
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CL300 "If the aircraft was permanently in Europe EASA Land, Part NCC applies, full stop."..... Again, I am no expert, but I believe that the aircraft location has little impact. It doesn't say that in the regulations does it?? My understanding is that it's to do with where the aircraft is OPERATED from. My example above details this....I can name two Falcons (a 900LX and 1x2000) that are permanently based in the UK, plus multiple CJ's. One has an owner/pilot and employs another guy to fly alongside him and is operated on the N reg, officially, from NJ.....the other is a pi** taker so far as these reg's are concerned and employs full time crew (two of which have EASA licences...but the self proclaimed CP has just FAA licence). These aircraft have permanent hangarage/parking in the UK and the 900 certainly has all Mx carried out in the UK, has all crew living in the UK, has an owner that lives in the UK as a UK resident (though of course, like anyone with serious money, is able to hide the ownership of the aircraft through multiple companies, offshore) and is OPERATED from the UK, but by a company that has a "PO Box" or similar and a phone number, thats in Guernsey. This makes an utter farce of the reg's and Part NCC...! I can add a phone number, right now, to my mobile, thats a Mexican number if I want to, or Australian, or Brazilian.or anywhere in the World.....but I would be answering it in Berkshire!!!
"Then : If the owner flies as Single Pilot --> N Licence is enough ( "safety pilot" is not paid anyway)." Again, I am not convinced this is the case for a Jet or type that is listed as requiring a TR....?? I know one CJ4 owner who is a UK resident, has an FAA ticket, that flies with another FAA ticket holder, in an aircraft based in ***K and is owned, by a company, owned by the owner, that is in the IOM! So again, either they are doing it illegally, or they are legal and are covered and outside of Part NCC.
"IF the owner flies with a "Captain" or a "Crew" whom is(are) paid for the job this pilot(s) has to have both licences.(EASA + FAA)." Really?? See above....! There are owners who don't know the front of an aircraft from the back, that just sit in and be flown, that are employing people to manage and fly their aircraft, in the UK, that do not have EASA licences.... simples.
We know it's bureaucracy at its finest. We know it hasn't done anything for safety. We know that it hasn't helped many EASA pilots get jobs (as they also need FAA tickets if a plane is N reg) and it hasn't even managed to stopped the little worms (in some cases, not all), who operate aircraft off the back of fag packets, from the sheds in their gardens (sorry..."Garden Office"). What it has done, is completely people like me up, who have made a living from flying aircraft on N reg for years and years and, BEFORE I get the obligatory "...go and get your EASA exams done mate(y)...", I am in that process...however, with a very ill wife, 2 kids and a small business to run, that I need just to (nearly) stop myself from having my house repossessed and to keep food on the table, it is VERY difficult. Not to mention, that now my Multi Crew Type has expired, EASA want me to do 15 hours of flight training in a twin, to show I can fly a plane (4 type ratings and 4000 hours doesn't prove that anymore).
I'm just frustrated.....and gutted....and EASA do not show any signs of being sensible about it. If they were, then they would issue validations, like the IOM do, so that previously experienced, TR holders, could continue to work and those starting afresh, from scratch, on the back of Bank of Mum and Dad, would have to start from scratch. It's not rocket science and IS sensible and logical.
"Then : If the owner flies as Single Pilot --> N Licence is enough ( "safety pilot" is not paid anyway)." Again, I am not convinced this is the case for a Jet or type that is listed as requiring a TR....?? I know one CJ4 owner who is a UK resident, has an FAA ticket, that flies with another FAA ticket holder, in an aircraft based in ***K and is owned, by a company, owned by the owner, that is in the IOM! So again, either they are doing it illegally, or they are legal and are covered and outside of Part NCC.
"IF the owner flies with a "Captain" or a "Crew" whom is(are) paid for the job this pilot(s) has to have both licences.(EASA + FAA)." Really?? See above....! There are owners who don't know the front of an aircraft from the back, that just sit in and be flown, that are employing people to manage and fly their aircraft, in the UK, that do not have EASA licences.... simples.
We know it's bureaucracy at its finest. We know it hasn't done anything for safety. We know that it hasn't helped many EASA pilots get jobs (as they also need FAA tickets if a plane is N reg) and it hasn't even managed to stopped the little worms (in some cases, not all), who operate aircraft off the back of fag packets, from the sheds in their gardens (sorry..."Garden Office"). What it has done, is completely
people like me up, who have made a living from flying aircraft on N reg for years and years and, BEFORE I get the obligatory "...go and get your EASA exams done mate(y)...", I am in that process...however, with a very ill wife, 2 kids and a small business to run, that I need just to (nearly) stop myself from having my house repossessed and to keep food on the table, it is VERY difficult. Not to mention, that now my Multi Crew Type has expired, EASA want me to do 15 hours of flight training in a twin, to show I can fly a plane (4 type ratings and 4000 hours doesn't prove that anymore).I'm just frustrated.....and gutted....and EASA do not show any signs of being sensible about it. If they were, then they would issue validations, like the IOM do, so that previously experienced, TR holders, could continue to work and those starting afresh, from scratch, on the back of Bank of Mum and Dad, would have to start from scratch. It's not rocket science and IS sensible and logical.
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U&M
I am not discussing who is right or wrong, I just give my experience as a supplier/advisor for Part NCC operators and the two audits and the results.
As far as "operation" is concerned, one of the audited customer (pilot owner single pilot) has the operating part, ( company, address, secretary etc.) in Luxembourg, but the plane flies from France and is hangared there. After a meeting with both authorities, France was the one that had to approve the manuals and deliver the certificate.
I am not discussing who is right or wrong, I just give my experience as a supplier/advisor for Part NCC operators and the two audits and the results.
As far as "operation" is concerned, one of the audited customer (pilot owner single pilot) has the operating part, ( company, address, secretary etc.) in Luxembourg, but the plane flies from France and is hangared there. After a meeting with both authorities, France was the one that had to approve the manuals and deliver the certificate.