The UK as an ICAO signatory commits to doing certain things but lots of the things it tells ICAO it does are actually things EASA does for it. When or if it leaves the EASA / EU there are a long list of things it will no longer have the technical ability to do and so either there is a massive increase in CAA capability (like 300 extra staff and five to ten years according to RAeS) or there is a load of state differences being filed by the UK and the associated risk control actions by other states for dealing with non-compliant signatories.

Picking on one tiny bit of Annex 19 .. it requires a system to collect, analyse and exchange safety data. How do we do that today...oh look it's via a pan European system that the UK only has access to through its membership of the EU / EASA. So come Brexit day, without an agreement, the UK loses access to a central support of its state safety program. Now maybe the CAA has kept the software for the MOR scheme kicking about on an old database somewhere and can solve this one... but this is just one of a very very long list of technical capabilities the UK is required by ICAO to have and will no longer have. Multiply this by everything else currently done by EASA and then think of the damage done by a decade of Cat 2 status to the UK industry.

Exactly. EASA is an EU club that has nothing to do with the ICAO. The UK is already a member.

It still does not solve my problem.

Daysleeper

You appear to be misunderstanding ICAO. The UK and all the other states of the EU are independently members of ICAO, indeed seven of them including the UK are permanent members of the ICAO council. It follows then that anything that EASA does is not in conflict with ICAO and EASA has never sought to be so.

Even if Brexit should happen without agreement there is nothing to prevent the UK continuing as an EASA operator, indeed EASA would like the whole world to join them.

Something I pray will happen!! The crass stupidity of Brexit will rob us of our voting seat at the EASA table but hopefully we will stay members in the Norway/Swiss style. To leave EASA will be a disaster of biblical proportions not only for the flight training industry but UK aviation as a whole. No number of nationally issued UK licences will make up for the loss of EASA privileges that so many of us rely on for a living. To think otherwise is just "fraggle rock" mentality.

I'm very sympathetic to the concerns that people like bose-x express. There is so much rubbish out there spurred on by amatuer dramatists. As many have already suggested the option to transfer the admin of your licence to another EASA state is an option, now! The Dept. of Transport (CAA), who will ultimately decide, in truth, will find it hard to refuse a UK citizen the issue of a UK licence based on a current held EASA ATPL/CPL/PPL licence, having previously forced the UK pilot down that path in the first place.

Although you cannot hold two EASA aeroplane licenses you can of course hold as many non EASA licenses as you choose. How these would be maintained is the relevant question.

It is true the EU parliament sans the UK will have the final vote but that in the main is irrelevant. The real work is dome in the working groups made up by representatives of all members. The working groups are constituted primarily by relevant professionals although I'm told some countries do send politicians to these groups. So, if the UK remains in EASA it will hopefully continue to influence.

You seem to be misunderstanding my ICAO post. I'm not saying the UK would leave ICAO, I''m saying that where the UK currently can point to its ICAO compliance in the future it will have to invest in staff and capability to replace EASA in-order to continue to do so. It is widely reported by both the CAA , RAeS and others that this cannot be done by Brexit day.

If the UK can stay in EASA then great, even better if it can stay as a full member... but that relies on there being a deal done and at the moment the UK government position is that a no-deal exit is the most likely scenario and the only deal they are prepared to offer is one that has been rejected by the EU. There are, approximately, 2 months left to agree a deal in time for it to be ratified. The UK is on the edge of a cliff and still arguing with itself about whether gravity does or doesn't exist.

As have I. However...... You can SOLI licence and ratings Including Instructor ratings, BUT you cant SOLI Examiner approvals. Examiners are appointed on a national basis and I have yet to find a country that will appoint a newly SOLI'd pilot as an Examiner. Just like the UK they expect you to have in depth experience and knowledge of your NAA before even considering your application. As a huge amount of my work is Examining its a show stopper for me......

I seem to be the exception to your rule. I was appointed a TRE shortly after changing state of licence issue.

A TRE is actually the outsider in the this discussion as it would normally be appointed as part of the day job flying for an airline or other AOC operator. Its the FE/CRE/IRE stuff that is more difficult as that is a result of progression. Every NAO I have spoken to so far have refused to transfer Examiner Ratings.]

For what its worth CAA statement 11 Sept:

They did re-issue all pilot licences a few years ago to include "ELP"

The full CAA statement in response to the Sky article:

Commenting on today's Sky News story on UK aviation and Brexit, Mark Swan, Group Director of Safety and Airspace Regulation at the UK Civil Aviation Authority, said:

“It is misleading for Sky News to say that pilots would need to renew their pilot's licence in a 'no-deal' Brexit scenario. Both commercial and private UK pilot licences would remain valid for use on UK-registered aircraft as the United Kingdom is a signatory to the International Civil Aviation Organisation (ICAO) Chicago Convention. Our licences are internationally recognised - including by the European Aviation Safety Agency (EASA) - both now and after 29 March 2019.

“The CAA will continue to issue and reissue pilots' licences when they are lost, damaged, when details need to be changed or pilots' privileges updated as we do now. Over time, this would include removing references to EASA - a purely cosmetic change. There will be no requirement for licences to be re-issued for any other reason meaning that there will be no change to this process.

“The CAA also strongly refutes any suggestion that we are concerned about our ability to provide safety oversight to the UK aviation industry should no-deal be reached between the UK and the EU. The safety of passengers, crew and those on the ground remains our absolute priority and nothing has changed in this respect. Sky News has unfortunately confused EASA approval of new aircraft and component design with our existing national safety oversight obligations.

“As a responsible regulator, the CAA has been planning for all eventualities in the negotiations, including that of a 'no-deal', for some time. Our planning and contingency is advanced and we continue to work closely with the Government to prepare the industry for all scenarios.”

are you guys really saying that you can't trasfer examiner tating like IRE or FE?

I can't find anything on that matter that would prevent that.

Please tell me you are wrong!

Each State appoints Examiners to meet its own requirements. There is no process for transfering an Examiner Certificate between States. A pilot who transfers SOLI would need to apply to the new Authority for an Examiner Certificate.If you hold a multitude of certificates that could be a lengthy process.

The doom-mongers are doing my head in. Both sides want a deal so only the most incompetent and lemming-like of negotiators could ever manage to end up without one.

(Oh, hang on a minute...)

A friend when moving from Belgium CAA to the IAA (for a well know operator) had all his examiner rating transferred at the same time. FE, IRE, CRE, FIE and TRE. the only thing that was not transferred was Senior Examiner.

I do not think the IAA have their own examiner course yet and rely on other authorities course.

An other friend, SOLI to Luxembourg, just had to make a AoC with a Luxembourg SE to regain his FE.

I wonder how much income the CAA will lose as airlines and pilots move their operations/licences to other EU Member States? The 2019 CAA Scheme of Charges consultation, due out next month, should prove interesting

I already approached them. If i Was flying for Ryanair they would do it. But as a third party with no other connection they are not prepared to do it. Currently having the conversation with Austro Control so will report back on the answer.

Just FYI and I appreciate I am a rotary pilot, the Belgian CAA will accept without question my FE / FIE / IRE certificates based on my UK issued EASA if that helps

That migh be to do with not having the capability to train their own and using UK resoures to do it. I trained a Belgian Examiner a few years ago.

Hey Whopity,

I filled out the form SRG1104 and have applied for a UK National ATPL(H) on the basis of my UK issued EASA ATPL(H).

I am not entirely clear though which type rating can go onto the UK ANO license, since my EASA license has a heavy multi-engine helicopter type rating on it - which is a "EASA" aircraft.

After having a look at the list of "Annex II to Regulation 216/2008" aircraft, it appears I would have to get rated on either a single-seater helicopter or some vintage model:
https://www.caa.co.uk/general-aviati...asa-aircraft-/

Any rotary PPruner out there who's been through this process? Any leads on concrete aircraft ratings currently available in the market that could serve the purpose of Annex II?

Many thanks.

Peter

In my experience, any valid ratings that are on your EASA licence will appear on your National licence.

Regulation 216/2008 has been repealed as of 11 September 2018 (over 2 months ago) and has been replaced by Regulation 2018/1139 - Annex II is now Annex I. Don't you just love the way that our 'competent' authority keeps us so well informed of fundamental changes in the law?

Don't you remember they sent out a letter saying that changes were on the way and its up to you to find out, because we are not going to tell you. So far they have kept to their word however; it does appear that they don't actually know when the changes took place.

If I may append my case and question:

I hold a UKCAA issued EASA CPL(A)
Long ago (2003) I have been flying a Piper J3, now a non-EASA a/c.
Now just that remote J3 experience may not be bring any rights, but can some training (plus Skills Test?) gain me a J3 non-EASA "type" rating and a UK ANO CPL?
If so, can I get ratings held on my UKCAA issued EASA licence copied into that UK ANO CPL?
The aim obviously is to maintain a UK licence, the non-EASA variant, and transfer the UK-EASA licence to a non-UK EASA licence, having all ratings (except J3) on both.

Thanks for any thoughts.

jr

My understanding was that the purpose of the National License was to allow pilots to fly aircraft that are still regulated by individual national authorities. This impression has certainly been reinforced after contacting the UK CAA licensing department, as the licensing officer describes issuing a National License as an exception under specific circumstances that justify doing so - not as a right.

The Air Navigation Order at article 152 requires CAA to grant a UK pilot's licence. If a suitable application is turned down then proceed with a regulation 6 appeal and if that fails seek a judicial review. Alternatively each of us can follow the CAA example and selectively ignore bits of law that are inconvenient.

Many thanks Selfin, I appreciate your input - however Brexit it just around the corner and I would hate to move in the direction of a judicial review (Aware that as I write this the government is still working on a deal). I find it somewhat confusing when the CAA uses so many "may" and present it as a conditional process. If one already holds a EASA license issued by the CAA, then issuing a national license should be a mere formality.

A J3 is covered by an SEP Class rating. So long as you have a valid SEP Class rating it can go onto either licence. Of course you don't need a UK licence to fly the J3 as it would also be covered by the SEP on an EASA licence which is rendered valid on UK registered (AnnexI) aircraft.

Thanks for clarifying.

jr

So finally received in the mail box my UK ANO license issued on the basis of my EASA license, however there are no entries under IR nor type rating - although I hold both an IR valid for multi-engine helicopters and an SK92 type rating (Which is an "EASA" aircraft). The only rating that was passed on was the FI(H).

This being the first time I hold a UK ANO license, would anyone to care to confirm whether national license can have an IR or a night rating on them?

Many thanks.

Peter

Your UK National licence should contain all ratings that were valid at the time of application. You should have provided them with certified evidence (Rating validity page) with your application of all rating you wished to have on the licence. If you did this then complain if they were not included..

Yes they can as long as they apply to class ratings and/or non-EASA aircraft types, but if they are for EASA aircraft types.

Here is some background, which some may know and others may not - plus some predictions:

In the beginning there were UK national licences that could carry ratings for any aircraft on the UK register.
Then JAR-FCL came along. These licences were still under national law and were added to the Air Navigation Order. Being national these could still include any aircraft type or class, including microlights etc. But some of the rules for JAR-FCL licences were different and they had the privileges of being valid for aircraft registered in any JAA Member State.
When EASA and Part-FCL arrived that all changed. Part-FCL licences are valid under European law and can only hold ratings for EASA aircraft. UK national licences remained valid under the ANO but only for non-EASA aircraft (formerly called Annex II, now Annex I due to a renumbering in the EASA regulation). JAR-FCL licences and rules were removed from the ANO leaving only the original national licences but with a prohibition on including EASA types/ratings in those national licences.
To try to prevent licences being issued with the wrong ratings, the CAA's computer software was amended to produce national licences and European Part-FCL with inbuilt rules that ensured that only ratings included in Part-FCL went on Part-FCL licences and only ANO ratings went on UK national licences. These cannot be overridden. And that is how it remains today as we are still in the EU.
So today, the CAA can't put anything associated with an EASA type on a national licence - computer says 'no'.
I am guessing that the machine and/or the staff see your night rating and IR as being tied to the SK92 and so not eligible to go on the UK licence.

So what about the B word?
The CAA's plan for Brexit is that they will copy all of the EU aviation regulations into UK national law, but alongside the ANO.
The draft legislation to do this has already been published. It is hard to read as it is just the edits, but what it appears to do is adopt all of the European texts but replacing: EASA with CAA, EASA aircraft with Part 21 aircraft; and non-EASA aircraft with non-Part 21 aircraft.
So if the UK leaves the EASA system the CAA will then issue UK-FCL licences in place of Part-FCL licences. The UK-FCL licences will have the ratings for Part 21 (EASA) aircraft and the old national licences will continue as now with just the ratings for non-Part 21 (non-EASA) aircraft types.
This will mean minimum change for licence holders and the CAA.

So, in years to come will they change it so the UK national licence can hold any rating?
I doubt it, because it is not essential and would cost a lot of time and money, not least in writing new software.

And my prediction is that the CAA is going to become very short of money very soon as other UK airlines follow Easyjet's lead and become European to protect their access to European routes. (It has been reported in the general media that Easyjet is moving it's AOC to Austria; that they have transferred 130 aircraft to the Austrian register; and over 3000 of their pilots now have Austrian issued Part-FCL licences). As I recall about 50% of the CAA's income is from the charges paid by UK airlines. I note that Thomson rebranded as TUI awhile ago (the name of their german parent company) and British Airways is owned by IAG who also own Iberia. So British Airways could just become 'BA' (as British Aerospace became BAES) and cut itself free from the UK and the CAA. I think that may happen whether or not Brexit goes ahead given that the government is incapable of giving industry any certainty for future planning.
So my prediction is that, within a few years of Brexit, there won't be any major UK commercial operators, even if we eventually settle on staying in the EASA system. Those companies will still be here but they will be European companies regulated by EASA and the remaining EU Member States. The CAA will be left with UK airspace, ATC, aerodromes and UK non-Part 21 (non-EASA type) aircraft - i.e. homebuilt aircraft, ex-military, microlights, gyroplanes and drones.
I understand this is called "taking back control".

Many thanks for your reply Whopity.

I certainly did provided the CAA with certified evidence with my application as required, otherwise they wouldn't even have processed my application.

What astonishes me though is that even if I hadn't submitted a certified copy of my current Part-FCL license with all my ratings, why can't the CAA just issue a document on the basis of what they have on file? Or isn't a there a file? I would have thought that they keep a database of pilots' records, specially considering the doc 155 procedure that requires the authority to officially confirm to another competent authority which type of license and ratings one currently has.

If one looses one's license for instance and can only provide the license reference number or even proof of ID, wouldn't the CAA be able to reissue a license on the basis of that person's identity without a "certified copy of the current license"?

I am all in favor of additional layers of security to confirm one's identity and prevent fraud, but it seems absurd that despite all the bureaucracy the licensing department cannot get this right.

All held in a big electronic pot and they Google it out. Once upon a time they had a microfiche with every bit of communication between you and them, but all long gone now. Its all down to the luck of the draw!

Oh and not to mention the actual form SRG1104 duly filled out with all the ratings on it (5. Ratings Held), so not only did the licensing officer have the "big electronic pot" to refer to, the certified copy of my license but also the form SRG1104 listing all the ratings. Despite all of that, still managed to cock-up. Perhaps things will get more efficient following a no-deal Brexit? :rolleyes: