N-Reg hire uk?
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2D, I am very glad that you met that FAA lawyer, because below is a reply I had from the FAA on the very subject.
Q: Can one use the UK IMC Rating in a U.S. registered aircraft?
A: Response (FAA Expert) - 07/06/2005 10:27 AM
The U.K. IMC rating is the equivalent of a U.S. instrument rating
Of course, the above position is the exact opposite of what has been going around everywhere for the last few years, including authoritative articles in the aviation press.
Good to see it settled. It has caused quite a few people (IMCR holders) unnecessary grief, believing they are unable to fly IFR (which includes most night flight in the UK) in their N-reg between putting it on the N and finishing off their full IR.
Q: Can one use the UK IMC Rating in a U.S. registered aircraft?
A: Response (FAA Expert) - 07/06/2005 10:27 AM
The U.K. IMC rating is the equivalent of a U.S. instrument rating
Of course, the above position is the exact opposite of what has been going around everywhere for the last few years, including authoritative articles in the aviation press.
Good to see it settled. It has caused quite a few people (IMCR holders) unnecessary grief, believing they are unable to fly IFR (which includes most night flight in the UK) in their N-reg between putting it on the N and finishing off their full IR.
(e) Instrument rating. No person may act as pilot in command of a civil aircraft under IFR or in weather conditions less than the minimums prescribed for VFR flight unless that person holds:
(1) The appropriate aircraft category, class, type (if required), instrument rating on that person's pilot certificate for any airplane, helicopter, or powered-lift being flown;
Seems like a very odd way to interpret the sentence, 2D. There are different flavours of FAA IR, and it seems that "appropriate" refers to that. I can see that an IMC rating might be interpreted as "an appropriate instrument rating". I find it harder to believe that no instrument qualification at all might be interpreted as "an appropriate instrument rating"
Did the counsel express an opinion on the oddity of the wording in 61.3(a)(1) which requires a foreign licence to be issued by (rather than just "rendered valid by") the country in which the aircraft is operated? It strikes me that the latitude of interpretation of "appropriate" that you cite is no less than the latitude required to make 61.3(a)(1) at least consistent with foreign law like ANO Art 26(3)(b).
(1) The appropriate aircraft category, class, type (if required), instrument rating on that person's pilot certificate for any airplane, helicopter, or powered-lift being flown;
Seems like a very odd way to interpret the sentence, 2D. There are different flavours of FAA IR, and it seems that "appropriate" refers to that. I can see that an IMC rating might be interpreted as "an appropriate instrument rating". I find it harder to believe that no instrument qualification at all might be interpreted as "an appropriate instrument rating"
Did the counsel express an opinion on the oddity of the wording in 61.3(a)(1) which requires a foreign licence to be issued by (rather than just "rendered valid by") the country in which the aircraft is operated? It strikes me that the latitude of interpretation of "appropriate" that you cite is no less than the latitude required to make 61.3(a)(1) at least consistent with foreign law like ANO Art 26(3)(b).
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Given our previous interpretation of that sentence this new interpretation is tricky to come to terms with. Presumably the argument is that an IMC is an appropriate instrument rating if you are flying an N reg aircraft in a country that has such a rating.
There is an element of common sense to it though if you read it as meaning that you can do in your country what your country would normally allow you to do!
Academic at this stage for me!!
Editted to say that the statement from IO540 that the IMC rating is equivalent to an IR in the eyes of the FAA is a little further than I'd go!!!
There is an element of common sense to it though if you read it as meaning that you can do in your country what your country would normally allow you to do!
Academic at this stage for me!!
Editted to say that the statement from IO540 that the IMC rating is equivalent to an IR in the eyes of the FAA is a little further than I'd go!!!
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I think the 'appropriate' is there to stop people with a multi rating, but only an IR on singles, flying IFR on multis. A FAA PP certificate will include night privileges if you have undergone the required training (as most but not all do). Perhaps you could say that makes it appropriate for night flying in the UK? If your certificate is restricted to day by the FAA, it is restricted to day in the UK too. IO540's 'FAA expert' got it wrong (and it's not relevent to this thread anyway)
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The privileges of the IMCR are limited by the ANO anyway. It isn't necessary to add the usual qualifications "UK airspace, no Class A etc" because they are implicit. I actually listed these restrictions in my comms with the FAA.
It just means the IMCR privileges in an N-reg are what they would be in a G-reg. No big deal at all.
This does not contravene anything in the FARs; one cannot *categorically* argue that an
"Instrument Meteorological Conditions Rating"
is not an
"Instrument Rating"
when clearly it IS - you can takeoff, fly and land on instruments with it, albeit with the limitations we all know about.
This is one of those areas where one could play with words and read the regs between the lines for ever. An opinion from a regulatory agency is better than that, even if some don't like it.
I have also had a reply from a certain Euro country which specifically states that only the JAA IR is acceptable for IFR in its aircraft, and that the UK IMC Rating is not valid (even, of course, as one would be considering UK airspace). Now, that sort of statement is very different!
The privileges of the IMCR are limited by the ANO anyway. It isn't necessary to add the usual qualifications "UK airspace, no Class A etc" because they are implicit. I actually listed these restrictions in my comms with the FAA.
It just means the IMCR privileges in an N-reg are what they would be in a G-reg. No big deal at all.
This does not contravene anything in the FARs; one cannot *categorically* argue that an
"Instrument Meteorological Conditions Rating"
is not an
"Instrument Rating"
when clearly it IS - you can takeoff, fly and land on instruments with it, albeit with the limitations we all know about.
This is one of those areas where one could play with words and read the regs between the lines for ever. An opinion from a regulatory agency is better than that, even if some don't like it.
I have also had a reply from a certain Euro country which specifically states that only the JAA IR is acceptable for IFR in its aircraft, and that the UK IMC Rating is not valid (even, of course, as one would be considering UK airspace). Now, that sort of statement is very different!
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Sorry IO540, you have got it wrong - again.
I'll let you find the authoritative source 
Two things can be deduced from this.
1) Your FAA Expert is wrong.
2) The FAA have a different view on what IFR means. It may be IFR in the UK speak, but it isn't in FAA speak. I think that is why you can fly at night in the UK using a vanilla FAA PP certificate, the FAA don't consider it IFR so FAR 61.3(e)(1) doesn't apply.
Why not put it to the test. It is clear you don't want to descend to the low quality N reg rental fleet with their strange knobs. So go take the foreign pilot instrument proficiency test and head to your nearest FSDO with your IMCR and demand an FAA IR. Wave your email in their face and tell the inspector he is talking nonsense. See how far you get.
Holders of the British IMC privilege are not qualified to receive a U.S. instrument rating because the IMC privilege is
not as high a level of qualification as the instrument rating, and it confers no privileges for flights requiring compliance with IFR.
not as high a level of qualification as the instrument rating, and it confers no privileges for flights requiring compliance with IFR.
Two things can be deduced from this.
1) Your FAA Expert is wrong.
2) The FAA have a different view on what IFR means. It may be IFR in the UK speak, but it isn't in FAA speak. I think that is why you can fly at night in the UK using a vanilla FAA PP certificate, the FAA don't consider it IFR so FAR 61.3(e)(1) doesn't apply.
Why not put it to the test. It is clear you don't want to descend to the low quality N reg rental fleet with their strange knobs. So go take the foreign pilot instrument proficiency test and head to your nearest FSDO with your IMCR and demand an FAA IR. Wave your email in their face and tell the inspector he is talking nonsense. See how far you get.
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A google on the exact phrase immediately turns up
http://www.faa.gov/library/manuals/e...a/2_029_00.pdf
which contains (on page 7 of the PDF file)
(4) The British CAA may issue an instrument
meteorological conditions (IMC) rating. Holders of
the British IMC privilege are not qualified to receive a
U.S. instrument rating because the IMC privilege is
not as high a level of qualification as the instrument
rating, and it confers no privileges for flights requiring
compliance with IFR. IMC privileges can be used
only within the U.K. Therefore, a holder of the IMC
privilege is not eligible to take the Instrument-Foreign
Pilot knowledge test or be issued a U.S. instrument
rating.
most of which is an obvious statement of fact!
The sentence "confers no privileges for flights requiring compliance with IFR" is a problem, but then they immediately contradict themselves by saying "IMC privileges can be used only within the U.K" which of course includes IFR.
The latter part could easily be taken to mean to include an N-reg plane. Everything not explicitly prohibited is permitted.
Anyway, what does one take? A guidance manual for issuing piggybacks dated 19/12/2003, or a more recent emailed reply from the FAA to a question whose context was precisely worded (as I always do when writing these questions; the one-liner Q posted above is the FAA's summary) and asked if the IMCR is valid for IFR in an N-reg in UK airspace?
I am sure that searching faa.gov/library for more phrases will turn up more stuff we could pick apart.....
This type of apparent discrepancy (if indeed it is that) is well known to American pilots too. The CAA does it too; if you dig deep enough you will find a CAA flyer saying that GPS is unauthorised.
http://www.faa.gov/library/manuals/e...a/2_029_00.pdf
which contains (on page 7 of the PDF file)
(4) The British CAA may issue an instrument
meteorological conditions (IMC) rating. Holders of
the British IMC privilege are not qualified to receive a
U.S. instrument rating because the IMC privilege is
not as high a level of qualification as the instrument
rating, and it confers no privileges for flights requiring
compliance with IFR. IMC privileges can be used
only within the U.K. Therefore, a holder of the IMC
privilege is not eligible to take the Instrument-Foreign
Pilot knowledge test or be issued a U.S. instrument
rating.
most of which is an obvious statement of fact!
The sentence "confers no privileges for flights requiring compliance with IFR" is a problem, but then they immediately contradict themselves by saying "IMC privileges can be used only within the U.K" which of course includes IFR.
The latter part could easily be taken to mean to include an N-reg plane. Everything not explicitly prohibited is permitted.
Anyway, what does one take? A guidance manual for issuing piggybacks dated 19/12/2003, or a more recent emailed reply from the FAA to a question whose context was precisely worded (as I always do when writing these questions; the one-liner Q posted above is the FAA's summary) and asked if the IMCR is valid for IFR in an N-reg in UK airspace?
I am sure that searching faa.gov/library for more phrases will turn up more stuff we could pick apart.....
This type of apparent discrepancy (if indeed it is that) is well known to American pilots too. The CAA does it too; if you dig deep enough you will find a CAA flyer saying that GPS is unauthorised.
Last edited by IO540; 15th Nov 2005 at 16:14.
