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EASA proposal to stop N-reg

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Old 18th Jun 2008, 13:53
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EASA proposal to stop N-reg

This is the NPA

http://www.easa.europa.eu/ws_prod/r/...202008-17b.pdf

and if you go to page 159 of the PDF you find stuff on "3rd country" licenses.

This time, there isn't the old style parking ban on N-reg planes. They are now attacking pilot licenses, apparently on the basis of citizenship.

There is a specific attack on ICAO (non JAA) PPL/IR holders who will have to sit some of the JAA ATPL exams. It is not clear how ICAO (non JAA) CPL/IR holders are affected if merely exercising private privileges.

This appears to be a cleverly conceived and hard hitting measure which will be just as "popular" as the previous ones which were based on say 90 days' parking.

Whatever law results from this, it is AFAIK due to be in place in 2012.
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Old 19th Jun 2008, 03:10
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I wouldn't have thought that EASA had any say what-so-ever in who flies, or in what conditions, on an FAA licence at the controls of an N registered aircraft.

They may be able to get involved in the *residency* of an N registered aircraft - but licensing has (surely) got @#$% all to do with them.
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Old 19th Jun 2008, 04:45
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I must be missing something... where is the reference to citizenship?

It isn't clear, to me anyway, what all the stuff about "complete the skill test" and so on means... does it mean in the third country or does it mean in the "Member Country"? Presumably the former since otherwise it would mean that when a N-tail plane belonging to am American airline is flown into an EASA country, the pilot wuold have to stop off and do a skills test...? In which case surely it is just reflecting ICAO policy?

I don't understand item 5: "the period of acceptance of a licence shall not exceed one year". What does that mean?

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Old 19th Jun 2008, 06:42
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Lets get this in context, it is related to non JAA licence holders flying aircraft that come under EASA jurisdiction i.e. EASA reg aircraft. Nothing to do with N reg!

Para 1 says that ICAO PPLs may be acceptable to the authority; exactly the same as it is at the moment.

Para 2 relates to commercial licences and the process of validating them to conduct commercial activity in EASA Reg aircraft. Again exactly the same procedure as the UK currently adopts.
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Old 19th Jun 2008, 07:19
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where is the reference to citizenship?
There isn't, but this is a proposal, not the final law. The real thing would have to define the requirements somehow - because they cannot stop a 'genuine foreigner' flying into Europe on his ICAO PPL/IR.

Typically, this kind of thing would be hung on citizenship, or taxpayer status.

The French already determine the eligibility of foreign license validation (for use in an F-reg) on this kind of stuff (I have some examples).

I don't understand item 5: "the period of acceptance of a licence shall not exceed one year". What does that mean?
It probably means you have to do the checkride every year.

Lets get this in context, it is related to non JAA licence holders flying aircraft that come under EASA jurisdiction i.e. EASA reg aircraft. Nothing to do with N reg!
Whopity, we would hope you are right but it doesn't actually say that. The only clue to "commercial activity" is the word "operator" and that one can be interpreted both ways.

If you have some other document which contains explanatory notes, or any other support for what you say, please post it here. I would be delighted if you were right, of course.
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Old 19th Jun 2008, 08:38
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Hmmmm. I did tell you this was coming last year and you told me I was wrong IO.

My understanding of where the proposal is heading is for N Reg ops to continue but if the pilot is based in Europe over a certain period along with the aircraft the pilot will have to be dual licensed. How this is achieved is going to be an interesting question. Simple validation the same as the US and a foreign instrument test for IR pilots is possible but I suspect unlikely so more likely to be a subset of exams and a flight test. I don't believe there will be any difference between CPL or PPL holders.

This basically means that visiting airline aircraft and crews will be unchanged but those based in Europe under a flag of convenience will have to be dual qualified giving EASA 'oversight'. I think there will be something similar come out of the woodwork on maintenance as well.
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Old 19th Jun 2008, 08:55
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The NPA does specifically comment on requirements to allow an EASA area resident Operator to exercise the IR privileges of a 3rd country PPL in an aircraft registered in the 3rd country. I.e. it is specifically framed at PPLs not at all licence holders. There is a lack of clarity of what happens to a CPL/ATPL holder who does not or can not validate there licence for commercial privileges in the EASA area.


In the non-AOC context, the word Operator is commonly used and would normally mean the pilot (as compared to the owner).

Keygrip,

EASA has no say on who can fly an ICAO compliant aircraft, registered in an ICAO country, on a licence issued by or validated by that country. However, EASA can definitely dictate what you as a European Citizen can and can not do. It is slightly more ambiguous what they can and can not do with regard to a resident alien exercising ICAO privileges conferred by a country outside the EASA region.
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Old 19th Jun 2008, 09:05
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EASA can also dictate what happens in European airspace. If you are based in Europe and want to fly through it you will need to meet whatever rules they set......
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Old 19th Jun 2008, 09:21
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Although they can only do this in an ICAO compliant way, which on this particular issue will not be achieved by rules around EASA's airspace. But can be achieved by rules imposed on people already signed up to European Rules being imposed on them .
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Old 19th Jun 2008, 09:27
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I guess that will be the key way of doing it. But it is my understanding that they can also file airspace differences as well.

So visiting crews are exempt as they are only visiting and are ICAO compliant. For based crews they naturally want oversight.
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Old 19th Jun 2008, 09:35
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Fortunatly Europe is a tiny and pretty insignificant player in Aviation (despite what some on here believe), the Feds are the big players and ultimately it is them who set the rules and procedures worldwide, eventually everyone else follows. I suspect thats lots of changes are iminent but then it has always been this way, I started flying in 1992 and there were always dark clouds on the horizon. Nobody really knows what will happen and like IO540 says we have until 2012, 4 years is a long time in aviation!
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Old 19th Jun 2008, 09:46
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Fortunately Europe is a tiny and pretty insignificant player in Aviation (despite what some on here believe), the Feds are the big players and ultimately it is them who set the rules and procedures worldwide, eventually everyone else follows. I suspect thats lots of changes are iminent but then it has always been this way, I started flying in 1992 and there were always dark clouds on the horizon. Nobody really knows what will happen and like IO540 says we have until 2012, 4 years is a long time in aviation!
Please don't take this the wrong way but I think you (and others) are burying your head(s) in the sand. Your very comment about the FAA setting the rules is the sort of thing that causes the EASA rule makers to flex their muscles. EASA are determined to be the major player just as the European politicians are intent on building the stupid 'country' of Europe USE. They want oversight of everything that goes on in Europe (it keeps them in jobs) and they will keep on maneuvering until they get what they want.

European airspace my be a tiny bit of the world, but if you want to fly through it you have to follow the rules they set. If you are an N Reg operator based in Europe you have to fly through the airspace!

This is the way politics works. Take a look at the Irish referendum, rather than listening to the very people they represent they are looking at ways of voiding the vote.....
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Old 19th Jun 2008, 10:02
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Trouble is where do you draw the line? For years they have been changing rules and moving the goal posts. If EASA say we must all be graduates of the Empire Test Pilots School does that mean we should all just accept it, bend over and let them give us one? I'm not burying my head in the sand, I accept things will change, but in 4 years my bet is that somebody else will put the rules into a box, shake them up and come up with something else, just like it has always been...

Besides it's quite useful for people to bury heads in the sand, it gives me somewhere to park my bicycle.

Last edited by youngskywalker; 19th Jun 2008 at 11:09.
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Old 19th Jun 2008, 11:05
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The key things to take away from this thread are
  • EASA have launched the next stage of the 'extend the European State' agenda.
  • People who read this particular forum are overwhelmingly EASA area residents so EASA's actions are directly relevant
  • European institutions have an established track record of creating their own special version (usually gilded) of things that work perfectly well elsewhere, even if this hurts European citizens and interests
  • It is clearly EASA's intent to bring private N-reg operation under their remit
  • Allowing 'the Feds to save us' won't happen. They don't care and even if they did, a lot of European officials would like to work one up the Feds.
  • NOW is the time to act - through comment and effectively organised engagement.
There has already been lobying to create this, but it is still only part way through the process. So, choose an organisation, get involved, make sure your voice is heard now when there is an opportunity to influence. In a few years the train will have left and we will get what we are going to get in 2012.

Last edited by mm_flynn; 19th Jun 2008 at 13:11.
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Old 19th Jun 2008, 12:47
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Couldn't agree more with mm-flynn.

As a general comment on bose-x's posts, unfortunately warnings about impending doom (in aviation) are two a penny. So nobody is entitled to claim credit for drawing attention to some hypothetical measure. In this game, there is always somebody trying to get you - pop along to the next NATS or Eurocontrol presentation and listen to the garbage about GPS not being acceptable for navigation. That boat left the port years ago but they still bang on about it. If they could, some of them would ban all GA (i.e. pilots with gold plated JAA IRs flying Cirrus SR22s) from Eurocontrol airspace. Of course they cannot (ICAO).

This EASA proposal is just another proposal. OK, it is nearer to reality than previous ones, but I am sure you all remember the bizzare UK DfT one, kicking out N-reg after 90 days' parking. That one had everybody's knickers in the twist, with some N-reg owners going back to G-reg purely because they were scared! How daft, when they had nothing to lose by waiting, and taking action only when mandated.

This is a cleverly worked out proposal, which takes advantage of a country's right under ICAO to shaft its own citizens in its own airspace in any way it wishes, and which is going to affect the usual players in the same way as booting out N-reg airframes from Europe would have done. So, expect much mobilisation of lobbying power - just as previously.

We must do our bit in the response to the NPA, of course.

IMHO, the final set of rules will be very different from this proposal - not least because this is very vague.

4 years is an awful long time in politics.

Some things could be harder than having to sit 4 JAA exams. Imagine a hypothetical mandating of Enhanced Mode S for PRNAV airspace. Imagine the massive avionics refit you would need to do to collect all the data in a form suitable for squirting into your GTX330 so it can be radiated on 1090ES. Easily well into 5 digits.

Finally, what we see here is the STICK. There is likely to be a CARROT. Certainly so, if they want to avoid a war from the bigger operators (turboprops and corporate jets). The carrot (e.g. FAA to EASA conversion rights on both certification and FCL) has not yet been published, and won't be for a long time, because in EU politics you have to keep the best meat in the bag, for the biggest dogs.
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Old 19th Jun 2008, 13:18
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Don't be such an ass IO, you just hate it when I am right.
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Old 19th Jun 2008, 13:21
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I havent read the document yet but going on IOs comments about having to sit the ATPLs to use your ICAO licence in certain circumstances, what happens 36mths after you have passed them?

Presumably if you have not then obtained the JAA/EASA CPL & IR you will lose them and have to do the whole thing again!!! So you sit the ATPL to use your ICAO licence and then get forced down the Euro route anyway....

I will have to sit down this weekend and read it but inclined to agree with IO, its probably more scare tactics to try and frighten N Reg owners and reascert their authourity upon us.

J.
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Old 19th Jun 2008, 13:25
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I think Julian you may be trying to read specifics into this rather non-specific and very poorly phrased proposal, and it is years too early to do that.

A lot of people far more clever than me have been reading those 3 pages, over and over, and they cannot work out what it means.
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Old 19th Jun 2008, 13:26
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No Julian, the proposal is that you sit the exams and a flight test you get an EASA licence. you then keep the FAA licence current and the EASA licence.

If you have an ATPL (no the legendary fATPL) then you sit the exams and get a licence. It is how it happens now for conversion, it is just the current proposal is to force the conversion on us.
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Old 19th Jun 2008, 15:03
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Don't be such an ass IO, you just hate it when I am right.
Are you ever anything else?
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