Updated EASA proposals on non-EU IRs
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Updated EASA proposals on non-EU IRs
I have finally stumbled across this
Page 18:
Pilot licences for non-commercial activities with an instrument rating.
43 In the case of private pilot licences with an instrument rating, or CPL and ATPL
licences with an instrument rating where the pilot intends only to
exercise private pilot privileges, the holder shall comply with the following
requirements:
(a) complete the skill test for instrument rating and the type or class ratings
relevant to the privileges of the licence held, in accordance with Appendix 7
and Appendix 9 to Part-FCL;
(b) demonstrate that he/she has acquired knowledge of Air Law,
Aeronautical Weather Codes, Flight Planning and Performance (IR), and
Human Performance;
(c) demonstrate that he/she has acquired knowledge of English in
accordance with FCL.055;
(d) hold at least a valid Class 2 medical certificate issued in accordance with
ICAO Annex 1;
(f) have a minimum experience of at least 100 hours of instrument flight time
as pilot-in-command in the relevant category of aircraft.
This is an update of the previous proposal (pages 159-161).
Relevant items appear to be:
The IR checkride.
Validation no longer limited to 1 year.
Class 2 medical is OK (they don't say if the Class 1 audiogram is still required though).
You have to sit 4 of the JAA IR exams.
The full stuff is here but it is thousands of pages. The "c" PDFs (CRC "c") are EASA comments to the responses. Their proposals have been absolutely comprehensively trashed by so many people, starting with the various national CAAs (you can start reading here) but they still seem to be living in an alternate universe which only occassionally intersects this one.
The political meltdown of "anti N-reg" EASA proposals, widely reported in the media, is not very evident in EASA's comments, but then it wouldn't be - they will be beavering away in their little expense-funded heaven until the very end...
Interestingly, non-EU PPLs (no IR) can be validated permanently if the holder has 100hrs and passes 2 exams and the skills test.
Page 18:
Pilot licences for non-commercial activities with an instrument rating.
43 In the case of private pilot licences with an instrument rating, or CPL and ATPL
licences with an instrument rating where the pilot intends only to
exercise private pilot privileges, the holder shall comply with the following
requirements:
(a) complete the skill test for instrument rating and the type or class ratings
relevant to the privileges of the licence held, in accordance with Appendix 7
and Appendix 9 to Part-FCL;
(b) demonstrate that he/she has acquired knowledge of Air Law,
Aeronautical Weather Codes, Flight Planning and Performance (IR), and
Human Performance;
(c) demonstrate that he/she has acquired knowledge of English in
accordance with FCL.055;
(d) hold at least a valid Class 2 medical certificate issued in accordance with
ICAO Annex 1;
(f) have a minimum experience of at least 100 hours of instrument flight time
as pilot-in-command in the relevant category of aircraft.
This is an update of the previous proposal (pages 159-161).
Relevant items appear to be:
The IR checkride.
Validation no longer limited to 1 year.
Class 2 medical is OK (they don't say if the Class 1 audiogram is still required though).
You have to sit 4 of the JAA IR exams.
The full stuff is here but it is thousands of pages. The "c" PDFs (CRC "c") are EASA comments to the responses. Their proposals have been absolutely comprehensively trashed by so many people, starting with the various national CAAs (you can start reading here) but they still seem to be living in an alternate universe which only occassionally intersects this one.
The political meltdown of "anti N-reg" EASA proposals, widely reported in the media, is not very evident in EASA's comments, but then it wouldn't be - they will be beavering away in their little expense-funded heaven until the very end...
Interestingly, non-EU PPLs (no IR) can be validated permanently if the holder has 100hrs and passes 2 exams and the skills test.
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Clearly, Justiciar, you do not fully appreciate the European intellectual superiority in these matters 
Of course I agree with you. If they meant sitting exams, why not say so?
Page 5 here is interesting too:
Third country licences and ratings
1. Without prejudice to Article 1, Member States may accept licences and associated ratings and/or qualifications and medical certificates issued by or on behalf of third countries, in accordance with the provisions of Annex III to this Regulation.
2. An applicant for a Part–FCL licence and associated ratings, certificates and/or qualifications already holding at least an equivalent licence issued in accordance with ICAO Annex 1 by a third country shall meet all the requirements of Part–FCL, except that the requirements of course duration, number of lessons and specific training hours may be reduced.
The credit given to the applicant shall be determined by the competent authority of the Member State to which the pilot applies, on the basis of a recommendation from an approved training organisation. [my bold]
3. The holder of an ATPL issued in accordance with ICAO Annex 1 who has completed the experience requirements for the issue of an ATPL in the relevant aircraft category established in Subpart F of Part-FCL may be credited in full with the requirements to undergo a training course prior to undertaking the theoretical knowledge examinations and the skill test, if his/her licence contains a valid type rating for the aircraft to be used for the ATPL skill test.
4. An aeroplane or helicopter type rating may be issued to the holder of a Part-FCL licence that complies with the requirements for the issue of that rating established by a third country.
Such a rating will be restricted to aircraft registered in that Member State and
excluded from the scope of the Basic Regulation in accordance with Article 4 thereof.
This restriction may be removed when the pilot complies with the requirements in paragraph C.1 of Annex III to this Regulation.
which, to my non-EU-trained and intellectually non-superior brain, appears to suggest that any EASA member state will be free to accept any ICAO license/rating, anyway, for planes registered in that member state...........
hey ho hey ho, does this sound like what I think it sounds like?
I cannot find the proposed regs defining this
Pilots shall apply to the competent authority of the Member State where
they reside or are established, or, if they are not residing in the
territory of the Member States, where the operator for which they are
flying or intend to fly has its principal place of business
(page 16 of above PDF).
This takes us into all kinds of areas such as residence for tax purposes (whose determination, as anybody involved knows, is a minefield for many), and which country you pay corporation tax in, etc. I find it hard to believe that the final enforcers of this dross (the national CAAs) will be willing to get stuck into what HMRC thinks of somebody's tax residence, etc etc.
I also wonder what the motivation behind this
(f) have a minimum experience of at least 100 hours of instrument flight time
as pilot-in-command in the relevant category of aircraft.
was. Given it is obviously trivial to forge instrument time (but such forging of logbooks is undetectable only if the forgery is consistent with one's actually provable flying e.g. aircraft maintenance records, airport records, etc) the purpose of this requirement must be purely to kill off the "get the FAA IR in the USA, do the EASA IR validation, and fly in Europe straight away in your brand new SR22" market; those people will not be able to pull out 100hrs instrument time without doing an awful lot of spamcan rental, and all of that will have to be dual time because without an IR (let's set the UK "IMCR remaining" aside for the moment) you cannot log instrument time in the first place.
I'd love to be a fly on the wall where this was drafted.
Of course I agree with you. If they meant sitting exams, why not say so?
Page 5 here is interesting too:
Third country licences and ratings
1. Without prejudice to Article 1, Member States may accept licences and associated ratings and/or qualifications and medical certificates issued by or on behalf of third countries, in accordance with the provisions of Annex III to this Regulation.
2. An applicant for a Part–FCL licence and associated ratings, certificates and/or qualifications already holding at least an equivalent licence issued in accordance with ICAO Annex 1 by a third country shall meet all the requirements of Part–FCL, except that the requirements of course duration, number of lessons and specific training hours may be reduced.
The credit given to the applicant shall be determined by the competent authority of the Member State to which the pilot applies, on the basis of a recommendation from an approved training organisation. [my bold]
3. The holder of an ATPL issued in accordance with ICAO Annex 1 who has completed the experience requirements for the issue of an ATPL in the relevant aircraft category established in Subpart F of Part-FCL may be credited in full with the requirements to undergo a training course prior to undertaking the theoretical knowledge examinations and the skill test, if his/her licence contains a valid type rating for the aircraft to be used for the ATPL skill test.
4. An aeroplane or helicopter type rating may be issued to the holder of a Part-FCL licence that complies with the requirements for the issue of that rating established by a third country.
Such a rating will be restricted to aircraft registered in that Member State and
excluded from the scope of the Basic Regulation in accordance with Article 4 thereof.
This restriction may be removed when the pilot complies with the requirements in paragraph C.1 of Annex III to this Regulation.
which, to my non-EU-trained and intellectually non-superior brain, appears to suggest that any EASA member state will be free to accept any ICAO license/rating, anyway, for planes registered in that member state...........
hey ho hey ho, does this sound like what I think it sounds like?
I cannot find the proposed regs defining this
Pilots shall apply to the competent authority of the Member State where
they reside or are established, or, if they are not residing in the
territory of the Member States, where the operator for which they are
flying or intend to fly has its principal place of business
(page 16 of above PDF).
This takes us into all kinds of areas such as residence for tax purposes (whose determination, as anybody involved knows, is a minefield for many), and which country you pay corporation tax in, etc. I find it hard to believe that the final enforcers of this dross (the national CAAs) will be willing to get stuck into what HMRC thinks of somebody's tax residence, etc etc.
I also wonder what the motivation behind this
(f) have a minimum experience of at least 100 hours of instrument flight time
as pilot-in-command in the relevant category of aircraft.
was. Given it is obviously trivial to forge instrument time (but such forging of logbooks is undetectable only if the forgery is consistent with one's actually provable flying e.g. aircraft maintenance records, airport records, etc) the purpose of this requirement must be purely to kill off the "get the FAA IR in the USA, do the EASA IR validation, and fly in Europe straight away in your brand new SR22" market; those people will not be able to pull out 100hrs instrument time without doing an awful lot of spamcan rental, and all of that will have to be dual time because without an IR (let's set the UK "IMCR remaining" aside for the moment) you cannot log instrument time in the first place.
I'd love to be a fly on the wall where this was drafted.
Last edited by IO540; 29th Apr 2010 at 09:38.
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It has always been that way. If you have a non EU IR and are not resident in the EU then the member state will validate your IR for the duration of your stay but if you are resident they will not. I am not sure residency is defined so I guess residency would take its every day meaning rather than the more complex meaning established through tax case law and legislation.
I suspect that there will be little change in the EU's position on non EU IR holders and the most dreadful fudge on the so called "simplified" IR for EU residents.
Unfortunately despite claims to the contrary the reps we have on the committee have very little understanding of the issues and even less understanding of the importance of ensuring UK pilots are able to excercise some sort of instrument priviliges without having to jump endless hurdles for hurdles sake. Ho, hum.
I suspect that there will be little change in the EU's position on non EU IR holders and the most dreadful fudge on the so called "simplified" IR for EU residents.
Unfortunately despite claims to the contrary the reps we have on the committee have very little understanding of the issues and even less understanding of the importance of ensuring UK pilots are able to excercise some sort of instrument priviliges without having to jump endless hurdles for hurdles sake. Ho, hum.
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It has always been that way. If you have a non EU IR and are not resident in the EU then the member state will validate your IR for the duration of your stay but if you are resident they will not.
Also, JAA has been limiting any such validation to 1 year.
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Yeap that is my understanding - by limiting the validation they are effectively defining residence for themselves. In other words we will accept that you could be a temporary visitor for up to a year - beyond that it looks a bit dubious to us 
Yes France has been doing this for years and I also understand so have a number of other member states. My mate got a validation while he was stationed in Germany.
The whole thing is pathetic. They will hand out validations for short periods which by definition means they are happy that you are capable of excercising the priviliges but that the more you fly in European airspace clearly the less capable you become.
European protectionism at its best - safety, humbug.
Yes France has been doing this for years and I also understand so have a number of other member states. My mate got a validation while he was stationed in Germany.
The whole thing is pathetic. They will hand out validations for short periods which by definition means they are happy that you are capable of excercising the priviliges but that the more you fly in European airspace clearly the less capable you become.
European protectionism at its best - safety, humbug.
Also, JAA has been limiting any such validation to 1 year.
"The period of validation of a licence shall not exceed 1 year, provided
that the basic licence remains valid.
This period may only be extended once by the competent authority that
issued the validation when, during the validation period, the pilot has
applied, or is undergoing training, for the issuance of a licence in
accordance with Part-FCL. This extension shall cover the period of time
necessary for the licence to be issued in accordance with Part-FCL"
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So, you reckon one would initially get the validation, and then have a year to pass the four JAA exams (or otherwise "demonstrate" one's superior knowledge 
) and pass the checkride?
If so, that is a lot less hassle than doing the JAA IR right now, out of fear of what might happen.... which quite a lot of people have done over the past year or two.
The current EASA proposals must (obviously, politically) represent the most adverse possible set of options.
) and pass the checkride?If so, that is a lot less hassle than doing the JAA IR right now, out of fear of what might happen.... which quite a lot of people have done over the past year or two.
The current EASA proposals must (obviously, politically) represent the most adverse possible set of options.
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Presumably, the risk of FAA IR holders waiting till EASA is done, in the hope of doing just the 4 exams (AIUI) carries the risk that the EASA FCL proposal will suffer a substantial meltdown.
Then there might be 2 outcomes:
1) A reversion to the present JAA IR conversion regime (15hrs flying, if which about 10 can be in a sim) plus the 7 exams
2) A loss of all conversion options for private IRs (not wholly without precedent; back in ~ 2001/02 there was no PPL/IR route at all and one had to sit all 14 ATPL exams, followed by a "reduced" CPL/IR checkride).
I suspect it is #2 which may be worrying some people. I wonder how likely it is.
Then there might be 2 outcomes:
1) A reversion to the present JAA IR conversion regime (15hrs flying, if which about 10 can be in a sim) plus the 7 exams
2) A loss of all conversion options for private IRs (not wholly without precedent; back in ~ 2001/02 there was no PPL/IR route at all and one had to sit all 14 ATPL exams, followed by a "reduced" CPL/IR checkride).
I suspect it is #2 which may be worrying some people. I wonder how likely it is.
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So, you reckon one would initially get the validation, and then have a year to pass the four JAA exams (or otherwise "demonstrate" one's superior knowledge 
) and pass the checkride?
If so, that is a lot less hassle than doing the JAA IR right now, out of fear of what might happen.... which quite a lot of people have done over the past year or two
) and pass the checkride?If so, that is a lot less hassle than doing the JAA IR right now, out of fear of what might happen.... which quite a lot of people have done over the past year or two
If so, that is a lot less hassle than doing the JAA IR right now, out of fear of what might happen.... which quite a lot of people have done over the past year or two
brdgs
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Is that view based on inside knowledge?
The "100% doom" scenario is always an option, but is it realistic? Every CPL/IR flying a non-AOC business jet, who has European "residence", will be fired by his employer unless he sits the 14 CPL/IR exams, flies 55 hrs, re-does his Type Rating perhaps, and passes the JAA CPL/IR checkrides. They are sure going to love this. This level of pilot privilege stripping is unprecendented in aviation, worldwide.
OTOH for all the obvious political / economic / job protection reasons I am not expecting EASA to do anything less than run the full course, with no weakness indicated till the last moment.
The "100% doom" scenario is always an option, but is it realistic? Every CPL/IR flying a non-AOC business jet, who has European "residence", will be fired by his employer unless he sits the 14 CPL/IR exams, flies 55 hrs, re-does his Type Rating perhaps, and passes the JAA CPL/IR checkrides. They are sure going to love this. This level of pilot privilege stripping is unprecendented in aviation, worldwide.
OTOH for all the obvious political / economic / job protection reasons I am not expecting EASA to do anything less than run the full course, with no weakness indicated till the last moment.
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Is that view based on inside knowledge?
The "100% doom" scenario is always an option, but is it realistic?
The "100% doom" scenario is always an option, but is it realistic?
Every CPL/IR flying a non-AOC business jet, who has European "residence", will be fired by his employer unless he sits the 14 CPL/IR exams, flies 55 hrs, re-does his Type Rating perhaps, and passes the JAA CPL/IR checkrides. They are sure going to love this. This level of pilot privilege stripping is unprecendented in aviation, worldwide.
There could be any number of circumstances which mitigate the current EASA FCL proposal. I just don't think this is one of them.
doing the JAA IR right now, out of fear of what might happen.... which quite a lot of people have done over the past year or two
