N-reg situation update
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Why do I think there will be a Bi lateral agreement of some sort?
We have to look at the route that has taken us to where we are now!
EASA has always stated that the present legislation re third country licences is not their chosen route or one they desire.
When the legislation went through the EU parliament it faced stiff opposition from a number of Key MEPs.
EASA could not in law remove part!
The whole had to be voted through or none.
Some sort of deal was made behind closed doors to persuade the MEPs who opposed what had been suggested for third country licence holders in Europe to vote the whole through.
EASA than changed the date to 2014 for the SOLE purpose of adding FCL to the recently signed up BI Lateral.
From thinking that this was all a CON to pretend to get a Bi Lateral and effectively also cheat the MEPs who were opposed but then let the legislation through I now feel that EASA is genuine in their intent.
My concern is that both systems are too far apart especially on the ground school structure to get an OVERALL agreement which would not damage the EASA training structure.
My feeling is there will be movement on ATPs and movement on trimming of other areas.
As to the question re the basic PPL with an IMCR rating if I was in that position I would get the EIR on top of my IMCR which would literally give me the benefits of an IR in the UK and an on top ability elsewhere.
Most PPLs spend their time in the UK or brief forays into France anyway.
BTW I am not only an FAA ATP but also hold JAA PPL IMCR Multi .
Should the whole lot go tits up and because of the behind closed door agreements with opposed MEPs I think EASA would be under a lot of moral pressure to make further gestures to those effected.
Pace
We have to look at the route that has taken us to where we are now!
EASA has always stated that the present legislation re third country licences is not their chosen route or one they desire.
When the legislation went through the EU parliament it faced stiff opposition from a number of Key MEPs.
EASA could not in law remove part!
The whole had to be voted through or none.
Some sort of deal was made behind closed doors to persuade the MEPs who opposed what had been suggested for third country licence holders in Europe to vote the whole through.
EASA than changed the date to 2014 for the SOLE purpose of adding FCL to the recently signed up BI Lateral.
From thinking that this was all a CON to pretend to get a Bi Lateral and effectively also cheat the MEPs who were opposed but then let the legislation through I now feel that EASA is genuine in their intent.
My concern is that both systems are too far apart especially on the ground school structure to get an OVERALL agreement which would not damage the EASA training structure.
My feeling is there will be movement on ATPs and movement on trimming of other areas.
As to the question re the basic PPL with an IMCR rating if I was in that position I would get the EIR on top of my IMCR which would literally give me the benefits of an IR in the UK and an on top ability elsewhere.
Most PPLs spend their time in the UK or brief forays into France anyway.
BTW I am not only an FAA ATP but also hold JAA PPL IMCR Multi .
Should the whole lot go tits up and because of the behind closed door agreements with opposed MEPs I think EASA would be under a lot of moral pressure to make further gestures to those effected.
Pace
Last edited by Pace; 30th Apr 2012 at 08:45.
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I sincerely hope they sort something out in June as I won't be taking 14 exams to fly the same non EU reg aircraft, the said 14 exams not forming any part of FAA training or the FAR's.
The 14 exams as MJ states may be passable but only with full time study over a period of months which for me and others would lead to job loss. There is also the moral duty of EASA not to put current rated jet pilots through the multi guess, cr*ppy 99% non relevant exams (it's not even the licensing authority of the aircraft reg, why should they)
Some of you may crumble through fear, desperation or whatever and sit the cr*ppy multi guess system and empty your bank account in the process, good luck to you.
However, I will use any means I can as a point of principle to avoid it. You may have noticed on another forum on pprune that many pilots with national CAA licences are being told they will have to sit the exams too. They are understandably furious and I doubt they will sit the exams either.
The 14 exams as MJ states may be passable but only with full time study over a period of months which for me and others would lead to job loss. There is also the moral duty of EASA not to put current rated jet pilots through the multi guess, cr*ppy 99% non relevant exams (it's not even the licensing authority of the aircraft reg, why should they)
Some of you may crumble through fear, desperation or whatever and sit the cr*ppy multi guess system and empty your bank account in the process, good luck to you.
However, I will use any means I can as a point of principle to avoid it. You may have noticed on another forum on pprune that many pilots with national CAA licences are being told they will have to sit the exams too. They are understandably furious and I doubt they will sit the exams either.
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The 14 exams as MJ states may be passable but only with full time study over a period of months
I did them over 4 months while doing 10-12 hour shifts in my day job, distance learning. And the only experence I had was a PPL and an engineering back ground which help in the AGK but thats about it. With experence they will be an awful lot easier.
And far from using only one % of them I have used well over 50% so far and the longer I keep flying and the more areas of the world I operate into the more of it I use.
However, I will use any means I can as a point of principle to avoid it.
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We shall just have to disagree then. I don't believe that it's utter rubbish as you put it.
Your 10-12 hours shift wasn't flying though, was it. More than likely home every night with weekends off, a bit easier to study then, no ?
Maybe you want us all to become clones of the sacred 14 exams system. I see the students of them at my local flight school. Many think they're a cut above the rest, wearing their gold two bars (or more) as they stride off to fly their 152. Thousands wasted on an archaic system that would be better for everyone if binned and stated from scratch. Those thousands wasted on the multi guess exams would be better invested in actual flight training. Maybe then they would graduate with more than 170 hours, and might not require so much time to bring up to scratch in the right hand seat of your J-41.
But I'll leave you to chew that over.
Your 10-12 hours shift wasn't flying though, was it. More than likely home every night with weekends off, a bit easier to study then, no ?
Maybe you want us all to become clones of the sacred 14 exams system. I see the students of them at my local flight school. Many think they're a cut above the rest, wearing their gold two bars (or more) as they stride off to fly their 152. Thousands wasted on an archaic system that would be better for everyone if binned and stated from scratch. Those thousands wasted on the multi guess exams would be better invested in actual flight training. Maybe then they would graduate with more than 170 hours, and might not require so much time to bring up to scratch in the right hand seat of your J-41.
But I'll leave you to chew that over.
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The exam workload depends on how you do them.
I can only refer you to my 20k word writeup
I know almost nobody has read it because it is so totally boring (I can hear a well known "forum personality" rolling over now ) but it does have useful stuff in it on how to cut through this crap.
In a nutshell, what you have to do is avoid the traditional ground school FTO route, because they load you up with about 5000 pages of crap in a dozen ring binders, and you have to study this crap to be signed off as good enough to sit the CAA exams at Gatwick.
But if you go to CATS then the homework is (I am advised) "aligned pretty well" with their online QB which you have to hammer anyway, to pass. So you just do that.
I didn't use CATS because I didn't discover this route until too late and I wasted a lot of time. In the end I did Met and Air Law purely by doing 37 mock exams in each
These take about 30 mins each so about 40 hours' revision for these two very unpleasant subjects. Navigation is worth booking a classroom (or some other study) session on because while the stuff is banally trivial (and wrong; useless for flying in Europe) it helps to know how you are supposed to do it.
The 14 exams could take 6 months of evenings if you spread it out, as a busy working person would, but it can be done a lot quicker. I did under 50% of it (PPL/IR conversion) and the total time spent was a couple of weeks. It is depressing and distasteful for a pilot with a life who does real flying to have to learn such near-total crap for no good reason other than the decree by the bent gravy train riders in Brussels/Cologne but if one gets stuck in, it doesn't take too long. I would do the 14 exams in four sittings, starting with the hardest ones.
Well, yes, of course, this system turns out pilots who cannot fly. They tend to pick up the essential skills later, except for some (AF447, etc...).
I can only refer you to my 20k word writeup
I know almost nobody has read it because it is so totally boring (I can hear a well known "forum personality" rolling over now ) but it does have useful stuff in it on how to cut through this crap.In a nutshell, what you have to do is avoid the traditional ground school FTO route, because they load you up with about 5000 pages of crap in a dozen ring binders, and you have to study this crap to be signed off as good enough to sit the CAA exams at Gatwick.
But if you go to CATS then the homework is (I am advised) "aligned pretty well" with their online QB which you have to hammer anyway, to pass. So you just do that.
I didn't use CATS because I didn't discover this route until too late and I wasted a lot of time. In the end I did Met and Air Law purely by doing 37 mock exams in each
These take about 30 mins each so about 40 hours' revision for these two very unpleasant subjects. Navigation is worth booking a classroom (or some other study) session on because while the stuff is banally trivial (and wrong; useless for flying in Europe) it helps to know how you are supposed to do it.The 14 exams could take 6 months of evenings if you spread it out, as a busy working person would, but it can be done a lot quicker. I did under 50% of it (PPL/IR conversion) and the total time spent was a couple of weeks. It is depressing and distasteful for a pilot with a life who does real flying to have to learn such near-total crap for no good reason other than the decree by the bent gravy train riders in Brussels/Cologne but if one gets stuck in, it doesn't take too long. I would do the 14 exams in four sittings, starting with the hardest ones.
Those thousands wasted on the multi guess exams would be better invested in actual flight training
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Nah flying the auld heap just now so its no auto pilot and fancy tellys.
Its usually 40 sectors which is the min required by the ops manual. If you get a 1000 hour GA instructor type they could get through in 25-30 sectors mainly becuase there PNF stuff is alot more organised and they don't struggle with the RT as much. And you don't have to teach them how to trim an aircraft properly (which seems to be universally ****e which ever method of training they have come through, including alledged experenced TP pilots with time on kingairs etc). Its much more of a struggle taking someone back to steam instruments and no AP from telly's and AP and radar vectored ILS's everytime.
I was working a a IT service engineer so no not home every night and working at weekends because thats when we could have the servers down and run scripts. Used to read the books at work while waiting for micro****e to sort its life out hitting ok every 15 mins.
Flying is much more friendly to distance learning. In fact I am doing an OU degree while sitting around in Airports.
And its hardly thousands its about 15 hours in a C152 to be honest or 7 hours in a twin doing instrument approaches.
Go for it get the knife stuck into them again. Nail another nail into the coffin and make the faceless civil servants that are driving this even more determind that come hell or high water that everyone will have to do the exams.
Its usually 40 sectors which is the min required by the ops manual. If you get a 1000 hour GA instructor type they could get through in 25-30 sectors mainly becuase there PNF stuff is alot more organised and they don't struggle with the RT as much. And you don't have to teach them how to trim an aircraft properly (which seems to be universally ****e which ever method of training they have come through, including alledged experenced TP pilots with time on kingairs etc). Its much more of a struggle taking someone back to steam instruments and no AP from telly's and AP and radar vectored ILS's everytime.
I was working a a IT service engineer so no not home every night and working at weekends because thats when we could have the servers down and run scripts. Used to read the books at work while waiting for micro****e to sort its life out hitting ok every 15 mins.
Flying is much more friendly to distance learning. In fact I am doing an OU degree while sitting around in Airports.
And its hardly thousands its about 15 hours in a C152 to be honest or 7 hours in a twin doing instrument approaches.
to learn such near-total crap for no good reason other than the decree by the bent gravy train riders in Brussels/Cologne
Last edited by mad_jock; 30th Apr 2012 at 14:00.
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EASA has published a table of countries and their derogations here.
It is not fully up to date; for example Netherlands has gone for the full 2 years but haven't told EASA yet
It is not fully up to date; for example Netherlands has gone for the full 2 years but haven't told EASA yet
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It gets better...
The UK CAA has just published its proposed ANO amendments.
One can't copy/paste from that stupid PDF but look up 61 (1) (a). (page 4/5 of the PDF).
They are now hanging the anti N-reg stuff on both the residence of the pilot and the residence of the operator.
Nasty........... How can this comply with EASA FCL ?
It's either deliberate or it's a c0ckup. The latter would be amazing, given how much publicity this Brussels garbage has received.
The UK CAA has just published its proposed ANO amendments.
One can't copy/paste from that stupid PDF but look up 61 (1) (a). (page 4/5 of the PDF).
They are now hanging the anti N-reg stuff on both the residence of the pilot and the residence of the operator.
Nasty........... How can this comply with EASA FCL ?
It's either deliberate or it's a c0ckup. The latter would be amazing, given how much publicity this Brussels garbage has received.
Last edited by peterh337; 15th May 2012 at 18:26.
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I always thought it was going on both. Its the faceless civil servants your up against so it will be on purpose.
It won't really matter if the EU goes tits up it will all be through the individual parliments. So even if all falls over at the end it will still be on everyones books. And the fall out will mean that it will be years until they have chamber time to sort any of it out.
Won't cost hardly anything to enforce it will just use the current inspectors. You have to submit you passport numbers anyway so any EU passports come in on an outside reg and its can I see your license please.
Its always been their goal for residents to have local licenses to be able to fly anything in their own countries. And make it almost impossible for you to operate anything other than the local reg if its perm based there, how ever you fiddle the paper work so it appears that its operated from somewhere else.
I must admit I did wonder why everyone was thinking that basing an aircraft in IOM or JER was going to solve anything with the pilots.
It won't really matter if the EU goes tits up it will all be through the individual parliments. So even if all falls over at the end it will still be on everyones books. And the fall out will mean that it will be years until they have chamber time to sort any of it out.
Won't cost hardly anything to enforce it will just use the current inspectors. You have to submit you passport numbers anyway so any EU passports come in on an outside reg and its can I see your license please.
Its always been their goal for residents to have local licenses to be able to fly anything in their own countries. And make it almost impossible for you to operate anything other than the local reg if its perm based there, how ever you fiddle the paper work so it appears that its operated from somewhere else.
I must admit I did wonder why everyone was thinking that basing an aircraft in IOM or JER was going to solve anything with the pilots.
Last edited by mad_jock; 15th May 2012 at 18:50.
The UK CAA has just published its proposed ANO amendments.
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BookWorm
As you are more conversant with these things!!! does that mean that an aircraft which is not European operated but uses a pilot who is EU resident that now the pilot has to hold equivalent EASA licences regardless of whether the operator is EU based or not?
So it is not based on the Operator but on the pilot as well?
Is there a definition for resident? Someone here for 3 days is resident by definition?
Seems if they are tightening the small print that EASA had no intentions of a Bi Lateral and it is indeed a smokescreen!
That whatever was suggested to the MEPs who opposed this going into law were also cheated to vote it all through?
Anyway if true it will have made Mad Jocks day!
Pace
As you are more conversant with these things!!! does that mean that an aircraft which is not European operated but uses a pilot who is EU resident that now the pilot has to hold equivalent EASA licences regardless of whether the operator is EU based or not?
So it is not based on the Operator but on the pilot as well?
Is there a definition for resident? Someone here for 3 days is resident by definition?
Seems if they are tightening the small print that EASA had no intentions of a Bi Lateral and it is indeed a smokescreen!
That whatever was suggested to the MEPs who opposed this going into law were also cheated to vote it all through?
Anyway if true it will have made Mad Jocks day!
Pace
Last edited by Pace; 15th May 2012 at 19:27.
They were hanging the anti N-reg stuff on both the residence of the pilot and the residence of the operator but, clearly in response to comments received, Article 61 has now been re-worded, albeit in the most obtuse manner possible. It now allows for the pilot of an EASA aircraft whose operator is resident or established outside the EU to hold either an EASA licence or a licence granted or rendered valid under the law of the country in which the aircraft is registered or in the State of the operator, which complies with Article 4.1(c) of the Basic Regulation.
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Its made my day that the light is actually dawning for you Pace what your up against. Not the fact you are getting shafted.
The residency thing is a bit of a bitch to be honest. Different countrys have different rules.
Some have 183 days in country a year.
Or the UK currently has that and also more than 90 days a year averaged over three years. So if you do 184 your instantly a resident but if you say do 80 in the first year 80 in the second and 115 in the third you then become resident from the first year. What screws things up is you can be deemed to be resident for tax purposes but not resident depending on various factors.
Now if they will have a EU residency ie 183 days total within the EU area I don't know. BUt if they do its going to be a whole heap of hassel having to prove your location for basically every single day of the year.
And Peter if you print it using a PDF printer then that removes all the crap that they insist on attaching to there PDF's.
The residency thing is a bit of a bitch to be honest. Different countrys have different rules.
Some have 183 days in country a year.
Or the UK currently has that and also more than 90 days a year averaged over three years. So if you do 184 your instantly a resident but if you say do 80 in the first year 80 in the second and 115 in the third you then become resident from the first year. What screws things up is you can be deemed to be resident for tax purposes but not resident depending on various factors.
Now if they will have a EU residency ie 183 days total within the EU area I don't know. BUt if they do its going to be a whole heap of hassel having to prove your location for basically every single day of the year.
And Peter if you print it using a PDF printer then that removes all the crap that they insist on attaching to there PDF's.
Last edited by mad_jock; 15th May 2012 at 19:59.
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I think this wording would be a change in the regs which the UK is not entitled to make.
It would also be stupid because how are you doing to define "residence"?
This would be piling one piece of "pub" lawmaking from the CAA onto another piece of "pub" lawmaking from EASA which EASA sneaked past a Brussels Transport Committee made up mostly of ignorant brown-nosing small-country MEPs, with the knowledgeable ones having been duped in a separate private audience by the promise of an imminent treaty with the USA.
However I am pleased to see MJ is on the case... 23 minutes after my post is not bad going. Business a bit slack, perhaps? The bitterness is impressive
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BillieBob
I must be mis-reading something. Could you explain where the new text is?
The funny thing is that if the bit I put in italics above were to be used, it would not comply with FAR 61.3, for example
It would also be stupid because how are you doing to define "residence"?
This would be piling one piece of "pub" lawmaking from the CAA onto another piece of "pub" lawmaking from EASA which EASA sneaked past a Brussels Transport Committee made up mostly of ignorant brown-nosing small-country MEPs, with the knowledgeable ones having been duped in a separate private audience by the promise of an imminent treaty with the USA.
However I am pleased to see MJ is on the case... 23 minutes after my post is not bad going. Business a bit slack, perhaps? The bitterness is impressive
If it were not for the background knowledge I would believe you are my ex wife BillieBob
I must be mis-reading something. Could you explain where the new text is?
It now allows for the pilot of an EASA aircraft whose operator is resident or established outside the EU to hold either an EASA licence or a licence granted or rendered valid under the law of the country in which the aircraft is registered or in the State of the operator, which complies with Article 4.1(c) of the Basic Regulation.
Last edited by peterh337; 15th May 2012 at 20:16.
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Nah playing skyrim was 30mins before I got fed up with getting my backside kicked by a giant earwig on steriods.
That means that if your aircraft is based outside the EU the locals can fly it. The airlines will have got that in there so they can dry lease out aircraft during winter. It also allows the likes of flybe to take a few Q400's outside the EU and then train local crews up for a local AOC while they wait for there own to turn up.
There is absolutely no bitterness at all. Just a slightly bemused feeling that two obviously intelligent people can't see a well planned sequence of events falling into place. The fact that I understand and agree with the policy is neither here nor there.
That means that if your aircraft is based outside the EU the locals can fly it. The airlines will have got that in there so they can dry lease out aircraft during winter. It also allows the likes of flybe to take a few Q400's outside the EU and then train local crews up for a local AOC while they wait for there own to turn up.
There is absolutely no bitterness at all. Just a slightly bemused feeling that two obviously intelligent people can't see a well planned sequence of events falling into place. The fact that I understand and agree with the policy is neither here nor there.
Last edited by mad_jock; 15th May 2012 at 20:41.
Peter, the proposed revised text is in the 'Action' column of the CRD and reads as follows:
Requirement for appropriate licence to act as member of flight crew of EASA aircraft or non-EASA aircraft referred to in paragraphs (a)(ii), (d) or (h) of Annex II of the Basic EASA Regulation that is flying for the purpose of a commercial air transport flight and in either case registered elsewhere than in the United Kingdom
61A A person must not act as a member of the flight crew which must by or under the EASA Aircrew Regulation be carried in -
(a) an EASA aircraft which is registered in a country other than the United Kingdom; or
(b) a non-EASA aircraft that is referred to in paragraphs (a)(ii), (d) or (h) of Annex II of the Basic EASA Regulation that is flying for the purpose of a commercial transport flight and which is registered in a country other than the United Kingdom, unless paragraphs 2 or 3 apply
(2) This paragraph applies if the operator of the aircraft is not resident or established in the European Union, and the person acting as a member of the flight crew is the holder of an appropriate licence granted or rendered valid under the law of the country in which the aircraft is registered or the State of the operator.
(3) This paragraph applies if the person is the holder of an appropriate licence converted, granted or rendered valid under the EASA Aircrew Regulation.
Are you perhaps reading the original NPA instead of the CRD?
Requirement for appropriate licence to act as member of flight crew of EASA aircraft or non-EASA aircraft referred to in paragraphs (a)(ii), (d) or (h) of Annex II of the Basic EASA Regulation that is flying for the purpose of a commercial air transport flight and in either case registered elsewhere than in the United Kingdom
61A A person must not act as a member of the flight crew which must by or under the EASA Aircrew Regulation be carried in -
(a) an EASA aircraft which is registered in a country other than the United Kingdom; or
(b) a non-EASA aircraft that is referred to in paragraphs (a)(ii), (d) or (h) of Annex II of the Basic EASA Regulation that is flying for the purpose of a commercial transport flight and which is registered in a country other than the United Kingdom, unless paragraphs 2 or 3 apply
(2) This paragraph applies if the operator of the aircraft is not resident or established in the European Union, and the person acting as a member of the flight crew is the holder of an appropriate licence granted or rendered valid under the law of the country in which the aircraft is registered or the State of the operator.
(3) This paragraph applies if the person is the holder of an appropriate licence converted, granted or rendered valid under the EASA Aircrew Regulation.
Are you perhaps reading the original NPA instead of the CRD?
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There is absolutely no bitterness at all. Just a slightly bemused feeling that two obviously intelligent people can't see a well planned sequence of events falling into place. The fact that I understand and agree with the policy is neither here nor there.
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Are you perhaps reading the original NPA instead of the CRD?
Many thanks.The CRD is here.
So in essence this appears to be a false alarm.
However I must confess I cannot get my head around the new ANO wording, especially given its lack of paragraph identing due to being squeezed into the narrow column.