JAA or EASA should I wait?

[Kolossi]

Hi BillieBob,

Thanks for those updates. Bizarre though it is I find myself preferring an anonymous internet poster over a senior management in a relevant regulator body - though with of course caveats in my own mind of wanting it in writing from CAA/EASA/whoever as mentioned in UV's post.

But perhaps then you could spare your opinion on the 7 April 2015 date mentioned by the CAA Manager? I'll accept what you said about the pilot licences and the EASA rules (until somebody proves otherwise ). But could it not be akin to the visibility requirements in VFR - the rules of the air specify one thing, but then your licence limits it further? What I mean is in this case could it be that the JAA licence itself is indeed valid for the full 5 years, but it won't actually be permitted to fly EASA-registered aircraft after 7 April 2015 on a JAA licence or something like that? I'm sure the man from CAA gave some explanation of that date at the time but I didn't note and can't recall what it was.

BTW, just out of interest (for me, as I'm sure for others here), where did you pick up the info BillieBob? I see that many of your posts on PPrune relate to regulation and are backed up with references - do you work in the field with CAA/EASA, or are you just good at finding and dissecting the docs? Unfortunately as in the visibility example above, in aviation it's often a case a a referencable document says something explicit, seeming to give a definitve answer, but another somewhere else contradicts or refines it - but it would be nice to know the provenance of the opinions that you are helpfully providing. Not meaning to doubt, just to understand. Thanks

[peterh337]

I don't know who Billiebob is but I think he is ex CAA and perhaps working as an aviation consultant.

The problem with the CAA is that so many smart people have left in the last 1-2 years. The contrast between now and say 10 years ago is staggering. It is virtually impossible to get a decent answer out of the CAA on anything now - unless you know somebody on the inside who happens to understand the stuff. The people on the public interface don't seem to know anything.

Also, the CAA is maneuvering carefully on anything to do with EASA so as to protect the various historical UK GA entitlements such as the IMCR.

[BEagle]

One final factor you may wish to consider is the following, though I couldn't get any definitive answer from anybody about whether it's true or not (even from CAA). With a JAA licence, you can still add on the IMCr, which when the licence is converted to EASA will be noted as IR(R). It's my understanding that if you get a straight EASA licence, you do not have any route to tack on an IR(R), so your only route to fly in anything other than VMC would be to do a full IR.

I will try to keep this simple and comment only on the issue of new IMCr / IR(R)s to those JAR-FCL PPL(A) holders who currently do not hold one, for use on EASA aeroplanes.

Please also note that the CAA will not be processing any applications between 13 and 16 Sep 2012 whilst they change over to the new licensing system.

1. If your application is processed before 13 Sep 2012, it will be issued as an IMC rating for inclusion in your JAR-FCL PPL(A).

2. If your application is processed after 16 Sep 2012, but before 8 Apr 2014, it will be issued as an IR(R), to be included in a part-FCL PPL(A).

3. The situation regarding issue of new IR(R)s after 8 Apr 2014 is still under debate.

4. You must convert any existing IMCr into an IR(R) if you wish to use it from 8 Apr 2014. The conversion is purely administrative. If you fail to do so, you won't be able to use the IMCr privileges on EASA aeroplanes until you do convert.

The IR(R) is identical to the IMCr as regards privileges, revalidation and renewal requirements!

[BillieBob]

But perhaps then you could spare your opinion on the 7 April 2015 date mentioned by the CAA Manager?

In relation to your specific query, I can see no significance in that date. A JAA licence is deemed to have been issued in accordance with Part-FCL and so there is no limit to its validity other than the final date of 7 April 2017 (now 2018) by which all JAA licences must have been replaced.

The derogations from Part-FCL that are allowed until 8 April 2015 by Article 12 of Regulation 1178/2011 are:

• All provisions related to licences for powered-lift aircraft, airships, balloons and sailplanes
  
• The provisions of subpart B (the LAPL)
  
• Introduction of the aerobatic, towing, mountain and flight test ratings
  
• The helicopter MCCI
  
• The mountain instructor and flight test instructor

None of these has anything to do with the validity of JAA licences.

As to knowing my way around the regulations - it is what I am paid to do. When I stopped flying commercially a few years ago, my employer kept me on with a brief to monitor the development of EU regulation and how it was going to affect the industry in general and the Company in particular. Up until recently, that has been focussed on the Aircrew Regulation but, increasingly, is now including the forthcoming Air Ops Regulation. I am also still active in my local flying club and so extend my interest to the effect on flight training generally. Contrary to Peter's assumption, I have never been employed by either the CAA or EASA, although I was involved as an industry representative in the early days of development of the Essential Requirements.

I might also say that, having grown up in a farming family, I have seen the dead hand of European bureaucracy, coupled with an incompetent government department (DEFRA in that case) all but destroy an entire industry. I can now see a repeat of that destruction in the making and the best (only) way of preventing it is to keep one step ahead of the bureacrats and maintain pressure on the appropriate government department (the CAA as an agency of the DfT) to avert the worst excesses.

Edited to add the following quote from CAP 804

JAR licences issued before 17 September 2012, that are fully compliant with JAR-FCL, automatically become Part-FCL licences. The legislation requires the physical replacement of JAR licences with their Part-FCL equivalents on calendar expiry (so that all are replaced before 8 April 2018).

I had missed the line in Article 1 of Regulation 290/2012 that amended the final replacement date in Article 4 of Regulation 1178/2011 from 2017 to 2018.

[Kolossi]

Thanks for all your replies, most interesting and very helpful to me, and hopefully to JAJW too as he started the thread

[BEagle]

I had missed the line in Article 1 of Regulation 290/2012 that amended the final replacement date in Article 4 of Regulation 1178/2011 from 2017 to 2018.

That was sneaked in when it was obvious that no-one else (apart from the UK) was going to be ready to issue part-FCL licences until Apr 2013, so Apr 2018 was the last valid date for a 5-year licence issued immediately prior to the EASA changeover date.

Incidentally, a non-JAR compliant pilot licence may still be used for flying EASA aeroplanes after Apr 2014, but only within the scope of the LAPL(A) and only until Apr 2015.

The CAA has already had to come up with 2 x 2 month deferments regarding Flight Examiners (1 refers to seminar requirements, the other to non-UK Flight Examiner briefing) - are we really sure that there won't be other issues too - such as the situation regarding PPL exams / mandatory 'groundschool'?

[JAJW]

Thanks for all of the replies. I have to admit, I got a little confused by some though. My impatience got the better of me and I have sent off for my PPL before the EASA transition.

Fingers crossed I get it soon, I'm bored of being on the ground.

[luckyllama]

So if I have a JAA PPL with four years to renewal, and intend to do an IMCr for the first time before April 2014, does it make sense to get an EASA now (first), get the IMCr first and then convert to EASA, or simply add the IMC to the JAA and wait until 2017 comes around to convert?

As a separate Q presumably an FAA piggy back becomes invalidated by the change to EASA and needs to be applied for again?

[iblackfin]

When you send all your paperwork to CAA in order to add your fresh IMCR the CAA will send you EASA licence back with IR(R) in it.

[Whopity]

In order to add the IMC to your JAA licence it will have to be converted as they cannot amend a JAA licence. Do it all at the same time. As you retain the same licence number it should not affect your FAA licence.

[S-Works]

You don't retain the same licence number and your FAA 61.75 will be invalid.

As an example my licence number changed to

GBF.FCL.CP.xxxxxxx.A

This has been confirmed by the FAA to invalidate a 61.75. There are steps being put in place at the moment to sort out reissue of these certificates.