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Brexit

Old 23rd Jan 2021, 19:55
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Originally Posted by ApolloHeli View Post
Ovc000 may be more informed than me, but from my understanding that is perfectly acceptable. The UK CAA have told me they will begin issuing UK Part FCL licences starting in April 2021. Why they are waiting till April, when the rules changed in January I have no idea. Maybe that would be too efficient. But from my understanding an EASA licence holder need only request a UK Part FCL licence and then in the usual CAA turnaround time of far too long, they will receive a UK licence (in addition to holding their EASA licence).

I would be happy to be corrected, or given more information.
Wont you need for that also to get a medical class1 in the country (CAA) the issues the licence?
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Old 23rd Jan 2021, 20:25
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I have a few ICAO licences and the issuing country will generally give credit for your licence, log book hours and type ratings. To issue the licence the new country requires a medical examination, an air law exam and a flight test. I doubt it will be quite that simple in EASA land for a 'third country' licence.

I anticipate that the requirements will be similar to a 10,000 hour Australian CASA ATPL(H) CIR holder applying for a UK licence - all 14 ground examinations, a medical, a flight test, type rating examination and a sizeable bank loan.
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Old 24th Jan 2021, 10:37
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Originally Posted by Northernstar View Post
I have read the same advert. Absolute HR nonsense given several of their pilots including management recently moved licences to EASA states. Indeed another North Sea operator encourage pilots to move to Sweden for their entire U.K. AOC operation and a third did the same for some of their U.K. training department.
The FOM has actually posted the advert on LinkedIn and states that they are only taking UK FCL because of their ATO and lack of flexibility by some EASA countries.
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Old 24th Jan 2021, 18:06
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Originally Posted by Northernstar View Post
I have read the same advert. Absolute HR nonsense given several of their pilots including management recently moved licences to EASA states. Indeed another North Sea operator encourage pilots to move to Sweden for their entire U.K. AOC operation and a third did the same for some of their U.K. training department.
Not nonsense, but a pragmatic approach until EASA enable some sort of reciprocity.

First problem is finding a UK based AME to conduct an EASA medical. As far as I know there is one in London that is approved ONLY by Austrocontrol , but EASA are insisting that the AMEs have to apply to each NAA to obtain individual approvals. The NAAs are not making things easy, e.g. I believe the Swedes are insisting that the AME speaks Swedish.

Second problem is that a UK licensed TRE is now not allowed to conduct a licence PC or Skills Test on an EASA licence holder.

Third problem is that a UK ATO can not conduct any ATO activity on an EASA licence holder e.g. initial Type Rating or Type Rating/IR renewal.

Perhaps Northernstar can explain how he would overcome these issues?
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Old 24th Jan 2021, 21:19
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Originally Posted by Variable Load View Post
First problem is finding a UK based AME to conduct an EASA medical. As far as I know there is one in London that is approved ONLY by Austrocontrol , but EASA are insisting that the AMEs have to apply to each NAA to obtain individual approvals.
That's not true. I've spoken with that particular London-based AME, as well as with my own NAA's aeromedical section and they confirmed that despite the AME being approved by Austrocontrol (not my NAA), they are able to revalidate my EASA Class 1 medical in the UK. Yes it's a pain to travel from Aberdeen down to London, but I don't see why the medical would be a factor in Babcock's strange recruiting limitation.
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Old 24th Jan 2021, 21:22
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Originally Posted by Variable Load View Post
Second problem is that a UK licensed TRE is now not allowed to conduct a licence PC or Skills Test on an EASA licence holder.

Third problem is that a UK ATO can not conduct any ATO activity on an EASA licence holder e.g. initial Type Rating or Type Rating/IR renewal.

Perhaps Northernstar can explain how he would overcome these issues?
FCL.900(c) & FCL.1000(c)
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Old 24th Jan 2021, 22:13
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Originally Posted by ApolloHeli View Post
That's not true. I've spoken with that particular London-based AME, as well as with my own NAA's aeromedical section and they confirmed that despite the AME being approved by Austrocontrol (not my NAA), they are able to revalidate my EASA Class 1 medical in the UK. Yes it's a pain to travel from Aberdeen down to London, but I don't see why the medical would be a factor in Babcock's strange recruiting limitation.
I'm no expert on AME approvals, but what you have written goes against what is being said by the AME based in Peterculter. No doubt things will become clearer over time, but the fact that only one AME in the UK has managed to obtain EASA approval speaks volumes that this isn't straightforward.

For a business to have to travel it's pilots to London for a medical is an unnecessary expense and complication. If it can be avoided, why not avoid it?

As mentioned earlier, the medical complication is only one consideration. There are others. If their decision doesn't suit you as an individual, it doesn't mean their decision is incorrect.
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Old 25th Jan 2021, 00:03
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Originally Posted by Variable Load View Post
Not nonsense, but a pragmatic approach until EASA enable some sort of reciprocity.

First problem is finding a UK based AME to conduct an EASA medical. As far as I know there is one in London that is approved ONLY by Austrocontrol , but EASA are insisting that the AMEs have to apply to each NAA to obtain individual approvals. The NAAs are not making things easy, e.g. I believe the Swedes are insisting that the AME speaks Swedish.

Second problem is that a UK licensed TRE is now not allowed to conduct a licence PC or Skills Test on an EASA licence holder.

Third problem is that a UK ATO can not conduct any ATO activity on an EASA licence holder e.g. initial Type Rating or Type Rating/IR renewal.

Perhaps Northernstar can explain how he would overcome these issues?
Well if you read my post again then you’ll see that clearly the operators themselves have found said solution to questions 2 and 3 where necessary especially if they have taken it upon themselves to encourage some to move state and even moved state for their own TRE’s. Indeed some have both U.K. and easa ATO’s, onshore U.K. ATO’s have begun the same. Medical as described can be done in U.K. and more AME’s will follow. Some EASA states are pragmatic.

My post was also calling HR nonsense as opposed to EASA or company ATO processes. But that may have been misinterpreted.
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Old 25th Jan 2021, 12:22
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Hi All, sorry to jump in but I have recently gone through the SOLI Transfer (State Of Licence Issue). The deadline on the UK CAA website to effect a transfer was 24/12/2020. I submitted on 22/12/2020. The CAA were very proactive and supportive.

Some things I learned along the way:

1. As of 01/01/2021 UK issued EASA Licences revert to 3rd Country Licences
2. The Brexit Trade Deal signed on 24/12/2020 has a mechanism in AVSAF-01 for mutual recognition of each others "Certificates" which in the definitions to the section include Flight Crew Licences. However, the text refers to "Annexes". The only "Annex" issued at the moment covers the mutual recognition of design certificates. It not clear whether there is a future intent to issue the missing Annexes..
3. In the SOLI process the applicant must relinquish the existing EASA Licence to take up the new one.
4. UK CAA will accept applications to issue a "National" Licence from applicants who previously held UK CAA EASA Licences from April 2021. The detail of how this will work they are going to publish on SKYWISE.

In my opinion, the CAA tried there very best to get mutual recognition but have been defeated by the political process.

DB
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Old 25th Jan 2021, 15:20
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DB is correct, the UK CAA appear to have been very pragmatic in their approach. They continue to recognise EASA certificates that were in place on 31st December for a period of up to 2 years or until it's next renewal. This applies to non-UK issued licences, TRE certificates, medicals, simulator certification, etc. They also have a blanket validation for EASA licenced pilots to continue to fly UK registered aircraft.

Has any UK licenced pilot managed to obtain an EASA State validation to fly a commercial aircraft registered to an EASA State?

To pick up on Aucky's earlier Part FCL references, does sub para (c) (2) (i) rule this option out for any training conducted within the EASA states e.g. simulators in France, Italy, Norway or Finland? Has any UK TRE managed to obtain an "EASA" TRE certificate?
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Old 25th Jan 2021, 21:22
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There is an AME in Stansted that has a Maltese approval. So that’s definitely two in the UK!
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Old 25th Jan 2021, 22:25
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EASA class 1 medical

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Old 25th Jan 2021, 23:47
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Originally Posted by Variable Load View Post
To pick up on Aucky's earlier Part FCL references, does sub para (c) (2) (i) rule this option out for any training conducted within the EASA states e.g. simulators in France, Italy, Norway or Finland? Has any UK TRE managed to obtain an "EASA" TRE certificate?
I believe it does, but I don’t have first hand experience of how this applies to simulators, and whether they are treated any differently to an aircraft being operated in that country. It would however allow training and testing of EASA licence holders in the U.K. subject to approval from an EASA NAA. I believe that once you have completed the process of standardisation and assessment with that NAA you have the privilege to train/examine for any other EASA NAA, subject to staying up to speed with the relevant NAA’s examiner differences document.
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Old 26th Jan 2021, 11:28
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Originally Posted by Variable Load View Post
Has any UK TRE managed to obtain an "EASA" TRE certificate?
Hi VL, I have been issued a TRE certificate from my new host EASA state based on the SOLI Transfer of my UK-EASA Issued ATPL(H) and TRE Certificate. It was very straight forward and facilitated by the CAA Form 155 that was issued. The 155 is the document that passes between EASA States to verify the qualifications and authorisation held in the first state. My understanding now is, as the deadline has passed, such transfers are no longer possible.
As it stand, it would appear that UK TREs are in a worst position than we were under the JAR rules where we had to complete State Briefings to certify fellow JAR State licences. As a "Third Country" we have been demoted to Pond Life. Such a shame for all the hard work and dedication those TREs have put in previously. Lorry Drivers have come off better.
Like I said, it was not the intent of the CAA. They simply wanted mutual recognition based on us continuing to follow the EASA rules. My understanding is that due to the morons in the Country and Government who cannot understanding the difference between Sovereignty and Mutual co-operation, we are left in a really poor situation. EASA was a great level playing field and now we are now not allowed to see the match let alone
kick the ball.
Maybe we can all seek solace in eating the Langoustines that are now trapped in the UK and not lavished onto the dining tables of our French Brothers.
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Old 26th Jan 2021, 19:22
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Hi DB, I've also been through the SOLI Transfer process and plan to apply for the UK licence as soon as is possible. A agree, now that the transition period has ended, SOLI Transfer is no longer an option for UK licence holders. EASA licence holders will be able to apply for a UK licence from April, although the CAA have stated this will be much easier for those with a "UK history".

My earlier question "Has any UK TRE managed to obtain an "EASA" TRE certificate?" was badly worded. My question related to Aucky highlighting that FCL.900 (c) and 1000 (c) does provide some provision for a Third Country Instructor/Examiner (read UK licenced TRI/TRE post 31st December) to obtain an EASA TRI/TRE authorisation. I wondered if anyone had used this provision successfully. If they have, I wonder what limitations are attached. My read is that it is intended to enable flight training and checking for initial licencing purposes to take place outside of the EASA States e.g. flight schools conducting CPL training in USA, Australia, New Zealand, etc.

The situation is an unnecessary mess, as mutual alignment and recognition of licencing standards between EASA and UK is such an easy win. It just needs political will, however that will is totally lacking on both sides. To think that EASA is still pursuing FAA licence reciprocity just shows how crazy this situation is.
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Old 27th Jan 2021, 00:40
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Originally Posted by Same again View Post
A reason that many (I am reliably informed) voted for Brexit was that whenever Brussels imposed new rules we - the law abiding UK - would always comply whereas EU states only did so when it suited them. It seems that even though we are no longer members of that illustrious partisan club we are still being shafted. Plus ca change plus c'est la meme chose.
This whole business falls out of ignorance of how we are governed, at any level. Particularly regarding EU legislation, this is illustrated by the difference between a Directive and a Regulation. A regulation is law and a directive is not and allows member states to pick their own path.

A perfect example is speed limiters on trucks. A fire brigade operating a national resource that they wanted to be able to deploy anywhere in the country talked to the RAF about airlifting the vehicles because, being limited to 90km/h, the vehicle could not get anywhere fast. The Directive explicitly exempts emergency service, military and certain utility vehicles (Art.6 IIRC) yet the UK Govt enforces it in such a way that emergency service drivers transporting life-saving apparatus across large distances were forced to travel at 56mph. Successive UK Governments keen on too much law, and their compliant bureaucrats, have been the problem all along and look where we are now.

Long past the time when we should have started calling stupid by its real name.
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Old 28th Jan 2021, 08:16
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Updated EASA statement about the cooperation agreement

https://www.easa.europa.eu/document-...tion-agreement
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Old 28th Jan 2021, 09:33
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Has anyone been brave enough to read and decipher?
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Old 28th Jan 2021, 10:46
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Originally Posted by Same again View Post
Has anyone been brave enough to read and decipher?
That page and the documents have been there for a few weeks now. What I can't work out for sure is what has changed, as EASA sent out an 'update' notification this morning.

Does anyone know what has been amended or added? I think it might be the Working Arrangement with Switzerland.
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Old 30th Jan 2021, 12:09
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Originally Posted by Same again View Post
Has anyone been brave enough to read and decipher?
If you are referring to the Trade Agreement, yes I have read the AVSAF part. As stated on the EASA website, there is a clear statement and mechanism for the mutual recognition of Compliance findings and Certificates of each party (this includes each others FCL Licences). However, the statement refers to the "Annexes" of which the only one in the detailed list that has been issued concerns certification of aircraft and components. Now I am trying to not be cynical as I slide gently towards my 6th decade, however, I suspect the very large AIRBUS FW component industry in the UK may have caused France to stamps its "pied" to ensure UK wings get glued to European fuselages.

In my SOLI Transfer process, someone in "the system" told me that UK CAA made best efforts for this mutual recognition to be in place. However, to facilitate this the UK had to agree to be bound by certain European Legislation (otherwise no certainty of compliance is assured). Despite the fact the UK is legally bound by many treaties already, such as the ICAO Chicago Convention, NATO etc the UK Negotiating team were not empowered to agree to be bound by the necessary legislation. Hence, the annexes relevant to FCL etc are not issued.

I believe it is for this reason that neither the UK CAA nor EASA are able to make any statements relevant to future co-operation and specifically whether these annexes will ever be issued.

UK CAA meanwhile, treated like a mushroom by the politicians, ended up agreeing to unilateral recognition of EU Members FCLs for a 2 year period and also have made a fast track process for those EU members caught up in the debacle to get UK National Licences if and when they need them. Of course that is good news for all our fellow EU Rotorheads who have made their home and lives in the UK working for UK AOCs.For those of us on the opposite side of that fence....well lets say the Big Rabbit got F**ked!

For my own experience, the UK CAA were extremely helpful is facilitating my SOLI Transfer. This process means I give up my UK Part-FCL Licence. However, they have made a commitment to a simple pathway in April for those of us who had to Transfer to be re-issued with a UK National licence once again.

I have to say that I was a great advocate of EASA. I believe they simplified a whole range of protocols and procedures to our benefit even if it seemed at some time to do otherwise. Much of the regulations and rules originating in dear old Blighty.

My wife just received her new "Blue" Passport, (I believe made in France) and my VW Toureg did not self destruct on my driveway at midnight on 31/12/2020. So maybe in a few years we will look back and see a small storm in a very small teacup. Who really knows what the bejesus is going on anyway!
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