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What will FAA IRs / N-reg pilots do in the UK after 21 December 2021?

WHEN (and most aeronautical commentators think it is ’When’ rather than ’If’ this time) the CAA fails to Derogate this 21 December 2021 – something it has done (very late in the day) for many years – Private Flyers ’resident’ or an ’Operator’ within the UK will be required to use a CAA license to fly within the UK and in exercising any Ratings these must be incorporated on to that license. This will therefore effect everyone in the UK who exercises a FAA IR.
For most, who exercise their FAA IR’s via a 61.75 FAA license (a ‘piggyback’), they will already have a CAA/EASA license upon which their IR is ‘based’. Likewise, most of those who (like myself for the past 20 years) have flown on a ‘Stand Alone’ FAA license have, nevertheless, maintained a CAA/EASA license. There will, though, be some who have no CAA/EASA license: These will have to start from scratch to obtain one.
But ALL will need to Convert their IR to a CAA one if they wish to fly in Class A airspace in the UK.
I have long argued, in the past, that such ‘conversions’ should be done Equitably and Mutually i.e. A UK pilot with a UK IR should be able – as he/she can – to have his qualification recognised and, with fair ease, receive an FAA IR with the responsibility to keep the FAA requirements thereafter in keeping it current i.e. 6/6 or an IPC.
Conversely, an FAA IR (which is ICAO compliment) should likewise be fairly easily exchangeable for a CAA one with the same responsibility to keep it current i.e. A Renewal every 12 months.
But, although the FAA is keeping its side of the exchange, the CAA is insisting that those holding an FAA IR must do an IR Initial TEST (NOT a Renewal) with all that that entails.
Jim Thorpe of Rate One Aviation at Gloucester, who has been heavily involved in the Conversion process for many years, and is respected for his knowledge and observations in this area, has written recently that many FAA IR’s in the UK will need up to 15 hours training for the Test: Not to fly IFR (many of us have been doing that safely for 20 years or more) but in order to learn and conform to the foibles of the UK Test. If one works on the basis of £250 per hour, one is therefore thinking of £3,750 to prepare for the Test which itself costs £850 + plane expense (£250) = £1,000.
For someone like myself who anticipates exercising their IR for only possibly another 4/5 years, with the Annual Renewals (@ £250 per year: another £1,000), one is talking of spending £6000 to fly in UK Class A – since I am already qualified to fly IFR in ALL the rest of the world.

Is it worth it? And what will other UK FAA IR pilot’s do?
Looking at my Logbook for my last ‘normal’ year i.e. before Covid, among all my flights I did 16 long-distance IR journeys, 4 of which were in the UK (a return trip to Scotland & a return trip to Ireland). Although it is nice and convenient to fly at FL100 above the muck, all those UK journeys could have been done exercising my IR(R) rights since all my landings were at fields OCA.
Likewise, flying from the South-East of England, I can easily & safely get to the French FIR using my IR(R) and ‘pick up’ my IR flight plan from there.
Peter In this forum post seems to imply that I am not alone in thinking/reacting in this way? Am I?

Last Edited by Peter_G at 03 Nov 18:06
Rochester, UK, United Kingdom

Although one needs to do an IR skill test rather than a proficiency check, the standards/requirements are essentially the same.

When I was preparing for my EASA IR skill test in Germany (for the FAA conversion to my EASA licence), I did a practice IR skill test with someone who is a CAA examiner and asked him whether he would give me a “pass” if I did the skill test with him and the answer was yes. Honestly, there wasn’t anything too special about the practical test especially if you regularly fly IFR in the UK today. The “hard part” is memorising the theory associated with the learning outcomes that are required by the CAA/EASA, some of which you should be familiar with anyway (e.g. Part-NCO stuff). That is all ground school only though and can be self-studied.

So in other words, I don’t think you need to spend 15 hours of additional practical training, if at all (you might need to practise and refresh one-rate turns using a compass only if you are not proficient in that anymore). 15 hours might apply to an FAA IR pilot who has NEVER flown in the UK/Europe to get the hang of how things work in practice but I think even 15 hours are over the top.

Last Edited by wbardorf at 03 Nov 18:31
EGTF, EGLK, United Kingdom

I just did my IR Initial test to go FAA to CAA and found it to be a completely practical and sensible test of ability to operate – there was nothing in the test which I don’t do day to day except stalls, limited panel and recoveries. I might use the AP a bit more but there’s nothing like keeeping hand flying sharp. Using the bearing needle for spacial awareness is useful, there’s no doubt. But then again I like to train every two or three times a year for at least four hours each time on top of keeping very current so maybe it’s just that I enjoy the punishment. I also fly IR, alot, with my family on board which changes ones perspective on costs. Looking at this versus the cost of doing a full CAA IR from scratch, my own view is the CAA are virtually giving it away in some contradiction to their normal MO. Ironically, flying in CA is a lot more relaxing than mixing it with the weekend warriors……… I know. Un PC. But true.

Last Edited by Pig at 03 Nov 18:53
If only I’d known that….
EG.., United Kingdom

I think most UK based pilots started their flying life with a UK PPL. I know some just went to the US and did it all out there but the numbers are small.

So these can regain their PPL with a flight with an FE and by getting a UK medical.

They can fly VFR up to the Channel airspace boundary and then they have the full FAA PPL/IR privileges This works very well and I have been doing it because it shortens the distance compared to London Control sending you e.g. all the way to TRACA and then you have to negotiate a shortcut. If you depart (Shoreham in my case) direct to BILGO you save a lot of distance. This is the typical situation going “south”

And if you have the IMC Rating (I am not sure if the CAA is still issuing the IMCR to anybody with an FAA IR and a current IPC i.e. they disregard the rolling currency) then you can fly legally IFR, below Class A. Not that anybody can tell the actual conditions of your flight, at 5000ft…

Otherwise, if the derogation is not extended in December, then the CB IR conversion route gives you a way in, with a skills test with a CAA appointed examiner.

has written recently that many FAA IR’s in the UK will need up to 15 hours training for the Test

He is probably right – in that bit

It is different for someone living up north; say Birmingham. For them, IFR in UK Class A is a desirable option.

However, we shall see what happens in December. The derogations have been running since 2011 or so and the political climate has not changed. Brexit is nothing to do with this; in fact if anything it makes the UK look extra aggressive, because the main mainland countries are continuing to derogate. I don’t “get” why the CAA here is getting so aggressive; putting a load of N-reg owners out of circulation will reduce the upper end of GA activity. These are people with the highest hours, the best-condition aircraft, and the biggest fuel spend. And dropping out is a real risk; CV19 has already caused a lot of these “old timers” (of which I am one ) to chuck it all in.

Shoreham EGKA, United Kingdom

I don’t think CAA IR is worth it for someone based in UK SE if you have a valid FAA IR valid worldwide and IRR for use in the UK, besides you will get routed out or dumped of LTMA anyway

Your FAA IR is way more desirable and useful if you are flying in Europe: complex airspace and tout ca

Paris/Essex, France/UK, United Kingdom

I agree.

The obvious exception is if you want to fly north, say Shoreham to Oban, when the VFR option is truly horrible. Try the Manchester/Liverpool low level route for a “guided missile experience”, mostly with transponders off due to the new CAA no-prisoners policy Or fly to Ireland; you have lots of Class G in the UK portion (if you do the long over water version) but the IR enables you to get above the wx and above icing conditions. Obviously implicit in this discussion is “VFR in IMC being undetectable” but with an IR you are a lot safer due to avoidance of icing.

So, if Dec 2021 is not extended, I reckon lots will drop the IR and just “hack it” like [almost] everybody else does.

Shoreham EGKA, United Kingdom

I know this has probably come up before, and notwithstanding any new regulations that might come into EASA in the near future, but why can’t a pilot of an N reg on FAA PPL/IR papers, fly IFR on a Eurocontrol flight plan in the UK?
And would those rules still apply to the same pilot and plane coming from say France where s/he is resident, for a flying holiday to parts of the UK?


gallois wrote:

but why can’t a pilot of an N reg on FAA PPL/IR papers, fly IFR on a Eurocontrol flight plan in the UK?

Only “UK based operators” and to be clear they can today but not after Dec21 unless there is an exception

One can define based/residency to your advantage if you have something that you can use to push back: aircraft not based permanently, you live abroad, you are US citizen…if you are 100% UK citizen, 100% UK taxpayer, aircraft is 100% in UK and you eat “full English” everyday…it will be hard to claim you are not “UK based operator”? unless you have a poker face

PS: same thing is happening in France but deadline is way down the road to bother…

Peter wrote:

Try the Manchester/Liverpool low level route for a “guided missile experience”

Yes I agree in some places it helps, especially the low level tunnels where VFR is hectic

Peter wrote:

with an IR you are a lot safer due to avoidance of icing

Yes it gives more options but I guess you mean with turbo & oxygen and other gadgets to go up and sit VMC on top fully in CAS?

Otherwise wrestling with an IR in airspace near boundaries and near 0C in clouds is not helpful or productive, the airways system is just not designed for tactical avoidance and you are likely to be put on hold in “the hottest spot of the day” all year along not just in winter: the only time where I felt going beyond where I should was being “blocked” in LTMA on the (usual) hectic departure from UK SE, I end up dipping back to Golf as it was way safer: flying aircraft in a predictable manner with plenty of room left, right and down

Last Edited by Ibra at 05 Nov 09:55
Paris/Essex, France/UK, United Kingdom

, fly IFR on a Eurocontrol flight plan in the UK?

Because the EASA FCL anti N-reg measure reappeared, post-brexit, in UK law. I think it is here.

EASA’s own measure was supposedly incorporated into UK law in the EU Withdrawal Act but IMHO / IANAL the wording would not have worked, due to the use of the word “Community” which obviously means the EU.

And would those rules still apply to the same pilot and plane coming from say France where s/he is resident, for a flying holiday to parts of the UK?

No, because you are not “UK based etc”.

Similarly a UK based FAA PPL/CPL/IR can fly worldwide, outside the UK, on just FAA papers – because as far as the above EASA FCL measure goes, the UK ranks no different to say the US, Botswana, etc. This is the OP’s drift – you can fly VFR, or “undetectably VFR in IMC”, all the way to the UK airspace boundary, and then your FAA papers are just fine.

Shoreham EGKA, United Kingdom

Or submit CAA form SRG2141 allowing a US pilot certificate to be used in the UK on any of 28 days in a calendar year.

London, United Kingdom
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