They should also be covered by the exemption in ORS4 No 1490 whose 21 December deadline should be treated as final.
Is there an expectation that the political situation (which has given us ~10 years of derogations) will change, thus making it “reasonable” to expect piggyback FAA PPL (and perhaps FAA Foreign Pilot IR Exam) holders to obtain standalone FAA papers? That is quite difficult nowadays, starting with this and that’s before you get onto the perenially tricky DPE situation.
I think this will be discussed on tonight’s Zoom.
The deadline applies equally to standard and restricted certificate holders so that question is moot. The art 12(4) derogation was only used by the UK pending the extension of the US–EU BASA to pilot licensing.
Great example of a “regulatory ratchet”.
Pre EASA, even under JAR-FCL, the UK accepted any ICAO licence for use on G-Reg aircraft for VFR without any formality, and had nothing preventing unrestricted use of FAA licences on N-Regs.No forms, paperwork or anything. EASA introduced time limits and mandatory paperwork for licence validation, and the infamous dual licencing requirement. It also introduced the ratingology, racked up training and theory requirements for the IR, etc. etc.
Any expectation that the UK CAA would sensibly go back to what it was before was, sadly but predictably, misguided.
They are called a ‘regulator’, not ‘de-regulator’, for a reason.
It would be great to know what is going on behind the scenes – to be a fly on the wall as the saying goes.
The impression I get is that the CAA is really short of smart people now. 3 years ago they “lost” my IR reval papers for 9 months (“found” only when I wrote to Mr Moriarty the chief exec who seemed to be the only person in there who gave a damn about anything) and robbed me of the missing 9 months’ validity despite telling me on the phone I would get a fresh 12 months because they messed up. When I pursued this, they made it clear to me that unless you record your phone calls with the CAA, they cannot be held to anything they say, which is absolutely appalling. So guess which phone app I bought right away 
The phone calls I had around that issue made it totally clear that the place was made up of (a) well meaning but clueless low level office staff and (b) “middle managers” who didn’t know what they were talking about, and waffled their way out of any difficult question.
And we all know what “less than smart” people do. They have to develop an entire ecosystem to safeguard their jobs.
It takes a chief exec with real balls to sort this out, but all the time the DfT is recruiting Cambridge Arts graduates, and all the time the CAA chiefs are quango queens who can’t tell one end of a plane from another and know even less about the tech issues, there is no hope.
Maybe in due course the depletion done by EASA over the years will be restored… but almost nobody recruits anyone smarter than them (I always did that because it makes my job way more fun ).
I see Mr Moriarty is still there.
By the way, the German LBA has recently published the form to be used in order to apply for an EASA license or rating on the basis of an FAA license/rating as per US-EU TIP-L. Here.
On this basis, from now on, Germany will likely no longer renew the derogations discussed hereunder. If they did, they would admit that the BASA is not effective.
That would be totally amazing.
With just an FAA PPL/IR, a German pilot can get himself an EASA Class 2 medical, and have a permanent EASA PPL/IR?
The treaty doesn’t AIUI provide for that; it doesn’t provide for anything actually useful, beyond the current CB IR conversion route. I recall this bit came from a website written in German.
Qalupalik wrote:
No, you do not need to submit an SRG2140.
@Qalupalik, I believe this was your response to the question and scenario of a UK-resident pilot with FAA and EASA papers flying an N-reg aircraft in the UK.
I have been trying to find the legal text or exemption for that. It looks as if CAP 2017 seems to offer a general validation document for operation of G-registered aircraft with EASA papers outside the UK (to ensure that the pilot has the correct papers when subject to a ramp check outside of the UK).
Where can I find any statement about the continued (temporary) recognition of EASA papers for the operation of G-registered or, specifically for the case above, N-registered aircraft in the UK?
I have been trying to find the legal text or exemption for that.
Pre- 31/12/2020, it was obviously the case that if you had both EASA and FAA papers (license, IR if applicable, medical) then you, as an EU based operator, comply with EASA FCL, and could keep an N-reg in the EU.
What the post- 31/12/2020 position is I don’t know but I can’t imagine it has changed. The EASA FCL “anti N-reg stuff” was incorporated into the ANO.
Where can I find any statement about the continued (temporary) recognition of EASA papers for the operation of G-registered or, specifically for the case above, N-registered aircraft in the UK?
The UK accepts EASA papers for 2 years post- 31/12/2020 so I would imagine that concession would cover you.
There is in any case no harm in sending in the SRG2140/2142 and I think quite a few people did that anyway, because it covers you (currently until Dec 2021) in case any of your EASA papers expire.
It is like possessing an NPPL and the medical self declaration (the PMD), in the pre-2018 days when this was valid for an N-reg (VFR UK etc). Lots of people have got the NPPL and the PMD “just in case” although the validity for an N-reg is probably questionable now – here.
Thanks, Peter. What you stated above has exactly been my assumption but I have not been able to find any text that refers to a general acceptance of EASA papers until the end of 2022 for the purpose of complying with the requirements of the retained Basic Regulation and Part-FCL.
All references on the CAA website seem to refer only to this in the context of the operation of G-registered aircraft but again I could not find any formal legal text/exemption except for the website text. In other words, what creates the legal basis for that acceptance of EASA papers until end of 2022?
wbardorf wrote:
I have not been able to find any text that refers to a general acceptance of EASA papers until the end of 2022 for the purpose of complying with the requirements of the retained Basic Regulation and Part-FCL.
Nor have I. You probably expected to find an exemption similar to ORS4 No 1454 (link) ORS4 1454 local copy for a Swiss Part-FCL licence. The reference to Part 3 of Schedule 8 to the European Union (Withdrawal) Act 2018 in CAP2017 might explain the absence of a similar exemption for EEA Part-FCL licences.
Re form SRG2140. That must be lodged in order to exercise US pilot certificate privileges in the UK either on a Part-21 (formerly an EASA type) aircraft registered there or, where the operator resides or is established in the UK, on any aircraft registered elsewhere than in the UK. The question raised by GRIFF in post 72 (21 May 2021) was a different one because it involved flying outside of the UK.
