Foreign/N-Reg Ops in Ireland, Should you be worried?

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Cosmic
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Foreign/N-Reg Ops in Ireland, Should you be worried?

Post by Cosmic »

http://www.dft.gov.uk/stellent/groups/d ... 35972.hcsp

From the British Department of Transport, worth a read if your operating an N-Reg or other foreign Reg aircraft in Ireland.I know this covers instruction but interesting to note also:

It should be noted that the Department is currently reviewing the legislation affecting the use of foreign registered aircraft in the UK. It is possible that the legislation may be amended to prevent foreign registered aircraft which are not involved in commercial air transportation from being permanently based in the UK.


Its been mentioned on other aviation websites that the various Aviation Authorities around Europe are a little un happy that there has been a sharp rise in the number of foreign Reg, especially N-Reg, in their countries and they have very little control over them.

On the other side of the coin, its very unfortunate that they are going to go this route instead of stopping and considering the frankly ludicrous requirements that PPL's have to meet to hold a JAA PPL/IR. That this is the reason people are going N-Reg. Would it not be a better idea to have a seperate PPL/IR to offer people as an alternative to what is essentially a commercial IR?

If the British Authorities are sucessfull are we going to see the IAA go the same route?

Discuss.

Lionel Hutz
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Post by Lionel Hutz »

Should we be worried, yes in a word.

Not so long ago, N-Reg aircraft were a curiosity in most of Europe, the only ones you saw were Airliners (Delta, United etc) and a few private aircraft on occasion.

Nowadays, N-reg is the new black.

Why did this happen?

In short the JAA.

All things in Aviation will follow the path of least resistance and when significant resistance was put in the way of private flying by creating onerous and expensive training, maintenance and currency requirements, with no safety benefit, then the people who fly privately found another way to do so without all the unnessescary hassle.

On the point of training. The JAA ATPL theory exams are of no safety benefit, in fact they serve no purpose at all.

Where is the proof of this?

In the USA

No airline pilot in the USA has ever sat these exams and yet they have the safest skies in the world. Taken in context, the USA accounts for 8 out of every 10 flights in the whole world.

Requiring Private pilots who desire an instrument rating to be subject to the same pointless exams serves only to make the JAA Instrument rating unpopular at best, unachievable for most.


On the point of Maintenance. The differences between JAA land and FAA land are too many to delve into in this post but in brief.

When an aircraft is delivered from the factory to the customer it comes with an FAA certificate of airworthiness. This remains valid as long as all the required maintenance (annuals, 100 hr checks etc) are done and all airworthiness directives are complied with.

In Short the C of A never needs to be renewed.

Is this a safe system?

Yes, General Aviation in the USA is the safest in the world.

Once again the USA accounts for the lions share of all GA activity worldwide.

In JAA land C of A's need to be renewed periodically at great expense. The aircraft it would seem needs to be disassembled and rebuilt to comply with the regulations.

Is this a safe system?

Yes, BUT.

We don't seem to be falling out of the sky in any great numbers, but then we don't fly anything like the number of hours our American cousins do.

All this disassembly/rebuiling only comes up second, in the safety stakes, to the Americans who never did it in the first place.

On the point of Currency. My FAA licence is at the moment current, my Instrument rating is not.

I have 1 more year of VFR currency left and then I will be forced to take a break for a while for budgetary and family reasons.

When I return to flying in the future what do I have to do to 'revalidate' my licence?

I have to work with an instructor until he/she is happy that I have satisfied the FAA requirements in respect of a Flght review, and an instrument proficiency check (if I so desire). How many hours this takes is between me and the instructor.

As long as I hold the required medical then no exams need to be repeated and no further checkrides need to be done.

Is this a safe system?

Yes, as above, the USA has the safest skies in the world, full stop.

If I had a JAA/JAR licence and was in the same situtaion outlined above I would be looking at written exams(irrelevant as stated above) and two renewal checkrides.

The hassle differential is significant and the cost differential is enormous.

All of this nonsense for no benefit.

I am not opposed to having a JAA/JAR licence, in fact I would like to have one, it would make international trips in EI reg aircraft a bit easier, but I don't see the point at the moment.

I have no doubt that the regulators see regulation as the only way out of this percieved problem so I have no doubt that we will see some curtailment by way of SI in N-Reg activities.

To fight for reasonable licensing, maintenance and currency. The lads at the new GA association have my full support. I believe however that this will be effective only if lobbied at a European Level.

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Post by Cosmic »

Excellent stuff Lionel, I knew I was leaving a bit of bait for you and was looking forward to your response.

I have done the Atpl's, CPL and IR. In some ways I like the fact that its a big hurdle to get over, its an achievement when its all completed and it is a fine net to weed out people of lesser ability, frombeing Commercial Pilots. I have enormous respect for the FAA system and hold a PPL and IR and a commercial soon hopefully, but I have seen some total "40 Watts" get through the system, and its too easy, there are just too many commercial Pilots.

On the other hand it is absolutely shocking to think that your average flying club Pilot, who might want a bit more flexibility and have a rating in some form that allows him to go IMC has to go through the thicker end of what I, as an aspiring commercial pilot, had to do.

The argument I have heard is that IFR is a very serious business and you can't do it by halves. I don't totally agree with this. PPL's shouldn't be looking to go out in really scabby weather or night time IFR. They should be able to file to avoid some en route low clouds, and make use of cloud break proceedures. For example, Australia recognise this. They have a busy GA environment. They have different grades of IR. There is a PPL IR and you add on the different ratings as required, NDB, VOR, ILS. There are different grades for the commercial world to with the top end being a "Command Instrument rating".

The problem with all this is that one country can't do it. They have to get all the member States to agree with it. Thats slow, not going to happen soon. Its also a case where, say the CAA of Britain, have very high standards and they won't decrease what they see as a minimum standard. So that brings it up for everyone else. In the same way we see strange things from each state being brought in to keep them happy. An example of this is the use of Nautical Air Miles in the ATPL's. This is a german thing.

Like I said, its such a shame they are going to deal with it this way. It would be nice if they would see the bigger picture and make the process of a PPL/IR more achievable.

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Post by Bearcat »

excellent replies 10/10. I have a G reg machine based here. If they make me change it EI it will cost me an arm and leg. I watch with interest.

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Post by YoYo »

Bearcat

I'd be very suprised if the IAA could force any Euro registered aircraft to take on Irish registration. Such a procedure would have to come from the EASA and I have not heard anything on the grape vine to indicate they are thinking of that route. In fact all indications are that EASA are looking at a common european policy for Sport Aviation which would negate the need to re-register in the country of residence.

'N' reg is a special case but once again I don't think the CAA would have the authority to go it alone on this as all policy has to come from EASA.

On the question of the JAA/IR. Its nothing to do with safety its all to do with money. If an individual can afford to learn to fly then he/she must be rich. If they want to fly under instrument conditions they must be very rich and rather mad. So with standard beauracratic logic - lets take as much money off the individual before they kill themsleves - helps to keep others of the dole who can be employed to teach ground school etc.

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Post by Cosmic »

Bearcat, European Reg Aircraft are not what the DFT and the CAA are after. As a G-Reg you are largely governed by the same rules as an EI aircraft. What they are after it would seem are people who they feel are outside the rules. N-Reg, OY etc.

The root of these problems as I understand it, is the result of recent prosecutions of N-Reg owners in the UK. Below is an example.

The CAA are prosecuting a Cirrus pilot for illegal IFR.The scene of the rampcheck was East Midlands Airport and that the flight had arrived off airways.The aircraft concerned had neither ADF nor DME (as is the case with many/most Cirruses) and the CAA is keen to make an example of the pilot - in line with its recent approach to infractions involving N-registered aircraft.

I certainly think if the CAA can do it they will, but it will be interesting to see if they can write a law that doesn't contravene the Chicago convention.

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Post by Bluebeard »

Lionel:"I am not opposed to having a JAA/JAR licence, in fact I would like to have one, it would make international trips in EI reg aircraft a bit easier, but I don't see the point at the moment. "

I understand there maybe a problem flying EI aircraft abroad on an FAA licence, is this what you referred to? I would like to hear the details.

This is not a problem with flying EI in the UK, as I have clarified this with the CAA, but other countries?

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Post by Lionel Hutz »

bluebeard, my interpretation of the Act, is that ICAO licences are Validated for Day VFR on EI-reg aircraft world wide, however the IAA (in my opinion, in error) have told a number of people that flight outside of Irish airspace is forbidden.

For the moment all of my flying is going to be local Day VFR, so it is not really something that I need to worry about right now, but in the future I do intend to do a bit of touring. Using a N-reg would clear all possible hurdles in one swoop, but if no N-reg is allowed in future, then I would consider converting my licence.

Glad to hear that the UK CAA are OK with EI-Reg on an FAA ticket.

If we are lucky EASA will say the same thing.

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Post by Bluebeard »

Lionel, you dont need to change your licence!

If you fly a G-reg around Europe, you won't have a problem. I have checked the status of flying G on an FAA licence (VFR) in many European countries. The answers have all been to the effect of either (i) it's OK, or (ii) its OK with us if it's OK under UK law. To cover the latter I have been quoting the relevant UK regulations, which are quite clear. In each case an FAA third class medical has been presented as part of my licence, which has been acceptable in every case (but of course as we know "higher" standards prevail now in Ireland).

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Post by YoYo »

Bluebeard

Have you checked the FAA license scenario with France. I was under the impression that they apply the 2 out of 3 rule. License, Aircraft & Location. In other words you cannot fly an EI registered aircraft in France with an FAA license.

I'd love to be proved wrong

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N regs - to fly or not to fly legally

Post by shrtfld »

Help

I am confused. JAA, IAA, CAA, FAA all subcribe to ICAO? Yes or no?

What is point in having a global organisation (ICAO) when local agencies seem to be able to vary the rules from one jurisdiction to another? I thought the purpose of JAA was to harmonise the rules and FCL/ flight operation procedures across Europe?

Let me ask another question. I like many others hold the "piggy back" FAA licence which is only valid as long as my JAA/JAR licence is. In point of fact the FAA licence is not valid unless I am physically carrying the JAR/JAA licence. I fly an N'regd aircraft regularly. If I fly this to Europe - which I plan to - does this mean I will fail France's two out of three rule?
In essence my FAA is no good without JAA ticket - making the priority licence the JAA one.

Equally if I get an IR rating for my FAA licence (also on the agenda) where and when can I use it? On N'regd only? In Ireland?

My fear is that people are inadvertantly flying in technical breach of local rules without knowing they are doing so. Unfortunately ignorance of the law is no excuse as the legal eagles will tell us. Pilots will only find there is a problem when there has been an incident warrenting the unwelcome attention of a national agency be it IAA or CAA.

This issue is one that should be high on the agenda of the proposed new representative body. Perhaps Mark might attempt to get someone to do a referance chart for the new magazine. I presume some officals in the IAA /CAA could be asked to confirm the chart is correct as at a particular point in time. Equally could a CFI from one of the FTO's pen the article for Mark? I presume they (FTO's) should have a reasonable handle on what one can or cannot do!
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Post by mark »

Hi Shrtfld,

This certainly seems like an interesting subject. We'll definitely have a look into it and see if we can get a definitive answer from the IAA or a CFI from one of the FTO's.

Regards,
Mark

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Post by YoYo »

Folks

Be very careful before you go bungling into the IAA with half baked ideas. You could open up a can of worms. Remember the FAA class 3 medical fiasco. Litterally the rest of the world say its OK to fly on a class 3 FAA medical but Ireland in its wisdom say NO in contravention of ICAO and the Chicago agreement.

If you want this sort of question answered I suggest you approach the National Areoclub for a resolution. They should have access to the right people.

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Post by HoldShort »

Has anybody got an update on the situation where an FAA licenced pilot is flying an EI-Reg plane in other coutries in JAA land?
I am particularily interested in the situation for the UK, France & Spain.

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Post by Pilot »

Gentlemen,

The IAA's take on FAA PPL licences used in EI registered aircraft is pretty clear. They say it is automatically validated for flight within the Irish State, for day, VFR use only. It is not automatically validated for flight outside of Ireland.

They have issued an AIC on this matter, dated 10 June 2004.

It can be found here on the EAD Site.

The UK CAA's position is that it automatically validates FAA PPL's for worldwide use in G registered aircraft. They don't attempt to validate it for other registrations, such as EI reg.


In relation to the issue of N reg aircraft operating in the UK, and the Dept of Transport review, this was discussed at some length last year on the UK boards. In the end it seems that the DfT was overwhelmed at the response it got, and it's all been swept under the carpet and forgotton about.

P.

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