Polite discussion about EASA, the CAA, the ANO and the delights of aviation regulation.
Forum rules: Please keep it polite!
User avatar
By Sooty25
Firstly, I'm asking this for a mate that doesn't do social media or forums. I'm just a lowly NPPL so haven't really got a clue, but said I'd ask the wise ones here.
Don't beat me up, I'm genuinely asking for a friend!

He has;
UK issued EASA (2011) ATPL(A), CPL(A), PPL(A)
UK (2016) ATPL(A), CPL(A), PPL(A)
FAA (2005) ATPL(A)
French issued SEP (2020)

He is living in france and last year was flying a rented F reg.
For various reasons he didn't sort his licences out before 1st Jan, and now doesn't know the way forward.
He has retired from all commercial flying, just wants to rent a Robin and keep flying.

Any suggestions?
User avatar
By Sooty25
Looking for guidance really. He knows he can't continue with what he's got. CAA seem either u helpful or unobtainable.

I'm aware there are some extremely knowledgeable people on here, as well as some familiar with French licences.

Obviously, those that don't have useful answers, FD, don't need to contribute.
User avatar
By Irv Lee
Well cannot predict easiest route without knowing what French rules are for FAA validations (combined with whether the FAA ticket is valid for sep with medical and BFR).
Conversion to an easa ppl is likely to be along the lines of 2 ground exams, easa medical, recommendation for test from dto/ato, and initial licence skills test- or a time machine
Annex III to the Aircrew Regulation has been replaced by Commission Delegated Regulation (EU) 2020/723 of 4 March 2020. Art 9 lists minimum requirements for an EASA Part-FCL PPL by conversion. Relevant guidance is published by DSAC under section Programme de formation adapté pour les titulaires d'une licence ou qualification OACI (pdf link) on this page (link).

Conversion could alternatively be done under the EU–US bilateral agreement recently extended to pilot licences. See Annex 3 to the BASA together with the Technical Implementation Procedures–Licensing (TIP-L) here (link).

France is listed in the EASA table of states allowing third-country licence holders to fly (non-annex I) aircraft registered in the EASA states in non-commercial operations until 20 Jun 2022, iaw art 12(4) of the Aircrew Regulation. It appears that France grants this permission by validating the third-country licence. See form 15i-Formlic (pdf link) under section validation d’une licence étrangère—licences privées (second file) on this page. This route could be useful in the short term should it prove difficult arranging a skill test for conversion.
User avatar
By Sooty25
Irv Lee wrote:@Edward Bellamy surely it was just an sep skills test by French examiner to put the rating in the UK easa (at the time) licence?

Irv, Yes, spot on!

@Qalupalik thank you for your detailed response, I've passed it on to my mate, who is investigating.
Your friend could not legally fly an F-Reg aeroplane since 31/12/2020.
He needs to be aware that the form linked to by @Edward Bellamy will only allow validation until 21/06/2021, not 2022 as mentioned by @Qalupalik

I dont know if there is any special allowance for FAA licence holders or if the same 3rd state validation would apply - you might like to try the EuroGA forum as I know there is a long-ish thread there on there about FfAA/EASA/Nreg and there might be more info from french posters about hiring N-Reg opportunities. https://www.euroga.org/forums/hangar-talk
Best of luck to your friend,

Regards, SD..
The DSAC form will probably be updated shortly.

The article 12(4) deadline has been changed half a dozen times since the coming into force of the Aircrew Regulation. The current deadline of 20 Jun 2022—the change came into force on 12 Jan 2021—ought to be the last now that the EU–US bilateral agreement has been extended to cover pilot licensing. It's possible though unlikely, I think, that DSAC won't apply the derogation after 20 Jun 2021.

The regulation on licence conversions and validations, Commission Delegated Regulation (EU) 2020/723 of 4 March 2020, has an entirely separate provision to permit third-country licence holders to fly non-annex I aircraft, registered in an EASA Member State, in non-commercial operations for up to 28 days per calendar year. This short-term validation (previously referred to as a declaration) is issued at the discretion of the Member State and will suit pilots wanting to do some recreational flying while on holiday in Europe although no residence condition is imposed. At least one acclimatisation flight with an instructor is required.

The EU–US TIP-L comes into force 180 days after being signed both parties. The document is dated 18 May 2021 so will come into force on 14 Nov 2021. This route is for licence and rating conversion rather than validation.
skydriller liked this
Qalupalik wrote:...
The EU–US TIP-L comes into force 180 days after being signed both parties. The document is dated 18 May 2021 so will come into force on 14 Nov 2021. This route is for licence and rating conversion rather than validation.

Interesting TIP, thanks for highlighting.

One minor correction though, it comes into force on 18 May 2021, which is 180 days after the document was signed (19 November 2020).
Qalupalik liked this
User avatar
By Qalupalik
That's a significant correction. Thanks for catching it. The effective date is on the TIP-L cover page.

Under the TIP-L there's a time limit for applicants who weren't residing in an EU Member State before Annex 3 was included in the BASA and who should like to use the US to EU conversion route in the future. In this case the time limit will only apply to a US class or instrument rating issued initially on or after the applicability of Annex 3. Presumably that means on or after 18 May 2021.

2.1.3 Eligibility for conversion under Annex 3


(b) The pilots holding an FAA certificate that are already residing in an EU
Member State before the applicability of Annex 3, shall prove their currency
by self-declaration that is contained in the application form. The proof of
residence before the applicability is determined on the basis of the
applicable national regulations, as appropriate.

(c) All other pilots holding an FAA certificate with PPL(A)/IR(A) whose
ratings where
(sic) issued after the applicability of Annex 3 must prove their
currency through means of the self-declaration and through the FAA issued
verification letter. The AA shall deem the ratings current only in the
following cases:

- for the instrument and multi-engine ratings: if the initial FAA rating has
been issued within the last 12 months.

- for the single-engine rating: if the initial FAA rating has been issued
within the last 24 months.

In this case, the FAA verification letter will include the initial rating issue
dates for licenses and ratings issued after the applicability of Annex 3.

(d) Airmen who do not satisfy the conditions defined in (b) or (c) above do not
qualify for conversion under the terms of Annex 3.
Interestingly the TIP-L won't allow you to obtain an EASA licence on the basis of an FAA certificate issued in accordance with Part 61.75, i.e. one based upon another ICAO licence.

Which is what I have, although it doesn't actually state '61.75' on the FAA certificate :whistle:

It does say 'foreign based' on the front and 'issued on the basis of...' on the back.