FAA IR TO UK IR
Conversion of an FAA IR into a UK FCL IR
This has been an issue for almost a decade. A proposal was made that all aircraft operators based in Europe flying IFR in N-registered aircraft would have to hold an EASA IR. Many years ago, the text of a Bilateral Aviation Safety Agreement (BASA) was agreed that set out the methods by which FAA and EASA qualifications could be converted. However, it was not introduced into European law. The implementation date was put back on several occasions for political reasons. Nonetheless, the proposed mechanism of the conversion was pretty much accepted.
Since the introduction of the CBIR there has been a less onerous route by which an FAA IR could be converted. It has not been worthwhile to many pilots since the seemingly endless delays in implementation meant that putting off any decision and hoping for the best was an option. As the deferrals were repeated, doing nothing seemed ever more attractive. With unhelpful timing – from a UK perspective – EASA agreed a BASA with the FAA in November 2020. There is now a fixed date, after which it will be illegal for pilots who come within the scope of the regulation to fly IFR in Europe just with an FAA IR.
The situation for a UK resident pilot with licence is now complicated by Brexit. While the CAA have expressed the intention of incorporating EASA FCL into the UK ANO it is not clear that would help in this case. A UK issued FCL IR would have the same legal standing as an FAA IR: to EASA the UK will be a third country, so any ICAO-valid IR would be equivalent.
The decision of the UK Department for Transport, DfT, will be the critical factor. It could be that they simply endorse the status quo, which would please FAA IR holders. The DfT are subject to a number of conflicting pressures and it is not as if they have nothing else to do. When all this started a decade ago the DfT were assertive in wanting the situation, as they saw it, regularised. One might imagine that the CAA would like us to keep in line with EASA in the hope of some future rapprochement. The current Secretary of State for transport flies an N registered aircraft on an FAA license. There is a current high-profile court case that may have implications. The bottom line is simply this: no one knows for sure.
The actual requirements for the conversion are not that onerous, assuming that an FAA IR holder is both based and operating in Europe:
It requires a proficiency check, which takes the form of the initial IR Skills Test. This must be booked with CAA Flight Test Bookings at a cost of £826 (December 2020). Your FAA PPL and IR will need to be current, as will your UK FCL PPL, SEP or MEP rating, and Class 2 medical with the addition of an audiogram. You will need 50 hours as PIC under IFR. There is no written exam; this is replaced by oral questions when you do the skills test. So will need to be familiar with the European IFR environment and have kept up to date with legal and technical developments.
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