How EASA FCL affects a JAR-PPL Private Pilot

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UK Private Pilot licencing changed on 8 April 2012 when EASA (European Aviation Safety Agency) regulations came into force. The intention is to standardise the rules across Europe, where previously there were many national variations. They will affect many pilots in different ways depending on their current qualifications/licences and the type of flying they want to do. This naturally leads to lengthy explanations of how this will affect a wide range of different circumstances, such as UK only licences, flying instructors and other special cases.

These notes are intended to help me (and other pilots with similar circumstances), who fall into a much more common category namely:

  • UK based JAR-PPL licence holder for Single Engine Planes (SEP)
  • Night Qualification
  • The JAR-PPL licence
  • Class 2 Medical, reissued annually
  • Flying a PA28 (or similar EASA aircraft), typically rented from a flying club or as a group share
  • Holder of a US PPL based on my JAR-PPL (so called piggyback PPL issued under FAR 61.75)
  • Native English speaker (or have conversational English)
I also hold an IMC rating but discuss that and the new simplified EIR/CB-IR in a separate article.
This article does not cover the position of the older UK only PPL licences, typically issued before 2002 when JAR came into force. Their position is somewhat more complicated and will require some more paperwork and possibly even additional training to make the transition. These pilots may even need to take a test to prove they can speak English (despite being a native).
These notes are provided based on my own research but are not definitive and subject to errors, omissions or change. You are encouraged to double check how the rules apply to your own situation. See the references section below.

Before we begin – Two important distinctions

There are two important distinctions or definitions that you need to understand before going any further:

1) UK PPL vs JAR-PPL licences

The UK CAA has been issuing its own licences for decades, but aligned with over 40 other European countries to become part of the Joint Aviation Authorities (JAA) from 1970 onwards. This organisation prepared a common set of regulations (JAA Regulations – JAR) and recognised the licences issued by other JAA states. The UK started issuing JAR-PPL licences around 2002. The UK CAA reported at end 2015 that there were over 14,000 JAR or EASA PPL licences with current medicals, and a further 13,000 UK only PPL licences. Double counting due to the same pilots holding both aren’t published. Both are full PPL licences which can be used worldwide, and are separate from the more restricted UK NPPL or EASA LAPL licences.

You can quickly determine which type of licence you have by looking at the front cover – the logo will state JAR rather than UK/CAA..
The transition arrangements and rules for UK only PPL licences are more complex than for JAR-PPL holders and are not covered in this post.

2) EASA vs non-EASA Aircraft

Not all aircraft are the same, and only those directly covered by EASA legislation will require a full EASA FCL licence. The other categories include so-called Permit-to-Fly aircraft, many of which are home built; Annex II aircraft such as the Bulldog or Tiger Moth; and microlight (flexwing or 3-axis). To determine if any particular aircraft is EASA or not, just enter the registration into the CAA’s G-INFO online lookup tool, and it will tell you (look at the field marked CofA/Permit). There’s also a long list in CAP 747.
The details below are aimed at JAR-PPL licence holder flying EASA aircraft.
What continues as before?

On 8 April 2012, my JAR-PPL licence automatically became recognised as an EASA PPL licence and my Class 2 medical certificate is considered to be an EASA Part-MED medical certificate.

For my typical VFR flying, I can carry on pretty much doing what I did before, with the same privileges and restrictions as before and don’t need to take any special action.

Valid for all the same SEP aircraft: I can continue to fly anything I could previously fly with my JAR-PPL, including so-called Annex II and Permit-to-Fly/Homebuilt aircraft. I can even fly microlights including Flexwings (some differences training isn’t legally required but strongly recommended), although the hours won’t count towards my renewal.

Same medical checkups: The same AME (Aviation Medical Examiner) will perform pretty much the same medical checkups (for me that’s now annually), and issue a similar medical certificate (for a similar fee). I’ll still need a Class 2. If anything, it’s slightly simpler with reduced requirements for ECG testing – for me now every two years rather than annually.

Same revalidation checks: As under JAR rules, I’ll need to fly a minimum of 12 hours (6 as PIC) every second year which includes an hour of dual instruction by a CRI or FI. Your logbook record must then be signed off on a form by a Flight Examiner. Under JAR, the associated paperwork (endorsing your licence and sending a form off to the CAA) couldn’t be completed earlier than 3 months before the end of the second year. I understand that rule wasn’t included in the Basic Regulation, and so may not apply – i.e. you should be able to be signed off anytime during the second year once you’ve completed the hours and instruction.

Same recency requirements to carry passengers: 3 take-offs and landings in last 90 days, including one of each type at night for night flights.

Same arrangements for VFR flights going abroad: Still need to file a flight plan and send off GAR forms to the customs and police depending on destination. This AOPA page explains the details.

Same arrangements for flying/renting in the US: In the US, foreign pilots must be issued with a US Airman’s Certificate based on their UK licence. These “piggyback” licences issued under FAR 61.75 remain valid in the medium term because they are based on a PPL licence issued by the UK CAA with a specified serial number. Unfortunately, the EASA licence number is not an exact match (it begins with GBR rather than UK), so wouldn’t be valid when it replaces my JAR-PPL licence. IAOPA lobbied the FAA in July 2012 to see if something could be worked out to avoid everyone having to revalidate and apply for another FAA licence. The FAA did setup a streamlined update process at their end in May 2013 and the UK CAA setup their side of the process in December 2013. Unfortunately, this requires a personal visit to the CAA offices in Gatwick during working hours to prove who you are, which strangely isn’t required for the issue of the EASA licence it’s based on [because you must visit a FSDO office in the USA in person]. This CAA webpage explains the process.

Same airspace restrictions: Part-SERA, the Standard European Rules of the Air, simplified and standardised most airspace rules throughout Europe.

Same ability to fly at night: Previously, all night flights were classified as IFR. From 17 September 2012, the rules changed to permit VFR flight at night – in practice, this is a technicality and does not affect where or how night flights can be made. The night VFR training and qualification is exactly the same as before (see FCL.810), but now renamed a Night Rating. You will of course need a Night Rating and be current if carrying passengers (one takeoff and landing at night in last 90 days).

What’s Changing?

LASORS replaced by CAP804. The long standing LASORS document, the reference book published by the CAA explaining licence requirements was replaced by the more comprehensive CAP 804 (over 800 pages last time I looked). This new document is intended to hold all relevant information in one place and is also a legal document. Read this if you want more definitive details on any aspect of UK pilot licencing. The CAA have also published a more digestible information and guidance for private aviators on their website.

No more flying on a medical declaration by default: Some pilots chose not to renew their full PPL medical annually, instead doing this every second year to co-incide with their bi-annual revalidation. In between, they have a medical declaration from their GP. UK airlaw automatically grants any PPL holder with a medical declaration the full privileges of an NPPL licence within UK airspace. The last UK regulation (ORS4 no 913)  that permits this ran out on 30 September 2013. Advance notice has been given (in CAA Information note 2012/100) that this option will be discontinued at that date.

You must carry Photo ID, licence and medical at all times: This used to apply only to commercial pilots, who could be “ramp checked” at any time. The new EASA rule (FCL.045) requires all pilots to carry their current pilot licence, medical and photo-id at all times. At least you don’t need to carry your logbook with you. Photo-ID could be the newer UK credit card sized driving licence or passport; other types may be acceptable.

New ratings required: Aeros, Towing, Mountain Flying and flight test ratings won’t be introduced by the UK CAA until April 2018 (deferred from 2015). Until then, there is no requirement to have a further rating for these activities. Although there are recognised courses, such as the AOPA aerobatics certificate, there was nothing legally stopping any PPL pilot doing any of these activities. From 2018, these will apply, and any new rating must be revalidated annually.

Prove you speak English: Back in about 2000, ICAO decided it would be a good idea if all pilots could speak and understand English on the radio, just as they are supposed to. After a transition period of 12 years, the CAA now require all pilots to have been checked that they have conversational English. The includes native born and resident British citizens. If they do and are assessed the highest Level 6, this is a one-off simple tick on the biennial licence revalidation form by your examiner. If not, then a longer test by a specialist is required (for a fee). Unfortunately, it doesn’t state the proficiency level on your JAR licence (it just states “Language Proficiency: English” regardless of what level you are at), so if unsure then you should fill in form SRG1199 and have a flight examiner sign it. This must be done before (or latest when) converting to an EASA licence. Recommend you do this anyway if at all unsure.

UK only national ratings lost: If I had any, these would need to be issued on a separate CAA UK PPL – I’d effectively have two licences (EASA and UK), with the UK national ratings on the UK licence. Since I don’t have any such ratings, this isn’t a problem for me. One exception is the IMC rating which has been retained and renamed to IR(Restricted) and does appear on the EASA licence – see separate article on how EASA rule changes affect the IMC rating. The EASA licence is valid to fly non-EASA aircraft, so there is no need for me to have a separate CAA UK PPL.

Valid in slightly fewer countries: There are three countries which were JAA member states but are not yet EASA member states. The mutual recognition of JAR licences ceased on 7th April 2012 between the UK and Serbia and Turkey. This doesn’t mean you can’t fly to these countries in a UK registered aircraft (G-reg), but does prevent solo hiring or flying locally registered aircraft in those countries using your EASA licence. See this EASA webpage for a spreadsheet regarding mutual recognition, which is incomplete.

Zero tolerance for incomplete/incorrect licence applications. From 4 February 2013, the CAA will simply return unprocessed any licence application deemed incomplete or incorrect, rather than notifying you of the issue and allowing you to send in supplementary documentation within 30 days. This is intended to reduce turnaround times, which had extended to months when EASA licences were first introduced.

Online licence applications: The CAA is automating some of its most common processes, such as pilot licence applications. An online form was launched in November 2013 and this includes that for a JAR to EASA conversion. There doesn’t seem to be any difference in turnaround times between postal and online applications, although it might save a day or two overall. The scope is planned to increase over time, with many approvals and counter signatures also being authorised online in the future.

Rating Changes

The JAR-PPL has 7 different qualifications related to more complex aircraft, achieved by differences training with an instructor, which continue into the EASA schemeThese are recorded in your logbook and don’t need to be renewed or revalidated.

  • Variable Pitch (Propellor)
  • Retractable Undercarriage
  • Turbo/Super-charged (Engine)
  • Cabin Pressurisation
  • Tailwheel
  • Electronic Flight Instrumentation System (EFIS), such as Garmin G1000 or Avidyne
  • Single Power Level Control (SPLC)

Added to those are the following new EASA ratings.

  • FCL.800 Aerobatic rating
  • FCL.805 Sailplane towing and banner towing ratings
  • FCL.810 Night rating (renamed from Night Qualification)
  • FCL.815 Mountain rating (two separate flavours exist for wheeled and ski undercarriage)
  • FCL.820 Flight test rating

To fly in cloud, private pilots can train and pass a test for IFR flight. These instrument ratings are described in more detail in a separate article:

  • Instrument Rating (Restricted) – formerly known as the IMC rating
  • Instrument Rating

Last but not least, there are various flight instructor ratings (CRI, FI) and flight examiner qualifications, some of which also require commercial pilot licence theory exams.

Upgrading from JAR to EASA licence

There are three ways to do this:

  1. Send off a postal application
  2. Submit an online application
  3. Visit the CAA’s office near Gatwick and do this in person

Options 1 and 2 are very similar and take about the same time (3 weeks at time of writing, I believe the target is 2 weeks). You’ll need to get two or three documents photocopied and signed by a Flight Examiner. These confirm who you are (e.g. passport or driving licence) and what you are currently licenced to fly (i.e. the ratings page from your JAR licence). Both photocopies must be endorsed with a specific set of words and signed. Although the guidance states a “Head of Training” at an ATO, it can be any current Flight Examiner. Sadly, a Flight Instructor or Ground Examiner can’t do this.

If uncertain whether you have been recorded as English Language proficiency, then also ask your Flight Examiner to sign you off for that on form SRG1199 (see earlier comment).

Then fill in the application form and send off, or scan in these documents and apply online. The fee (Feb 2014) is £73 plus an optional £6 if you want it sent by recorded delivery.

The CAA website has guidance, application forms and online applications for PPL licence conversions here.

During the application process, you can continue to fly on your existing JAR licence (provided it’s current) and you don’t need to send off your logbook or other valuable documents.

For those in a rush, you can travel up to Aviation House at Gatwick and do this in person. You’ll need to take ID (passport or driving licence) and current licence (ratings page), but don’t forget that signed off English Language form 1199. I don’t believe you can take the language proficiency test there.

Most people try to arrive there as early as possible,. When it opens at 8:30 you will get a numbered ticket and be called out in sequence. Your transaction is normally dealt with all at once (i.e. no waiting around for hours until the licence is printed – it’s issued immediately). The wait to be seen can be several hours unless you are lucky enough to arrive at a quiet time, so don’t plan to turn up late afternoon or you may leave empty handed.

Unless you are in a particular rush, I’d suggest doing this by post. A few people have commented that their licences were issued with errors, but provided you fill in the forms correctly then unless you have something unusual (such as UK only ratings) I would expect few problems. After issue, those who have FAA “piggyback” licences will need to visit Gatwick to have them replaced. One option is to do both of these during the same visit. Your FAA licence would then be posted to you from the USA a short time later.

Timeframe

8 April 2012: EASA Basic Regulation applied. All existing JAR-PPL licences were legally EASA licences, but anyone applying for a new/replacement licence would still get a document printed with JAR-PPL and could apply for existing UK ratings (e.g. IMC). JAR-FCL medical certificates were considered to be EASA Part-Med certificates.

17th September 2012 (deferred from 1st July 2012): All EASA Part-FCL Annexes apply in UK. From this date, EASA licences and EASA medical certificates are issued. The licences are lifetime documents and don’t need to be renewed after 5 years like the JAR-PPL ones. Those renewing their JAR-PPL licences after this date will receive non-expiring EASA licences. (Of course, they will still need the same 2 yearly revalidation process). IMC rating is renamed IR(Restricted). Night VFR introduced. New applications for Registered Training Facilities from this date, all new training organisations must be ATOs (Approved Training Organisations) with all the associated paperwork and CAA approvals.

30 September 2013: From this date it’s no longer possible for EASA PPL holders to fly on a medical declaration from your GP with NPPL privileges rather than a full Class 2 medical.

8 April 2014: From this date, commercial pilots must have upgraded to EASA ones. Those with older UK only licences will be limited to VFR for simple aircraft (LAPL privileges). JAR-PPL licence holders can continue as before until their licence reaches its own 5 year expiry date.

17th September 2017: The last JAR-PPL licence will have been replaced by an EASA licence and these documents will not (legally) exist any more.

8 April 2018: The four new ratings (Aeros, Towing, Mountain Flying, Flight Test) are mandatory for those activities in EASA aircraft. Transition arrangements to upgrade from UK PPL to EASA PPL may change.

References

UK CAA LASORS (which described most of the licensing rules quite clearly in one place) has been replaced by the new and comprehensive CAP 804 which is a legal document in force from 17 September 2012.

EASA Part-FCL is based on EC Rule 216/2008, known as the Basic Law, the contents of which and implementation rules are to be found on the EASA website

CAA personal licensing page for EASA Licensing and Training Transition contains many relevant documents explaining the changes and how they will be implemented. There’s also a specific new page for private pilot licencing.

I’ve discussed the IMC/EIR/IR changes in a separate article

Irv Lee’s helpful list of valid combinations of licences and medicals and FAQ section on EASA licence issues.

Feel free to comment below if you believe any of this information is wrong, outdated or incomplete.

Last updated: 16 Aug 2016

5 comments

  1. Great article David. I started my PPL training in 2009 but had to stop after 20 hours. Having recently started again I am getting conflicting information from instructors about whether the 20 hours from 2009 can count towards the 45 I need in 2017. Would you have any clues?

    1. Sadly no longer for a full EASA PPL. The CAA announced that any PPL training hours prior to 17 Sep 2012 (when EASA licences were first issued by UK CAA) would only count towards a PPL if the course was completed and skill test passed before 30 Sep 2017. This information is still available on the AOPA website but the original CAA Information Notice has been withdrawn since it no longer applies. However, these hours would count towards an NPPL (which is a national licence) and if obtained before April 2018, could be converted to either a LAPL or PPL at a later date.

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