Flying outside of the US Airspace
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Joined 10/27/2018 - 28 Posts
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Here's a question for one and all.

The SFAR I find very clear - my medical which expired last month has been extended - great.

My flight review expires this month - I have one of only two airplanes in the country (both are US registered) - I have offered it to the government in case anything urgent needs to be flown in or out (not commercial so at my cost) - no call yet, and as we are now down to only two active cases I hope it won't need to be - so not a member of one of the prescribed US charities - so can I get my review date extended like my medical?

I could see nothing in it that deals with airplanes outside of the US. My prime concern now is once a month 20-30 minute engine health flights - I am currently in the government quarantine here (comfortable hotel suite!) after I was compelled to do a round trip 400 mile international flight as I was not permitted to fly in the circuit for 20 minutes(!) but an international flight if I could find an airport to land at and refuel (400 miles was the closest). A most bizarre situation - but I'll be out of here on Friday and back in after a couple of weeks.

I should say there are no maintenance facilities here who can lay up the engine with the correct oil, wicking plugs etc. - if I could find one it begs the question of how I would get home and not having the airplane here defeats the idea of making it available.

Big question is the one about getting the 3 Wings credits and extending the flight review date if I am not going to be flying for one of the prescribed US charities? 
6 Replies
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Joined 06/11/2017 - 789 Posts
If you read paragraph 2a of SFAR 118, you'll see what flying is allowed for those with otherwise-expired flight reviews.  Under subparagraph (iii) are four sorts of flights you can make without it being for one of those approved charitable airlift groups, as long as you meet the 400 total hours and, 50 PIC in the last 12 months, requirements.  However, exercising the engine isn't one of them,

As for getting the three Wings Knowledge credits, you can do that from anywhere thee is internet via faasafety.gov.
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Joined 10/27/2018 - 28 Posts
I have 385 hours and have more than 50  in the past year so just missed that parameter.

The one that seems to apply is the exemption for flights for charitable organisations - I am kind of doing that as all such operations fall under the government control of this country - but of course is not on the list. Possibly that restriction only applies if one is in the US and can otherwise be ingnored.

The only place I have seen issue guidance on engine health flights is the UK CAA - they have a section on it - no more than 10 miles from the airport, ideally in sight of the tower, no more than 30 minutes and solo - kind of what I wanted to do here (before I saw that guidance by the way) - but an international was the only thing permitted upping the chance I could have bought the virus back.

 The Wings credits are not a problem.

As one would expect the FAA and AOPA response is naturally UScentric - but it fails to acknowledge that there are tens of thousands of non-citizen US licenced pilots flying US registered planes on trusts - it reminds me very much of the BasicMed thing other aviation authorities will accept it, but the pilots cannot use it as they do not have US driving licences - I spoke with AOPA about five years ago about this asking that they lobby that it should be like the UK system (in the UK it is "meet the standard for a HGV - heavy good vehicle - licence - so us "meet the health standard hold a US drivers licence") - I was told that they were not stupid and would of course not make it dependent on a US only document - but here we are:)
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Joined 06/11/2017 - 789 Posts
Eric Butcher:
The one that seems to apply is the exemption for flights for charitable organisations - I am kind of doing that as all such operations fall under the government control of this country - but of course is not on the list. Possibly that restriction only applies if one is in the US and can otherwise be ingnored.

 

You can try to get a legal interpretation on this from the FAA Chief Counsel.  Here's their contact page:

https://www.faa.gov/about/office_org/headquarters_offices/agc/contacts/

Include "AGC-200" in the address line.

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Joined 10/27/2018 - 28 Posts
It is no good - there are no email addresses on the contacts page and the number is coming up as invalid when I try to call.
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Joined 06/11/2017 - 789 Posts
Eric Butcher:
It is no good - there are no email addresses on the contacts page and the number is coming up as invalid when I try to call.

They don't take these requests by phone or email (just old-fashioned letters) and they take 2-6 months to produce an interpretation, so emailing vs snail-mailing won't save you a significant amount of time anyway.  You're not going to get a reliable answer any faster unless AOPA's folks who work with the FAA get involved.  For that, you need to contact them directly.  The 800 number isn't going to work from outside the USA, so call +1 301-695-2000 and ask for the Regulatory Policy office.

Votes
Joined 10/27/2018 - 28 Posts
Great info Ron, I will drop a line to AOPA to see what their opinion is and if they can get something definitive from the FAA.

Just looking to fly the plane for 20-30 minutes once a month - the way this thing is panning out it looks like it could site for month 100m from the sea in a county with no A&P and so likely will be written off - I don't think it will be covered by insurance so looking at a huge financial hit.