Sunday, June 29, 2014

The Paperwork

I'm not anti-regulation. I am anti-onerous regulation, but I admit it's a bit hard to codify a test for that. I do, however, think that aviation is a risky enough activity for pilots, passengers and innocent bystanders that regulation is probably a very good idea. Heck, look at the mess we make on roads, where there are only two measly dimensions to deal with, and stopping just means getting out of the car.

As a result, getting a pilot's license is much harder than getting a driver's license in the United States. This is a good thing. Someone once told me that it's the equivalent of around two college courses, and that feels about right. When you're a working adult, finding the time and brainspace and energy for those two college courses can be a challenge. Finding the money for them, well, that's a whole other level of difficulty.

Sorry, back to the thread. The point is that in no way should you expect to be able to waltz into another sovereign state, proudly flash your U.S. Private Pilot's License (PPL), and hop in a plane and go. Ah, I've had people tell me, but what about airline pilots? Don't they do exactly that? Well...yes and no. Bear with me, because I'm not an expert here - I have learned a few things to avoid getting in trouble and hopefully to allow me to fly overseas this one time. The U.S. and Australia are members of the ICAO (International Civil Aviation Organization). This is a special arm of the United Nations, if I remember correctly. This body coordinates aviation, since by its very nature aviation can easily involve more than one country in the course of a flight.

If you are a U.S. pilot, and you fly a U.S. registered aircraft into another country (say, Australia) - you may operate that aircraft on the basis of your ICAO member nation pilot's license. Thus, United Airlines pilots can land jetliners there, for example. Qantas pilots can operate their airplanes in the United States.

The real problem starts if you want to operate an aircraft registered in the foreign country. Then everything changes - you must be licensed and operate under the regime of the host country's aviation regulatory body. In the U.S., it's the FAA. In Australia, it's called CASA, or the Civil Aviation Safety Authority. Sub-organizations of CASA license Australian aviators, register Australian aircraft (tail number prefix VH- Victor Hotel) and regulate Australian airspace and airports. So in order for Outback Overflight to happen, I needed (still need, sort of) to convince CASA to authorize it.

The United States does not, as far as I'm aware, have a provision to allow foreign pilots to operate here and act as Pilot in Command (fly solo, or fly with no other PIC-qualifed pilot in the crew). You can get a permanent U.S. FAA license, but I'm not sure how long that takes or whether you have to turn in your foreign license (although I doubt it). Australia, however, has a process which will allow a foreign pilot to be certified to fly in Australia temporarily (up to 3 months, I believe) without exchanging their license. You must acquire what is called a 'Certificate of Validation of Foreign Credentials' or just 'Certificate of Validation.' That document, along with your U.S. pilot's license, will allow you to operate.

So. How do you get one? There's the first part of the saga.

As with the US FAA, the first thing you need is to get registered in the computer system at CASA. So you apply for an ARN - an Aviation Reference Number, just like the U.S. IACRA FTN number. Once you have been assigned an ARN, you can apply for your other documents. First, the CoV.

To acquire a CoV, you must have and submit:

  • Either an ARN or a completed application for an ARN (CASA Form 1162) submitted along with the CoV application (CASA form 523)
  • A valid U.S. Pilot's License (Private Pilot or higher, not student pilot license) valid at time of application and for the time you are applying to have your CoV be valid for
  • A valid U.S. Airman's Medical Certificate (Class 1, 2 or 3), valid for the period you will be flying in Australia
  • Proof of an ICAO Level 4, 5 or 6 English Language Proficiency (ELP).
That last was my bugbear.

The ICAO has decreed that English is the international language of aviation. That isn't a style choice or sponsorship deal, it literally means that to fly an aircraft in a country other than your own, you must be a proficient English speaker. To act as an Air Traffic Controller, you must be proficient in English. This way, no matter where you go, you'll be able to communicate with people on the ground and in other aircraft. So it makes perfect sense that Australia requires this ELP level.

The FAA, however, never bothered (for a long time) documenting the English Language Proficiency on the U.S. Airman's Certificate (pilot's license), much less setting formal examinations using ICAO specifications. You have to be able to communicate in English to get a license in the US, but your CFI (flight instructor) and pilot examiner (check ride test giver) certify that you are such before you can receive your license.

As of 2008 or 2009, I think, the FAA finally got around to putting the words 'ENGLISH PROFICIENT' on U.S. airman's certificates.

According to CASA, however, the FAA 'ENGLISH PROFICIENT' notation does not repeat not satisfy the ELP documentation requirements for Australian certification. In other words, CASA told me I had to prove that I could speak English in order to process my CoV application. That would be no problem - except that the only allowable way to prove that is to take a standardized Australian listening comprehension test - and you can (according to CASA) only take that test in Australia, with a certified Australian examiner, usually a CFI.

They won't process your application for a CoV until you have done this.

The problem is that there's no guarantee how long it will take to process after you have taken it, or how long it will take to mail to you (even in Australia) and so forth. This means that unless you intend to visit Australia prior to your flight trip, your application won't process until you arrive. In my case, while I allowed for several days of jet lag recovery and checkout/training prior to leaving on the tour, I had a week. Five business days, with a weekend in the middle.

I've never heard of a licensing bureaucracy completing an application and mailing a credential in anywhere near that timeframe.

I spoke to folks at CASA. I spoke to a sympathetic person at the FAA, who said "Well, we've heard this before. I'm sorry to tell you, according to us it's an ELP level 4, but if they won't accept that, there's really nothing we can do." Which, let's be fair, makes sense - they're not responsible for the policies of entirely different governments.

This looked like it would sink the trip, if anything, or at least cause dramatic changes and scaling back - if I wasn't able to get this document without first going to Australia, it would mean a very good chance I would miss the tour departure date. The tour moves rapidly enough that catching up really isn't a viable option, not without having to do a whole bunch of our own (duplicate) arrangements for lodging, fuel, etc.

Oh, I forgot. That's not, actually, all you need. The CoV is a make or break, but it's not the end.

The tour we chose involves stops at a couple of larger airfields (aerodromes). One of them is actually a RAAF airbase. This means that in order to get on or off of these airfields, I need to have something called an ASIC - an Aviation Security Identification Card. U.S. airports use these as well, they are (I believe?) TSA-issued. In Australia, the CASA issues them. But (naturally) you can't get an ASIC card as aircrew until you have a valid license - or a valid CoV. So they won't finish processing that application either until the CoV has been issued - and until they have verified from Australian Immigration that I have legally entered the country. So no matter what I do, there will be critical documentation that requires CASA work following my arrival.

I will write up a less histrionic and more informative page later, and link it here, which serves to simply list out and describe the requirements as well as contain links to the appropriate forms.

At present, it's June 29th. I'm in Los Angeles. I'm flying to Sydney on Tuesday July 1st. The Certificate of Validation, I have been told, has actually been issued - the agency I'm renting the airplane from, which I used as my Australian mailing address, has confirmed that they have received it. Whew, one huge hurdle down. The ASIC is on hold - CASA has told me that they've set up a computer check to inform them when I pass through Australian immigration so that they can continue to process it, and that they will mail it to the rental firm when ready. I'm hoping like crazy it gets there in time. If not, we'll have to adapt - I'll have to find out if I can get on and off the airbases with the tour company pilots, who do have ASIC cards. Or we may have to find a way for us to skip the controlled airfields (unlikely). Or possibly we can have the rental firm express the ASIC to the first controlled stop, which is (I think) four or five days in to the trip - maybe that's enough time for it to catch up.

We'll have to see!

There are other bits of paperwork as well, of course. I needed an entry visa. Fortunately, United Airlines offered to handle that electronically. I had to send the rental company copies of my logbook and PPL. And naturally, I had to put down a significant deposit on the airplane and prepay for the tour tagalong fee.

All that is done, though. Things are looking quite good.

How did I handle the English Language Test? Ah, well. Maybe we'll write that up later. :-)

Can't wait.


  1. Hi, I do have an FAA commercial helicopter pilot certificate and I'd like to do the conversion to CASA. You mention, that the 'English Proficient' on the certificate is not sufficient for the required ELP. How did you handle this? I'd be very grateful for your advice. My email is Cheers, Carmen

  2. Hi, I do have an FAA commercial helicopter pilot certificate and I'd like to do the conversion to CASA. You mention, that the 'English Proficient' on the certificate is not sufficient for the required ELP. How did you handle this? I'd be very grateful for your advice. My email is Cheers, Carmen