20 October 2024
If you hold or are thinking of applying for an FAA issued certificate, rating or authorisation, and you don’t live in the United States, 2025 sees the arrival of an unwelcome change with the catchily named “Subpart C Designated US Agents for Service”.
Writing for FLYER, Nigel Webb explains that prompted by the cost and the occasional difficulty or delay in getting time-sensitive communications to overseas certificate holders, the FAA has decided that each overseas holder of an aircraft registration, pilot, cabin-crew, maintenance, medical or drone certificate (licence) is going to need to appoint a US based “Agent” through which the FAA can send any and all communications.
For existing certificate holders, you have until 7 July 2025 to appoint an Agent, with new applicants for certificates being required to provide an Agent’s details for any application made on or after 6 January 2025.
The FAA thinks that this will affect some 115,000 individuals globally and with no useful exemptions having been listed, even those who only hold a so-called piggy-back pilot’s licence (properly referred to as a Part 61.75 certificate) are caught up in the change.
Options for compliance are quite broad. A US Agent can be any willing US resident at or above the age of 18 that is mentally competent to understand and perform the role. Those with friends or family in the US may well elect to follow this route, since the duty of the Agent is no more than to forward any correspondence received from the FAA onward to the pilot concerned on a timely basis.
The FAA considers that commercial organisations in the US will be able to provide the service to pilots at an estimated annual cost of between $50-$200, although only time will tell if that is optimistic.
Southern Aircraft Consultancy, a popular UK trust provider for N registered aircraft has been researching options for its clients, and has worked with Cogency Global to provide its clients with the service for between £160 and £240 per year.
An FAA Aeronautical Circular (AC) will be published shortly providing detailed information about the rule change, along with suggested means of compliance.
The change to FAA regulations
Southern Aircraft Consultancy
Cogency Global
