View Full Version : SEP Class Rating re-validation - Important!


BEagle
20th December 2004, 17:38
LASORS 2004 stated the following for re-validating a SEP Class Rating by Experience:

• If revalidating by flying experience, and
providing the examiner signs the Certificate of
Revalidation page within the 12 months prior to
the rating expiry, the validity of the revalidated
rating will be calculated from the date of expiry
of the preceding rating

However, the latest 2005 version now states:

• If revalidating by flying experience, and
providing the examiner signs the Certificate of
Revalidation page within the 3 months prior to
the rating expiry, the validity of the revalidated
rating will be calculated from the date of expiry
of the preceding rating.

So what of those folk who'd already re-validated their SEP Class Ratings more than 3, but less than 12 months from the date of the previous rating expiry date? Are they now, as the latest GASIL mentions, flying illegally? Ironic if they are - through following the CAA's own LASORS 2004 guidance!

Have sent an e-torpedo to the Belgrano and will note the reply with interest.

A topic which I'm sure would get G-KEST's beard a-bristling!



Keygrip
20th December 2004, 19:27
I remember this 3 month/12 month question coming up at an instructor refresher seminar three years ago.

I was adamant that it was 3 months - was beaten into submission (by ppruner "BlueLine") that it was 12 months.

I would expect that the Lasors 2005 is a typo, rather than a policy change (we've all seen some fun non-proof read material from Battleship House [anybody seen the new Form172, CPL Skill Test Report]).

Who has a current copy of FCL1 for the correct answer?.

BEagle
20th December 2004, 19:48
Not a typo, I fear. More due to some idiot bolloxing up the ANO through ignorance and introducing things which even JARocracy doesn't require. And then not sorting it out properly.

I swear the Belgrano is getting ever worse.....

MLS-12D
20th December 2004, 20:01
I am so glad that I live in one of the last remaining countries not plagued by such over-regulation of all things aeronautical.

skydriller
20th December 2004, 20:25
Beagle,

I distinctly remember contacting the CAA directly about my revalidation here in France a couple of years ago (ie. not this last revalidation) as I wanted to make sure I would be OK flying with a local instructor/examiner, and was distictly told that the 1 Hour flight must be within the 3 months prior to expiry. So the CAA have been telling people this since January 2002, regardless of what is written in LASORS, and is probably where Keygrip got his info from too. I suspect that as you say it is an ignorance issue of those working at CAA-FCL.

In their defence, I have had nothing but positive help in my dealings with them as a Brit PPL getting things done over here in France - at least wrt licence revalidation and medical renewal so far - only the 5 Year Licence re-issue to go now, if they can make it 3 in a rowwithout a hitch;)

Regards, SD..

BEagle
20th December 2004, 20:42
Skydriller, it is the LPC with a FE which must be flown within 3 months of expiry if you choose to re-validate by LPC rather than by Experience.

The Training Flight with a FI must be completed within the 12 months prior to expiry only if you choose to re-validate by Experience.

skydriller
20th December 2004, 21:44
I agree with you Beags!! I revalidated by experience myself!!

I was just relating what I was told by the CAA bod so as to maybe explain why the change to lasors and the overall confusion that clearly exists out there amongst us....

Sorry if I wasnt clear:ugh:

Regards, SD..

Whopity
20th December 2004, 21:48
The ANO says :

For revalidation of single-pilot single-engine piston aeroplane (land) class ratings and/or touring motor glider class ratings the applicant shall on single engine piston aeroplanes (land) and/or touring motor gliderssatisfy the requirements specified in paragraph 1.245(c)(1) of JAR–FCL1.

which says:

Revalidation by Test within 3 months
or
by Experience in the 12 months preceeding expiry.


The ANO then contradicts itself by saying:

Single-pilot single-engine class ratings

(i) Validity

"Single-pilot single-engine class ratings are valid for two years from the date of issue, or the date of expiry if revalidated within the period of three months preceding the date of expiry."


Three months should have read 12 months! It has been confused with the Renewal requirements. The error has been known about since it was published 5 years ago.

BEagle
20th December 2004, 22:39
Correct - the drafter of the ANO has had 5 years to sort this out but has abjectly failed to do so. So we re-validated people in accordance with JAR-FCL 1.....because that was the initial intent.

Nowadays it seems that the legal people at the CAA are more concerned that the requirements in LASORS reflect the incorrect statements in the ANO than make any effort to get the ANO corrected. It's the same malaise which has afflicted NPPL requirements; it's been known for nearly 2 years that the ANO is wrong concerning SSEA re-validation requirements but again the CAA has failed to move with any speed to correct things.

FlyingForFun
21st December 2004, 00:08
I don't see any contradiction in the ANO... is it just me?

If you choose to re-validate by experience, the experience must have been gained within the 12 months preceding the expiry of the rating. The actual re-valdiation, though (i.e. the process whereby an examiner looks over your logbook, confirms that you have met the requirements and then signs the relevant bits of paper) must be completed within the 3 months prior to the expiry. This is the way I've always understood it, and it's the way I read Whopity's quotes.

If I'm correct then the change in LASORS which BEagle has highlighted is simply a correction.

FFF
--------------

BEagle
21st December 2004, 00:26
FFF - that administrative process is the whole problem. Why on earth, if a pilot completes the requirements within the first month of the second 12 month period, should he/she then have to wait another 8 months just to get a mere signature? JAR-FCL doesn't require it, it's a cock-up in the ANO pure and simple. Nothing whatsoever to do with 'safety' as the 90 day recency requirement is specifically intended to cover that.

The 'correction' merely brings LASORS into line with the CAA's own cock-up in the ANO; what is needed is for the ANO to be corrected in line with JAR-FCL 1.

They'll have to do so anyway once EASA takes over, so they may as well sort their $hit out now.

englishal
21st December 2004, 14:34
i.e. the process whereby an examiner looks over your logbook, confirms that you have met the requirements and then signs the relevant bits of paper) must be completed within the 3 months prior to the expiry.
I've never done it that way. As soon as I meet the requirements, I get revalidated, which runs for a further 2 years from the ORIGINAL date of expiry.

I've noticed in the past with the CAA that often you can get a different interpretation out of them depending on who you speak to....a bit like a PC World "engineer" :D (i.e. haven't got a clue what they're doing).

DubTrub
21st December 2004, 15:04
...So I guess all this means we're supposed to revalidate the SEP license periodically?

Mine says "valid for ever" or words to that effect.

Oh well, another fine mess.....

Sky Express
22nd December 2004, 04:07
On another note regarding revalidation,an AIC quoted that the required dual flight could be replaced by any other proficiency check or skill test for a class or type(eg LPC).Unless I'm missing something am struggling to find this in LASORS.Any pointers??

BEagle
22nd December 2004, 10:18
Section F1.4 page 9 (231 of 608 of the .pdf):

This instructional flight may be replaced by
any proficiency check for a class, instrument or type
rating (or, in the UK, for an IMC rating) with a JAA
qualified examiner.

GuinnessQueen
22nd December 2004, 10:31
I apologise for perhaps asking the obvious, just I'm about to re-validate my PPL for the first time in the next couple of months.

I have read through lasors, but also seems to get conflicting advice from examiners.

Can someone clarify that ANY instructional flight (1+hrs)on same class (eg SEP), that has a signature by the instructor to state they were happy with your performance will count, as long as it is in the preceeding 12 months?

Cheers

GQ

Whopity
22nd December 2004, 12:22
Any instructional flight is OK provided it is at least 1 hour and is signed by the FI, doesn't even need to be in the same class but it does need to be a JAA qualified instructor.

.

ALEXA
22nd December 2004, 12:54
Interesting thread!

I am in the exact position that BEagle states in his original post:-
12 hour requirement (including 1 hr with an FI) satisfied early in the second year and I'm already signed off by an examiner, with the appropriate entry made by him in my licence and the correct form sent to the CAA. All before this "change" appeared in LASORS.

So I'd like to know whether the CAA will bounce my revalidation, or (worse) do nothing immediately but attempt to throw the book at me after the event if I come to their notice for some other reason.

I doubt it, since I've relied on their previous statements in LASORS, but something in writing from them now will certainly put the issue to bed once and for all.

BEagle: I'm very grateful that you have spotted this nonsense and drawn attention to it.

Alexa

blagger
22nd December 2004, 13:16
Isn't it so sad that our flying talk is constantly occupied with changes to regulations/requirements and paperwork-in-the-weeds-trivia. The 'system' seems to have lost site of the core point of all this - to ensure safe and competent pilots. Surely the 'system's' effort would be better spent engaging with FIs and people actually doing the job out there to look at recurrent problems like carb icing/landing accidents, rather than stupid paperwork exercises that mess everyone around.

The military seem to regulate their aircrew without such reams of paperwork. From what I have seen, there is more emphasis on local supervision/standardisation and empowerment of local supervisors - perhaps something to learn from??

BEagle
22nd December 2004, 14:10
I'd far sooner have an independent regulating authority than one which just changes things because it can....and I don't think that the military way has anything much to offer either.

My gut feeling is that the CAA is more concerned about making sure that LASORS doesn't contradict their own ANO cock-ups than it is in correcting those errors!

No replies yet from the Belgrano, incidentally.

FlyingBeachball
22nd December 2004, 22:03
I am now totally confused!!!!!!!!!

I thought to revaildate your licence, you must have completed 11 hours flight experience as P1 within the second year and an hour flight with a flying instructor, who signs your log book. After which you can hand in your log book to be signed at a maximum of 3 months prior to expiry date.

This is right.

BEagle
22nd December 2004, 22:28
"I thought to revaildate your licence...."

No, it is your SEP Class Rating which must be re-validated, not your licence.

".., you must have completed 11 hours flight experience as P1 within the second year and an hour flight with a flying instructor, who signs your log book."

No, in the second 12 month period it is 12 hours flying of which 1 must be a Training Flight with a FI and 6 must be as PIC, including 12 take-offs and landings.

"After which you can hand in your log book to be signed at a maximum of 3 months prior to expiry date."

No, the only log book signature required is that from the instructor who conducts the Training Flight. It is the Ratings - Certificate of Revalidation page in your licence which must be signed by the FE to whom you submit your LST/LPC SPA/MPA Form (SRG\1119).

This is right. No it isn't.

The issue in question is the CAA's incorrect interpretation of JAR-FCL 1 in requiring the FE's signatures within 3 months of the expiry date irrespective of when you actually completed the re-validation requirements. If you were to complete these requirements in the first month of the second 12 month period, why on earth should you have to wait another 8 months for a scribble on a couple of pieces of paper?

FlyingBeachball
22nd December 2004, 22:48
Thanks for clearing that for me, I've been doing it correctly in order to revalidate my rating but having the wrong information.

With regards to waiting the extra 8 months could it be to keep you being current, i.e. a single flight to Malaga and back will constitute of 12 hours. The trip could be done in one week, therefore in theory, having completed that flight it is not necessary to continuing flying until two years later, where your skills and reactions would have been reduce. By making you wait, you’re continuing to fly and increase your 12 hours. Isn’t 12 hours a minimum??

BEagle
22nd December 2004, 23:32
The 90-day recency rule is designed to keep people 'current', nit the re-validation process. The 'last 3 month' requirement was only ever intended for those re-validating by LPC, not experience - as is stated in JAR-FCL 1.

bookworm
23rd December 2004, 18:33
Section F1.4 page 9 (231 of 608 of the .pdf):

This instructional flight may be replaced by
any proficiency check for a class, instrument or type
rating (or, in the UK, for an IMC rating) with a JAA
qualified examiner.

At least this has been cleaned up a bit in LASORS 2005. It used to be rather vague about exactly what sort of proficiency checks counted.

BEagle
23rd December 2004, 18:47
But if you're a UK/FE PPL, they won't allow the 'Observed Flight Test' to count for this purpose......