NPPL-SSEA reval based on a PPL-MEPL LPC

[hugh flung_dung]

I've sent this question to flcweb but no answer yet; what's the view of the assembled pool of intellect?

Someone recently passed their MEPL LPC with me.
This individual has an MEPL rating on a PPL, both SSEA and microlight ratings on an NPPL, but no SEPL rating on the PPL. They have thousands of Multi-piston hours and regularly also flies SSEA/SEPL aircraft on the NPPL, but does not have a 1 hour instructional flight that could be used for revalidation.

It seems reasonable that the successful MEPL LPC can act as a replacement for the 1 hour "instructional flight" for the NPPL-SSEA revalidation because it would do so for an SEPL rating on a PPL.
Is this the case?

HFD

[BEagle]

Why does your colleague not simply include a SEP Class Rating in his PPL?

Until the end of the NPPL transition period, SSEA Ratings may be maintained under the previous 'rolling validity' principle until the licence holder changes to the new system. However, when the holder of a NPPL with valid SSEA and Microlight Class Ratings wishes to transfer to the new system, both Class Ratings must be valid at the time of transfer.

If he hasn't flown the 1 hour training flight in a SSEA Class aeroplane (under the old scheme), then his SSEA Class Rating will not be valid and he will need to fly a GST before transferring to the new scheme.

The NPPL P&SC specifically insisted that the training flight must be relevant, or it would serve no valid purpose. Hence it shall be flown on aircraft of the Class for which revalidation is sought. So, unlike under JAR-FCL, a LPC on something completely different is not acceptable for a SSEA, Microlight or SLMG Class Rating revalidation.

Once your colleague is on the 'new' system, he will be able to maintain his NPPL SSEA and Microlight Ratings by a combination of hours flown on both - and the 1 hr training flight has been replaced by a minimum of a total of 1 hour's training flying accumulated on any aircraft for which a Class Rating is included in the NPPL.

[hugh flung_dung]

Why does your colleague not simply include a SEP Class Rating in his PPL? ... Expenditure for no benefit, I presume.
The CAA will charge for issuing the SEPL rating and he doesn't gain anything compared to flying on the NPPL.

I fail to understand why we need to invent different sets of rules for what is the same practical situation. In my long experience of dealing with standards, the EC, governments and various other (non-aviation) bodies it is invariably better to harmonise on something and then work to improve it, rather than to introduce yet another unique requirement that then competes and confuses.

Given that the content of the training flight is not prescribed, that the MEPL LPC content IS prescribed and that it includes several skill demonstrations that carry-over directly to SSEA operation - why is a successful MEPL LPC not acceptable for SSEA revalidation when it is for an SEPL rating?

HFD
(Apologies if I'm shooting the messenger, but the message tastes of re-invention rather than re-use)

[Whopity]

why is a successful MEPL LPC not acceptable for SSEA revalidation when it is for an SEPL rating?
Because the SSEA relates to the NPPL and you can't have a ME rating on an NPPL! If you have the necessary medical to fly MEP; then why would one want to mess about with an SSEA when its easier to maintain a SEP rating.

[hugh flung_dung]

Whopity, you've missed the point. The training flight required for SEPL revalidation "may be replaced by any other aeroplane proficiency check or skill test ...", so someone who has just passed their MEPL LPC can use it in place of the SEPL training flight requirement. I am trying to get confirmation that this principle is also OK for the NPPL SSEA, and if not, why not.

You asked: "why would one want to mess about with an SSEA when its easier to maintain a SEP rating." - cost!
For historical reasons my chap has an SSEA on an NPPL and an MEPL on a JAR PPL. Where's the logic in paying the aircraft costs, an LST fee and £80 to the CAA to get an SEPL issued when the SSEA already gives the S/E privileges he needs?

HFD

[BEagle]

If you want to revalidate under JAR-FCL, get a SEP Class Rating.

If you want to revalidate under NPPL requirements, read the recent AIC and meet the requirements.

I am currently sounding out the views of the NPPL P&SC members. But quite how a Boeing 747 Type Rating LPC can be used to meet revalidation criteria for a SEP Class Rating under JAR-FCL is beyond me - not much in the way of stalling or PFL practice....:hmm:

I grant you that a few aspects of a MEP Class Rating might be more relevant, but if I recall correctly the view of the BGA/BMAA/LAA/AOPA reps that the '1 hour of training flying' had to be relevant if it was to be acceptable. Hence they decided that it had to be on aircraft for which the Class Rating revlidation was sought.

The other options are either a GST - or, for Billy-no-mates in his Turbulent/Cosmic Wind/Pitts, no training flying at all and a single seat restriction on his SSEA Class Rating.

[hugh flung_dung]

Thanks for taking it up BEagle, I look forward to the outcome.

I take your point about the relevance of an MPA LPC/LST but the MEP LPC includes: stalls, steep turns, circuits, an aborted take-off, NOTAMS, met, performance, W&B, and sometimes also a bit of nav - all directly relevant to any SPA.

HFD

[Whopity]

I doubt that you will get an answer because the CAA don't have anything to do with administering the NPPL; at best they will refer you to the NPPLG who will simply quote the regulations. Two different licences, no cross over! Logic has nothing to do with it.

[BEagle]

Whopity, that's not entirely true.

NPLG and BMAA recommend initial NPPL applications, but the licence administration itslef is the Authority's responsibility.

Policy proposals are made to the NPPL Policy and Steering Committee. This is an executive with representatives from all UK GA organisations - with CAA observers/mentors. Once any policy proposals have been agreed - and the CAA has given its informal agreement, everything passes to the CAA's legal department before it finally appears either as an ANO amendment or under an AIC.

A sensible process - industry agree what they want, the CAA advises whether it's do-able or needs amendment, then the legal bods do the 'shall not unless' scribbledegook and it eventually becomes law.

However, those who really want a SSEA, SLMG or Microlight Class Rating included in a non-NPPL must be careful to note that the Class Rating revalidation requirements are the same as they would be for a NPPL holder.

[BEagle]

An update following information from the CAA:

"The rules for revalidation of NPPL ratings are covered by separate requirements agreed by NPLG and CAA. If these require the one hour flight instruction for SSEA, and there is no similar provision for exemption as in JAR-FCL, then that is what the pilot will have to do."

NPLG (actually the NPPL P&SC) have not agreed to any such exemption.

[hugh flung_dung]

Thanks for the update BEagle. FYI the chap passed an SEPL LST with me on Saturday so will be applying for an SEPL on his PPL.
It seems bl**dy silly to have different rules for what are effectively the same situation so I didn't charge for the test and have written to propose changes to the rules.

HFD

[BEagle]

The CAA won't make any changes arbitrarily without the agreement of the NPPL P&SC. That is their firm commitment.

So very few people would be affected by any such change that it is unlikely to receive much support. Besides, such changes might have adverse ramifications for Microlight and SLMG Class Ratings.

I have yet to receive any reply from any of the NPPL industry groups, by the way.