Confused about the LAPL

[Leonard320]

Hi all

I am currently doing my NPPL in a PA28. I have nearly 10 hrs in just over 6 months, so by rate of training I will be validating on to a LAPL licence instead of the NPPL one I originally started.

Due to Aspergers Syndrome I decided at my time of life, the NPPL was better for me and looking at the draft rules I'm hoping the LAPL won't cause a stop to my flying.

But after looking at numerous links, can anyone confirm what the privileges of the licence will actually be or when they will be announced?

I have seen a few things on EASA blurb, medical documents and a old CAA presentation which suggested that you will be able to fly any EU aircraft in any EU country.

What is not so clear is what additional ratings will be available( I know there are none apart for tail wheel on the NPPL) and what the minima will be.

From the above blurb it also seemed that if you had good vision and that was not the reason for an NPPL, a night rating would be available to train for as well as aerobatics. Does anyone have any information on weather this is just old and now outdated information, or something which is being looked at.

It would be nice to have other some of the other ratings like IMC available on it but as their is unlikely to be any hope on that, Im just confused on what I'll come out with the other end.

Many Thanks
Ben

[bookworm]

But after looking at numerous links, can anyone confirm what the privileges of the licence will actually be or when they will be announced?

FCL.105.A LAPL(A) — Privileges
The privileges of the holder of a LAPL for aeroplanes are to act as PIC on single-engine piston aeroplanes-land or TMG with a maximum certificated take-off mass of 2000 kg or less, carrying a maximum of 3 passengers, such that there are never more than 4 persons on board of the aircraft.

What is not so clear is what additional ratings will be available

While the night rating is quite explicitly available (FCL.810) for LAPLs, I can't see any restriction on aerobatic rating, towing rating, mountain rating. The flight test rating is restricted to CPL/IR. Instructor ratings are complicated as the LAFI was changed at comitology, and I think the upshot is that you need at least a PPL to get an FI rating on aeroplanes and helicopters. The instrument rating is not available to LAPL holders.

[BEagle]

I concur.

Medical requirements will be published once part-MED has been approved; nevertheless, a suitably-qualified GP will be permitted to issue LAPL medical certificates.

If an applicant's colour vision is acceptable, he/she will be able to include a Night Rating in a LAPL(A).

A LAPL(A) holder may not hold an instructor certificate.

Aerobatic, towing and mountain ratings may be inluded in a LAPL(A).

The LAPL(A) will not become mandatory for EASA aircraft (such as the PA28) until 8 Apr 2015; however, a NPPL (SSEA) may continue to be used for non-EASA aircraft (such as the Bulldog, Chipmunk or Tiger Moth) after that date.

Subject to ANO amendment, non-EASA aircraft may also be flown by a LAPL(A) holder.

[Miroku]

Could I ask what you mean by 'a suitably qualified GP'?

If this means with aviation experience they are going to be few and far between.

[bookworm]

If this means with aviation experience they are going to be few and far between.

Yes. It's a daft compromise, designed to satisfy the letter of the Basic Regulation while protecting the interests of the European AME community.

[Art 7]
A person shall only be issued a medical certificate when he or
she complies with the rules established to ensure compliance
with the essential requirements on medical fitness as set out in
Annex III. This medical certificate may be issued by aero-medical
examiners or by aero-medical centres.

Notwithstanding the [paragraph above], in the case of a leisure
pilot licence [LAPL] a general medical practitioner who has sufficient
detailed knowledge of the applicant's medical background may, if
so permitted under national law, act as an aero-medical
examiner, in accordance with detailed implementing rules
adopted pursuant to the procedure referred to in Article 65(3);
these implementing rules shall ensure that the level of safety is
maintained.
...
[Essential Requirements] 4.a.1. All pilots must periodically demonstrate medical fitness to satisfactorily execute their functions, taking into account the type of activity. Compliance must be shown by appropriate assessment based on aero-medical best practice, taking into account the type of activity and the possible mental and physical degradation due to age.

When this was drafted, I think the model in mind was the UK NPPL and the GP medical declaration, which most GPs were happy to certify as consistent with known patient history.

But when the implementing rules were developed, a requirement for an examination, not just a declaration, was introduced. Thus although the LAPL Medical is easier to get than the Class 2, it's still an exam and no doctor with any sense is going to sign off on such an exam without a substantial fee. So the cost advantage is lost. I think it's unlikely that a GP would want to do LAPL medicals but not bother to become an AME.

[BEagle]

No, there have been many recent changes, thanks to the excellent work of the CAA's Dr. Sally Evans!

From the Draft Opinion for part-MED:

LAPL medical certificates shall be issued by an AeMC, an AME or, if permitted under the national law of the licensing authority, by a GMP.
(AeMC = Aeromedical Centre, AME = Aeromedical Examiner, GMP = General Medical Practitioner).
MED.E.035 Requirements for general medical practitioners

(a) GMPs shall act as AMEs for issuing LAPL medical certificates only
(1) if they exercise their activity in a Member State where GMPs have appropriate access to the full medical records of applicants; and
(2) in accordance with any additional requirements established under national law.

(b) In order to issue LAPL medical certificates, general medical practitioners (GMP) shall be fully qualified and licensed for the practice of medicine in accordance with national law.

(c) GMPs acting as AMEs shall declare their activity to the competent authority.
The focus now is on 'assessment' rather than clinical examination. The full definition of 'assessment' in this context is:
‘Assessment’ means the conclusion on the medical fitness of a person based on the evaluation of the person’s medical history and/or aero-medical examinations as required in this Part and further examinations as necessary, and/or medical tests such as, but not limited to, ECG, blood pressure measurement, blood testing, X-ray. Note the words 'as necessary' - this doesn't mean that every single item is mandatory!

As for the LAPL assessment itself:

MED.B.095 Medical examination of applicants for LAPL medical certificates

(a) An applicant for a LAPL medical certificate shall be assessed based on aero medical best practice.

(b) Special attention shall be given to the applicant’s complete medical history.

(c) The aero-medical examination shall include at least the following:

(1) clinical examination;

(2) blood pressure;

(3) urine test;

(4) vision;

(5) hearing ability.

(d) After the first issue of a LAPL medical certificate, the aero-medical examinations until the age of 50 can be reduced with due regard to the evaluation of the applicant’s medical history.

Validity periods will be as follows:
LAPL medical certificates shall be valid for a period of:

(i) 60 months until the licence holder reaches the age of 40. A medical certificate issued prior to reaching the age of 40 shall cease to be valid after the licence holder reaches the age of 42;

(ii) 24 months after the age of 40.

All of the foregoing is subject to approval by the European Parliament.

[bookworm]

No, there have been many recent changes, thanks to the excellent work of the CAA's Dr. Sally Evans!

That would be the first time I've seen something good come out of comitology if that's where the changes were made.

So are you saying that the requirement for an examination in MED.B.095(c) has been dropped since the Opinion? The comitology went to some sort of written procedure (http://ec.europa.eu/transparency/regcomitology/index.cfm?do=search.documentdetail&pEO0OPbSn+raDp6Z0Zp/YEQVKeLDy1NX/6sM4uhhxv4xdbQ+AI/X9VTTMRqv00VG), so I haven't seen the latest draft of Part-MED.

[BEagle]

Most of the changes to which I referred are those applicable to the GMP. Previous versions called for a level of 'avaition experience' or 'aeromedical training'.

My reading is that between the first issue of a LAPL Medical Certificate and age 50, the extent of revalidation assessments can be reduced.

I suspect that it will be slightly more formal than the NPPL Medical Declaration, but should be pretty straightforward.

[David Roberts]

Bookworm,

Most of the 'negotiation' was done in the EASA medical group (NAAs and 'industry' experts) in Cologne before the Part Med Opinion went to comitology. Certain people you know well prepared a detailed case for the LAPL medical, covering inter alia the 'assessment' vs 'examination' issue, as well as periodicity for revalidation, empirical risk evidence etc. Much lobbying was done - and is still ongoing - but Sally Evans and the team at UK DfT stood their ground in comitology, I am reliably informed. Full marks to them, and I have said as much to their bosses.

Yes, the Part Med output from the written procedure is still awaited. Fingers crossed, then it goes to the Transport Committee of the Parliament later this year. But their only option under EU Lisbon Treaty rules is to accept all the text (covering all licences and related medicals) or reject all the text. They are not going to do that (reject).

The detailed AMC and GM material, covering detailed standards, is still being worked on, with key input from UK CAA using NPPL experience.

[Captainkarl]

Urine test....thats me with type 1 diabetes mellitus screwed over...Ill rather keep my NPPL...

[bookworm]

David

I can see that a lot of hard work has been done, and I know almost as well as you that this is the art of the possible. The changes from the CRD to the Opinion are undoubtedly helpful (particularly MED.B.095(d)), but they don't address the key issue of cost of an assessment/examination compared to a declaration.

In the CRD (http://www.easa.europa.eu/ws_prod/r/doc/crd/CRD%20a.1%20-%20Explanatory%20Note%20A.pdf) EASA wrote:

68. Fit assessment: The Agency is of the opinion that a GMP who acts as an AME is assessing the pilot as fit to fly, or, if this is not possible, refers him/her to an AeMC or AME.

The Opinion (http://www.easa.europa.eu/agency-measures/docs/opinions/2010/07/Opinion%2007-2010%20Part-MED.pdf) reiterates this:

12. British pilots and their associations strongly request that no change occurs to their present national regulations for glider pilots and holders of national private pilot licences (NPPL). The information on the CAA UK website for general practitioners (GP) is: "The first thing to emphasise is that you, the general practitioner, are not being asked to assess an applicant's "Fitness to Fly". Your countersignature confirms only that there is nothing in the applicant's medical history which would prevent him/her meeting the DVLA Group 1 or Group 2 driving standards. …".

13. However, the Basic Regulation states in Article 7 that, in the case of a leisure pilot licence (LAPL), a general medical practitioner (GMP) may act as AME if permitted under national law. This may lead to the conclusion that the GMP, just as the AME, assesses a pilot's fitness to fly.

I cannot believe that a professional will sign off such an assessment without reflecting on the accountability and requiring commensurate remuneration. One could argue, as EASA does, that the issue is not whether an examination takes place, but rather that the BR requires an assessment, and that the nails were in the coffin for the declaration long before the NPA was published. But it's not the only topic where the letter of the BR has been used to override what many stakeholders considered to be its spirit, in this case by another group of stakeholders with a vested interest.

As long ago as 2000 Peter Saundby wrote (http://oem.bmj.com/content/57/1/69.full):

Many pilots think that medical certification has become a medical tax, unjustified by flight safety. Although age or disease will end all flying careers, pilots doubt whether the medical screening can separate those who will become incapacitated from those who will remain fit....
Having rejected the objections made by pilot's organisations, the medical subcommittee of the Joint Aviation Authorities is vulnerable. Attackers will ascribe unworthy mercenary motives.

In the same way that I'm reluctant to attribute EASA's often disproportionate regulations to malice rather than a genuine but misguided quest for safety, I'm a little reluctant to attribute the opinions of European AMEs to greed. Nevertheless, if they wish to be taken seriously as part of the aviation safety management process, AMEs will have to avoid such delightfully emotive titles as:

Leisure pilot license proposed for Europe: do you want such pilots crossing your flight path? (http://www.ncbi.nlm.nih.gov/pubmed/19601512)

and start concentrating on assembly the evidence that Peter quite rightly demands in response (http://www.ncbi.nlm.nih.gov/pubmed/19653580).

FWIW, I think the scriptwriters of Airport 75 have a great deal to answer for!

[Miroku]

with key input from UK CAA using NPPL experience


But where are they going to get this from? I have an NPPL and nobody asks me anything, I don't even have to inform the CAA if I've renewed my medical, how many hours I've flown, nothing!

[bookworm]

I have an NPPL and nobody asks me anything, I don't even have to inform the CAA if I've renewed my medical, how many hours I've flown, nothing!

And despite that, not only are you still alive but you haven't even ploughed into the side of a 747?? Remarkable! ;)

[David Roberts]

"But where are they going to get this from? I have an NPPL and nobody asks me anything, I don't even have to inform the CAA if I've renewed my medical, how many hours I've flown, nothing!" (Sorry, can't fathom the quote function on PPrune)

The NPPL does not require renewal but its validity is linked to, inter alia, having a current medical which you are responsible for.

Granted the exposure data (i.e. hours flown by NPPL holders) is not collected, nevertheless the CAA has the data on all reportable accidents and the type of licence held.

Those accidents resulting from (possible) medical incapacitation are known and for the NPPL it is one unproven case in the period 2002 to 2008. The NPPL started in 2002. There have been no fatal accidents due to medical incapacitation of NPPL holders from 2002 to 2008.

During the same period there were 8 cases (including one unproven) with PPL(A) holders and two student cases. In the majority of cases the medical contribution was uncertain, and of the 3 PPL (A) cases with a definite or probable medical cause, 2 were alcohol related.

There were approx 22,000 holders of a UK PPL(A) in 2010; since 2002 over 5,000 NPPL licences have been issued, but the stock of current holders is not known as the licence is not subject to renewal.

The risk assessment took this data into account when arguing for the LAPL medical standards.

[Leonard320]

Many thanks for your replies.

I think the medical I should be able to pass.

Will the simple validations for the tailwheel rating remain with the lapl.

I know that's about the only rating you can get with the nppl.

Many thanks
Ben

[BEagle]

For the LAPL, if you wish to fly any aircraft 'variant' which differs from the aircraft in which you took your Skill Test, you will need to have a logbook endorsement stating that relevant training has been given on the 'new' variant. Quite what that consists of will depend upon the difference between the variants, but should be proportionate. Clearly there is a lot more difference between flying a PA28-140C and a PA28-161 than there is between a -140C and a -140B and even more between a PA28 and a taildragger.

Some of this training would just require a cockpit brief; other training would require some flight instruction. But there's nothing specifically laid down.