aerial work, private operator, UK

[Bertie Thruster]

Anyone here done any aerial work for a private operator using a UKCAA issued aerial application certificate?

If so I'd be very interested if there are any accepted ways of working round this bit of the ANO?-

A person may act as a member of the flight crew on a private or aerial work flight where the operator does not hold a national air operator's certificate if, at the time when the flight begins, the aggregate of all the flight times of the member of the flight crew concerned since last being medically examined and found fit by a person approved by the CAA for the purpose of article 72(3) is not more than 25 hours.

[Helinut]

Bertie,

Where is that in the ANO? I had not come across it before.

[Bertie Thruster]

Helinut:

Section 1 Part 20 Page 2

Flight times – responsibilities of flight crew

147 (1) Subject to paragraphs (2) and (3), a person must not act as a member of the flight crew of an aircraft registered in the United Kingdom if, at the beginning of the flight, the aggregate of all that person's previous flight times:

(a) during the period of 28 consecutive days expiring at the end of the day on which the flight begins exceeds 100 hours; or

(b) during the period of twelve months expiring at the end of the previous month exceeds 900 hours.

(2) This article does not apply to a flight which is a private flight in an aircraft which has a
maximum total weight authorised of not more than 1600kg.

(3) A person may act as a member of the flight crew on a private or aerial work flight where the operator does not hold a national air operator's certificate if, at the time when the flight begins, the aggregate of all the flight times of the member of the flight crew concerned since last being medically examined and found fit by a person approved by the CAA for the purpose of article 72(3) is not more than 25 hours.

[Helinut]

Jeez,

They don't make these things easy to follow do they!

My take on this is as follows:

Art 72(3) relates to pilots holding National PPL(H)s. It says they have to have a valid medical to fly, which is no surprise. It says the pilot can either have a full Part MED (i.e. EASA) medical or a medical cert from his GP as per Art 72(A) (i.e. the downgraded medical)

Art 147 seems to me to put together 2 quite different things. I see no real connection between 147(1) and 147(3). However, to try and understand what it is saying, I went through the whole thing.

147(1) says (more or less) you cannot fly more than 100hrs per 28 days or 900 hrs per yr. That seems to be any flying, not just CAT/PT (except if the aircraft flown has a MAUM of less than 1600kg and it is a private flight).

I find the application of 147(2) very confusing wrt 147(1). There are 2 alternative possible interpretations I can see:

a)That 147(2) allows you to fly a <1600kg private flight if you have exceeded the monthly/100hr and yearly/900 hr flying limits (BUT that you need to include such flights when adding up all your hours to get your running 28day/yearly totals for other flights)

b) You take NO account of <1600kg private flights when you add up your rolling total of hours flown 28days/yearly, regardless of what the next flight type is.

The wording of 147(2) seems to me to be highly ambiguous:

"This article does not apply to a flight which is a private flight in an aircraft which has a maximum total weight authorised of not more than 1600kg"

So, I move on, thoroughly confused, to 147(3) and it just gets worse:

i) Art 72(3) is discussing the medical certification of NPPL(H) licence holders ONLY. So presumably 147(3) is only talking about those pilots too, since it describes a procedure for enabling such pilots to complete a medical procedure to allow them to do certain types of flying.
ii) the privileges of an NPPL(H) licence quite clearly exclude ANY aerial work (as you would expect) - see Schedule 7. So what on earth is 147(3) doing suggesting that an NPPL(H) pilot can do ANY aerial work?
iii) Then finally, the procedure that 147(3) requires is that such pilots should get their medical certificate renewed every 25 flying hours.

At this point I gave up, removed the steaming towel from my head and :ugh: :ugh: :ugh:

Can anyone help me?

(Very much as a PS, it appears an NPPL(H) who flies a hele on private flights with a MAUM between 1600kg & 2000kg will need to get a new medical every 25 hours, if he uses the downgraded national medical process!)