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pembroke
24th Nov 2012, 08:56
Yesterday I was asked to complete a "revalidation by experience", using the pilot's airline LPC/IR test to qualify as the "training flight with an instructor". My reference was Stds Doc 14 (version 6), Part 6 "Reval. by experience"
Last sentence in para. 6.2 "Applicants shall be exempted from this flight if they have passed a class or type rating prof. check, or skill test in any other class or type of aeroplane"
I then completed the SRG 1119E and, to ensure "level 6" ,completed page 1 of SRG 1157.
As the above will apply to many GA pilots who are also airline pilots, I thought I'd highlight here, and ask for comments.

beerdrinker
24th Nov 2012, 09:23
Pembroke,

Does that also mean that the Annual LPC/IR I do to re-validate my MEP Class Rating /SPA IR also revalidates my SEP Class rating?

BD

S-Works
24th Nov 2012, 09:51
might be worth checking the new examiners hand book and Part FCL. I seem to recall that it now has to be on the same class but stand to be corrected.

smithgd
24th Nov 2012, 11:10
The FE handbook and Part-FCL don't make any reference to having to do it on the same class of aircraft.

Beer drinker: remember that the 1hr flight with an instructor is only 1 requirement to revalidation your SEP by experience. The others being 12hrs flight including 6hrs PIC and 12 take offs and landings.

BEagle
24th Nov 2012, 12:23
This is something I raised at EASA! Strict interpretation of the EASA rule regarding exemption from the 1 hr dual training flight required as part of SEP revalidation by experience would mean that includes IR tests, instructor tests etc. do not meet this criterion – whereas an airline LPC would.

So I have formally drafted an amendment proposal, which received unilateral support (including from the UK CAA), changing the current wording 'Applicants shall be exempted from this flight if they have passed a class or type rating proficiency check or skill test in any other class or type of aeroplane' to read ‘Applicants shall be exempted from this flight if they have passed any other skill test, proficiency check or assessment of competence in the same category of aircraft.'

Note that, under EASA definitions, 'Category of aircraft' means a categorisation of aircraft according to specified basic characteristics, e.g. aeroplane, powered-lift, helicopter, airship, sailplane, free balloon.

Level Attitude
24th Nov 2012, 14:59
Clarification please:

Aren't airline pilots LPCs, IR renewals, etc carried aout in a SIM?

Where as exemption says: "or skill test in any other class or type of aeroplane"

"in" not "for" so exemption does not apply in this case?

pembroke
24th Nov 2012, 18:51
I quoted Stds. Doc 14, Version 6 because this is dated Sept.2012 and Annex 1-Part FCL, so in theory should be correct. I also don't have CAP 804 or EU/AMC docs to hand, hence the query.

Level Attitude
24th Nov 2012, 23:34
Pembroke, your quote was word perfect for FCL.740.A, but I wasn't querying that.

The way the exemption is worded (whether intentional or not) suggests that the
successful test has to be conducted in an aeroplane.
A successful test in a simulator not being acceptable for this purpose.

Same way a successful SPA IR Test in an aeroplane can also be used
to renew an IMC rating, but a successful SPA IR test in a simulator
cannot.

Whopity
25th Nov 2012, 09:02
The way the exemption is worded (whether intentional or not) suggests that the
successful test has to be conducted in an aeroplane.
A successful test in a simulator not being acceptable for this purpose.I don't think it suggests anything of the sort, it is badly worded, but the implication is that if you have completed a proficiency check or skill test in another type or class of aeroplane, you are exempt the experience requirement. If such a test is permitted in a Synthetic device, which would need to have appropriate credits to be used in such a role, then you have fulfilled the requirement. The original purpose was to exempt people who operate in a controlled environment from the need to fly with an instructor.

We are starting to see the problems all this EU micromanagement is having, where the powers that be have little idea of what or why they are doing things and now people in the industry are starting to suggest slavish adherence to pedantic nonsense rather than applying a little common sense.

Level Attitude
25th Nov 2012, 14:37
I don't think it suggests anything of the sort, it is badly worded, but the implication is that if you have completed a proficiency check or skill test in another type or class of aeroplane, you are exempt the experience requirement. If such a test is permitted in a Synthetic device, which would need to have appropriate credits to be used in such a role, then you have fulfilled the requirement. The original purpose was to exempt people who operate in a controlled environment from the need to fly with an instructor.



Are you sure? Handling skills would seem to me to be the most important thing.

It doesn't matter how experienced an SEP pilot is, they may have picked up some bad habits. The point of the 1 hour flight with an instructor in an
SEP was to identify (and hopefully correct) these.

I would suggest that the exemption was intended to apply to pilots who have already completed an equivalent flight and that is why it is purposefuly
worded the way it is: "..... in any other class or type of aeroplane"

An airline pilot passing an LPC, in a full-motion Sim, in a multi-crew enviroment is about as far removed from SEP flying as you can get;
and many flying schools say airline pilots take longer to get checked out (especially Approach and Landing) than pilots who only fly SEP.

I do not know whether the intention of the "rule makers" was to accept successful tests, etc in a Sim or not.

As BEagle has already drafted a proposed amendment to the Exemption wording perhaps (if not too late) he could add in a line, either confirming that
a simmulator is acceptable for this purpose or specifically excluding it, before it gets discussed at any rule making commitee?

mad_jock
25th Nov 2012, 21:45
The point of the 1 hour flight with an instructor in an
SEP was to identify (and hopefully correct) these.

Aye you would think so, then you turn up and some clueless plonker would try and get you to fly 3 degree PAPI approaches, power out of stalls ****e them self when you do a 60 degree steep turn and then try and tell you that you are risking death by not adding airline factors onto the approach speeds and ignore the POH speeds.

And then when you get two instructors together you end up trying to land a tommy only using the doors for yaw and moving your seat for pitch. Or one of you falls asleep half way to where you are going. Or you have a hangbags at dawn because the plane has just been flying itself for 15 mins because both thought the other one was flying it.

The fact that there is no syllabus for the hour and there is no failure critria and it is only a "has done an hour with an instructor" means it is meaning less.

You could go for a 1 hour trial flight and present your log book afterwards and they couldn't refuse to sign it because you had done your hour. The only way you stop someone that is well below standard is to stop the flight before the hour is done. Even if they are the worst pilot you have ever seen if you do the hour they have complied with the experence requirements.

DB6
26th Nov 2012, 12:04
If an airline pilot has done 12 hours SEP in the preceding 12 months, he can fly light aircraft. There is no real need to check that, and an LPC in the sim is acceptable (as I was told by a CAA staff examiner).
When you have fun is when a heavy jet pilot pitches up for an LST, not having flown light aircraft for some years. But that's a different question.
The point of the 1 hour flight was to ensure that e.g. owners who operate from farm strips - outside any regulated environment - don't get too far removed from reality. Again, as I was told by a CAA man.

nick14
26th Nov 2012, 13:20
If you are not happy with the hour flight that you have just seen someone fly you should refuse to sin the logbook, that is the idea behind the signature. It's written in one of the standards docs somewhere.

BEagle
26th Nov 2012, 14:29
I have now e-mailed EASA with an amended proposal for FCL.740.A(b)(1)(ii), to read: ‘Applicants shall be exempted from this flight if they have passed any other skill test, proficiency check or assessment of competence for the same category of aircraft.'


But as Whopity so rightly says, EASA micromanagement and poorly-written regulations have replaced common sense......

I'm so glad that I decided to give up PPL-level instructing and examining - EASA has made it impossibly expensive and the mountain of wholly unnecessary paperwork now required is just plain ridiculous.....

mad_jock
26th Nov 2012, 18:52
That was there idea but unfortunately the ANO requirement was just 1 hour with an instructor so the instruction dissappeared it can't be enforced. You have your hour and thats all thats required.