SEP(Sea) Revalidation by Experience

[S-Works]

Can anyone point me at the revalidation by experience requirements for the SEP(Sea). In the old world it was done as a combination with the SEP(Land) by including the 12 take off and landings on water. There is not a single reference to it in CAP804 and I can't find anything clear in Part FCL.

Is it still the same as it always was?

[Whopity]

FCL.740.A Revalidation of class and type ratings — aeroplanes

This does not differentiate between Land or Sea and does not delegate any responsibility to the NAA therefore; the requirement must be the same for each separate Class.

[S-Works]

So you are saying that the SEP(Sea) holder must now do 12hrs with the 12 take off and landings in a seaplane?

[Whopity]

In the absence of any other requirement that is how I would interpret it. Yet another example of ill conceived regulation.

[Whopity]

New IN (http://www.caa.co.uk/docs/33/srg_lts_%20IN%20SEPland&SeaIN2013_013.pdf) with the answer, exactly as I deduced See Para 3.2

[S-Works]

Yep, that was published as a direct response to my formal inquiry with the CAA.

I have now applied to the EASA team for a change to the rule making to correct it. This is just another stupid drafting error that all issuing an IN does is attempt to cover up the screw up.

There is no safety case for the change.

I have flown 54 sea plane landings in the last couple of days and that's only 5hrs. By the time I have done the 12hrs next week I will be approaching 250 landings on water. It's not exactly rocket science.......

[Whopity]

What would happen in the case of an amphibian?

[BEagle]

Instead of saying "This is bolleaux - we will issue a 14(4) until a new rulemaking task resolves the situation", yet again the CAA has rolled over with their usual "It's not our fault - the Big Boys won't let us" type of response....

We need people with the attitude of Churchill, not Chamberlain, to absurd nonsense emerging from Europe!

[S-Works]

Whats a 14(4)?

[Cows getting bigger]

The ability for a member state to issue an exemption from the EASA regulation for urgent operational circumstances or needs for a limited duration.

I'm not sure that Bose's larking about on the water qualifies as such a need. :)

[BEagle]

Article 14(4)
Member States may grant exemptions from the substantive requirements laid down in this Regulation and its implementing rules in the event of unforeseen urgent operational circumstances or operational needs of a limited duration, provided the level of safety is not adversely affected. The Agency, the Commission and the other Member States shall be notified of any such exemptions as soon as they become repetitive or where they are granted for periods of more than two months.

'Operational needs of a limited duration' surely includes reverting to earlier, safe JAR-FCL practices until such time as the leaden hand of €urocracy can unbugger yet another of its crass regulatory errors.

[S-Works]

Whopity

Join Date: Oct 2004
Location: Europe
Posts: 3,644
What would happen in the case of an amphibian?


Indeed, which the aircraft I am flying are. Does this mean I now have to do 24hrs in the same aircraft if I wanted to revalidate land and sea?

[Whopity]

My inclination would be to say No because an amphibian clearly meets the specifications of both classes. Part FCL requires experience in the Class and if its dual class it must fulfill the basic requirement

The latest IN states clearly that when the aircraft are in a separate class, the experience requirements of each class must be separate. Applying the same logic, if the two classes are concurrent, the experience requirement can also be concurrent!

[S-Works]

So...... In my circumstances, would five hours of flying a Cub on amphib floats and the 54 landings on water along with the 500hrs of SEP land in other types meet the requirements for revalidating the sep sea rating? Plus the instructional flight etc. of course.

[Whopity]

Clearly not! You still need 12 hours in each class and only 5 overlap the two classes, so in the absence of any credits you are back to square one.

[Turnberry]

So what do I need to do now (under EASA) to convert my FAA SEP (Sea) on to my EASA ATPL?

Pre-EASA, all I needed to do was the UK JAR Seamanship examination (Private or Commercial) as I had the 12+ take-off and landings and a few hours on a seaplane over the last 12 months.

I have a current SEP (Land).

Can I get the SEP (Sea) issued on my EASA licence merely by doing the Seamanship exam or have the requirements changed?

[ifitaintboeing]

So what do I need to do now (under EASA) to convert my FAA SEP (Sea) on to my EASA ATPL?

The requirements for acceptance of class ratings are contained in Annex III to Part-FCL which states:

C. ACCEPTANCE OF CLASS AND TYPE RATINGS

(1) A valid class or type rating contained in a licence issued by a third country may be inserted in a Part-FCL licence provided that the applicant:

(a) complies with the experience requirements and the prerequisites for the
issue of the applicable type or class rating in accordance with Part-FCL;

(b) passes the relevant skill test for the issue of the applicable type or class rating in accordance with Part-FCL;

(c) is in current flying practice;

(d) has no less than:

(i) for aeroplane class ratings, 100 hours of flight experience as a pilot in that
class;

.....

This information is also in CAP 804, Section 4, Part Q, Subpart 2. If you don't have the 100 hours then you will want to review the course credit policy on page 1 of that section.

ifitaint...

[Turnberry]

Thank you.

So - totally different from pre 17 Sept 12 requirements.

[BEagle]

Unfortunately, yes. Except, that is for NPPL (SSEA) Class Ratings to which seaplane privileges have been added.

Incidentally, there is no 'LAPL-seaplane' and the CAA is working on suitable proposals to put to EASA.

I will raise the current absurd requirement regarding consolidated SEP (Land) and SEP (Sea) at April's FCL Implementation Forum and also with a top chap at CAA L&TS later this the week.

[Turnberry]

Just had a closer read of CAP 804.

100 hours+ on SEP (Sea) to even consider putting it on my EASA licence.

It would be quicker, and cheaper, doing a full EASA course in the UK with the superb Neil Gregory up at Lochearnhead (even though I did the FAA rating course some years ago and have remained current).

I am glad I asked the question - I was just about to book myself on the OnTrack refresher day for the Seamanship exam. Everything on hold for the foreseeable future as it is not a priority. Money saved and custom lost by OnTrack.

[CLOUD999]

As I read the FCL.740.A - 12 hrs flying amphibian would probably satisfy Land and sea class revalidation requirements. However 6 hours required as pilot in command, this is a difficulty for those of us new to seaplane flying as insurance for Pilot in command requires more hours on type.
Its amazing that touring motor glider time can satisfy requirements for both classes yet seaplanes do not get a mention in EASA land.
I wonder if P1s will satisfy the PIC requirement?
If not I think its a case of save my money till 3 months prior to expiry then do a short work up for skills test. A case of the regulations deterring real recency.

[S-Works]

I picked this up some time ago and submitted a rule change request for it.

This is currently going to NPA to restore it to the way it was.

You ate incorrect, amphib time is still not counted, the requirements are 12hrs in each class at the moment.

[CLOUD999]

Thanks for the reply Bose, why would amphibian time not satisfy both requirements as it is both classes by definition.
Good to see that the rule will change back again due to your efforts however. Thank you.

[S-Works]

That was exactly my point, why should amphib time not count? It will satisfy the time requirements. For each class! So as the rule stands you would need to do 24hrs in the same aircraft to meet the requirements! Stupid!

The CAA and EASA agreed that we had a problem hence the rule change request. As I understand it, this was an unintentional transposition from JAA to EASA as user JAA there were no clear rules in pace and each NAA implemented there own rules. The UK CAA implemented a very pragmatic rule and its that which we are seeking to reinstate. In fact actually a slightly lighter touch if that original rule.

[CLOUD999]

Thanks for the explanation Bose, lets hope that the pragmatic approach is reinstated.
F900- Neil Gregory at Loch Earn Scotland is perhaps the most popular choice for a sea plane rating in the UK.
Also try a search for GDRAM - a cessna 172 amphib based at Prestwick. The owner is also a Seaplane Class Instructor I believe.
Another option is in Northern Ireland I think its called the Amphibious Flying Club, that was pretty expensive when I last looked, operating a Maule.

Hope that helps

[Trim Stab]

Interesting thread - maybe there should be a sticky thread on "regulatory absurdities".

My current one is that although I have current MEP and SET ratings, I am not allowed to fly a SEP...

[CLOUD999]

Has there been any progress on revalidation by experiehce using an Amphibian?
I am still confused, i see no reason to do more than 12 hours in an amphibian which would satisfy both land SEP and sea SEP. Anybody revalidated by experience recently?

[BEagle]

The issue is now with FCL.002.

However, their NPA isn't due until the end of this year, at the earliest. Then it goes to consultation, after which they produce a comment response document. Following a period within which reactions can be made to the CRD, EASA then drafts an 'opinion'. Which then has to be voted upon at 'comitology' within the European Commission - after which it is moved to the European Parliament for MEPs to debate and to decide whether or not to introduce it into law.

So don't expect rapid movement. Mañana is a concept deemed far too urgent for EASA to adopt!

[Daniel_11000]

Aero Club Como in Italy ,on the lake of Como ( 25 km north of Milan, 4 km from Swiss boerder) operates a mixed fleed of Lake Anphibian, C172 (sea) , C206 (anphib-sea) C172 XP (Anphib) , PA 18 (180 HP , anphib), L19 (float) and a 'new' SeaBee just arrived from USA
Many instructors, wonderful area, you can convert or receive primary seaplane/anphib instruction - they instruct continuosly from 1932 !
D_11000

[CLOUD999]

Thanks Beagle - so this state of confusion will continue.
I have just re - read IN 13/2013 which states:

nts are as follows:

FCL.740.A “(b) Revalidation of single-pilot single-engine class ratings.

(1) Single-engine piston aeroplane class ratings and TMG ratings. For revalidation of single-pilot single-engine piston aeroplane class ratings or TMG class ratings the applicant shall:

(i) within the 3 months preceding the expiry date of the rating, pass a proficiency check in the relevant class in accordance with Appendix 9 to this part with an examiner; or

(ii) within the 12 months preceding the expiry date of the rating, complete 12 hours of flight time in the relevant class, including: - 6 hours as PIC, - 12 take-offs and landings, and - a training flight of at least 1 hour with a flight instructor (FI) or class rating instructor (CRI). 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.

(2) When applicants hold both single-engine piston aeroplane-land class rating and a TMG rating, they may complete the requirements of (1) in either class, and achieve revalidation of both ratings.”

3.2 As the above requirements specify relevant class, and the SEP(Land) and SEP(Sea) are separate class ratings, this means that applicants wishing to revalidate by experience both SEP(Land) and SEP(Sea) have to meet the experience requirements in full for both class ratings. i.e. The revalidations and renewals of the two ratings must now be independent; there is no credit from one to the other.

I just do not understand why and how the class ratings can be revalidated independently of each other on an amphibian.
Eg
12 hours flying amphibian including 6hr p1 -and a 12 to and landings water and 12 to and landing land. Plus the hour with a FI or another relevant test complete.

So what gets signed off by experience? Land or Sea?
The answer has to be both, they cannot be independent of each other as the aircraft class is both.
FCL seem to have a lack of understanding of the meaning of amphibian.
Indeed when I completed my SEP land renewal and SEP Sea initial rating last year on the same flight they initially refused the application stating that they had to be on different aircraft. It took several emails to them to explain that an amphibian is by definition both land and sea and that requirements of both skills tests had been met.
In conclusion, I think the IN is only considering sea planes and land planes independently however the statement in para 3.2 makes it difficult for an examiner to sign any revalidations by experience on an amphibian.
FCL740.A is not the problem for amphibians - the incorrect interpretation in the IN is!
This can be sorted overnight IMHO by the CAA issuing an IN that considers the case of amphibians and interprets FCL 740.A with due regard amphibians.

[keenpilot]

Have this situation improved since this 2013-thread?

I will need to revalidate my SEP SEA in August and I don't have 12 hours this season, have plenty on land though.

I'm considering to change my license to a country that accepts land hours towards sea renewal unless UK CAA now also accepts this? I did send them an email but it will take some time to get the reply.

[spRom]

isn't it easier to let the rating expire, and then do it again?. the course consists of 8 hours and no solo time, so it will be cheaper and better refresher than the 12 hours incl. 6h PIC

[BEagle]

keenpilot, the requirements of FCL.740.A(b) were amended by Commission Regulation (EU) 2015/445 as follows:

When applicants hold both a single-engine piston aeroplane-land class rating and a single-engine piston aeroplane-sea class rating, they may complete the requirements of (1)(ii) in either class or a combination thereof, and achieve the fulfilment of these requirements for both ratings. At least 1 hour of required PIC time and 6 of the required 12 take-offs and landings shall be completed in each class.

Sorry I didn't see your post in time - hope that your Examiner was aware of the change.