Proficiency check renewal expired between 3 and 5 years.

[Camp Freddie]

As I understand how EASA is working in the UK right now, if a type rating is expired by more than 3 years it becomes a "previously held type rating" on a JAR (deemed EASA) or actual EASA licence, and a full type rating course is required to recover this rating.

I am slightly confused by this and wonder if this applies to all type ratings no matter when they were gained or is this just type ratings gained since the implementation date in sept 2012. I am assuming the former, but wonder if the recovery of a type rating gained before EASA, expired by more than 3 years but less than 5 years, is possible with a proficiency check preceded by sufficient training (2 hours minimum under the previous system)?

Comments welcome,

Regards CF

[idle stop]

The Part-FCL AMC say you should do the entire type rating course again if expired more than 3 years. There's no other provision. BUT the HoT at the ATO (TRTO) may take into account your previous experience etc and recommend a truncated course. Note that the training MUST be done at an ATO and the HoT will have to issue a Course Completion Certificate which must be sent to CAA with application to renew the type rating. AND the CAA will not update your FCL150 type rating validity page in your existing UK or JAR licence: you'll have to apply and pay the fee for a new Part-FCL (or UK National, if it's an Annex II aircraft type) licence.
Simple, really:ugh:

[nigelh]

I haven't done an LPC for 4 years on the basis of why bother when nearly all my flying is on my faa ticket . For me to now say do a ferry flight in a G reg , I think after October 2014??, I will have to do full type ratings again ..... Even in the types I have done hundreds of hours in during the last year or two :ugh:
This is plainly daft and once again , I would say , encourages one to bend the rules . Why , logically , should I do the entire rating again when I am current ?
Once again the Campaign Against Aviation , have no regard to safety .... This is more jobs for the boys and fees . You Americans don't know how lucky you are with your lot !!!!

[Camp Freddie]

Thanks Mr Stop for your helpful comments, I did try to read the AMC but from the EASA website was a baffling list of 10-12 documents all with very similar names.
Sounds to me like EASA are trying to kill the Flight training industry a bit.
I currently have expired type ratings (>3 years) on 2 medium twin types and 2 heavier twin types and all will disappear forever with this rule.
It makes it prohibitive for companies and individuals to get themselves back up to speed as far as I can see.

Regards CF

[Aucky]

CF - if you haven't already updated you licence to EASA you can get them current on your JAA License with just an LPC (until April, I believe, when you must have been issued your EASA licence) and they will be put onto the EASA when you renew. Annoyingly if you have already renewed it's probably too late. A rule for Double Bogey to justify... To anyone who has NOT yet renewed. Get all types you want to keep current PRIOR to reissue!

[Adroight]

Anyone now putting a new type on thier JAR licence will HAVE to change to EASA (and pay £130 for the privilege of course) - even if you have many years validity on your existing JAR licence. Anyone who has not seen it will be wondering what the £130 is for as it is a little, cheap, blue piece of plastic with tiny, unreadable print.

[Kelly Hopper]

My question is where were the representing bodies, (unions etc) when these licence privileges that we have earned and paid for taken away?
As both a rotary and fixed wing guy I am losing my marketability in the jobs arena and that is simply unfair.
I am afraid that very quickly I have come to the conclusion that EASA is nothing but another nail in the coffin of European aviation!

[Camp Freddie]

Hi Mr Aucky, thanks for that, but what you are saying is fundamentally different to what Mr Idle Stop is saying 🙇 but I hope it's true!

Is it written down anywhere what you are saying? Because my understanding is that all JAR Licences are deemed to be EASA ones since 7/9/12 and therefore subject to the EASA regime / renewal.

[misterbonkers]

NigelH - if you have 100hrs or more on type and currently fly it on another ICAO licence then you only have to do a Proficiency Check (there may be an upper weight limit for the types). Then you pay a fee to get it issued on your EASA licence. I'll try trawl through Part FCL/CAP804 to find the section on this for you but that's like 2000 pages and I don't have trouble sleeping at the moment...! :confused:

CampF - when you apply for an EASA licence ANY non current types (not just those that have expired by more than 3 years) go on the back - which is highly frustrating because it's ANOTHER bloody fee to pay. :ugh:

EASA licence are valid for life.

[Aucky]

Hmmm apologies, I should have checked my dates a little more closely. It may well have been September. For some reason I had April in my mind as a month of relevance too.

In my understanding, it is mandatory to reapply for an EASA licence on your next application for a new type after September 2012, or licence renewal. your JAR license effectively becomes an EASA licence until reissued, and so the relevant parts of Part-FCL apply, so the 3 year limit becomes problematic for you, unfortunately. For anyone else looking to reissue who's ratings are not expired by 3 years or more - be sure to get the types current (within the 3 years) before submission for the EASA licence if you want to avoid the additional costs or reinstating them.

[nigelh]

Mister bonkers ..... So you reckon that if I have flown the helicopters rated on my UK licence regularly over the last 4-5 yrs , but on my FAA ticket , then I am still deemed to be current and just need an LPC ??? Sadly ,knowing the morons that rule aviation in the UK , that is highly unlikely to be correct because it is too logical and sensible !!!!
I do know that having flown my 109 for around 200 hrs now ...I will still have to do 8 hrs of training :ugh: to put it on my new EASA licence . For anyone flying their own G reg on an FAA ticket they should look at changing it to N reg .

[misterbonkers]

Gifthorse, mouth...

Although if you want it for a 109 you'll need a few more hours... So maybe you should go back to the as350?

The UK 'morons' you refer to don't make the rules no more...

CAP 804, section 2, part Q, subpart 2, page 3;

2 Annex III to Part-FCL

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;

Part FCL Annex III states experience requirements as follows;

(iii) for single-engine helicopters with a maximum certificated take-off mass of up to 3 175 kg, 100 hours of flight experience as a pilot in that type;

(iv) for all other helicopters, 350 hours of flight experience as a pilot in that class.

EN L 311/172 Official Journal of the European Union

[Kelly Hopper]

That is a help if you have a rating and time on type on a foreign licence. I however under EASA find myself losing a bizjet rating (3 years out now) that will cost $65,000 to recover not just a few hours on type!
The shifting of goalposts by the relevant authorities when it has such dire consequences for those it affects is, or at least should be criminal!

[misterbonkers]

Kelly, not sure about fixed wing rules but in helicopters if you have a ME type rating that has expired by more than three years then you have to redo the whole type rating HOWEVER it's classed as a second ME type rating so you don't have to do the full 8hrs (unless you need the practice). So the minimum hours are reduced.

If I have an expired type rating for a larger type then I'm pretty certain I'm going to need some retraining to get back into practice (and if it's been a while then some ground school wouldn't go a miss either).

I wasn't a big fan of EASA when it came out. There are still issues with it but it's not all as bad as we think. A large part of the issue is that our CAA didn't implement a lot of JAR - this would have made the transition to EASA a lot easier AND perhaps Gatwick's life easier too! Unfortunately Gatwick seem very capable of making us pay every time. What really gnarls me is hearing that there are a number of ex CAA bods now cashing in on all the rule changes that they managed to make so complicated - consultants. The industry wouldn't need their expertise if the rules had stayed where they were so not a bad pension plan eh?

Perhaps all us pilots should fly the longest route every time - then they'd need to employ more of us to cover the routes... :ugh:

[Kelly Hopper]

Thanks for the input Bonkers!
Yes the rules for F/W and R/W are quite different.
After 3 years now, previously 5, I have to do the entire F/W rating again. A whole month of sim and school. At massive cost!
The previously mentioned foreign licence idea is the way to go. Get it on my FAA ticket and then no matter how "out" you are only a pass in the LPC is required. That has to be the plan now.
It is crazy however that I have to use another authority's licensing requirements to maintain my status in EU land because a penpusher pushed me out!

[misterbonkers]

Kelly, I agree with you entirely! Interesting that the UK CAA aren't keen to post the idea in CAP 804 either but it's written in PART FCL in dark grey and white! I'm going FAA for the same reason. Good luck!

[Helinut]

For most regulators it is a standard requirement that they prepare a Regulatory Impact Assessment of their proposed new regulations. Does anyone know why EASA seem to be entirely exempt from this process?

The value in such a process is twofold:
- Interested "stakeholders" can see what level of assessment has been done by the regulator and, in the regulator's view, what the effect of a regulation would be.
- It also has the very beneficial effect of reminding the regulator that there is a balance to be struck, that the idea is to achieve higher levels of safety whilst minimising unnecessary cost.

EASA seems to be free to run riot without any of these normal constraints.

[nigelh]

OK Mr Bonkers ...they are not UK morons but EU morons :ok:
If I continue to fly the 109 and say next year have 350 hrs ....then will I have to do the full course if its a first twin on my licence or will I still be able to do abbreviated one ? It does appear that using an FAA ticket is the way , as you can get current again without any training needed and then convert .
Thanks for your help .

[misterbonkers]

Just get 350hrs on type and all you have to do is a licence skills test.

The rules I posted above are for any type not just expired ones or previously held ones.

Note you have to be current on the type you are doing this with I.e have 2hrs in 12 months on type flying on the icao licence from which you are transferring the priveledge. Easy peasy! It's all there written for you. Cap 804 and part FCL are free to download. I'm just gutted I never managed to reach 350hrs on the as365 - looks like that will be long lost now :(

[nigelh]

HILARIOUS :D:D:D:D
After 25 mins waiting on the telephone to the CAA licensing dept I got a very nice girl ..... ( they obviously know how irritating they are as they say while you are waiting that they will not allow any abuse or verbal attacks on their staff !!!!)
Anyway , I ask about renewing my ratings after a lapse ....but whilst still flying and being current on my faa etc etc . She goes on hold for 10 minutes and comes back with Part 4 section x etc etc on their website . I explain that I need a steer from them as to what is required ... She says they cannot tell me what I need to do ....it is up to me to interpret it :D. She then says she spoke to another expert there ...I ask " what was his view ? Do I just need an LPC or full type rating training all over again ? ". She says " I can't tell you . He just says its up to you to decide ".
I point out , very politely , that she has been as useful as an ashtray on a motorcycle and say goodbye .
You really couldn't make it up .

[Old Age Pilot]

nigelh

The best way to go about this is to send them in an application form, having done nothing, with a note to say that this is how you interpreted it. Then you may get an actual answer with specifics :ok:

I have to agree, it is indeed hilarious that they put you on hold for any length of time to "check for you", and come back with that very same answer they come up with every time one is unsure of what the hell they need to do and need some advice from the people implement the rules! It's been this way down there for a few years now!

[nigelh]

Having said that sometimes it works for you . I emailed them many years ago asking if I could operate my helicopter commercially here without an aoc and they said " yes" and then told me how :ok: Which is what i have done for the last 15 yrs or more . If you have it in writing from them it must be true ..

[misterbonkers]

Try emailing;

[email protected]

Or phone and speak to Barry Mooney.

But it's written down in published documents so it's the school who decides - try speaking to Leon Smith or John Daly at helicopter services.

[2Sticks]

Leon Smith at Helicopter Services is certainly very knowledgeable on this, from my experience. CF - it might not be as dire a situation as you think.
2S.

[idle stop]

Helinut:
Paraphrased from a recent Industry/CAA 'crisis' meeting on Licensing issues post introduction of Part-FCL....the CAA man on EASA licensing committee pointed out that due to the 11000 comments to the Part FCL CRD, and that the EC imposed a start date for Part FCL, the committee did not have time to consider all the replies to the CRD! You just couldn't invent that scenario, could you?
Translation:
1. It was not the EASA committee's fault.
2. It was not the CAA's fault.
3. It must be our fault for raising all those comments.....

Am I feeling cynical.......?

[Helinut]

Outrageous, but absolutely no surprise..........

[misterbonkers]

11000 comments?!? And they ignored them?

And we live in a democracy? I think not!

Perhaps Stalin succeeded after all... The common man paying for few people at the top to have cushy lifestyles!

[nigelh]

I asked Leon some time ago and I think he said 3 hrs training and LPC for the singles and 8 hrs and ground school plus exam for 109 .
As it is up to the ATO to decide , all I need to do is find one who agrees with us that only skill test / LPC required !!
Having said that , isn't it so sad that we have , over many years , allowed the lunatics to take over a wonderful industry ...which surely and steadily they will kill . How many ppl,s will give up flying over the next 10 years I wonder and how many AOC ,s will be left ( disregarding offshore etc ) .:{

[md 600 driver]

Nigel
Surely your twin training for your FAA licence would count anyway coupled with a LPC (OPC?)
Why don't you just do a 109 LPC and send the forms into the CAA for inclusion on your licence as per the cap 804

[nigelh]

I sent an email with all the info last week to the CAA . What's your best guess as to how long it will take them to respond ??
Ok. . I shall do an LPC with someone and send it in and see what they say !!
There isn't any official training on the FAA side ....I just jumped in with an instructor and went through emergencies and that was it .

[flight beyond sight]

Nigel the whole subject has now become in the CAAs words 'at the discretion of the Head of Training of the ATO.' It really depends on the individual circumstances and other similar flying activities during the lapsed period. We are renewing ratings which have lapsed on twins by over 5 years with as little as 2 hours flying training plus test.The judgement falls completely on the ATO and is reflected on the course completion certificate. We are all learning the new EASA speak but must understand the words should are not the same as must so there lies the problem in interpretation. If you wish to PM me I will try and see the easiest way forward.

[Camp Freddie]

the whole subject has now become in the CAAs words 'at the discretion of the Head of Training of the ATO.'

where specifically are these CAA words actually written down please, because
in the "Acceptable Means of Compliance and Guidance Material to Part-FCL" it says on page 247:

"The amount of refresher training needed should be determined on a case-by-case basis by the ATO,"

I cant see where it mentions any specific person?? is there another document where there is guidance??

Regards CF

[misterbonkers]

CF - the HoT is the person in charge of the ATO, the nominated post holder, therefore by default the buck stops with them so they decide.

However, from my posts, of you a current on type (2hrs in last 12months) flying the same type on an ICAO licence (inc FAA) have 100hrs (SE) or 350hrs (ME) then the rules clearly state you only need to pass an LST with an FE/TRE provided the ATO is willing to sign you off for the test.

If you are not current or do not meet the minimum hours on an ICAO licence then the HoT must assess and decide what training you need. See CAP 804, Part FCL and the AMCs - under type rating sections - simples!:)

[Camp Freddie]

misterbonkers,

thanks for that, unfortunately it all seems to have been written in a woolly fashion. i.e. on the face of it its clear but when you get into the detail its not.and creates much uncertainty for the expired type rating holder.

also the training organisations are going to have to balance the needs of the student with the desire to make money, i am sure some will revert to the default position of "you need to do the whole type rating again" when actually the student doesnt need to do that much.

also it fails to address how some organisations work where the head of training is not physically based on site, he/she may be at another base and/or difficult to get hold of at short notice as this type of business will often be a walk in.

I am very pleased i dont have involvement with this on a full time basis, it would drive me mad as well as make me angry that the flight training business is being killed by overegulation in my opinion.

[misterbonkers]

It drives me mad too. Even at schools where the HoT is full time, it's still very restrictive.

As is more common nowadays the rules have been devised by those who have no clue about OUR industry.

There are now fewer and fewer qualified pilots in roles at the CAA and, more importantly, EASA. The head of the CAA is an ex railway man! Traditionally the medical division used to be headed by a doctor who flew and knew about flying.

They are even looking at charging a fee for using the open counter service despite the fact we have to use this service (even driving 5hrs each way to do so) because the postal service is so poor (3mnths to get an EASA which was mandatory to renew an FE ticket!).

Bring back the olds school boys who weren't afraid to put their name to something, stood up for aviation and didn't give a toss about politics and 'pleasing' them above for the sake of their careers.

Grass routes aviation with people who know HOW TO FLY, how to wander with the clouds, how to endure the foggy days and enjoy the sunny ones.

We all have our differences that air frequently on this site but ultimately we stand united with our passion for flying and sadly, so it seems, this passion no longer exists amongst those that 'govern' us!

Rant over.

[Kelly Hopper]

Misterbonkers! You need a new handle....
Can I suggest "MisterFarTooSensibleToWorkForTheCaa."


'Totally support your POV.

KH

[212man]

This issue has caused us real headaches. We recently recruited a pilot who, for HR delay reasons, joined us after the November deadline. His S92 LPC had lapsed by 3 years - which we were fully aware of - and we sought a solution to renew it as we are not an ATO (but have UK licenced TREs.) One idea that seemed sensible, was to carry out his 20 hours of Operator Conversion simulator training and then have his PC carried out by a TRE having his TRE certificate revalidated by a CAA FOTI - all in the UK. Not deemed acceptable by LTS! :mad:

The EC225 grounding has caused a massive demand for S92 training at the - very few - ATOs, so the only other option was FSI (none of the operators could handle the request.) I asked them to check if the 5 day/8 hour recurrent course would be acceptable to the CAA. It wasn't. So, full initial type rating course it is then, in June! :ugh::ugh:

The really annoying thing about all this (apart from the cost, delays, and the fact that prior to September we could have administered all this ourselves) is that the AMC says applicants should be assessed on a 'case-by-case basis' but the authority is simply sticking to the suggested requirements in the AMC.

Now, if we fail a pilot during a Proficiency Check, he'll be grounded until we find an ATO with capacity to assess and train him. Guess how many failures there are going to be? :mad::mad:

[Geoffersincornwall]

Shock horror to hear somebody actually mentioning those words 'fail a prof check' in public.

We have, in our industry, a blind spot when it comes to the important process of assessing the competence of our peers, colleagues and would-be arrivals on a new type.

There are administrative disincentives (a la 212's dilemma) and there are cultural disincentives where sitting in judgement on a colleague is seen as an evil process best handled by hurrying through the test and signing off the paperwork.

To persist with this lack of rigour does nobody any favours yet for economic and cultural reasons the vast majority of prof checks are, I suspect, unrealistic with unhelpful outcomes.

If a pilot needs a little extra training to get to the required standard then you are not helping if you are the TRE that nods him or her through the test. Your colleagues will have to fly with somebody who is sub-standard and the customer likewise.

This lack of rigour is pervasive and threatens the instructor corps as well. If we expect the line pilot to be good at his job then we should be even more demanding of those that are teaching and examining.

Continuing to pat each other on the back and say "well we know you can do it really, you just had a bad day" is not an attitude that will help us in the long run.

I know 212's operation well and I am confident that they have he right ethical and professional approach and could deliver on my craving for competence if not impeded by bureaucracy. This is NOT the way we should be going.

I believe it was Winston Churchill who said that 'power corrupts and absolute power corrupts absolutely'

"Let competence rule and let competence rule absolutely", would be my 'crie de coeur'.

Sorry for any thread drift.

G

[Camp Freddie]

Having just got a shiny new bus pass (EASA licence) and finding that I have now lost the SK76, AS332L, A109, and AS355 ratings which have been removed from my licence and placed in the "previously held ratings" section, I can say that I am definitely annoyed about the whole thing, and disappointed that the Authorities have no regard for the cost and difficulty in getting these ratings in the first place.

[nigelh]

I can see no reference so I assume having a rating ( CAA) on your licence that has lapsed OR never having had that rating makes no difference ? Ie I have ratings for 206 . , 341(2) and AS350 last valid 2009 ......if I am current on them and have over 100 pic on type , I can just do a skills test ...LPC and my ratings become valid again . If I do same on a type I do not already have a rating for ....I will then gain that rating . Then I assume it stays as before ...ie you do your LPC on any one of your group ( not incl Robbos ) and you get them all ?
Simple question ...slightly off topic ....but one close to my heart !!. Is it too late to have any sort of influence on the running of OUR CAA ....or do we have to accept that a British Rail Ticket inspector is going to take full charge of our industries future ? I have long said that ALL the medium and small aoc,s should withhold payment and carry on doing leases for the time being . I would bet they would be more profitable and also there would be no action from the CAA . To my knowledge there has NEVER been a prosecution for a lease deal flight and my lawyers tell me that the fact that the CAA have allowed it for 50 years with no attempt to stop it IS effectively condoning it .....therefore by default it IS legal and lots of us have done it for millions of hrs over the last 50 years or so :ok:
We will end up like Greece where their pilots have to come here for their check rides as all the instructors etc have quite sensibly gone elsewhere ......

[Geoffersincornwall]

The only Greek instructor I had the pleasure of meeting was in Italy. He had a CFI rating but had never taught anyone in his life and a CFII rating but had never seen the inside of a cloud.

Now do you see what I am getting at when a bash on about competence management???

G. :{