EASA differences training by non-EASA flight instructor

[Zonkor]

Dear forum,

Is differences training (Part-FCL 710) from non-EASA flight instructors acceptable for an EASA license? (For example, a tailwheel endorsement by a US instructor.)

Thanks,

George

[Mark 1]

If you have an endorsement from a US CFI that means you have experience of tailwheel aircraft and hence don't require any further differences training, assuming that you've flown tailwheel aircraft in the last 2 years.

[Zonkor]

Is that an interpretation or (backed by) Part-FCL?

I'm asking since Part-FCL is quite specific in other areas about what it deems acceptable training providers for licenses or ratings (i.e., ATOs), but FCL.710 only mentions "differences training" by an "instructor".

The 2-year recency rule you mention seems to not hold for tailwheel aircraft due to FCL.710(b), at least for SEP ones.

Best,

George

[Mark 1]

I think you're right that the 2 year requirement doesn't apply for SEPs.

It's difficult to get down to the letter of the law, but it doesn't make sense to require differences training for a variant that you have qualified for under the privileges of a foreign licence.

I guess that you are covered by grandfathered privileges, but I'm afraid I can't put my finger on the chapter and verse.

[S-Works]

You will require an endorsement in your log book from a Part FCL Instructor for differences training unless you can demonstrate grandfather rights and recency on a ICAO licence.

[mad_jock]

The night experence doesn't need to be done by an EASA instructor for commercial licenses either.

[Zonkor]

Sorry if I'm rambling, but it's Monday morning, and Part-FCL is starting to become quite frustrating :)

If a rather simple question yields multiple different answers (interpretations /guesses, since without source?) from experienced people (but in any case thanks for your answers!), then something is seriously amiss with this EASA transition. I'd not fly unless totally sure about the validity of an endorsement, due to the harsh consequences (e.g., insurance coverage).

Sure the pilot is responsible to know the law, more so than in any other activity it seems. (Do you know a driver who fully read and understands the laws of the road? In any country he/she goes to?) But I'd say for European pilots it is close to impossible even with the best of efforts.

If I read Part-FCL or CAA CAP804, then more questions than answers arise. However, it seems right now we (private) pilots are left in the rain: The CAA is to my knowledge the only so-called competent authority that already issues Part-FCL licenses. However, they are less than "competent" in answering any kind of questions that go beyond the trivial. A email inquiry routinely yields no reply, and the phone agents have little clue about the legislation, it seems.

Who else should one refer to? An (EASA-certified ;-) aviation lawyer? EASA itself (has anybody had luck inquiring directly with them)? An ATO (and how would they know)?

No wonder general aviation becomes less and less attractive in the eyes of many over here ...

</ramble>

[S-Works]

With respect some of the problems are of our own making and there are non worse than the British Pilots.

The rules were not made with the intention of mixing and matching licences and ratings to achieve the results we often seek. This leads to a layer of complication that is not expected. The UK CAA have historically been one the most pragmatic of the European NAA's.

The rules are actually quite simple, if you want to fly something with differences that is on a European reg then you have to meet the requirements. In the case of Tailwheel, you do Tailwheel differences training and receive a logbook endorsement from an EASA FI(A). There is an allowance for the holder of an ICAO licence who has been trained and can show recency to be exempt from this requirement which is fair. However do you think it reasonable to go and train with an non EASA instructor to gain credit on an EASA licence and type?

Now there is a lot left to the discretion of the Instructor on the content of the differences training, so there is no reason why you could not do a quick flight and demonstrate to the Instructor competence as a tailwheel pilot and be signed off. Other differences may not even require a flight, for example if you have been flying a turbo charged engine, a ground session demonstrating the required knowledge may be all thats needed.

You have to think outside the box rather than having the usual British mentality of looking for blocks and problems where in reality none exist.

Having said all of that, I do think that there are flaws in Part FCL that need to be worked out, just as there were in JAR. As an example the requirements for renewing an SEP(Sea) changed in Part FCL so that you cant combine the SEP(Land) and SEP (Sea) ratings anymore, meant I had to haul my bum to Florida and spend 12hrs cruising around the Winterhaven Lakes. I have submitted a rule making proposal to change this back to the way it was.

My advice, read the CAP and the Part FCL documents and engage with the new system rather than kicking it.

[BEagle]

I have submitted a rule making proposal to change this back to the way it was.

I will also be suggesting the same thing at the EASA FCL Implementation Forum immediately after Easter.

Although FCL.740.A (b)(2) outlines a process whereby a pilot holding both a single-engine piston aeroplane-land class rating and a TMG class rating may combine revalidation requirements, no similar process currently exists for pilots holding both a single-engine piston aeroplane-land and a single engine piston aeroplane-sea class rating.

(We) consider that it is unreasonable to require pilots holding both a single-engine piston aeroplane-land and a single engine piston aeroplane-sea class rating to meet the revalidation requirements for each class in their entirety.

We therefore wish to propose a new FCL.740.A (b)(4) as follows:

(4) When applicants hold both a single-engine piston aeroplane-land class rating and a single-piston aeroplane-sea class rating, they may complete the requirements of (1) in either class, and achieve revalidation of both ratings, provided that they have also completed the following minimum requirements in each class:
— 1 hour as PIC,
— 12 take-offs and 12 landings

(Delegates might wish to note that this was the UK position under JAR-FCL and that it raised no safety concerns.)


NB - FCL.740.A (b)(1) to which I refer is simply the current 'revalidation by experience' requirement.

If the meeting supports the proposal, I will then ask the CAA to raise an Article 14(4) or Article 14(6) exemption to this effect, because it will take ages for the appropriate Part-FCL working group to raise a draft Opinion....:rolleyes:

[S-Works]

I will also be suggesting the same thing at the EASA FCL Implementation Forum immediately after Easter.

Drop me an email and I will send you the correspondence from EASA as it has already gone into the machine and been acknowledged.


If the meeting supports the proposal, I will then ask the CAA to raise an Article 14(4) or Article 14(6) exemption to this effect, because it will take ages for the appropriate Part-FCL working group to raise a draft Opinion....


I have already asked for this as well. It currently sits with David Conduit.