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 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]

Converting FAA SEP(Sea) to EASA

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.