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Solo supervision Lapsed SEP

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Solo supervision Lapsed SEP

Old 21st Dec 2013, 11:07
  #81 (permalink)  
 
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The integrated student has already completed the SEP class rating its just they were never signed off for it by an examiner to allow the class rating to be issued so your only revalidating there training to bring them up to speed for class test.
You just made my point exactly.......


You have stated that you don't think its worth it so now you are actively trying to get the authority to issue a policy to make others comply with your interpretation.
Where do you get that idea? I have asked for clarification thats all.
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Old 21st Dec 2013, 11:32
  #82 (permalink)  
 
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Yes so there is no syllabus for SEP class rating.

No clarification was required, it was just running to the teacher because someone isn't doing what you want them to. And as usual teacher is saying what you want to hear to get rid of you. But I suspect when teacher goes to talk to the deputy head and they look at the rule book they will find they can't do anything about it because as such there is no rule. They can try and make a rule up if they want but then someone will start a complaint procedure. And the whole thing is going to cost time and money for an issue which they haven't had a single safety related incident involving. So keep quite and put nothing in writing and point to wards the relevant legislation I suspect will be the way of dealing with it.

The usual rubbish has been brought up about insurance and AAIB. And as usual it has been dismissed as pish.

For over thirty years it was a requirement under the UK ANO to do solo x-country qualifier if your equivalent of SEP class had been up for more than 5 years.

I say again what is your safety case for stopping the rest of us doing it?

Because that's the first thing that's going to be asked to the CAA for this statement of policy.

And all you can say to the points raised by the supporters is "no it doesn't"

How many lives would banning this practise save "err none"
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Old 21st Dec 2013, 14:04
  #83 (permalink)  
 
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There is an SEP sea class rating syllabus in the AMCs
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Old 21st Dec 2013, 14:06
  #84 (permalink)  
 
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Come on MJ grow up. There was no need for that sort of personal attack.

I have sought clarification on what is acceptable. As it would be the CAA that picked up such activity during routine audit, I would rather not have the discussion that we were doing something wrong. You should have seen the grief I got over a missing first aid kit at the last audit and a missing NOK entry on a student form. Imagine what it would be like if we were interpreting the rules incorrectly because of assurances on PPRune that it was OK?

There is an SEP Class rating course. I have one and its in our approved manuals.

At the end of the day I am not prepared to send people with expired licences solo. However I am open minded enough to seek clarification from the regulator as to whether it is an acceptable thing to do.
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Old 21st Dec 2013, 14:26
  #85 (permalink)  
 
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I am not prepared to send people with expired licences solo
Why not? No problem at all to do this.
FI authorises solo flight using their privilege (a)

Did you perhaps mean "expired ratings" rather than "expired licences"?
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Old 21st Dec 2013, 14:33
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As has been said what you are prepared to do is up to you. And if the regulator even says it is allowable you won't be doing it.

The rest of us have been perfectly happy sending them out for years.


And you need to grow up as well because like it or not running to the regulator because people are doing things which you don't like the idea yourself is plain childish. Especially as your not going to allow it anyway at your ATO.

We should be fighting to get people flying as much as they can safely not fighting to keep people on the ground for zero safety benefit.

From my experience you are in the minority not doing it. In fact the first person to suggest it to me for solving a problem student who was 10 years out was a single digit exam call sign. And it worked.

I say again what is your safety case for stopping the practise?
Please answer the question.

And also how many auld farts have you got flying again after 5-15 years not flying?

I had one who the Ministry of Aviation had issued his life time license. He I might add did 15 hours solo time including Nav solos. Not particularly because I wanted him to but because he wanted to. "Best not to be silly about these things young man"

It is crazy that someone that held a license 20 years ago can't do solo work under supervised conditions for exactly the same reasons why we have it in the PPL license. If they don't need it we don't require it. If they want it anyway there is no safety reason to say no you can't.

Last edited by mad_jock; 21st Dec 2013 at 14:53.
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Old 21st Dec 2013, 15:01
  #87 (permalink)  
 
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It doesn't matter how many times you insult me or bludgeon me with your view of how things should be I will await the response from the CAA.

Asking for clarification on a matter of policy is not 'running to the teacher', it is common sense. The rules are not clear enough to me to convince me to change what we have established and to be frank you trying to bully me into agreeing with you by sling personal insults is not going to change that.

Play the ball not the player mate.....
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Old 21st Dec 2013, 16:04
  #88 (permalink)  
 
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Typical thread of the two sides battling it out, neither changing their mind.

The fact is there is nothing in the law to prohibit it.

In law, that is all that matters. In court, that is all that would win the case, open and shut.

If the part fcl said someone who has previously held a licence may not fly solo until that licence is valid once more, fair enough, but it really doesn't say that anywhere.

As head of training you are free not to send people solo, just as others are free to send them off.
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Old 21st Dec 2013, 17:13
  #89 (permalink)  
 
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I am playing the ball. The running to teacher has obviously hit a cord. Its not a matter of policy its a matter of legislation.

So your going to wait for something which is not going to change the way you operate anyway.

Please answer the question.

I say again what is your safety case for stopping the practise?
Anyway we all know that the caa watch the forum so its best they know they are going to have to deal with a load of complaints if they give policy which is in contradiction of the legislation.

So with any luck they will state.

"There is no requirement for solo flight to be taken for renewal of SEP Class rating. But if the head of training deems it beneficial to the student there is nothing in legislation which prevents this."

Then those that don't can continue and those that do can continue. And everyone is happy.

Last edited by mad_jock; 21st Dec 2013 at 17:29.
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Old 22nd Dec 2013, 08:48
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This may seem naive but surely a PPL with a lapsed SEP rating but with a valid medical certificate devolves to a Student Pilots Licence with the attendant privileges and restrictions?

Simple!
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Old 22nd Dec 2013, 09:48
  #91 (permalink)  
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What's a student pilots license? Never had one if those in the UK at-least. I've been a student loads of times but never needed a licence for it.

G
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Old 22nd Dec 2013, 10:54
  #92 (permalink)  
 
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Genghis: When a student first undertakes flying training he has no licence. When dual he is flying with a licenced pilot - the instructor. To be sent off solo under the supervision of the instructor he must be in possession of a valid medical certificate. This is what used to confer privileges and used to be referred to as a Student Pilot Licence. It used to be printed on the back of the certificate. With JAA/EASA land this statement has gone however the principle still applies.
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Old 22nd Dec 2013, 13:30
  #93 (permalink)  
 
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PPL with a lapsed SEP rating but with a valid medical certificate
devolves to a Student Pilots Licence
A Licence gives an individual certain privileges to act as a Pilot.
What those privileges are depends on the level of Licence held, and
remain valid for as long as the Licence remains valid.

The rules do not say that a Licence stops being valid without a Medical;
they say a valid Medical, appropriate to the privileges being exercised,
must be held.
No Medical does not mean no Licence, it means Licence may not be used.

To exercise Licence privileges in a particular aircraft requires a valid Rating
for that aircraft.

An expired Rating has no effect on Licence privileges - think of pilots
with several Ratings, some valid, some not.

Of course, if no valid Ratings are held on a Licence, then it is not possible
to exercise the Licence privileges at all; but that is not the same as saying
the Licence is not valid.
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Old 2nd Feb 2014, 14:07
  #94 (permalink)  
 
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So, did the CAA ever come back with a definitive answer on this one?
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Old 2nd Feb 2014, 14:44
  #95 (permalink)  
 
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Of course, if no valid Ratings are held on a Licence, then it is not possible
to exercise the Licence privileges
Except as a student pilot
50 (1) Subject to paragraph (2), a person must not act as a pilot of an EASA aircraft that is
registered in the United Kingdom without holding an appropriate licence granted,
converted or rendered valid under the EASA Aircrew Regulation.
(2) A person may act as a pilot of an EASA aircraft without holding an appropriate licence
granted, converted or rendered valid under the EASA Aircrew Regulation when
undergoing flying training, including solo flying training authorised and supervised by
a flight instructor
, in accordance with the EASA Aircrew Regulation as amended from
time to time.
So, did the CAA ever come back with a definitive answer on this one?
It is not the CAA's job to give definitave answers; they will simply point you at the regulation.
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Old 2nd Feb 2014, 17:43
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True, but I was meaning in response to Bose-x's comments that he had contacted the CAA for clarification, just wondered what the results were.

As you say, I'm sure they just pointed at the rules which clearly show that it is allowed, just wondered what the response from them would have been.
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Old 2nd Feb 2014, 19:41
  #97 (permalink)  
 
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Rightly or wrongly EASA is very specific, a Licence does not cease to be valid just
because no valid medical is held, nor valid rating attached:
FCL.040 Exercise of the privileges of licences
The exercise of the privileges granted by a licence shall be dependent upon the validity
of the ratings contained therein, if applicable, and of the medical certificate.

Quote: 50 (1) Subject to paragraph (2), a person must not act as a pilot of an EASA aircraft
that is registered in the United Kingdom without holding an appropriate licence granted,
converted or rendered valid under the EASA Aircrew Regulation.
(2) A person may act as a pilot of an EASA aircraft without holding an appropriate licence
granted, converted or rendered valid under the EASA Aircrew Regulation when
undergoing flying training, including solo flying training authorised and supervised by
a flight instructor
, in accordance with the EASA Aircrew Regulation as amended from
time to time.
Whopity,
Your quote (from ANO), your Red, my underline

In the case under discussion the person does hold a valid Licence, so this
exception does not apply. Even if it did, as solo flight is not required for
SEP Rating renewal, I cannot see how that could count as "flying training
in accordance with the EASA Aircrew Regulation"

It would have to rely on the ATO and Instructor deciding that any training
they liked was valid for SEP renewal - and, given that authorising solo
flight is only specifically allowed for Licence training, deciding themselves
which Instructor, presumably an FI, was the most "appropriate".
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Old 2nd Feb 2014, 21:04
  #98 (permalink)  
 
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In the case under discussion the person does hold a valid Licence
Valid to do What? In order to be valid you need to meet all of the requirements, the licence, the ratings, the medical. If you cannot exrercise the privileges then it is not valid. EASA regulataion is not written in such pedantic detail.

Under FCL.040 you cannot exercise the privileges; therefore the licence is invalid. But under Art 50 you can fly without the need to exercise the privileges if supervised by a flight instructor.

We have a load of shambolic regulation, you have to apply a bit of common sense and make the most of it, its not going to get any better.
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Old 2nd Feb 2014, 21:10
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I wonder if they knew when they wrote these regulations that they would be debated down to the very word like this

Still don't see anything that says it's illegal, so will happily continue to do it.
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Old 2nd Feb 2014, 22:36
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Level attitude,

your underlining in the quote above does not say "flying training for the initial issue of ..." It simply says "flying training"; that means any type of training! Could be initial training, refresher training, advanced trainign such as aerobatics etc.

When a pilot has a lapsed SEP rating he requires training in order to renew his rating but the regulation is quite specific that the content of that training is to be determined by an ATO. I am Head of Training at an ATO and, if I consider that solo practice is beneficial to the trainee I am perfectly within my rights to send him solo. There is no regulation which says I can't!

We did this to death before Christmas and, as far as I can see there are no new arguments here so I'm out!

Happy landings

3 Point
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