CRI for LAPL(A)--> EASA PPL(SEP)

[Genghis the Engineer]

I'm a CRI, I have a student who would like me to instruct them for an upgrade from LAP(A) to EASA PPL(SEP).

Wading through CAP 804 and FCL they seem to imply that I can do this within an ATO (I have a friendly ATO happy for me to work for them). But it's only really implied rather than explicitly stated.

I've emailed CAA whose automated reply says that they'll get back to me in 18 days, or 30 days if it's a difficult question.


Does anybody have an answer to this one already anywhere definitive, that might beat CAA's 18 days?

G

[nick14]

I would say no as it's a licence issue, the SEP rating yes but in guessing not for the issue of a PPL.

[BEagle]

FCL.210.A(b) requires that the training course for LAPL(A) to PPL(A) upgrade is completed in a training course at an ATO. All ATOs require approval for Part-FCL training courses - does your 'friendly ATO' have such approval for LAPL to PPL training?

FCL.905.CRI(a) defines the privileges of a CRI. Para (1) makes it clear that these are for 'the issue, revalidation or renewal of a class or type rating for non-complex non-high performance single-pilot aeroplanes, when the privileges sought by the applicant are to fly in single-pilot operations;'

I therefore conclude that the LAPL(A) to PPL(A) course may not be conducted by a CRI - flight instruction for PPL(A) initial issue must be conducted by a Part-FCL FI(A).

The rest of €uroland seems rather less keen on CRIs for SEP work than has been the case in the UK hitherto.

[Whopity]

I concur with Beagle. A LAPL is a Non-ICAO licence therefore any training towards an initial ICAO licence is ab-initio and must be conducted by a FI(A) and does not fall within the privileges of a CRI.

In any event such traing must be conducted in accordance with the Operations and Training Manuals at the ATO. RFs do not necessarily have such manuals and can only conduct PPL training under grandfather rights. The LAPL did not exist pre EASA, so is not included in those grandfather rights.

I have a friendly ATO happy for me to work for them

These days are over, its all tightly controlled and documented now!

[Genghis the Engineer]

I really hope that the days of friendly ATOs aren't over!

Thanks for the responses chaps - not what I was hoping for and I can see that you may be right, but as nobody has anything more definitive than I have as yet, I shall I think have to wait for CAA, whether the answer's "yes" or "no" at the moment.

G

[Whopity]

What makes you think the CAA will even understand the question? It is the ATO who make the decision in accordance with their approval!

[Genghis the Engineer]

CFI at the ATO has told me to get an answer from the CAA, I was just hoping here that somebody might have got an answer before me. I can't, whether I like the answer I get or not, see why CAA FCL wouldn't understand the question.

G

[S-Works]

No you can't. We asked this of the CAA a couple of months ago. You are a class rating instructor. You can add a class to a licence but not train for the issue of a licence.

[Genghis the Engineer]

Thanks Bose.

Shame, but no point in fighting the system. I need to get around to an FI rating one of these days when I can find the time and money.

G

[Captainkarl]

Sorry to dig up old bones but why cant the CRI party play some role in the LAPL to EASA PPL conversion?

LAPL to EASA PPL requires 15 hours flight. 5 which can be since issue of LAPL and 10 which must be with an ATO & approved course - 4 of 10 hrs need to be solo and 2 of the 4 hrs should be a XC of 150nm and 2 landings away.

So is there anything to stop the student using the 5 hours since issue of LAPL to do some work with the CRI to get some types added to the LAPL such as retractable gear, tail wheel & CSU prop etc?

[BEagle]

Captainkarl, FCL.210.A states:

(b) Specific requirements for applicants holding an LAPL(A).

Applicants for a PPL (A) holding an LAPL(A) shall have completed at least 15 hours of flight time on aeroplanes after the issue of the LAPL (A), of which at least 10 shall be flight instruction completed in a training course at an ATO. This training course shall include at least 4 hours of supervised solo flight time, including at least 2 hours of solo cross-country flight time with at least 1 cross-country flight of at least 270 km (150 NM), during which full stop landings at 2 aerodromes different from the aerodrome of departure shall be made.

There is no reason why a CRI could not conduct differences training for VP prop / tailwheel etc. within the 5 hours of flight experience which are not required to be in the ATO's training course because such 'differences training' is obviously outside the mandatory 10 hrs of flight training.

Incidentally, it is likely that the LAPL(A) to PPL(A) flight training requirement will be amended to include dual training for 'any parts of the PPL course which were not previously completed in the LAPL course'.

[Level Attitude]

Incidentally, it is likely that the LAPL(A) to PPL(A) flight training requirement will be amended to include dual training for 'any parts of the PPL course which were not previously completed in the LAPL course'.

I am sure this would be an improvement but why only "Dual training"?
That would still mean that a candidate who had already completed a supervised 150nm solo cross country would need to do it again.

Why "LAPL course"?
Why not "any approved course towards a Licence Issue"?
Otherwise any training covered during an NPPL course would not count and many (most?) current LAPL holders in the UK received their LAPLs based on other Licences.

[Whopity]

That would still mean that a candidate who had already completed a supervised 150nm solo cross country would need to do it again.

Yet another piece of nonsense, the 150nm X ctry is an experience requirement and experience does not expire!
Look at Article 4 Para 7

7. A Member State may authorise a student pilot to exercise limited privileges without supervision before he/she meets all the requirements necessary for the issuance of an LAPL under the following conditions:
(a) the privileges shall be limited to its national territory or a part of it;
(b) the privileges shall be restricted to a limited geographical area and to single-engine piston aeroplanes with a maximum take-off mass not exceeding 2 000 kg, and shall not include the carriage of passengers;
(c) those authorisations shall be issued on the basis of an individual safety risk assessment carried out by an instructor following a concept safety risk assessment carried out by the Member State;
(d) the Member State shall submit periodical reports to the Commission and the Agency every 3 years.

This allows those countries (France) that think fit, to allow "students" to gain experience towards a LAPL without "supervision". That experience including a (150 nm X ctry) may be carried forward to a PPL!

[Level Attitude]

Yet another piece of nonsense, the 150nm X ctry is an experience requirement and experience does not expire!

Sorry Whopity, that is not correct. The requirement for LAPL and PPL is for the 80nm/150nm Cross Country to have been completed as "Supervised Solo" as part of a Training Course.

The 300nm for CPL is an Experience requirement for a Modular Course but is part of the required "Training" for an Integrated Course (though doesn't specify supervised solo ).

Of course the relevant Part-FCL sections could also be re-worded but I think that unlikely.

This allows those countries (France) that think fit, to allow "students" to gain experience towards a LAPL without "supervision". That experience including a (150 nm X ctry) may be carried forward to a PPL!

No it doesn't, for two reasons:
1) Supervised solo as part of a course is required

(b) the privileges shall be restricted to a limited geographical area

2) The limited geographical area is something like within 25km of Home Airfield and, as far as I am aware, does not permit landing at a different airfield.

[Whopity]

The requirement for LAPL and PPL is for the 80nm/150nm Cross Country to have been completed as "Supervised Solo"

That is because the avereage student does not have a licenace and this is the only way it can be legally completed However; there are people, (military pilots etc ) who have met the requirement in a perfectly legal way and not under the supervision of an FI. There is no safety case to make them repeat it just to satisfy some bureauocrat. Certainly the UK did not follow that stance prior to interference from Europe.

I stand corrected re the distance limit on a Brevet de Basse however; that does not mean a cross country flown legally as the holder of a LAPL would not be counted towards the PPL requirements.

How does a FI supervise a licence holder who is responsible in law for all their actions on a flight when they are acting as PIC? The can only oversee it.

[Level Attitude]

There is no safety case to make them repeat it just to satisfy some bureauocrat. Certainly the UK did not follow that stance prior to interference from Europe.

The requirement is unambiguous:

FCL.210.A PPL(A) — Experience requirements and crediting
(a) Applicants for a PPL(A) shall have completed ....

(2) 10 hours of supervised solo flight time, including at least 5 hours of solo cross-country flight time with at least 1 cross-country flight of at least 270 km (150 NM)....

No "ifs", no "buts", no exceptions and no alternative means of complying (unless someone knows differently?)

This is exactly how the UK CAA interpret Part-FCL. There was a Thread several months ago where an NPPL Holder who had completed a 150nm solo flight as part of his NPPL instructional course was still required to repeat it in order to upgrade to an EASA PPL.