Information Notice 2016/049
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Information Notice 2016/049
Hi
Just reading IN-2016/049, para 2.1 test/checks, i see the FI course pre-entry proficiency check is included under the scope of the IN. Reading notes 1 & 3 do i read it correctly that this has to be done in a simulator, or an application for exemption from Appendix 9 requirements be submitted?
What is going on, or am i reading this wrong?
Just reading IN-2016/049, para 2.1 test/checks, i see the FI course pre-entry proficiency check is included under the scope of the IN. Reading notes 1 & 3 do i read it correctly that this has to be done in a simulator, or an application for exemption from Appendix 9 requirements be submitted?
What is going on, or am i reading this wrong?
No, you are reading it right. This stupidity started with IN-2012/155 which, in turn, was based on a misinterpretation of the statement in Appendix 9 of Part-FCL.
A discussion with a member of the FCL.001 working group, which originally drafted Part-FCL, confirmed that it was never the group's intention to make the use of FSTDs mandatory across the board. Unfortunately, the error is now established in law and we are stuck with it - even worse, EASA are now proposing (in NPA 2014-29) a definition of 'available' that will override the UK CAA's convoluted attempts to circumvent its own stupidity. If the proposal is adopted, the use of a FSS or OTD for skill tests and proficiency checks will be mandatory if one exists anywhere in the EU that is 'certified' and 'obtainable for lease or hire'.
Perhaps one answer would be for examiners to comply strictly with the IN and deluge the CAA with notifications each and every time that they intend to use an aircraft for a skill test or proficiency check (including the FI course pre-entry PC) in an SEP or MEP aeroplane since no FFS or OTD exists or is ever likely to exist for these classes. (Bear in mind that an OTD is defined as a training device other than an FFS, FTD or FNPT).
A discussion with a member of the FCL.001 working group, which originally drafted Part-FCL, confirmed that it was never the group's intention to make the use of FSTDs mandatory across the board. Unfortunately, the error is now established in law and we are stuck with it - even worse, EASA are now proposing (in NPA 2014-29) a definition of 'available' that will override the UK CAA's convoluted attempts to circumvent its own stupidity. If the proposal is adopted, the use of a FSS or OTD for skill tests and proficiency checks will be mandatory if one exists anywhere in the EU that is 'certified' and 'obtainable for lease or hire'.
Perhaps one answer would be for examiners to comply strictly with the IN and deluge the CAA with notifications each and every time that they intend to use an aircraft for a skill test or proficiency check (including the FI course pre-entry PC) in an SEP or MEP aeroplane since no FFS or OTD exists or is ever likely to exist for these classes. (Bear in mind that an OTD is defined as a training device other than an FFS, FTD or FNPT).
According to the IN, one of the criteria for the simulator / OTD to be 'available ' is that it:
So if your licence only includes an aeroplane class rating, not a type, then no problemo......
c) replicates an aircraft type contained within the candidate’s licence endorsement.
So if your licence only includes an aeroplane class rating, not a type, then no problemo....
It might also be said that a candidate's class rating endorsement 'contains' every type within the class and para c) refers to any one of them. Notice that it does not refer to a type rating
The fact is that the IN is badly written and symptomatic of the ever decreasing standards in evidence at Aviation House as a result of utterly inept management.
