In the last day or two, we have hard evidence that other authorities are, subject to approval on presentation of paperwork from their current employer, PPC forms etc., allowing JAR pilots affected by this ruling to renew their licences and IR's. This is a clear case of discrimination under EU law, and we will be sending this information to the CAA within a week. BALPA agree with this point of view.
BALPA are helping us, so may I suggest for £24 per year you become associate members, it's only fair given their help in this matter.
As you all know, when you correspond with the authority they ALWAYS refer you to LASORS, so, regarding the ICAO caveat in LASORS, there was absolutely no reference to the ANO or any JAR-FCL references in this regard, therefore it could be argued in court that a normal pilot would have no inclination or idea that the caveat was there in error.
Last edited by Fart Master; 15th Aug 2012 at 10:45.
Well, the 17th September 2012 came and went without much fanfare because it was, ladies and gentlemen, a landmark day in a further erosion of the way things used to be. Today was the day that the UK CAA opted out of LASORS and adopted CAP 804.
From today (in a very subtle manner) we're all a little more European (than British).
But it's serious; if you're working in the sandpit or elsewhere and have been keeping your cherished UK/ JAA/ EASA licence current there are, as of today, far more onerous requirements to keep that licence warm. If your LPC expires by more than 15 months (12 months, plus 3 grace) you can't just hop in a simulator and do the check; you're going to need additional training. Even if you are flying the type on a foreign licence. It progresses in stages but after 3 years now you are (under EASA) obliged to do a full type-rating to get your licence current again. Regardless of the fact that you're flying on a regular basis somewhere else in the world. And without a type-rating you can't do a PC and without a PC ...... your licence will lapse.
It gets worse chaps. It looks as if it is now 6 years under EASA, from another thread:
Under JAA rules:
To renew an IR(A) that has EXPIRED BY MORE THAN 7 YEARS, applicants must: For single-pilot aircraft pass an IR(A) skill test in an aeroplane with a UK CAA Staff Flight Examiner. Applicants will also be required to retake the IR(A) theoretical knowledge examinations.
So you got 7 years from the expiry date to renew it without losing your ATPL exam credits.
Under EASA rules:
If the IR(A) has not been revalidated or renewed within the preceding 7 years, the holder will be required to pass again the IR theoretical knowledge examination and skill test.
So you get 7 years from the test date to renew it without losing your ATPL ground credits.
I tried to argue this with Adam Whitehead recently but he confirmed that you only get 6 years from the expiry date.
Not sure if this is new news or not. It sure made my eyes open when I heard. The 5 year rule regarding I/R is, quite rightly imho, being challenged by various members on PPRuNe and I wish you the very best with your rightous fight against bureacracy.
However, I have recently returned to SE Asia from a sim ride in EASA land which I thought I had booked for an I/R (might as well do an LPC anyway) as it was just over 4 years since my last I/R & LPC on my JAA licence. I am current on the same type on a non EASA but ICAO licence.
The sim was booked for early evening and in the afternoon I got a call from the examiner asking if I was aware of the new 3 year rule? I wasn't and he had only learned of it that morning. Bottom line is if your JAA/EASA LPC has expired by more than 3 years then you have to do the full type rating course again. If it has expired by a lesser amount then the training requirement gradually increases with the length of expiry. I'm afraid I can't quote you the reference but I did check directly with CAA who confirmed all the details. It came into effect 17/9/12 with EASA but was, apparently, only published some 6 weeks or so before that.
I guess that means there are now another bunch of guys who thought they were ok to wait just over 4 years before doing a JAA-EASA I/R and now find themselves staring at a type rating course if they wish to regain currency in EASA land.
Part H - Class and Type Ratings / Subpart 1 - EASA - Class and Type Ratings for Aeroplanes / FCL.740 - Validity & renewal of class and type ratings:
(b) Renewal. If a class or type rating has expired, the applicant shall:
(1) take refresher training at an ATO, when necessary to reach the level of proficiency necessary to safely operate the relevant class or type of aeroplane; and
(2) pass a proficiency check in accordance with Appendix 9 to Part-FCL.
Surely the relevant & guiding statement in the above item (1) is the 'when necessary' ?
Would it not be the case that if wishing to revalidate / re-activate ones (expired 4 years ago) UK CAA / JAR B737 Type Rating (on the NG), it being a Type which one is currently flying here in the UAE, if one were to pitch-up at a UK TRTO and ask them to conduct a PC (IR, whatever?), in that instance one would expect the requirement for 'refresher training at an ATO, when necessary' to be a "not required" - what with already being extremely current on the exact same type - or did I miss something somewhere in amongst all those new regs ?!
Also, where in the EASA stuff is the precise amount of required 'refresher training' stipulated (regulated), and / or is that perhaps up to an 'arrangement' between the candidate pilot and the specific TRTO ?
I can certainly predict various TRTO's trying to up-the-ante by saying that one needs all manner of 'training', simply as a means to make more money out folk whom are trying to get (return) into the EASA system.
Ps (hence the edit). Fwiw, I was planning to nip back to the UK in the next few months and revalidate my B757/B767 Type Rating (and latterly exchange my JAR license to an EASA one), wherein my last sim on the B767 was in Apr 2008. I was planning to do a (hopefully ) modest number of 'refresher training' sims prior to actually doing the PC/IR ('coz quite frankly, after so many years off of it, I can barely remember how to start the bloomin' thing ).
Last edited by Old King Coal; 1st Oct 2012 at 14:02.
I read, am afraid can't provide a reference at the moment, that LPC an is good for 12 months, you get 3 months 'grace' to renew without penalty. After that and before 3 years you need 'additional' training. I can't define 'additional' in this context. After 3 years as stated complete type rating, and 7 (6) years do the exams. I suspect there will be a new lease of life for the Seneca's dotted around the UK as I think the cheapest way will be a MEP class rating and IR to avoid re-sitting the exams and a ride with CAAFU.
AMC1 FCL.625(c) IR — Validity, revalidation and renewal
RENEWAL OF INSTRUMENT RATING: REFRESHER TRAINING
(a) Paragraph (b)(1) of FCL.740 determines that if the instrument rating has lapsed, the applicant shall go through refresher training at an ATO, to reach the level of proficiency needed to pass the instrument element of the skill test prescribed in Appendix 9 to Part-FCL. The amount of refresher training needed should be determined on a case-by-case basis by the ATO, taking into account the following factors:
(1) the experience of the applicant. To determine this, the ATO should evaluate the pilot’s log book, and, if necessary, conduct a test in an FSTD.
(2) the amount of time lapsed since the expiry of the validity period of the rating. The amount of training needed to reach the desired level of proficiency should increase with the time lapsed. In some cases, after evaluating the pilot, and when the time lapsed is very limited (less than 3 months), the ATO may even determine that no further refresher training is necessary. The following may be taken as guidance when determining the needs of the applicant:
(i) expiry for a period shorter than 3 months: no supplementary requirements;
(ii) expiry for longer than 3 months but shorter than 1 year: a minimum of one training session;
(iii) expiry for longer than 1 year but shorter than 7 years: a minimum of three training sessions;
(iv) expiry for longer than 7 years: the applicant should undergo the full training course for the issue of the IR.
(b) Once the ATO has determined the needs of the applicant, it should develop an individual training programme, which should be based on the initial training for the issue of instrument ratings and focus on the aspects where the applicant has shown the greatest needs.
(c) After successful completion of the training, the ATO should give a certificate to the applicant, to be submitted to the competent authority when applying for the renewal.
SUBPART H — CLASS AND TYPE RATINGS
AMC1 FCL.740(b)(1) Validity and renewal of class and type ratings
RENEWAL OF CLASS AND TYPE RATINGS: REFRESHER TRAINING
(a) Paragraph (b)(1) of FCL.740 determines that if a class or type rating has lapsed, the applicant shall take refresher training at an ATO. The objective of the training is to reach the level of proficiency necessary to safely operate the relevant type or class of aircraft. The amount of refresher training needed should be determined on a case-by-case basis by the ATO, taking into account the following factors:
(1) the experience of the applicant. To determine this, the ATO should evaluate the pilot’s log book, and, if necessary, conduct a test in an FSTD;
(2) the complexity of the aircraft;
(3) the amount of time lapsed since the expiry of the validity period of the rating. The amount of training needed to reach the desired level of proficiency should increase with the time lapsed. In some cases, after evaluating the pilot, and when the time lapsed is very limited (less than 3 months), the ATO may even determine that no further refresher training is necessary. When determining the needs of the pilot, the following items can be taken into consideration:
(i) expiry shorter than 3 months: no supplementary requirements;
(ii) expiry longer than 3 months but shorter than 1 year: a minimum of two training sessions;
(iii) expiry longer than 1 year but shorter than 3 years: a minimum of three training sessions in which the most important malfunctions in the available systems are covered;
(iv) expiry longer than 3 years: the applicant should again undergo the training required for the initial issue of the rating or, in case of helicopter, the training required for the ‘additional type issue’, according to other valid ratings held.
(b) Once the ATO has determined the needs of the applicant, it should develop an individual training programme that should be based on the initial training for the issue of the rating and focus on the aspects where the applicant has shown the greatest needs.
(c) After successful completion of the training, the ATO should give a certificate, or other documental evidence that the training has been successfully achieved to the applicant, to be submitted to the competent authority when applying for the renewal. The certificate or documental evidence needs to contain a description of the training programme.
I would bring to peoples attention to the use in the above regulations of the phrase 'should' (which certainly does not have the same meaning as 'must' ) and also lots of mention of the terms 'guidance', 'case-by-case basis', 'taking into account', 'taken into consideration', 'needs of the applicant', 'individual training program', etc...
To paraphrase a certain Captain Barbossa, the above regulations seem "more what you'd call guidelines than actual rules" !
Last edited by Old King Coal; 1st Oct 2012 at 11:10.
Reason: Additional detail wrt IR and TypeRating renewal
So, after being in a company for about 3 years on whatever type, any other ratings you may have are lost entirely and you can never fly one of those aircraft again? Is that really correct? (unless you or the company hiring you pay for the full hugely expensive type rating course...unlikely)
If this is the case, that will have a significant effect on the movement of pilots in the industry, since you will effectively only be able to apply for jobs on your current type, not on any previous type..
Wow that's a lot worse than the actual 7 year rule now ... at least the ATPLs only take time and a few hundred quid, the complete rating renewal must be 20 grand
On the bright side, it will mean that the current massive crop of lemmings who leave flight school and buy 737 / A320 ratings will be completely scuppered as they'll now be up for two more recurrent sims (a few grand worth of recurrent training) if they haven't got a job within 3 months
Out in QR and facing the P2 hurdle in addition to the previous 7 year stuff. There are other threads here on PPRuNe which relate to the conversion of ICAO to part-FCL licences and they don't give much cause for thinking there will be a speedy resolution to this. The gist of the rules are that if you wish to convert an ICAO licence you have to sit all the exams for the equivalent part-FCL licence.
We already hold JAR licences (in the main) but you can see the lack of consideration of how to deal with qualifications gained abroad.
I currently fly a big Boeing but have lapsed by less than 3 years on a little one. So I'm currently working out which is less expensive, renew the little Boeing or get back into flying MEP and renew my IR that way. Neither option will be cheap
These rules are clearly meant for pilots who stop flying and let their licenses expire. Not for those who keep working in other parts of the world. My "own" CAA have never enforced these rules, all I had to do was show them my ME license and the IR/PC/OPC documentation, and my JAR license would be renewed. I fell sorry for you UK guys, UK CAA are reading these rules like the devil is reading Al Quran! The new EASA license will not have an expiry date, how will this affect you?
Last edited by ManaAdaSystem; 2nd Oct 2012 at 09:58.
Well that depends on how your home CAA interprets the EASA rules. As far as the UK CAA were concerned they could interpret away as much as they wanted with JAR but now it's EU law they can't touch it at all. They'll just blindly administer and probably gild the lily too by applying the most adverse interpretation of the law as written. That's what happens with a lot of EU law and regulation in UK.
Looks like an enormous coo for the Training Organizations & CAA to make stacks of filthy lucre. Fight this one really hard or trump up the cash & time. Absolute disgrace when compared to other professions. Doctors, Lawyers, Accounts execs do not have to renew basic skill qualifications when returning to the UK from long stints abroad. And three years is just inane.
However, Regulation is Regulation & Standards are Standards. We have rarely been able to exchange one licence for another. an ICAO licence was good because most Regulators acknowledged the standard and issued validations or issued a member country licence. The old UK CAA ATPL was long considered (by the UKCAA) to be the most outstanding & sought after licence. Of course the US FAA laughed out loud if we presented the UK version in exchange for a FAA ATR. So, in good diplomatic tradition, we laughed at them if they tried to reciprocate.
Once you have the Uk licence, I appreciate the current discussion is about renewing it after a period of not exercising it's own, unique, privilages. This is where the Regulators really take a long hard look at what you have been doing. In the past, it was sufficient to show that you were in regular practice , on type, with an ICAO operator. Just five years ago, I approached the UK CAA asking to renew my 10 year UK ATPL. For type inclusion, I needed to show what I had been doing with type checks etc. All previous types were shown in Part 1 but for a "valid" type rating, I was required to do a prof check with a UK CAA approved Type examiner.
We have developed through the JAA validation & now the EASA debacle. I submit that the Regulatory Authorities are looking too hard at the renewal process & rubbing their hands with glee at the thought of vastly enhanced fee revenue.
I'm almost lost for words. Just when you think the UK CAA and EASA can't screw it all up even more, they do. It really does seem like they're out to get us.
This has nothing to do with flight safety, that much is certain.
What are you supposed to do with your previous type ratings - do three sim sessions and an expensive and pointless check ride every three years on each plane you don't currently operate, in case you need the rating for a future job?? To be honest, if anything, that is bad for safety, as you're then getting negative training for the aircraft type you do currently operate..
The bottom line seems to be this - Unless you work for an airline at home which you can reasonably expect to stay with for your whole career, this profession will get too expensive and too much of a ball ache to be involved with in Europe.
FlyingCroc your 'old JAR licence' is now actually an EASA licence. When it expires and you renew you will get the actual EASA licence. I believe that regardless of the currency of your licence e.g. 3 or 7 year qualifiers the licence is good. However without a current Class or Type rating you can't actually use it and without a current IR you won't be able to fly IFR.
Looks like a single engine piston rating would be the cheapest to maintain as it remains current for 2 years as oppose to 1 year on the Multi Engine piston. An IR on the SEP every 6 years should prevent the need for a retake of the IR exams, until they change the rules again of course. Anyone know if there's any rules that prevent maintaining an EASA ATPL with an SEP/IR or does it have to be MEP or Multi-crew ?
Last edited by Stall Inducer; 3rd Oct 2012 at 07:39.