Sorry, it's another JAR>EASA revalidation question...
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Sorry, it's another JAR>EASA revalidation question...
Currently I hold a JAR PPL (expires 2016) with SEP and IMC ratings. SEP expires 13 Aug, IMC expires 15 Aug. I had hoped to revalidate both by taking the IMCR test but for aircraft serviceability reasons this looks unlikely by 15th, though not impossible. As I write I qualify for revalidation of the SEP by experience and I was going to take my logbook and licence to a friendly examiner this afternoon for a signature and complete form SRG1119B. I wasn't going to worry about the IMCR as if it lapses I can just retake the test anyway.
What I can't work out is:
a. Can I revalidate the SEP rating by experience without applying for a licence reissue as EASA? Difference web pages on the CAA site contradict each other.
b. If not, what happens with the IMCR? If it's not valid when they process the paperwork will I lose it?
c. How do I apply for the IMCR to be transferred to IR(R)? The application form for reissue as EASA doesn't include any mention of IMCR though of course the IR is mentioned. Do I simply state I have an IR? [after all as my licence is 'deemed' EASA presumably I already do!]
If the answer to a. is no, and b. is yes, then I need to get the IMCR revalidated urgently so it doesn't lapse and might need to go to another club to do so, hence the urgency!
What I can't work out is:
a. Can I revalidate the SEP rating by experience without applying for a licence reissue as EASA? Difference web pages on the CAA site contradict each other.
b. If not, what happens with the IMCR? If it's not valid when they process the paperwork will I lose it?
c. How do I apply for the IMCR to be transferred to IR(R)? The application form for reissue as EASA doesn't include any mention of IMCR though of course the IR is mentioned. Do I simply state I have an IR? [after all as my licence is 'deemed' EASA presumably I already do!]
If the answer to a. is no, and b. is yes, then I need to get the IMCR revalidated urgently so it doesn't lapse and might need to go to another club to do so, hence the urgency!
Last edited by tmmorris; 27th Jul 2015 at 09:31. Reason: Too rambling
Don't be sorry! 
We all struggle to keep track of this.
Yes. SRG 1119E is the form you need for that. 1119B is the form you use if you are sending your logbook and Licence to the CAA for Revalidation, rather than having a Field Examiner do it.
If you apply for re-issue in EASA format with an expired IMC, you will loose it, but it will be put on the back of the new Licence to show that you once had it. It can still be Renewed in the normal way by a Test, but you then have to apply to the CAA to make it valid again, (with a fee, of course) and have it transferred onto the front of the Licence.
EASA recognise the IMCR as an IR(R) (Instrument Rating Restricted) and that is why there is no mention of IMC on the form. Just claim a valid IR(R) and they will add it to your EASA licence.
MJ
Ps.
Maybe I misunderstood what you typed there, but the IMCR Test doesn't count as an SEP Revalidation Proficiency check.
MJ
We all struggle to keep track of this.
a. Can I revalidate the SEP rating by experience without applying for a licence reissue as EASA? Difference web pages on the CAA site contradict each other.
b. If not, what happens with the IMCR? If it's not valid when they process the paperwork will I lose it?
c. How do I apply for the IMCR to be transferred to IR(R)? The application form for reissue as EASA doesn't include any mention of IMCR though of course the IR is mentioned. Do I simply state I have an IR? [after all as my licence is 'deemed' EASA presumably I already do!]
MJ
Ps.
I had hoped to revalidate both by taking the IMCR test...
MJ
Last edited by Mach Jump; 27th Jul 2015 at 11:11. Reason: Resolved slight ambiguity
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Thanks, very helpful. The plan was to use the IMCR test as the flight with an instructor, which is what I've done before. Instead, I did a type conversion onto the club's new Firefly (which was useful, as I'd got very lazy about practising PFLs and was rightly brought up short by the instructor who made me do several).
So I will do the revalidation of the SEP using SRG1119E, and arrange the IMCR test when the aircraft have been fixed (annoyingly the club's two nicely instrumented aircraft are both u/s at the same time though A and C is working on both...)
Just to check - I am right that letting the IMCR lapse only means I can't use the IMCR privileges until I've taken the test? (Assuming the lapse is only a week or two.) No retraining required?
So I will do the revalidation of the SEP using SRG1119E, and arrange the IMCR test when the aircraft have been fixed (annoyingly the club's two nicely instrumented aircraft are both u/s at the same time though A and C is working on both...)
Just to check - I am right that letting the IMCR lapse only means I can't use the IMCR privileges until I've taken the test? (Assuming the lapse is only a week or two.) No retraining required?
Just to check - I am right that letting the IMCR lapse only means I can't use the IMCR privileges until I've taken the test? (Assuming the lapse is only a week or two.) No retraining required?
Instead, I did a type conversion onto the club's new Firefly
MJ
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Under JAA there was never any requirement to sign the entry, it was just something the CAA invented in their efforts to 'gold plate' the 'training flight of at least 1 hour' into a Test.
Under EASA, all training flights have to be countersigned by the Instructor, whatever their purpose, or they don't count.
MJ
Ps. I can't, for the moment, remember where this is stated, but I'll try to find it and come back with the reference, unless someone beats me to it!
MJ
Under EASA, all training flights have to be countersigned by the Instructor, whatever their purpose, or they don't count.
MJ
Ps. I can't, for the moment, remember where this is stated, but I'll try to find it and come back with the reference, unless someone beats me to it!
MJ
Last edited by Mach Jump; 27th Jul 2015 at 16:25. Reason: Added Ps.
do you have chapter & verse for the regulation that requires an Instructor to countersign the entry you intend to use for Reval by Experience?
(4) instruction time: a summary of all time logged by an applicant for a licence or rating as flight instruction, instrument flight instruction, instrument ground time, etc., may be logged if certified by the appropriately rated or authorised instructor from whom it was received;
DaveW:
As I recall, the AMC quoted by Whopity was introduced to allow a relaxation of the requirement to sign every entry, in circumstances where a course of training was being undertaken, in which case, a series of flights with a particular instructor could be signed for as a summary.
I haven't yet been able to find the original requirement to sign every entry. I'll let you know when I do.
MJ
As I recall, the AMC quoted by Whopity was introduced to allow a relaxation of the requirement to sign every entry, in circumstances where a course of training was being undertaken, in which case, a series of flights with a particular instructor could be signed for as a summary.
I haven't yet been able to find the original requirement to sign every entry. I'll let you know when I do.
MJ
AMC1 FCL.050(i)(10)
"column 12: the 'remarks' column may be used to record details of the flight at the holder's discretion. The following entries, however, should always be made:
(iv) signature of instructor if flight is part of an SEP or TMG class rating revalidation"
"column 12: the 'remarks' column may be used to record details of the flight at the holder's discretion. The following entries, however, should always be made:
(iv) signature of instructor if flight is part of an SEP or TMG class rating revalidation"
Yes. Thanks, BB. That answers DaveW's question about the Revalidation, but I still haven't been able to find a reference in Part.FCL, or the AMCs that supports my statement that all instruction should be signed for. So I'll continue to search for that.
On the Revalidation flight, though, as long as instruction is signed for, you can then pick any hour of instruction that falls within the prescribed period to use for revalidation. It doesn't have to be nominated as such at the time of the flight.
MJ
On the Revalidation flight, though, as long as instruction is signed for, you can then pick any hour of instruction that falls within the prescribed period to use for revalidation. It doesn't have to be nominated as such at the time of the flight.
MJ
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There needs to be certification* if the training is for licence or rating, that's clear - and if summarised in the logbook, then AMC1 FCL.050 says the logbook needs to be certified accordingly.
But if it's NOT training for a licence or rating, as many instructional flights will be, then my question stands: Must the logbook be signed?
*But not necessarily in the logbook itself - that's what (e.g.) the Head of Training declaration on the relevant SRG forms when applying for licence/rating does.
Let's not confuse the issue with HoT Certification. 
This wording only makes sense as an alleviation of an overall requirement for Instructors to sign for each flight.
I'm convinced that I have read that requirement, but, so far, I can't find it.
I wouldn't put it past EASA to have amended Part.FCL to delete that bit, and forgot to delete the modifying bit of the AMC!
I'll spend some time tomorrow looking for the relevant reference.
MJ
AMC1 FCL.050 instruction time:
Quote:
(4) instruction time: a summary of all time logged by an applicant for a licence or rating as flight instruction, instrument flight instruction, instrument ground time, etc., may be logged if certified by the appropriately rated or authorised instructor from whom it was received;
Quote:
(4) instruction time: a summary of all time logged by an applicant for a licence or rating as flight instruction, instrument flight instruction, instrument ground time, etc., may be logged if certified by the appropriately rated or authorised instructor from whom it was received;
I'm convinced that I have read that requirement, but, so far, I can't find it.
I wouldn't put it past EASA to have amended Part.FCL to delete that bit, and forgot to delete the modifying bit of the AMC!
I'll spend some time tomorrow looking for the relevant reference.
MJ
I see it's "should" not "must", which allows for later nomination of a PUT flight as the revalidation hour.
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I'm clearly missing something, as I don't understand that, BB.
The existing AMC recommends but doesn't demand a logbook signature (i.e. it says "should" not "must").
Why would there need to be an additional AMC statement to deal with the situation where the current AMC recommendation ("should") is not taken up?
The situation is surely in practice anyway covered by the Form 1119x asks for the date of the nominated Revalidation flight, which is in the logbook (along with Instructor name as P1) for the Examiner to see when signing for Reval by Exp.
(The above assumes that MJ or anyone else doesn't find an over-riding requirement for all instructional flights to be signed for every time, which it appears may not exist).
The reason this is interesting to me is that in the last year or so I have trained for 3 Ratings/Certificates and engaged with 3 different training organisations. None of them have had their instructors sign every logbook entry.
(Edit: Actually, it is 4 training organisations, as the lack of logbook signatures hasn't been queried by the examiner who signed my Cert of Reval.)
The existing AMC recommends but doesn't demand a logbook signature (i.e. it says "should" not "must").
Why would there need to be an additional AMC statement to deal with the situation where the current AMC recommendation ("should") is not taken up?
The situation is surely in practice anyway covered by the Form 1119x asks for the date of the nominated Revalidation flight, which is in the logbook (along with Instructor name as P1) for the Examiner to see when signing for Reval by Exp.
(The above assumes that MJ or anyone else doesn't find an over-riding requirement for all instructional flights to be signed for every time, which it appears may not exist).
The reason this is interesting to me is that in the last year or so I have trained for 3 Ratings/Certificates and engaged with 3 different training organisations. None of them have had their instructors sign every logbook entry.
(Edit: Actually, it is 4 training organisations, as the lack of logbook signatures hasn't been queried by the examiner who signed my Cert of Reval.)
EU legislation is split into 'hard' law (the regulations) and 'soft' law (the AMCs). Where only one AMC is published, that is the only means of complying with the associated Regulation. It is open to anyone to propose to their competent authority an alternative means of compliance with the Regulation but, until this is accepted, there remains only one means of compliance.
Take, for example, the requirement for a minimum of 100 hours of theoretical knowledge instruction for the PPL that exists in AMC1 FCL.210; FCL.215. Until the UK proposed to EASA an alternative means of compliance, all ATOs had to ensure that a minimum of 100 hours TK instruction was completed prior to taking the last of the PPL examinations. There is now no minimum amount of PPL TK instruction required in the UK but 100 hours remains the minimum in the rest of Europe.
In the case of FCL.050, there is no AltMoC in the UK and so the only way to comply with the Regulation is to comply with the AMC. You can propose an AltMoC to remove the requirement that all flights used to revalidate a SEP class rating are countersigned but until then it remains 'soft' law.
Take, for example, the requirement for a minimum of 100 hours of theoretical knowledge instruction for the PPL that exists in AMC1 FCL.210; FCL.215. Until the UK proposed to EASA an alternative means of compliance, all ATOs had to ensure that a minimum of 100 hours TK instruction was completed prior to taking the last of the PPL examinations. There is now no minimum amount of PPL TK instruction required in the UK but 100 hours remains the minimum in the rest of Europe.
In the case of FCL.050, there is no AltMoC in the UK and so the only way to comply with the Regulation is to comply with the AMC. You can propose an AltMoC to remove the requirement that all flights used to revalidate a SEP class rating are countersigned but until then it remains 'soft' law.