EASA Type Rating Touch and Goes

[svinhas198]

Hello All,

I hold an EASA CPL(A) issued by the Portuguese CAA. I've completed recently a Type Rating for a jet aircraft (my 3rd TR) and I intend to do the touch and go's with an EASA TRI. The problem is my local CAA says, as the Touch and goes will be performed in a non-EASA registration Aircraft (Registration VP) my qualification will be resctricted to FL200 or above only operations. I can't find any information on the PART-FCL or any other document stating this restriction applies in this case.

Is this legal? Is anyone out there with the same issued or limitation because of the registration of the aircraft used for touch and goes?

Thank you everyone for your help

[PigeonVoyageur]

Hi Sergio,

I suppose that you meet the requirements as specified in PART-FCL Part-H Subpart 1 Part-FCL requirement 720.A (d) for multi-pilot aeroplane.

If you meet the requirements, then PART-FCL Part-H Subpart 1 FCL.725 states this:

FCL.725 Requirements for the issue of class and type ratings
(a) Training course. An applicant for a class or type rating shall complete a training course at an ATO. The type rating training course shall include the mandatory training elements for the relevant type as defined in the operational suitability data established in accordance with Part-21.

Part-21 concerns the "Certification of aircraft and related products.....".


I suppose that if you are not doing your type rating according to the above (hence an aircraft not certified under EASA Part-21), you might be issued with a restricted type rating as specified in PART-FCL Part-H Subpart 1 Part-FCL requirement 720.A:

"(e) Notwithstanding paragraph (d), a Member State may issue a type rating with restricted privileges for multi pilot aeroplane that allows the holder of such rating to act as a cruise relief co-pilot above Flight Level 200, provided that two other members of the crew have a type rating in accordance with paragraph (d)".

That's my opinion.

Now, there is a difference between the word "registration" and "certification". The Part-21 mentions "certification" not "registration" - a bit of gray area as far as I'm concerned. Secondly, PART-FCL mentions explicitly ".. complete a training course at an ATO" meaning an approved training organisation. Do you consider what you will be doing as part of an approved training organisation?