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Old 9th Mar 2018, 08:28
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PeteMonty
 
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So... dragging up an old thread here to try and get it up to the current regulation changes. And just so folks know where I'm coming from here, I'm an instructor trying to advise LAPL holders as opposed to a LAPL holder myself.

Since this thread last saw the light of day NPA 2014-29 has been amended to revision (B). I get tired of read through these EASA legal documents so have given up reading both the (A) revision mentioned above and the current (B) revision to see what has been changed so lets just focus on what the (B) revision states. Oh and this is still only a PROPOSED amendment so still nowhere near implementation before anyone gets excited into thinking we are almost at having a sensible clarification of the rules!

The issue is that it would seem it is this ability to count 3 axis microlight time for recency that they have back-pedaled on as in another forum someone has stated this from EASA:
"After consultation with the EASA experts, the decision taken was to remove the text amendment in FCL.035(a)(2) proposed with NPA 2014-29 because with this amendment the requirements of the Basic Regulation would have been altered. If deemed necessary this should be done in the Basic Regulation itself rather than in its implementing rules. EASA has prepared an AMC and proposed it with NPA 2014-29(B) and this AMC will be published after the adoption of the amendments to the Aircrew Regulation as GM."

However when I read that bit in revision (A) I'm not sure I took that to say you count Microlight hours anyway!

In amendment (B) it now states the following:
A new AMC is added after GM1 FCL.135.A;FCL.135.H: ‘AMC1 FCL.140.A Recency requirements; FCL.740.A(b)(1)(ii) Revalidation of class and type ratings — aeroplanes All hours flown on any aircraft registered in an ICAO Contracting State shall count in full towards fulfilling the hourly requirements of this Part as long as the aircraft matches the definition and criteria of the respective Part-FCL aircraft category as well as its class and type ratings.'

Soooo... it states "Part-FCL aircraft category" but I have been through Part FCL and it uses the phrase "aircraft category" a LOT but nowhere in part FCL does it state what the part-FCL aircraft categories are! There are lots of other documents that state aircraft categories but this line clearly states PART-FCL. Does anyone care to pin their colours to the mast and state what they see as these 'categories' and therefore whether a 3 axis microlight would count as/when/IF this NPA ever gets adopted?

To save you hunting revision (B) is available here: https://www.easa.europa.eu/document-.../npa-2014-29-b

The fact that they allow TMG hours which are potentially more 'different' to SEP than one of these modern fast microlights just seems stupid to not allow microlight time to count.

Slightly off topic but still related - the LAPL recency requirement is to have logged 12hrs as PIC in the preceding 12 months. It then states that if they don't have said time they can, and I quote:
perform the additional flight time or take-offs and landings, flying dual or solo under the supervision of an instructor, in order to fulfil the requirements in (a).

But (and this has been done to death elsewhere on this forum) when flying with an instructor in the aeroplane the 'student' can't log it as PIC as the instructor is PIC and there is no such thing as 'dual' other than for multi-crew aircraft and then in this one little phrase in this regulation! SO while all the rest of the regulation says when you cannot command the aeroplane as PIC (IE with a lapsed rating/recency out of validity) you cannot log it as PIC, yet this bit states you must log it as PIC to get the recency back! Solo supervised the 'student' is PIC but dual?! Or am i missing something here? When you do fly with said instructor on-board - what does the instructor log if the 'student' logs PIC? You cannot both log PIC and yet the instructor is there acting in an official capacity as crew on that flight...!?
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