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Old 3rd Jul 2019, 12:57
  #17 (permalink)  
212man
 
Join Date: Oct 1999
Location: Den Haag
Age: 57
Posts: 6,251
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Originally Posted by rotarywise
No, it doesn't, and never has. The requirement of FCL.740 is that, prior to the proficiency check to renew the rating, the pilot must "take refresher training at an ATO, where necessary to reach the level of proficiency to safely operate the relevant class or type of aircraft". (my emphasis). The associated AMC states that, "The amount of refresher training needed should be determined on a case-by-case basis by the ATO". The widely discredited tables implying that a specific amount of training was required according to the time since the rating expired have been removed from the AMC and replaced by a list of factors that the ATO should take into account when determining if and how much refresher training will be required.

For the removal of doubt: The decision as to whether and how much refresher training is required prior to taking the proficiency check for the renewal of an expired type rating is entirely that of the ATO. (or DTO in the case of single-engine helicopters certified with 5 seats or less).
With respect, you can't really say that "it never has". The wording has indeed changed, I now see on further research, but it previously contradicted itself by listing the items to take into consideration on a "case-by-case basis" and then tabling specific requirements (that you refer to):

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
That part was latched onto by the UK CAA, when Part FCL came into force, and was what I battled with in the case of the S92 pilot I mention earlier. I tried to make the case that we would conduct 25 hours of operator conversion training and then conduct an OPC/LPC (as was) using a TRE that would be having his Examiner approval and TRI rating revalidated by a CAA FOTI in the simulator. But, that wasn't good enough and we had to send him back to FSI in WPB, having waited with him idle for 5 months due to the demand in S92 training courses resulting from the first EC225 grounding!

Anyway, good to see that common sense seems to be prevailing now and thanks for the update - I haven't looked at Part FCL for two or three years.
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