FCL.060 Recent experience
(b) Aeroplanes, helicopters, powered-lift, airships and sailplanes. A pilot shall not operate an aircraft in commercial air transport or carrying passengers:
- (1) as PIC or co-pilot unless he/she has carried out, in the preceding 90 days, at least 3 take-offs, approaches and landings in an aircraft of the same type or class or an FFS representing that type or class.
Just to "
Put the cat amongst the pigeons"
:
EASA do not define what they mean by "carried out" (no mention of "Pilot Flying" and certainly not a whisper of "as sole manipulator of the controls") therefore this terminology is open to interpretation.
A pilot monitoring an Autopilot approach, all the way down to Autoland - Have they not carried out their
required function for this phase of flight - and hence "carried out" an approach and landing?
Pilots required to monitor other pilots during flight (Instructor with Student, Pilot Monitoring in multicrew operations) - During Approaches and Landing, are they not carrying out their
required function - and hence "carrying out" an Approach and Landing?
Isn't anyone who insists Recency only counts if the pilot was physically handling the aircraft guilty of using their own individual interpretation and thereby 'Gold Plating' the Regulations?
It may be that
FCL.060 Recent experience was not originally written in English and some specificity was lost in translation.
My main point being that EASA continuously prove themselves incapable of writing unambiguous, easily understood rules and spend years thinking about re-drafts while expecting the aviation community to manage in the interim.