flying Solo on expired Class rating

[selfin]

Comment #655 by: UK CAA
Page No: 46
Paragraph No: FCL.205.A (a) - see also the UK CAA comment on FCL.040, page 34

Comment: It is understood that the intent of the change is to allow the PPL(A) to be used as a LAPL(A) if the pilot’s medical standard reduces from Class 2 to LAPL. However, there is a problem in that the ratings on a PPL have expiry dates, whereas the privileges of the LAPL do not, they have a rolling validity based upon recency.

The UK CAA does not believe that these two systems can or should be mixed. Whilst it is accepted that the holder of a PPL(A) should be able to exercise the privileges of the LAPL with a LAPL medical, it is suggested that the PPL(A) holder must continue to comply with the requirements for the revalidation or renewal of the aircraft ratings in accordance with FCL.740.A(b).

The same amendment should be made to the CPL(A) and ATPL(A) (but not the MPL(A)) - and also to the PPL(H), CPL(H) and ATPL(H) as these should also be usable as LAPLs.

Justification: To avoid confusion. Type and class ratings must be revalidated and renewed according to the rules that apply to those ratings.

Proposed Text: Amend FCL.205.A (a) to read: ‘…. and exercise the privileges of the holder of a LAPL(A) provided they have a valid Class Rating in accordance with FCL.740.A(b).” In addition, the equivalent text for the CPL(A), ATPL(A), PPL(H), CPL(H) and ATPL(H) should also be amended.

EASA RESPONSE

Not accepted

Thank you for your comment. The reason behind this amendment was made is that any additional burden for competent authorities or pilots should be avoided. Furthermore, it was considered that what works for the CPL should also be possible for PPL holders. It is clear that a pilot who holds a PPL and uses it as LAPL has to comply with all requirements for the LAPL as well and there it is not important if the licence was issued physically or not.

EASA CRD 2014-29(A), comment no. 655, pp 106-107. https://www.easa.europa.eu/en/docume...s/crd-2014-29a