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Old 18th November 2007 | 18:19
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Whopity
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Joined: Oct 2004
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From: UK
If you hold a FRTOL then you can log it as Radio Operator (FRO) in accordance with Article 35. If for some reason you didn't maintain your PPL and wanted to renew the FRTOL you would be asked for evidence of use of this licence which according to the ANO Schedule 8 is a Flight Crew Licence.
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