It was him that told us that as EASA only has domain over EASA CofA aircraft and that only time logged in EASA CofA aircraft was countable against the issue or revalidation of an EASA Class Rating. In order to gain an EASA Part FCL licence or add a Class rating the the time must be logged in an EASA CofA aircraft.
Yet absolutely no where does it say that in
licensing terms you are limited to something with an EASA C of A! Of course, to train for a licence or rating you wil be constrained by other requirements, i.e. maintenance, to use a fully certificated aircraft, though that begs the question as to where the restricted type certificate aircraft sit.
But, revalidation by
experience is not the same as training and experience means exactly that. I would like to know what Mr. Whitaker's authority for that position is. I, like you, am prepared to be educated, but I suspect that when it comes to a revalidation by experience, the NAA will be the judge as to whether logged hours amount to "experience" for the purpose of Part FCL. FCL merely talks about hours logged in the appropriate class to which the licence relates. As the regulations do not define what a particular Class is beyond saying that Class
"means a categorisation of single-pilot aeroplanes not requiring a type rating", the wording seems open to subjective interpretation.
If Mr. Whitaker is right it is rather surprising that this very significant point has not been picked up by the CAA as of course it will mean that anyone operating a permit or Annex II aircraft will be saddled with having to renew biennially by test. It also then raises issues such as can you ever do differences training on a Permit/Annex II aircraft?
There may of course be more regulation coming which defines various class categories, but at the moment the only one defined is Touring Motor Glider!