Just to clarify, ar you saying time on any aircraft can be counted for issue but not for revalidation by experience
This is the view expressed by EASA in the CRD for NPA 2008-17b and backed up by the changes to the draft Part FCL
My opinions are formed by reading the source documents, which is the way I generally work professionally as well as on a personal basis
The only thing I may have not understood is you post, which has not until just recently addressed the point I was making. I made the point earlier that there was nothing in the draft Regulations saying that revalidation by experience could not be done using hours flown on an Annex II aircraft. Your last post, specifically:
EASA expressed, in the Comment and Response Document to EASA Part FCL, its intent that qualifying experience for the revalidation of EASA type and class ratings could be obtained only in EASA aircraft but there is nothing explicit in either the Basic Regulation, the Cover Regulation or in Part FCL to back this up.
confirms precisely what I have been saying. I have scanned the comment and response document (not read it line by line) but I cannot see where Easa stated revalidation by experience must involve non Annex II aircraft. However, I am fully prepared to be corrected on this point, though I would be grateful for the specific reference, if you have it. However, the point also needs to be made that the comment and response document does not represent the law, which is contained in the basic regulation and in Part FCL, if and when it passes the legislative process (we should not forget that this document is not yet law).
The result of this is that the ambiguity will be down to NAAs to resolve. What concerns me is that the CAA may too readily have jumped to the assumption that it is EASA aircraft only for revalidation by experience. I have made the point that this conclusion is not justified and is probably in practice unenforceable without a search against every aircraft a pilot has flown to see how it is registered. It would also be inconsistent with other provisions of the regulations.
It is also my view, based on the drafting, that EASA do not in fact mean to change the position from the existing JAA rules, which allow hours on permit and indeed third country registered aircraft to be counted. I am not so privy to EASA policy making to say if indeed this is the case but it is a reasonable assumption, given the comments by the Commission to EASA a few months ago about not "reinventing" the wheel.
What the CAA should be doing is actually asking the question of EASA. They may well be doing this, as may other NAAs. I hope so.