DB6, I certainly hope so. EASA part-FCL is a totally unwanted, unnecessary embuggerance which will do absolutely nothing to improve safety in any way whatsoever.
Why on earth the rulemakers can't accept:
- Revalidation=Either meet 'experience requirements' or fly a test.
- Renewal=Do whatever refresher training you think you need, then fly a test.
But no. For example, they've now added 'demonstration of competency' for FI 'certificate' holders, because some precious people didn't like the idea of periodic 'retesting' for FIs. "Ve haff passed the Skill Test, ve do NOT need more testink!".
Also, under part-FCL, a Skill Test only applies to the
initial issue of a rating/certificate - thereafter even renewal is by Proficiency Check.....