EASA FCL: Annex II aeroplanes for training?
One aspect of the "motor-gliding" thread has got me racking my memory for something that I clarified with EASA sometime ago (2 years or so). The question of what aeroplane one can be trained on to get an EU licence. Before I provide the rationale, it is clear that, for maintaining validity of an EU PPL(A) or LAPL(A) licence for an aeroplane (obviously), hours clocked on an Annex II aeroplane count. This was confirmed a long time ago by EASA and has also been confirmed by the UK CAA. In FCL.140.A the recency requirements refer only to 'aeroplanes', not 'aeroplanes within the scope of EASA regulation.' See the definition of aeroplane, which interestingly does not specify it has to be type certified!
So, now what about hours on an Annex II aeroplane to get an EU licence? I quote from the EU Air Crew Regulation (EC 1178/2011) as regards the LAPL(A):
FCL.035 crediting of flight time
Unless otherwise specified in this Part, flight time to be credited for a licence, rating or certificate shall have been flown in the same category of aircraft for which the licence or rating is sought.
[Note 'categories of aircraft' = aeroplane, sailplane, balloon, helicopter.]
FCL.105
(b) Conditions. Applicants for the LAPL shall have fulfilled the requirements for the relevant aircraft category and, when applicable, for the class or type of aircraft used in the skill test.
[Note that category = aeroplane in this example. Then it is 'class' or 'type'.]
FCL.110.A
(a) Applicants for an LAPL(A) shall have completed at least 30 hours of flight instruction on aeroplanes or TMGs, including at least: (1) 15 hours of dual flight instruction in the class in which the skill test will be taken (2) 6 hours of supervised solo flight time, including at least 3 hours of solo cross-country flight time... etc
FCL.135.A Extension of privileges to another class or variant of aeroplane
(a) The privileges of an LAPL(A) shall be limited to the class and variant of aeroplanes or TMG in which the skill test was taken. This limitation may be removed when the pilot has completed in another class the requirements below:
(1) 3 hours of flight instruction, including:
(i) 10 dual take-offs and landings; and
(ii) 10 supervised solo take-offs and landings.
(2) Skill test.....
(b) Before the holder of an LAPL can exercise the privileges of the licence on another variant of aeroplane than the one used for the skill test, the pilot shall undertake differences or familiarisation training.....
Again, the references to 'aeroplane' are generic, not specific to 'EASA aeroplanes'.
The text also covers the TMG extension to the LAPL(S).
Unless I have missed another relevant clause, it seems to me that one could train in an ATO on your own Tiger Moth (Annex II) and get your EU licence providing you take the skill test on the Tiger Moth or the same CLASS of aeroplane. Thereafter, if you want to fly something different you need to comply with FCL.135.A
No doubt someone will prove me wrong. Or maybe this has been clarified already by someone else.