I have submitted a rule making proposal to change this back to the way it was.
I will also be suggesting the same thing at the EASA FCL Implementation Forum immediately after Easter.
Although FCL.740.A (b)(2) outlines a process whereby a pilot holding both a single-engine piston aeroplane-land class rating and a TMG class rating may combine revalidation requirements, no similar process currently exists for pilots holding both a single-engine piston aeroplane-land and a single engine piston aeroplane-sea class rating.
(We) consider that it is unreasonable to require pilots holding both a single-engine piston aeroplane-land and a single engine piston aeroplane-sea class rating to meet the revalidation requirements for each class in their entirety.
We therefore wish to propose a new FCL.740.A (b)(4) as follows:
(4) When applicants hold both a single-engine piston aeroplane-land class rating and a single-piston aeroplane-sea class rating, they may complete the requirements of (1) in either class, and achieve revalidation of both ratings, provided that they have also completed the following minimum requirements in each class:
— 1 hour as PIC,
— 12 take-offs and 12 landings
(Delegates might wish to note that this was the UK position under JAR-FCL and that it raised no safety concerns.)
NB - FCL.740.A (b)(1) to which I refer is simply the current 'revalidation by experience' requirement.
If the meeting supports the proposal, I will then ask the CAA to raise an Article 14(4) or Article 14(6) exemption to this effect, because it will take ages for the appropriate Part-FCL working group to raise a draft Opinion....
