so, what do you think is the reason behind the rule you are believing in?? Do you think it is for safety reasons to make sure the Pilot applies in time (before exp. ?) Just to avoid this guy wastes 19 month with sending the forms&logbook out? Just to avoid he doe not get rusty?
As long as he/she doesnt apply for the rev. and have them finally revalidated he is Not allowed to get airborne. Right?
From the second year on, the watch is ticking. He s got 12 month to prove the 12 h. But he is not allowed yet to fly
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So what? Thats why the aviation authorities of several countries decide from case to case and are flexible (you call it magic).
My impression from the discussions with the EASA and especially with the CAA is:
The are not happy with some details. The have more troubles with the current details. And I think they made their experiences over the last couple of years.
I was told that some details in regulations are not "smoothies" and not practicable and some changes are taking place soon. Cause neither the CAA nor the EASA wanna make us angry.
Back to the definitions in 1178/2011
The EASA declared in 2 mails that the defintion how a reval. and a renewal in case of a SEP rating differs, is just an example to make it easier to understand what the words mean. It is NOT a regulation for revalidations of SEP ratings. Cause a fixed regulation is written in a more professional form.
And several nations expected to have the right for their very own national ways how to handle some administrative details.
From this point of view the document 1178/2011 makes sense.
Last point .
The CAA takes now 9 weeks to revalidate a rating (and they r def. not lazy). When do u want me to apply then? How many month do you allow me to fly my 12 h ?
You r thinking now, the timestamp of my FedEx envelope is the key? Pls show me that rule
I am feeling sad for those pilot who lost their ratings in a similar way.
Sorry if I sound a bit arrogant now. Maybe you can imagine that I m just happy now. Hoping my sadness disappears soon.
TomTom