SEP revalidation signature

[737-500]

Hi all

I have an Irish issued JAR-CPL. My SEP rating expires on the 07/04/2010. I am starting a type rating course in late January and wont be able to get my licence signed. However I have all the requirements(12 hours etc.) meet now and I am just wondering if it is to early to get it signed. I am aware that in the UK it can only be signed in the 3 months preceding the expiry date, but what about Ireland?

B735

[Captain Stable]

Irish rules, unless they differ from JAR, would be the same as UK.

[peter272]

Is there any reason we can't present logbook evidence to an appropriate signatory and complete the form before the 3 month period.

Then the signatory could hold on to it until the 3-month threshold and sign it then.

It does seem stupid that we can't sign off as soon as ot has been done. Mine was due in November but I'd done everything by last Feb. I just had to remember to get the signature in August.

[737-500]

Thanks for the replies. As far as I know the 3 month date limit is only a CAA requirement. I have checked JAR-OPS1 and could not find any reference to a 3 month date limit. So if anyone has any dealings like this with the IAA please enlighten me!

[englishal]

In the "old days" there was no such 3 month time frame. I had my first JAA signoff into about week 2 of the second year. This meant I had almost 3 years until the next one.

What safety rational is there behing the 3 month signature? I meet all requirements, and did some time ago, yet the 2 years is not up until May. I could get an examiner to sign me now (if allowed and to continue my 2 years from original date of xpry), or I could forget and have to do another flight test.

It is utter crap.

[flybymike]

It is totally and exclusively a CAA drafting cock up which (as has been pointed out) did not used to exist but was accidentally hashed up when redrafted as part of the MEP 3 month revalidation period (or some such similar exercise- I can't remember the exact details ) . As soon as the error was noticed by the populace at large it was pointed out to the CAA by one and all , but they seem to be too proud to do anything like admit the mistake and simply put right what is a completely pointless anomaly.

[BackPacker]

I don't understand what the big fuss is about. If you've got the hours and everything now to get signed off "by experience" then by all means get signed off now. That'll make you good for the next two years.

The only difference is that in that case "the next two years" is measured from the moment the instructor signs the paperwork. While if you wait until the three months before your class rating runs out, your extension is two years measured from the original expiry date.

[englishal]

It is the examiner who has to sign. But anyway, why should we, due to a CAA cock up?

The CAA make a lot of cock-ups, and then are seemingly too proud / stubborn to go back and rectify their mistakes. The ANO is littered with them. It is a bit shocking really, perhaps there are too many ex-civil servants employed by them...

[peter272]

It might be an idea to start a new thread listing the CAA's hash-ups.

[24Carrot]

I am in a similar situation in the UK and so looked it up in LASORS recently.
As I read F1.4, BackPacker has it right about when the next two years starts from.

However you need "flying experience completed within the 12 months preceding the rating expiry date." I'm not sure what "completed" means though. The final hour of experience should be in the last 12 months, or the whole 12 hours? I read it as the latter, to play safe.

[BackPacker]

However you need "flying experience completed within the 12 months preceding the rating expiry date." I'm not sure what "completed" means though. The final hour of experience should be in the last 12 months, or the whole 12 hours? I read it as the latter, to play safe.

I have always understood that the 12 flight hours and other requirements have to be done in the second year. Whatever you did in the first year is not relevant at all. But now that I read LASORS I agree that the language is a bit ambiguous. They should have left out the word "completed".

What is also interesting is that this makes it harder to "revalidate by experience" well before the two-year period is over. Suppose you're at the end of the first year and you have all the requirements sorted. You cannot go to an examiner right there and then to get your two-year extension. Because the experience requirements have to be met "within the 12 months preceding the rating expiry date", not "within the 12 months prior to revalidation".

So you cannot put yourself voluntarily on a one-year "revalidation by experience" regime instead of a two-year regime. Odd.

Anyway, I have found that doing an LPC is cheaper than doing a one-hour instruction flight, since there is no minimum time set for an LPC and it can usually be done in less than one hour, assuming you're current. And there are no timetables like above associated with that LPC, so you can do it at any moment.

[flybymike]

I don't understand what the big fuss is about. If you've got the hours and everything now to get signed off "by experience" then by all means get signed off now. That'll make you good for the next two years.

The only difference is that in that case "the next two years" is measured from the moment the instructor signs the paperwork. While if you wait until the three months before your class rating runs out, your extension is two years measured from the original expiry date.

Precisely . You have answered your own question. Why should we have to give up what may amount to several months of "free" rating validity when we would not have had to had there been no such cock up, just for a paperwork regulation which serves zero useful purpose, and for a revalidation procedure which we managed perfectly safely without for many decades before JAA and which has had zero proven safety benefit since introduced to an industry which is already being strangled to death by unnecessary over regulation

[XXPLOD]

Irish rules, unless they differ from JAR, would be the same as UK.

There's a Murray Walker esque statement if ever there was! :ok:

[Whopity]

The 3 month requirement was an "error" that appeared in the ANO in 1999; they got confused with the requirement for revalidation by Test in the last 3 months, it is not a JAA requirement. Nobody wanted to admit to the error so its never been changed.

Nobody took any notice of the 3 months period until it appeared in LASORS around 2005.

If you look at the Certificate of Revalidation issued with the licence, it does not include the date of signing! So who knows or cares?

[flybymike]

But presumably the date of signing of the certificate would be assumed to be the same date as the CAA return form (which is dated) and which presumably could not therefore be signed before the final 3 month period (except for a full test)?

[Whopity]

Quite right, but does anyone read them? No, they just get copied onto your record and that's that. Would anyone prosecute you? Of course not.
(except for a full test)?A full test would be a Renewal and therefore there is no "3 months" involved!