Currency requirements

[PilotPieces]

Hi all,

Looking for some advice regarding the currency of my licence.

I obtained my PPL June 2010 and flew 50 hours P1 + 2 hours P/UT in the first 12 months. In the next 12 months (June 2011-June 2012) I have only flown 5 hours P1.

I am currently in Canada and most likely will be until past June 2012. So my understanding is that I need to complete 12 hours (7 hours more) from now until June 2012 + 1 hour with an instructor and have a signiture from an examiner?

If I was to obtain a temporary Transport Canada licence, issued under the conditions of my JAA licence, would any hours accumulated count towards that 12 hour requirement? I assume so, but then what about the examiners signiture?

I am completely out of the loop with the EASA changes so need to do my homework with that respect but does that throw another spanner in the works?

Any help greatly appreciated :)

[BillieBob]

Any hours gained in Canada will count towards the experience requirements for revalidation. However, the hour with an instructor must be done with a JAA FI and the licence must be signed by a JAA authorised examiner. Revalidation/renewal requirements under EASA are pretty much the same as under JAR-FCL except that the flight experience must be gained in an EASA aircraft and mandatory refresher training is required to renew an expired type or class rating.

[BackPacker]

PP, the other way to revalidate your class rating is by simply doing a flight test with an examiner. Funnily enough, there is no minimum duration for that test, so if you are current you may well find that doing the exam is cheaper than the one hour with an instructor. And a lot cheaper if you add in the additional 7 hours you're lacking for the reval by experience anyway.

You could even consider letting the whole thing expire until you get back, and do the exam then. If your class rating is expired for less than five years, the exam for getting it renewed again is still pretty simple.

For a plain JAR-FCL PPL like you EASA is not going to make a big difference. From april 2012 onwards you will have to abide by EASA Part-FCL and EASA Part-MED but at your level they're virtually identical to the JAR regulations that are currently in the ANO. And when you eventually renew your PPL in 2015 it will say EASA instead of JAR.

[S-Works]

where in Canada are you? I will be in Halifax (Debert actually) and Vancouver in April/May. I can do a skill test or your hours instructional flight. Drop me a PM.

[peterh337]

the flight experience must be gained in an EASA aircraft

Does that mean EASA-reg aircraft? Or ones with an EASA TC?

[dublinpilot]

Also watch out that the examiner needs to sign the class rating page in your log book BEFORE it expires.

It's no use getting them to sign it the following day. One it expires you need to go fly with an examiner to get your class rating back.

[Maoraigh1]

the flight experience must be gained in an EASA aircraft
Is that certain? (Meaning EASA type)

[BillieBob]

An EASA aircraft in this context is any aircraft not listed in Annex II to the Basic Regulation and yes, it is certain.

[ifitaintboeing]

the flight experience must be gained in an EASA aircraft

This is inaccurate, as experience gained in any SEP will count, so LAAers and any Annex II pilots can use experience on those aircraft to revalidate - this was one of the things which was amended.

See 3.5 here (http://www.caa.co.uk/docs/620/e-Sept2011_v3.pdf)

[peterh337]

The thing which is important to me is whether one can prolong one's UK/JAA PPL and UK/JAA IR by flying an N-reg aircraft, on the privileges of FAA papers.

I am not sure if this worked in the past for the PPL. I let my UK PPL lapse by more than 5 years (and then had to renew with an examiner) but the big Q is whether at some point I would have had to re-set all the PPL exams?

On the JAA IR, I have understood that if you never renew it (using the annual flight test) but are flying IFR on foreign papers, then you never have to re-sit the exams and can just renew the IR by doing the annual flight test, but (a) I have never seen this clearly written down and (b) am not sure if this will continue under EASA.

Does anyone have any references for this?

[mad_jock]

peter they have changed that rule.

There is a thread in the middle east forum about it.

Overnight the caa went from saying that an ICAO IR kept your exams live to you will have to sit them again if your JAR IR is out by 7 years. As you might expect this has screwed quite a few pros in the middle east.

[BillieBob]

This is inaccurate, as experience gained in any SEP will countThe reference that you quote states that "....the CAA considers that all hours flown in the specified capacity in any aircraft of the relevant class/type using the EASA licence may be credited". I understand that you may interpret this as including flights in Annex II aircraft (assuming that the UK CAA makes EASA licences valid on those aircraft) but this is not the view of EASA. Some changes were made to allow for some Annex II SEP experience to be accepted for the LAPL requirements but this did not extend to other licences and ratings. With that single exception, the basic premise remains that Part-FCL relates only to EASA aeroplanes, as stated in the Basic Regulation.

[Aware]

Morning Peter, Just had this situation with a student of mine, who found renewing JAR IR expensive every year, he had a multi so about £1500.00 a throw. He does not have his own aircraft. Also has an FAA IR which of course is self renewing according to approaches etc:

Answer was this from CAA:

Up to 5 years IRE can renew.
Over 5 years CAA Staff test again.
Over 7 years CAA Staff test again + retake all the exams.

He like me is hoping for the IMC to transfer to an EASA licence, at some stage, as all this becomes expensive.

And if you do no need airways, or do long distances IMC usually does the job.

[BEagle]

No, the CAA have said that any experience in the relevant class will count towards revalidation criteria, irrespective of whether the aircraft is EASA or non-EASA.

However, in response to a query from the Swiss, EASA stated that this will be clarified by FCL.002. Which won't be until 2013 at the earliest....

[Aware]

Not sure about the FAA situation regarding exams, but seven years seems to have always been the term at which you needed to do them again, under JAR anyway. Im sure its a revenue making exercise all this exams expiring nonsense. I could understand if the exams were relevant to what your were actually doing, but as we know they are not. They are just another hoop to jump through.

[peterh337]

Overnight the caa went from saying that an ICAO IR kept your exams live to you will have to sit them again if your JAR IR is out by 7 years. As you might expect this has screwed quite a few pros in the middle east.I have heard this from elsewhere, very recently, too, affecting some non-UK ATPs.

Surely that is legally actionable, if the pilot can find a written statement on the previous situation? We are talking a very big economic loss in re-doing the stuff.

Answer was this from CAA:

Up to 5 years IRE can renew.
Over 5 years CAA Staff test again.
Over 7 years CAA Staff test again + retake all the exams.That is super info, thank you, but presumably you want to get that in writing so if they go back on it you can pursue it appropriately ;)

What I am thinking is that I don't need to renew the JAA IR until the EASA FCL dual-paper requirement is clarified, which won't be before April 2014. An IR check flight will be £150 for the IRE plus the flight. I don't mind the flight (the practice is always good) but the £150 seems a waste if you don't need it. I can bang ILSs for far less than that, with a free safety pilot.

He like me is hoping for the IMC to transfer to an EASA licence, at some stage, as all this becomes expensive.

And if you do no need airways, or do long distances IMC usually does the job. It did me pretty well for my pre-2006 long trips, but having had the IR since then I would not want to go back to "official VFR" because of various foreign ATC practices which screw one up right when least expected.

It's totally perverted that one puts all that work into getting the IR, only to do trips like this (http://www.peter2000.co.uk/aviation/kithira/) where one logs ~20hrs of which ~10mins is instrument time.

If one did such a trip under VFR, the instrument time would be a lot higher (but obviously you would not want to log it ;) ) and there would be a much higher risk of icing, etc, because you don't have airspace access.

Not sure about the FAA situation regarding exams,

They never lapse. If you fall out of the 6/6 IR rolling currency, you do an IPC. The PPL ones never expire; you just do a BFR at any time. Demonstrated competence = very sensible. But the regulator makes no money out of that, because the renewal is done with a freelance instructor...

but seven years seems to have always been the term at which you needed to do them again, under JAR anyway.

I don't think so - if you flew on another ICAO IR in the meantime and could prove it.

Yes the exams are rubbish.

[mad_jock]

http://www.pprune.org/middle-east/467898-has-your-uk-caa-i-r-lapsed-more-than-7-years.html

here is the thread.

[peterh337]

Interesting reading.

Legal action must be the way.

Doing the 7 IR exams, for anybody but especially a long serving airline pilot, is bonkers. Their relevance to the real world is somewhere between zilch and zero and I know - I've just done them. And read through the 3000 pages of the GTS study material (goode olde ex RAF 1950s finest PPSC (http://www.ppsc.net/contact.asp) stuff).

One could understand various safeguards but resitting those hugely irrelevant exams? :ugh:

[mad_jock]

I disagree they are useless I have used quite a bit from them

But agree that if you are working there isn't much point repeating what ever licsense you hold.

[PilotPieces]

Thanks to everyone for the info. I just want to clarify the bridge between revalidating my licence to fitting in with the EASA change over.

So in the next few months I either do my 7 hours + 1 with an instructor and get the examiners signiture OR let it lapse and just to the skills test. Assuming I do the skills test in June, my JAA licence is still valid for 3 years and I just have my class rating valid for another 12 months. As far as EASA is concerned nothing really effects me until I renew my actual licence?

Off to Transport Canada shortly to get a temporary licence here...they told me all I have to do is show up with all paperwork and I will be issued one but I suspect what they mean is show up and they will issue one in a months time. I think I can see myself letting it lapse and doing the skills test back in the UK anyway.

Cheers

PP

[mad_jock]

It works out cheaper usually doing that. Its what I do.

You might be suprised at how long it takes to get your ticket in Canada some countrys the turn up is just to check you can speak english and then its all done and dusted in 5 mins.

just remember though alot of these validations are on the condition that you keep your home license valid both medical and ratings.

BTW there is nothing stopping you doing a test early. One of the examinors will be along to say how far in advance of your valid to date you can do it without it becoming your new valid from date.

[BillieBob]

Doing the 7 IR exams, for anybody but especially a long serving airline pilot, is bonkers.If you think that's bonkers, how about the requirement to do the initial IR course again? [See AMC1 FCL.625(c)]

[S-Works]

To get a TC licence based on your UK licence, the UK licence has to be valid and kept valid. TC are merely giving you a validation of your UK licence rather than anything that us stand alone.

I would suggest that if you are going to be in Canada any length of time you FI a full licence. It's simple enough to convert an ICAO licence by doing the written and a test. If you have an FAA licence its even simpler to convert.

[peterh337]

OK, Billibob, many thanks; after a lot of googling I did eventually find the 562 page tome (http://easa.europa.eu/agency-measures/docs/agency-decisions/2011/2011-016-R/AMC%20and%20GM%20to%20Part-FCL.pdf). It is on page 226.

Would I be able to ask people posting important info to always include references?

This change is scandalous. Obviously it will shaft loads of UK airline pilots who went to work abroad, but it will also make any non aircraft owning IR holder think twice about doing the IR, given that the cost of a MEIR renewal in a rented can is over £1000. The cost of "suspending" it for even 1 year is a load of money dumped at an FTO.

One has to wonder about the make-up of the committee which came up with this outrageous bollox :ugh:

[S-Works]

You don't need to keep the IR current for ME to keep the exams valid. You could just do a SE renewal every few years to keep resetting the clock. I know plenty of guys who only do a JAA IR renewal every five years and then do it SE. Not exactly difficult if current on another licence is it?

I think we may just be making mountain out of a molehill..

[mad_jock]

I reckon there must be getting on for 25% of the UK ATPL holders are working as expats. Its only going to get higher as well.

This change is almost punishing them for stepping away from working in the EU.

But to be honest if you plan for 3 k every 5 years you should be able to protect yourself.

Must admit I have been looking at getting a MEP/IR again just because its the cheapest way of keeping exams and license valid and leaving an option to do a type rating. But it looks like I will have to take the complete MEP class rating course again because I haven't flown one for over 7 years. The fact that in that time I have been flying twin TP's all the time doesn't seem to matter.

[peterh337]

What about the training required after just 1 year's lapse?

See page 226, above ref.

[PilotPieces]

Right, back from Transport Canada and I have a validation in hand now (very painless process).

Mad Jock, that was my next question, how early can I do this test? What is the difference between doing the test BEFORE the expiry date and doing it AFTER the expiry date? I ask because it expires the 6th June, my due date back in the UK isn't until end of June.

Bose-X, already started the process for the full licence here, have the medical and just need to get paperwork in order + take the exam. Not sure its worth it now though, I have probably left it a bit too late.

[mad_jock]

I had a look at lasors and you can do it up to three months before its due with no penalty.

There is no difference I believe in the test. It will just mean you can't fly on your validation either until you get it done.

But.. there is nothing stopping you using a JAR CRE over there if you can find one. So if you could meet up with Bose you would be sorted.

Depends how much flying you intend to do in that 3 weeks.

[S-Works]

What about the training required after just 1 year's lapse?

It's at the discretion of the Head of Training of the ATO. The guidelines are based on someone has lapsed an IR totally. As Head of Training, if you came to me with a valid ICAO IR and were in current practice I would be happy to allow you to direct sit an LPC.

You have to remember that a lot of this regulation is written to by read by the blinkered eyes of EASA people who have no realisation there is a world beyond Europe.

As I have said before, even stuff that seems black and white has a lot of room for interpretation and as Head of Training it is up to me to take a pragmatic approach to situations that don't fit exactly in the box.

[peterh337]

As Head of Training, if you came to me with a valid ICAO IR and were in current practice I would be happy to allow you to direct sit an LPC.

As I have said before, even stuff that seems black and white has a lot of room for interpretation and as Head of Training it is up to me to take a pragmatic approach to situations that don't fit exactly in the box. If you weren't writing anonymously, bose-x, claiming you are a head of training of an anonymous FTO, that might be useful to some.

Currently, however, all one has to go on is what is written, what is coming.

The EASA doc states

expiry for longer than 1 year but shorter than 7 years:
a minimum of three training sessions;

Will you write publicly, using your CRE/IRE license # and your FTOs full name, that you are willing to skip the "three training sessions" and do somebody's IR renewal in a single flight?

Or you will put in three logbook entries, written up as "training sessions"?

Remember that the resulting logbook entries (or more to the point the lack of them) will be there for all to see, for ever after (or until the pilot moves on to his next logbook) so if somebody decides to have a dig........... this business is positively the last kind of business where I would like to be over somebody's barrel.

[S-Works]

Or you will put in three logbook entries, written up as "training sessions"?

I certainly would not do such a thing, it would be fraudulent and negate several years of hard work on my part to gain significant credibility with not only the UK CAA but many other NAA's.

What I will say is that if anyone wishes to contact me directly seeking flight testing in a situation where they have an expired IR then I would be happy to deal with them on an individual basis.

I will also say that it in my opinion as Head of Training of a UK FTO/TRTO if a pilot with a current ICAO IR were to approach me for renewal of a JAA IR then I would consider the case on it's merits and if required seek guidance from the CAA.

[BillieBob]

One of the differences under EASA is that where there is an AMC it must be followed. Any person or organisation may propose an alternative means of compliance to that/those already published and, if accepted by the competent authority, either/any of the alternatives may be followed. The last I heard, the UK CAA was proposing to charge a minimum of £2,000 to process a proposal for an alternative means of compliance.

There is nothing to stop an individual proposing an alternative means of compliance to another competent authority, provided that they fall under the responsibility of that authority (e.g. they hold approval for an ATO in that state or have transferred their licensing records). In such cases, where one competent authority approves an alternative means of compliance, it must be accepted by all other EU states. This is known as regulatory tourism and frightens the cr@p out of the UK CAA.

On the up side, there is no definition anywhere in the Regulation of a 'training session'; arguably, a 10 minute chat over a cup of coffee could be considered a training session. Two 10 minute chats and the game's on.

[PilotPieces]

Guys, thank you all for the help so far appreciate it :)

I just wanted to find out a bit more about this examiner's signature. Say I do my required hours, including 1 with an instructor (doesn't have to be a JAA instructor I assume??) then I just need a JAA examiner to sign my SEP paper?

So, can I just fedex my logbook and licence to the examiner (or to someone who will take it to an examiner)? Do I have to be there in person? If there is any doubt I am sure I can have an old instructor verify my identity to said examiner.

I would be very interested to hear thoughts on this because if that would work out it would save me a skills test + flights back to the UK.

Cheers

[BillieBob]

....doesn't have to be a JAA instructor I assume??Yes, it does.