Bought a type rating? Let it go uncurrent? You're screwed

[Luke SkyToddler]

Just want to point out something to you guys that I found on another thread ... an EASA law change that's come in in the last few weeks regarding type rating and IR renewals


SUBPART G — INSTRUMENT RATING — IR

AMC1 FCL.625(c) IR — Validity, revalidation and renewal

RENEWAL OF INSTRUMENT RATING: REFRESHER TRAINING

(a) Paragraph (b)(1) of FCL.740 determines that if the instrument rating has lapsed, the applicant shall go through refresher training at an ATO, to reach the level of proficiency needed to pass the instrument element of the skill test prescribed in Appendix 9 to Part-FCL. The amount of refresher training needed should be determined on a case-by-case basis by the ATO, taking into account the following factors:
(1) the experience of the applicant. To determine this, the ATO should evaluate the pilot’s log book, and, if necessary, conduct a test in an FSTD.
(2) the amount of time lapsed since the expiry of the validity period of the rating. The amount of training needed to reach the desired level of proficiency should increase with the time lapsed. In some cases, after evaluating the pilot, and when the time lapsed is very limited (less than 3 months), the ATO may even determine that no further refresher training is necessary. The following may be taken as guidance when determining the needs of the applicant:
(i) expiry for a period shorter than 3 months: no supplementary requirements;
(ii) expiry for longer than 3 months but shorter than 1 year: a minimum of one training session;
(iii) expiry for longer than 1 year but shorter than 7 years: a minimum of three training sessions;
(iv) expiry for longer than 7 years: the applicant should undergo the full training course for the issue of the IR.
(b) Once the ATO has determined the needs of the applicant, it should develop an individual training programme, which should be based on the initial training for the issue of instrument ratings and focus on the aspects where the applicant has shown the greatest needs.

(c) After successful completion of the training, the ATO should give a certificate to the applicant, to be submitted to the competent authority when applying for the renewal.
Quote:
SUBPART H — CLASS AND TYPE RATINGS

AMC1 FCL.740(b)(1) Validity and renewal of class and type ratings

RENEWAL OF CLASS AND TYPE RATINGS: REFRESHER TRAINING

(a) Paragraph (b)(1) of FCL.740 determines that if a class or type rating has lapsed, the applicant shall take refresher training at an ATO. The objective of the training is to reach the level of proficiency necessary to safely operate the relevant type or class of aircraft. The amount of refresher training needed should be determined on a case-by-case basis by the ATO, taking into account the following factors:
(1) the experience of the applicant. To determine this, the ATO should evaluate the pilot’s log book, and, if necessary, conduct a test in an FSTD;

(2) the complexity of the aircraft;

(3) the amount of time lapsed since the expiry of the validity period of the rating. The amount of training needed to reach the desired level of proficiency should increase with the time lapsed. In some cases, after evaluating the pilot, and when the time lapsed is very limited (less than 3 months), the ATO may even determine that no further refresher training is necessary. When determining the needs of the pilot, the following items can be taken into consideration:
(i) expiry shorter than 3 months: no supplementary requirements;
(ii) expiry longer than 3 months but shorter than 1 year: a minimum of two training sessions;
(iii) expiry longer than 1 year but shorter than 3 years: a minimum of three training sessions in which the most important malfunctions in the available systems are covered;
(iv) expiry longer than 3 years: the applicant should again undergo the training required for the initial issue of the rating or, in case of helicopter, the training required for the ‘additional type issue’, according to other valid ratings held.
(b) Once the ATO has determined the needs of the applicant, it should develop an individual training programme that should be based on the initial training for the issue of the rating and focus on the aspects where the applicant has shown the greatest needs.

(c) After successful completion of the training, the ATO should give a certificate, or other documental evidence that the training has been successfully achieved to the applicant, to be submitted to the competent authority when applying for the renewal. The certificate or documental evidence needs to contain a description of the training programme.


The type rating thing is more restrictive than the IR now, so in other words boys and girls what it means is that right now, all across Europe, if your rating is more than three months uncurrent, you have legally lost it until you pay for a minimum of two sim sessions. Outside a year it's three sim sessions ... and most importantly of all for you long term unemployed, IF YOU ARE MORE THAN THREE YEARS UNCURRENT ON YOUR TYPE RATING, YOU LOSE IT ALTOGETHER

They snuck this in on the first of September with no prior warning, a few people who've gone to do renewals recently have just gotten a very nasty surprise.

This is having a huge effect on us professionals who went overseas to fly 'bus and Boeing for middle east and asian airlines ... turns out under EASA law we no longer have a type rating and have to resit basic training in the type we have been flying every day in another country :hmm: but I can see it also having a very large effect on the market for those fresh from school who casually purchase type ratings.

[ei-flyer]

Good news for real pilots who don't pay for type ratings tho!

[Longhitter]

So how do non-EASA aviation authorities treat EASA type ratings? I would be very surprised if you could walk into an office in all of those and get your EASA type rating transferred onto a non-EASA license without any training or scrutiny, let alone a rating that has expired...

The idea behind having a current type rating is that it is current through compliance with the relevant rules (i.e. an annual LPC and recency requirements). Under the new rules a type rating stays on your license beyond the previous 7-year limit, but to revalidate it requires training and the rules have been sharpened. That in itself is not unreasonable.

If you bought a type rating thinking that it would take no effort or cost to keep it current: very naive.

If you went to work abroad (by choice or by necessity) one must be mindful of the possible consequences of flying under a different jurisdiction. This is one of them: experience and ratings have never been easily transferable between all aviation authorities (anyone remember the days before JAA and EASA came about?).

If you're flying a type every day in a far-away country it is reasonable to get credit for the hours on type, which is still the case although subject to scrutiny, but seven years without an LPC in any jurisdiction seems a long time to me.

[Luke SkyToddler]

Mate ... it's not about conversion from a foreign licence, it's about renewal of the thing I've already got!

I've got a UK issued ATPL with a UK issued A320 rating and about 2000 hours airbus time logged with a UK airline, that was after the several years I spent as a turboprop captain in Scotland. Then I went to the sandpit and been in continuous practice on the same aircraft for the last 5 years, during which time I have flown in and out of the UK and Europe on a regular basis. I have 5 and a bit thousand hours on the narrowbody and widebody airbus family, 700 hours in the last 12 months and I last flew the aircraft this morning ... I think it's slightly unreasonable for them to expect me to complete basic instrument rating training and type rating training again prior to renewing my UK licence don't you?

There are a number of UK / European captains, instructors and examiners with some of the best operators on earth i.e. Cathay, Emirates, Singapore, who are in the same boat - without any warning we have totally lost our UK licences and aircraft ratings, and will be chucked in the same boat as the 200 hour nubs on a full type rating training course for the very aircraft we already fly, should we wish to return to Europe.

I'm all in favour of anything that makes it difficult for people to buy speculative type ratings, but on a personal basis I'm pissed off with this :mad:

[zondaracer]

If I read the regulation correctly, someone doing an EASA conversion for the first time (regardless if it is with a type and 500 on type, or an IR etc) has less training to do than someone who has been actively flying on type overseas.

Another excellent rule by EASA to increase air safety! ... Not

[Longhitter]

Luke,

In no way do I want to discredit your experience and proficiency or that of any pilot who works outside of EASA-land.

There is a bit of a jurisdiction and reciprocity issue, though...

You have not lost your license or rating, nor will you under the new rules. Only to make a rating CURRENT again the rules have tightened somewhat. So here's a question: if you were to leave the sandpit for three years and later on decided go back, would you be able to get a local license with the ratings you hold on your EASA license without having to do training and a skill test? Or would the sandpit-CAA accept a skill test carried out by an EASA-examiner who is not an examiner under sandpit-FCL rules?

The basic idea (under any jurisdiction) has always been that you keep a rating valid, and that it expires after a year. A lot of people let their ratings expire thinking that 'they could always revalidate it with a skill test within 7 years'.

Credit for licenses, ratings and experience between different jurisdictions has always been an issue. In the days before JAA even between neighboring countries in Europe. That has now largely, but not completely, ended which goes some way in leveling the playing field in Europe.

I can understand your frustration, though.

[Artie Fufkin]

Luke, looking at your posting history do I have this right? You flew the A320 in the UK and then went to the Middle East, got a A330 rating and are currently flying the A330 in Vietnam?

Do you also currently fly the A320, or are you saying that your A330 time should keep your A320 rating current?

Admittedly, I don't fly Airbus but I understand the A330 and A320 to be distinct and seperate ratings, albeit with a shorter conversion course between the two types.

If you're current on the A320 the new EASA rules shouldn't affect you, if you are not current on the A320, well...

[Luke SkyToddler]

Currently on 330, starting my command training on 320 in the next few weeks.

And yes the new EASA rules affect everyone who's abroad no matter what they are flying or whether they changed types or not, if they haven't done a renewal in Europe in the last three years they're stuffed. It doesn't matter which of the two ratings I attempted to renew I couldn't do it now, I can't get my UK licence back without doing my full ATPL theory subjects, full basic course of IR training and now a full type rating course :mad:

It used to be a seven year allowance from the time the rating went uncurrent and they've taken that away from us with no prior warning, that's my main gripe. I was planning to do a renewal next summer to keep it all legal and now I can't.

It's not really about my personal set of predicaments though, we expats are bitching about this on another thread over on the middle east forums if you want to check it out, we're planning to take them to court over it anyway.

What I really wanted to do was give a heads up / start a discussion amongst the inhabitants of this forum who are all hell bent on buying type ratings fresh out of school, give them the heads up that a potentially very large expense of multiple sim sessions awaits them should they fail to find employment within a very short space of time after completing their rating training.

[The African Dude]

I think the angel is in the wording:
The objective of the training is to reach the level of proficiency necessary to safely operate the relevant type or class of aircraft. The amount of refresher training needed should be determined on a case-by-case basis by the ATO, taking into account the following factors
In other words, there is no requirement for the TRTO to administer the full rating courses. If you were to come back and be inducted in-house I would expect that the airline could use this to their (and your) advantage and complete the minimum company conversion in SOP and such: limited change to the current process. You would not, in this case, be in the same boat as fresh licence holders with no experience.

[Callsign Kilo]

Luke,

I commend your intention, however it won't change anything I suspect. This is an issue for expat pilots like yourself, possibly looking to keep an option open with regards to returning back home at some stage.

Those working in the industry do all they can to 'advise' wanabees. SSTRs, PTF, flexiscrew, pseudo self employment, paid by the hour contracts. The aviation industry in Europe is a dead dog with the largest two lo-cos no longer expanding. Yet still people are queuing round the corner to sign up for licences and type ratings, all based on marketing dupe and false promises.

[LS-4]

What I really wanted to do was give a heads up / start a discussion amongst the inhabitants of this forum who are all hell bent on buying type ratings fresh out of school, give them the heads up that a potentially very large expense of multiple sim sessions awaits them should they fail to find employment within a very short space of time after completing their rating training.

And that's an important reason why I'm currently a tad skeptical about buying a TR in Europe these days. It should at least be connected with a job guarantee in order to make sense for me. I'll be glad to receive some input on this, though.

[Jaydubya]

I have just renewed my JAA to a EASA atpl and my B737 rating which expired 4 years ago is no longer on the licence, it is over the page under the section ratings previously held:{ Bit of a nasty shock which means that if I have now to do the whole course my job prospects have just taken a nosedive. I have 4500 B737 time.

[B737900er]

You would think that if this rule was going to be implemented firstly a heads up would of been given.
2. It would give a date or even say with immediate effect.

And finally 3. Given grandfather rights to those who are expatriate and still within the 7 year rule then from their next renewal the new EASA rules apply.

The EU is a cash generating machine, soon every country will go bankrupt at least once to a debt that does not exist.

[turbine100]

Isnt everything suppose to come from ICAO. If someone was flying on a foreign license with a type rating that has a multi crew IR. You would think they could do a LST on their EASA license and get it added back or similar.

Flying schools could take advantage of those trying to renew IR's in light twins and those flying abroad wont want to resit 7 ATPL exams after a few years of their last IR either.

Its bad for those who cannot find employment, those working abroad and airlines who require people that may have an expired rating with experience. Eventually their will be a shortage of type rated crews.

Is BALPA or any of those affected abroad getting together to legally challenge the the IR and type rating rule changes?

Perhaps everyone should go FAA, including the European airlines operating here :)

[stuckgear]

Bit of a nasty shock which means that if I have now to do the whole course my job prospects have just taken a nosedive. I have 4500 B737 time.

You and a whole barrow load of others.

EASA, - Working to make working in Aviation even harder!

[Piltdown Man]

Is BALPA or any of those affected abroad getting together to legally challenge the IR and type rating rule changes?


This isn't a BAPLA battle. Realistically, they can only look after people employed by UK companies. However, this is another example of the drivel generated by the :mad: in EASA Towers. It appears that the way they work is: 1. Draw up legislation which is pointless and unworkable. 2. Start a consultation process (in which those with a vested interest have no representation). 3. Change their name. 4. Move. 5. Return to 1.

And I like this: EASA, - Working to make working in Aviation even harder!

[de facto]

Having just looked at the caa uk website and CAP 804, i didnt see any amendment to the 17th sept one.
The 7 year year rule is mentionned (loss of ir theory) and the 3 months limit to ir proficiency.
There is no mention on the 3 year rule...

[turbine100]

I think this also affects some people who were flying in other countries using a UK or European license as a validation too.

On some of the other threads in Middle East and similar, I think some pilots were or associations in Hong Kong were getting together to try some sort of legal challenge.

[davve]

So as long as I don't let my TR go invalid I have nothing to worry about?

[ISBN]

No suprise, probably this regulation was written by the T.R.T.O. together with the european commisars.

They need money, your money. :D

[mct777]

I have a B737 type rating with hours on type. However its 2 years lapsed; will I lose it completely in a years time? What happened to grandfather rights as its a JAA rating and licence?

[costas1979]

Hey everybody.

I have an JAR type rating but haven't renewed for the past 4 years. I'm aware that according to EASA after 3 years I will lose my type and will have to do an initial again.

Does anybody know if I will need to do the whole 42 hours in the sim all over again, or will I just do as much as I need inorder to get it back on my license. Does it depend on proficiency? Will I also have to do the base training again?

EASA regulations are vague and I would highly appreciate an answer,

Thank you in advance

[Gulfstreamaviator]

I am operating in the UAE, and hold a UAE Licence...... for a period of several years, lets say 7, I take a GCAA PPC for my UAE based company, and operate under the GCAA FCL.

Is the GCAA Licence is a VALIDATION or FULL Licence.?

My understanding is that it is a VALIDATION.

Thus my GCAA licence ceases to exist when my UK CAA / JAR / ETC licence TR becomes extinct.

[Steak&Kidney_Pie]

Having recently discussed this topic with a very well respected CAA examiner and instructor examiner, he made it clear that the requirements for training are a suggestion, and that the training required and plan thereafter, are at the discretion of the Head of Training of the ATO.

Before panicking about losing ratings, I would therefore talk to the CAA and training providers. (It would be interesting to see the answer you get from each one!)

Also, the reason for sticking the expired rating on the back, is another CAA money generating technique to get you to pay and issue you with a new piece of paper! :ugh:

[tornadof3raf]

So the way I understand this,

Im working in the UAE on a GCAA APTL on a 777. My UK 737-300/900 IR expired on the 30/11/2011. I have until 30/11/2014 to get a UK class 1 medical and do 3 Sim sessions in a 737 sim to keep it valid. Also my ATPL expires on the 20/10/2014 so I presume that date overrides the type rating dates.

Correct? Or have I read it wrong......

Some people are telling me you don't need a valid rating to convert to EASA, just a rating that can still be validated e.g. like mine.

Any help would be great.......:ugh:

[de facto]

Correct you dont need a valid rating on your UK licence.
To convert to easa you need a easa medical,pass the Test of English aviation and send your old licence.

To revalidate your rating or transfer your icao rating to a easa,you will need to go via an ATO.They will let you know how much training if any is required depending on when your rating was expired and whether you are current in another icao member state or not.

[Sephore]

Hello,

what about transfering a non EASA rating on a EASA licence (UK) do you need only a LST + 500h on type or not ?

Thanks :ok:

[DeltaT]

Non-JAR IR rule for getting your JAR/EASA IR back has since been updated so it's like it was before I believe.

[RVR800]

It's a shame that there isnt some internation convention that standardises all civil aviation so that there is some agreement.

Maybe they should meet; I believe that Chicago is nice at this time of year:cool:

[johnpilot]

Hello Delta-T. Can you expand a little bit please?

[DeltaT]

Just the recognition of a overseas ICAO IR bit has been reinstated, well not quite termed that way, but in effect it amounts to that.
I picked it up via their RSS feed after someone lobbied the CAA about it.
Found it here (http://www.caa.co.uk/application.aspx?catid=33&pagetype=65&appid=11&mode=detail&id=5624)

[Luke SkyToddler]

Yeah DeltaT is on the case, as always :ok:

Since I started this thread, they have altered their policy with regard to those of us who have been operating under non-EASA IR's (i.e. expats flying outside Europe with European licences) so now we are able to return and get our licence current based on the fact we kept our IR current somewhere outside Europe.

If you haven't been flying at all however, which is quite possibly the case for those of you who bought speculative TR's without a job offer := there's no change to the policy

[johnpilot]

I currently fly a type which was on my UK licence and it has been more than 3 years but less than 7 since I did an LPC with a UK examiner.

I needed to get my EASA licence issued and thus I had to go to an ATO in the UK get assessed fly an LST rather than an LPC and take a written exam as the view of the CAA is that it does not exist on my licence.

I fall under the NON EASA Type Rating conversion case. I needed recency currency on my non EASA type rating and more than 500 hours.

Do not let your rating expire for more than 3 years.

The CAA also wanted ELP and would not accept the one from my airline. I had to get the Examiner to sign a CAA form. Luckily he did it on the day and faxed to the CAA.

Expensive and laborious

[hueyracer]

Since I started this thread, they have altered their policy with regard to those of us who have been operating under non-EASA IR's (i.e. expats flying outside Europe with European licences) so now we are able to return and get our licence current based on the fact we kept our IR current somewhere outside Europe.


Could you explain that a little bit further?

My problem at the moment:

I am holding a JAR-FCL (Helicopter) licence with IR.
I am also holding a FAA ATPL(H), and another ICAO-licence with IR.
Currently flying type and IR on ICAO-licence.

1. My JAR-FCL IR lapsed Dec. 2011. ATO says i have to do at least 3-5 hours with them (check, then training, then checkflight).
My ICAO-IR is valid.
What´s the "cheapest" way of renewing my JAR-FCL/EASA IR?

2. My type rating also lapsed in Dec. 2011.
Type rating is valid on ICAO licence, i am flying it every day.
Same applies when talking to the ATO: 3-5 hours (in addition to the IR).

Any help appreciated...the more i read in Part-FCL (The german CAP804), the more confused i am ....

[DeltaT]

Having a ICAO non-Jar/EASA IR doesn't pass the EASA IR test for you, it just stops the clock from ticking from having to do a full EASA IR initial test or losing your ATPL subjects, so yes you would still have to pass a EASA IR renewal.

I think in your case, the 3-5hrs flying in type would also be covered in the 3-5hrs IR training they are asking you to do. I would argue about the 'in addition', does it say that in the regs? As for how much of that flight time you actually do depends on you. Aren't the rules a 'recommendation' of 3hrs not compulsory??:confused:

If you know the requirements for a EASA test, you are fully up to speed as you say on type and IR fly regularly then push for a Checkflight straight off, as this should satisfy "time required before test" and then do the test.
Make sure you have the regs to quote to the ATO, and if necessary an agreement from CAA in an email or letter to save you $$.

Are you doing all this because of lapsed rating and IR on the JAR licence, or you have a job offer? If it is just because of the lapsed ratings, then as long as you are remaining on type and IR flying on the other licence I wouldn't worry about it.

[hueyracer]

Thanks for your answer...

The German LBA reads "recommendation" as "minimum requirements", and don´t allow anything less than what´s recommended in the regs....

:ugh:


I al just speaking to different CAA´s right now (as has been recommended before), as i am not happy with the way the German authorities treat experience...

-Time on non-EASA types does not exist for them
-other licenses does not count for them
-experience does not count for them...

At least the UK CAA will just let you do a check ride only if you are holding a non-EASA IR that´s current.....

[JB007]

I heard at work the other day the rules regarding type rating time scale had returned to 5 years!? Can anyone confirm this is the case?!

[echofly]

Hey everybody.

I have an JAR type rating but haven't renewed for the past 4 years. I'm aware that according to EASA after 3 years I will lose my type and will have to do an initial again.

Does anybody know if I will need to do the whole 42 hours in the sim all over again, or will I just do as much as I need inorder to get it back on my license. Does it depend on proficiency? Will I also have to do the base training again?


Hey all, I have the same douts than COSTAS1979

I have passed my TR 3 years ago...but it was still under JAR. So, how could we know that our TR would expire at the end of 3 years, whereas it was 5 initially ?!

Normally a law is not retroactive right ?? for us it should apply the 5 years rule for a TR.

anybody could confirm it ?

that's unbelievable....not legal if we have to do all again.

we could not know because there was no law about that yet, so this rule should not apply for all people who got a TR before the new rule. This is the basic in laws.

Thanks a lot

[CaptainJim]

I see there is no definition of how long each training session is in FCL.740(B)(1)? Could it be a one hour session?

Has anyone renewed their expired EASA type rating recently?

[Mustapha Cuppa]

Not only is the length of a session is not defined, the content is also open to interpretation. Therefore, a session may also include some form of ground or theoretical training.