Solo supervision Lapsed SEP

[172510]

The student has a PPL, his SEP is lapsed, he needs a training to prepare himself for the renewal SEP skill test.
- May the student fly solo if supervised by an instructor. (Under JAR such thing was allowed in France for instance.)
- Would that solo flight count for FI restriction removal?

[nick14]

Don't see why not, the regs only account for not first solo or cross country and you are working within your instructor privileges.

[Whopity]

he needs a training to prepare himself for the renewal SEP skill test.So what value is there flying solo for this event? Whilst not illegal, there is no requirement. With regard to claiming such a flight towards the 25 supervised solo flights, there is nothing that says what flights they should be however; the clear intention is that to be meaningful, they should be ab-initio flights.

As such a flight now has to be conducted at an ATO (or RF) surely they will have some say regarding the suitability of a solo consolidation flight!

[mad_jock]

So what value is there flying solo for this event?

I had a couple like that as well.

Basically they want to go and bang some circuits in to practise.

And one wanted to go on a xcountry as well, so we went on a triangle as they requested and then I sent him off on a land away.

My opinion is if the student wants to spend money on more than is required who am I to tell them how to spend their money.

I wouldn't say it should count but as the whole FI derestriction thing is a joke I can't really get fussed about it. But you are leaving yourself open to getting the paper work sent back depending who is looking at it.

[S-Works]

To my understanding supervised solo flight is only allowable to someone who does not hold a licence. If the pilot holds a licence and the rating is lapsed then it is training as required to pass a test. There is no room for solo practice as either the pilot is ready for test or requires further training, there is no in-between.

[RTN11]

It's certainly a grey area, with no specific provision in the law, as bose-x says the only time solo flight is covered in the law is for people who don't have licences.

However, I'd say common sense should prevail, and if the student wanted to bash the circuit, or practice a pre-planned nav, I don't see why they couldn't do this on their own.

Would that solo flight count for FI restriction removal?

I'd say no.

[S-Works]

I don't see it as a grey area. The law is actually very clear, in order to fly solo as the holder of a pilots licence, you must have a valid rating. If the rating has lapsed then you can't fly solo. In order to regain the rating you must undertake training as defined by the HoT of an ATO and take a skill test.

Certainly as a HoT myself, there is no way I would permit solo flight for a pilot training to regain a rating.

[172510]

So what value is there flying solo for this event?

The regulator sees some value in flying solo for ab initio training. The regulation says nothing about solo training for renewal. After years out of practice, solo training helps to re-built confidence.
It might also be possible that your student is ready but no FE is available. To keep your student current, flying solo seems a good idea.

[S-Works]

Rubbish. Thats a very poor justification.

There is no benefit whatsoever in sending someone renewing a rating off for solo training. They do the training as required to pass the test, get the test done and move on.

I have tested hundreds of people in the same situation.

[ifitaintboeing]

As such a flight now has to be conducted at an ATO (or RF) surely they will have some say regarding the suitability of a solo consolidation flight!

Recency requirements for a LAPL(A) holder specifically mention this. If the pilot has not fulfilled the experience requirement in the preceding 24 months they can:

FCL.140.A

Holders of a LAPL(A) who do not comply with the requirements in (a) shall:

...

(2) perform the additional flight time or take-offs and landings, flying dual or solo under the supervision of an instructor, in order to fulfil the requirements in (a)

ifitaint...

[mad_jock]

To my understanding supervised solo flight is only allowable to someone who does not hold a licence. If the pilot holds a licence and the rating is lapsed then it is training as required to pass a test. There is no room for solo practice as either the pilot is ready for test or requires further training, there is no in-between.

I had this issue with a local examiner who decided to report me for it and refuse to do a test until it got sorted out.

The CAA confirmed it was acceptable for lapsed SEP's class ratings as previously they had a requirement for solo time after a certain period. But this was 9 years ago now.

Now it could very well be that it has changed under EASA. But there are lots of instructors that have done it and will continue to do it.

And what's the safety case to stop it or not allow it?

[S-Works]

I don't think its a matter of a safety case. There is no point to it. The requirements are training to pass the test. When they are ready to pass the test they take it. What is the point of sending someone off solo. If you deem them safe to solo you deem them ready to pass the test in my opinion.

I personally think it is to much of a bag of worms to open up sending someone with a lapsed rating off to swan around solo.

ifitaint, with all respect throwing the LAPL into the equation is a bit of a misnomer. I can't find anything similar for a PPL, have you?

[mad_jock]

I personally think it is to much of a bag of worms to open up sending someone with a lapsed rating off to swan around solo.


no bag of worms they go off into the circuit like any other student and gain confidence and fine tune there technique just like any other student.

Apart from anything I hate doing bloody circuits so as soon as they are safe they can go and practise by themselves while I go and do something more productive like get some peace and quiet with a newspaper in a small cubical.

[S-Works]

That's my point MJ, as soon as they are safe then they should be able to an LPC. There is no pint whatsoever I doing solo consolidation.

[3 Point]

Have to say I'm strongly on MJ's side in this discussion.

Ask yourself, what's the purpose of solo flying in the basic PPL training course? If it is just to satisfy the regulators requirement for 10 hours P1 then there would seem to be no justification for sending a lapsed licence holder on solo flights prior to renewal by skill test. However, the requirement for pre-licence solo is clearly not just a box ticking exercise but rather an opportunity for the tyro pilot to develop his confidence, hone his judgement end decision making skills.

A pilot who holds a licence, possibly expired many years ago, needs to develop these skills just the same as the new pilot does hence solo flying is perfectly justifiable in appropriate cases.

This, as I see it, is one of the great benefits of Part FCL. As Head of Training it is entirely within my gift to assess that a particular individual would benefit from solo practice and to send him off on his own just as I would for a ab-initio student.

Bose,

Consider a pilot who did his PPL 25 years ago, flew a total of 100 hours over the next two years and has not flown since. His licence (old CAA lifetime variety) is still valid but his SEP rating is long expired. Can you see that this (albeit extreme) case is just like a basic PPL student and therefore needs solo as part of his training? Indeed, the AMC suggests that for a rating renewal after just three years then entire training should be repeated - surely this would include solo flying??

I have sent renewal students on solo flights before and would certainly do so again if I felt it would be of benefit.

As far as using these solos towards de-restricting an inexperienced instructor; I don't see why not. The process of sending a student off on a solo is essentially the same. I don't work with restricted FIs in my school so not something I've ever considered.

Happy landings

3 Point

[ifitaintboeing]

I can't find anything similar for a PPL, have you?

AMC and GM to Part-FCL: AMC1 FCL.740 (b)(1)

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.

If solo flying is desirable for the applicant, then I do not see why it shouldn't be included. The test is a by-product of what we are doing isn't it?

ifitaint...

[mad_jock]

And after they have passed the test what then they go off unsupervised solo or with innocent pax onboard.

Far better they get there PIC skills up under supervision than not.

I don't train for tests they are the lowest standard which I will accept.

If the person wants more training than the minimum required then they can have it. I have no doubt that some will say well do the test then they can do any extra they like.

But realistically they will gain more from flying solo in the circuit that having a big lump sitting next to them. They just need the old wiring opened up to get the touch back.

[dhorgan]

Bose-X is correct and BTW
what do you think the Investigators and Insurance Guru's might have to say in a post accident situation?

[mad_jock]

Absolutely nothing abnormal your covered was the reply when I asked the insurance firm the first time I did it, 60 second phone call followed by a fax 5 mins later confirming it.

As for the AAIB I presume what ever they normally say after a student has an accident solo. A solo student under flight instructor supervision.

As I said I have been reported to the CAA for doing it with JAR rules enforce and the head of policy said it was fine and the examiner should do the test.

[3 Point]

"Bose-X is correct and BTW"

dhorgan, what's the basis on which you make this statement? Where does it say so in the regulations? As I and others have said, the HoT of an ATO is empowered to devise an appropriate training programme. The AMC specifically says ...

"develop an individual training programme that should be based on the initial training for the issue of the rating" (thanks ifitaint...)

so, that would include solo flying where judged relevant by an HoT.

Insurance? My club insurance covers the aeroplane to be flown by students for training - no issue there.

AAIB? Ditto what MJ said

Let's not invent difficulties and complications which do not exist in the regulations. rather, lets work within the rules to deliver quality training for our students and make them into safe, competent and confident pilots.

3 Point

[Whopity]

An entirely predictable range of repliesTo my understanding supervised solo flight is only allowable to someone who does not hold a licence.
So what does the Regulation say? Regulation 216/2008 Article 72. Except when under training, a person may only act as a pilot
if he or she holds a licence and a medical certificate appropriate
to the operation to be performed. So any person under training is exempt the requirement to hold a licence. FCL.020 Student pilot
A student pilot shall not fly solo unless authorised to do so and supervised by a flight instructor. I have found no definition of a student pilot!
May the student fly solo if supervised by an instructor. Yes
Would that solo flight count for FI restriction removal? Yes
what do you think the Investigators and Insurance Guru's might have to say in a post accident situation? So as lonng as the regulations regarding training have been complied with, they have no cause to say anything!

[ifitaintboeing]

I have found no definition of a student pilot!

I had spotted that too, and thought it quite amusing that there is a restriction ('shall not..') without a clear definition to whom it applies!

ifitaint...

[S-Works]

I would define a student pilot as one who does not hold a licence....

[RTN11]

what do you think the Investigators and Insurance Guru's might have to say in a post accident situation?

What nonsense.

Is this how you live your life? Every time you get in an aircraft you think what some hypothetical AAIB investigator will have to say about your actions, or what some insurance bod will say.

The insurance is there to cover the aircraft, if it is a flying school this will include solo students. That really is the end of it.

Who cares what the AAIB say anyway? They're there to look at the facts and make safety recommendations, the fact that the student previously held a licence would not be a proximate cause of any accident, so would really not be relevant to the investigation. It would simply be stated at the start of the report as fact, and I'm sure hardly make it in to the conclusion.

[3 Point]

"I would define a student pilot as one who does not hold a licence..."

And I would define a student pilot as someone who seeks to learn something about aviation or who is undergoing training to develop his or her skills, knowledge or judgement as a pilot!

I taught groundschool on Thursday to a class of pilots holding ATPLs, were they students? Of course they were!

[mad_jock]

If I came to you to get my out of date FI renewed would you generate a student record for me even though I hold an ATPL?

A student to me is anyone who is under taking a course of training.

I am student when I take a type rating or class rating until I hold said rating. I am a student while undergoing line training even though I hold all the rights to fly that particular aircraft.

I have a student record for every bit of training I have done be it SEP or multicrew type rating. And only the first 45 hours I didn't have a valid license.

In this case the pilot is a student under taking training for the renewal of the SEP class.

[S-Works]

The renewal of a Class they already hold. All the other instances you have quoted are for a new rating.

I would still argue that training for the renewal of a rating does not come under being a student pilot.

We are arguing semantics here I think. Unless the CAA are going to make a ruling it comes down to the head of training to decide. In my case I have decided there will be no solo element for the renewal of a rating. Other heads of training my interpret as they see fit. :ok:

[chrisbl]

The pilot renewing his class rating has to training as determined and needs a course completion certificate and are therefore a pilot under training; Synonymous with student pilot in most people's book.


The AMC gives HoTs' flexibility in deciding what training is required. That training will vary from student to student and be based on the student needs.


Why toss that flexibility away?

[mad_jock]

And why does anyone need a reason to go flying?

Even if the flight had no training benefit at all and the pilot just wanted to go up for an hour of circuits and there was an aircraft free why on earth wouldn't you sign them out?

[Level Attitude]

There is no solo requirement for SEP or MEP Ratings.
This is why CRIs can teach for them.

Not training for a Licence - only for a Rating for which there is no solo
requirement - then, by the letter of Part-FCL, no FI has the privileges to
authorise solo flight (because, in this instance, they would be exercising
their CRI privileges)


If it is believed it is allowed then it relies on an FI being the most
"appropriate" Instructor Certificate. I cannot see an FI(R) being appropriate
for this purpose - so no, it cannot count as one of the 25 supervised solos
required to remove the restriction.

[Genghis the Engineer]

I had a lapsed syndicate member a few years ago who had clearly lost all confidence in their own ability to manage the aeroplane on their own - constantly using the person sat next to them as a crutch.

We got the help of an experienced FI who used supervised solo as part of his plan for getting their command confidence back up. It seemed to work.

[mad_jock]

There is no such thing as cri privileges for FI. Cri is a JAR construction which they really didn`t know what to do with when it appeared. So much so it was ontract that invented the syllabus for it. You have to apply for a new rating if you wish to have cri. You can`t just ask the fie to make it a cri this time.

Only difference between unrestricted and restricted is the requirment to be supervised and no first solos to be authorised. Even if the pilot hasn`t flown for 20 years they have still gone solo so the restricted instructor can signed them out.

The other time i have used this is when someone got failed for class 2 with a current ppl and had a NPPL getting processed with a NPPL medical in hand but no license.

[BillieBob]

Agreed, FIs do not have CRI privileges (or IRI, TRI or STI privileges for that matter), they have FI privileges in accordance with the relevant paragraphs of FCL.905.FI.

[mad_jock]

CRI was never intended for the GA market. It was put in to allow commercial single engine operators to do the required training in a SPA.

Which is the reason why in some ways pre EASA the CRI is less restrictive than an FI. They can train at night without doing anything extra and they used to be able to do aero's as well.

But because of the way the UK ANO is set up a CRI in the UK was actually and extremely useful rating for minimal cost. So people started getting them. I wouldn't be surprised if the majority of CRI's for SEP are in the UK for Europe.

[Whopity]

CRI was the JAA term for a TRI (SPA); in the helicopter world they remained TRIs so everyone knew what they were.

[Level Attitude]

Given
FCL.905.FI FI — Privileges and conditions
The privileges of an FI are to conduct flight instruction for the issue, revalidation or
renewal of:
(b) class and type ratings for single-pilot, single-engine aircraft, except for single-pilot high
performance complex aeroplanes; ....and
FCL.905.CRI CRI — Privileges and conditions
(a) The privileges of a CRI are to instruct for:
(1) the issue, revalidation or renewal of a class or type rating for non-complex non-high
performance single-pilot aeroplanes, .....I think it is ludicrous to state
There is no such thing as cri privileges for FIor
FIs do not have CRI privileges

[mad_jock]

Its a separate rating.

CRI has some of the privileges of FI. Currently it also has privileges which are not available to FI's without further qualification.

For example a FI without night restriction removed can't go and do 1 circuit at night with a pilot for there night currency. A CRI can without any further training or addition to their license.

The FI can't just say I am off to fly at night using my CRI privileges.

[Level Attitude]

CRI has some of the privileges of FITrue

Currently it also has privileges which are not available to FI's without
further qualification.Not true - If you believe so then please give example(s)

For example a FI without night restriction removed can't go and do 1 circuit
at night with a pilot for there night currency. A CRI can without any further
training or addition to their license.The "no night instruction" restriction does not exist under EASA. There
is only a requirement in order to instruct for the Night Rating (which is not
a CRI privilege).

The FI can't just say I am off to fly at night using my CRI privileges.Why not? If you believe a CRI has the privilege to instruct at night.

[mad_jock]

I haven't looked at the EASA changes yet as I don't hold a EASA licence. I am still bound by my current license restrictions.

But having a quick look at 804 it appears neither are allowed to instruct for 90 day currency or for currency at night. Did a pilot actually look at any of this before they published it?

[S-Works]

The FI(A) does not include a CRI(A) it just happens to have a number of equivalent privileges.

I hold as independent ratings the FI, CRI SE/ME and IRI. My FI has the statement FCL.905.FI applies as in (a)/(b)/(d)/(e)/(f)/(g)/(g)(IR(R)/(h).

My CRI has For SEP(Land)/SEP(Sea)/MEP/SMG92/Cessna SET/Do28

My IRI just says FCL.905 IRI(A) applied.

Now if you go look them up you will see that there cross equivalency between the ratings but they are not embedded.

[mad_jock]

Is that an EASA ticket Bose?

[S-Works]

Yes it is.

[FlyingOfficerKite]

Isn't the danger here (for those who believe the premise is correct?) that pilots whose SEP Rating has lapsed could just go down to the local club once in a while and ask a duty instructor to supervise their solo flight and never actually revalidate their SEP rating - I'll get round to the test some day, just need more solo practice ...

It's seems bizarre to me that anyone would think, post-PPL, that they could expect to be sent solo without a valid Rating - I don't see it?!

You either have a valid SEP Rating or you don't - if you don't, you pass a LPC (or have the experience requirements) or you don't fly.

The idea of 'solo' is for a student pilot, pre-PPL, to gain the necessary experience to achieve the licence, not for a PPL to bypass the regulations.

You might just as well say when your ME/IR has lapsed that you'll just go off a do a couple of 'supervised' asymmetric ILS approaches solo at night in IMC for practice before your test!.

[Level Attitude]

The FI(A) does not include a CRI(A) it just happens to have a number of
equivalent privileges.As far as I can see an FI contains all the privileges of a CRI.
If not so, could someone please suggest an example.

Bose,
Your CRI SEP(Land) and SEP(Sea) - not required as included in your
FI Privilege (b)
Your CRI MEP - not required as included in your FI Privilege (h)
Your CRI SMG92/Cessna SET/Do28 also included in (b) and (h) unless
they are classified as "complex, high performance" aircraft - in which case,
according to Part-FCL, surely a TRI is required?

Of course listing various CRI privileges separately on a Licence is an easy
way of knowing/proving what an Instructor can teach - but that doesn't
mean those privileges do not all exist within an FI Rating - Else why would
Part-FCL.905.FI say that they do?

[Whopity]

I don't hold a EASA licence. I am still bound by my current license restrictions.As of Sept 2012 a JAA licence was deemed to be an EASA liccence. At that time the privileges and limitations of JAA licences were removed from the ANO and the EASA rules apply.

[S-Works]

Level attitude.

You have merely restated the point I was making about equivalent privileges within the ratings. Just because the FI has the equivalent privileges does not mean it has a CRI embedded in it though.

[nick14]

You are entitled to get the CRI as part of the FI course all that is required is the application.

[S-Works]

You are entitled to get the CRI as part of the FI course all that is required is the application.

Indeed, but as I keep saying its still a separate rating with many equivalent privileges not an embedded rating..... They have different restrictions and revalidation requirements.

[BigGrecian]

I'm suprised no one has mentioned FCL.045:
(d) A student pilot shall carry on all solo cross-country flights evidence of the authorisation required by FCL.020(a).

So in any case you would have to provide a written "authorisation" / or endorsement to the student to fly the flight solo.

[3 Point]

I don't think anyone is saying that the purpose of sending a refresher course student solo is to side-step the rules. The value of solo flying is the same for a pre-licence student as it is for a licence holding but expired class rating pilot. It develops judgement, confidence and airmanship.

FO Kite; so, if a pilot undertakes a training course reaching solo standard and then, for some reason stops for a couple of years then picks it up again what's the problem with that? If he actually passes his licence and then stops for a few years before starting again his training requirement will be determined by the HoT at and ATO. If that HoT decides that solo flying would be valuable and includes it in his "assessment of training" then what's the problem??

The great thing about the EASA FCL philosophy is that it specifically devolves this sort of decision to individual HoTs who are experts in the training of pilots. The old system with its "one size fits all" approach had effectively removed this flexibility, or at best left it to the CAA to make decisions based on reading someone's log book and considering his total hours. Now, as an HoT I can go on a flight with the holder of an expired rating, see for myself what training he needs, write that down and then have my team of instructors deliver it. Much better and more effective.

Different HoTs will have different views but Part FCL seems to be sufficiently mature to accept that - well done the Eurocrats!

Happy landings

3 Point

[BigGrecian]

The great thing about the EASA FCL philosophy is that it specifically devolves this sort of decision to individual HoTs who are experts in the training of pilots. The old system with its "one size fits all" approach had effectively removed this flexibility, or at best left it to the CAA to make decisions based on reading someone's log book and considering his total hours. Now, as an HoT I can go on a flight with the holder of an expired rating, see for myself what training he needs, write that down and then have my team of instructors deliver it. Much better and more effective.


On the other hand Part FCL removed HT discretion for conversion training though, as the NAA must approve the training plan unless it conforms to their AMC.

[3 Point]

You win some, you loose some!

Not sure exactly what you mean by "conversion training" Care to expand??

There are certainly areas where the introduction of Part FCL has not been a good thing but it is not universally bad in the way that it is often portrayed.:):)

[Whopity]

but it is not universally bad in the way that it is often portrayedExcept that certain National Authorities are attempting to maintain the status quo by insisting on things that are not in the regulation. Many of their new EASA forms do not match the EASA requirements, neither do the guidance documents.

[FlyingOfficerKite]

If that HoT decides that solo flying would be valuable and includes it in his "assessment of training" then what's the problem??

The Law, funnily enough.

Student pilots can be supervised solo.

Qualified pilots have to have a valid rating to operate as PIC (solo).

No valid rating = no privilege to operate the aircraft as PIC = no solo.

From the CAA website

I have an EASA PPL(A) | Private Pilots | Personal Licences and Training (http://www.caa.co.uk/default.aspx?catid=2701&pagetype=90&pageid=15220)

'Ratings within your licence may need revalidating or renewing in order to keep them valid. For example, your PPL(A) may include a SEP(land) rating that allows you to fly a non-complex aeroplane defined in the Single Engine Piston (land) category class. This privilege initially lasts for two years from the date of passing the skills test.'

'If the rating has expired you cannot fly as a pilot in command until it has been renewed.'

I can't really believe we're having this conversation but, once again, it is not always that obvious and if an instructional opportunity is gained then that can only be for the good. :)

[3 Point]

FO Kite,

Nothing I have seen in any law prevents me from sending a refresher student flying on his own! You have not shown us any regulation which would prevent it; simply quoting a generic comment from the CAA web site, out of its intended context will not do!

"No valid rating = no privilege to operate the aircraft as PIC = no solo"

Agree with your comment right up to the second equals sign! No privilege to fly as PIC then the pilot may only fly under the supervision of an instructor.

Consider a pilot who had a licence 30 years ago but has not flown since. He comes along and asks to undertake training to renew his licence; what training do you recommend?? The AMC says quite clearly that training should be based on the initial course and it also suggests that, after just three years the entire course should be repeated to regain a rating. So, after 30 years of no flying are you really going to train a pilot with no solo? I'm not! He needs to regain his judgement, confidence and airmanship by solo flying under the watchful eye of an instructor before he goes out to fly with 3 pax on a crappy day.

"Qualified pilots have to have a valid rating to operate as PIC (solo)." No real argument with this statement but I'd add that once his rating has expired he is no longer a "qualified pilot" and he reverts to being a student - simple!

Don't know if you are a HoT or not but, if you are then you are entitled to make up your own mind what training you think is reasonable and so am I

apropos of Whopity's comment; it's not just the National Authorities who insist on things which are not in the regulation. Why do we seek to make things more difficult for ourselves??

I seem to be in tune with the majority here and I will therefore continue to use solo practice as an important tool for training all students; pre or post licence!!

Happy landings

3 Point

[FlyingOfficerKite]

Hi 3 Point

I'm afraid we'll have to agree to disagree.

So, after 30 years of no flying are you really going to train a pilot with no solo?

Probably not, but that would be the decision of the Authority (CAA) - not the flying instructor or examiner. The pilot may have a lifetime licence but would require a medical and rating to fly as PIC (solo). After 30 years I'm sure the CAA would require 're-training' in order to 'regain' his/her licence. That 're-training' may indeed include a requirement for solo flights. But that's a different scenario to the one proposed on this Thread.

The example above is extreme. Generally, once a qualified pilot, always a qualified pilot in relation to the licences and ratings already obtained - student pilot re-trains (including solo as required), qualified pilot 'regains' (including all necessary dual instruction and flight tests required - 'solo' days are over in the student pilot sense).

All the best for Christmas and the New Year.

FOK :)

[BillieBob]

There is nothing in law, either national or European, to prevent a person being sent solo by an instructor as part of a course of training for renewal of an expired type or class rating.

ANO Article 60(2):
A person may act as a pilot of an EASA aircraft without holding an appropriate licence granted, converted or rendered valid under the EASA Aircrew Regulation when undergoing flying training, including solo flying training authorised and supervised by a flight instructor, in accordance with the EASA Aircrew Regulation as amended from time to time.

AMC1 FCL.740(b)(1)
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.

The ATO is perfectly at liberty to develop a course that includes solo flight if it considers that appropriate. What is not permitted is for an instructor to act outwits the course developed by the ATO and send a student solo when none is called for.

[FlyingOfficerKite]

BillieBob

Yes, 'when undergoing flying training' - without holding an appropriate licence - but not when already qualified.

Once qualified, ratings are either 'revalidated' or 'renewed'. Without a valid rating you're not going flying as PIC (solo), as described by the CAA in my reference above.

FOK :)

[RTN11]

FlyingOfficerKite, read the worlds more carefully

ANO Article 60(2):
A person may act as a pilot of an EASA aircraft without holding an appropriate licence granted, converted or rendered valid under the EASA Aircrew Regulation when undergoing flying training, including solo flying training authorised and supervised by a flight instructor, in accordance with the EASA Aircrew Regulation as amended from time to time.

so if one has a rating, but it is not valid, they may be authorised to fly solo by an instructor.

[FlyingOfficerKite]

RTN11

With the greatest respect (I have read the words very carefully) - NO.

If you are 'undergoing flying training', 'without holding an appropriate licence', 'rendered valid under the EASA' ...

How can you possibly have a Rating?

You haven't got a licence to include it in!!!

You would be a student 'undergoing flying training, including solo flying training authorised and supervised by a flight instructor',

Not a qualified pilot renewing or revalidating a Rating included in a licence.

Previous comments apply.

Best wishes

FOK :)

[RTN11]

I still feel common sense should apply.

This isn't a one size fits all discussion. Some people go to renew a recently lapsed rating, do the training, pass the test, job done.

For others, the whole reason they let the rating lapse was due to a total lack of confidence and a fear of going off on their own, beyond the fold on their map, for whatever reason.

For these people, some supervised and constructive solo before a test is of great benefit, something which perhaps the law doesn't cater for, but at the same time doesn't definitely say is prohibited.

[Whopity]

Probably not, but that would be the decision of the Authority (CAA) - not the flying instructor or examiner. NO its the responsibility of the Head of Training
After 30 years I'm sure the CAA would require 're-training' in order to 'regain' his/her licence.It is no longer the CAAs call. AMC1 FCL.740(b)(1)
How can you possibly have a Rating?

You haven't got a licence to include it in!!!Not a valid licence or rating, but as the holder of a previous licence (maybe with lifetime validity) you are entitled to renew that licence and rating; to do so you will complete a licencing proficiency check not a licensing skill test associated with initial issue. Since 1999 there has been no repeating of initial issue items in order to renew an expired licence /rating just training as required. The AMC provides guidance on what may be required therefater its up to the HT. In that process solo may be included and is perfectly legal.

[3 Point]

Sorry FOK, we will have to continue to disagree.

Whopity beat me to the keyboard, Under EASA Part FCL it is nothing to do with the CAA what training a pilot requires to renew his rating, even in the extreme example I created above. It is for the HoT to assess the training requirements and it is entirely his purgative to include solo flying if he feels that is appropriate.

BillieBob summarized it very nicely and in particular his reference to FCL.740(b)(1) is the key. This is the law; no more, no less! I absolutely agree that an individual instructor can't just send a pilot with an expired rating off on a solo; but, if the HoT assesses that solo flying is appropriate then an instructor can send the pilot flying to achieve that.

I think this discussion has just about run it's course. I'm quite confident that I understand the rules as they exist today and I'll carry on working on that premise.

Merry Christmas to all and many happy landings in 2014

3 Point

[RTN11]

I'm quite confident that I understand the rules as they exist today and I'll carry on working on that premise.

I think this is the key point. The fact is that there are plenty of schools out there who will be sending people in this exact situation solo, without any problems from insurance, the CAA or the AAIB.

It's very easy to sit in an armchair at home and create hypothetical legal problems that just don't exist, the fact is that if you phone the CAA seeking guidance, they will clear it right up, as would any insurance company.

The few on here are free to not send these students solo.

For the rest of us, we'll carry on doing so, and noone will stop us, as it isn't illegal to do so.

[BillieBob]

It is always convenient to take sentences or parts of sentences out of context in order to make a point, no matter how flawed that point may be. Unfortunately, the whole EASA Regulation (i.e. the Basic Regulation, the relevant Enabling Regulation, the relevant Annex and its AMCs and GM and, in some cases, other regulations) has to be understood if the context of an individual requirement is to be correctly interpreted. As we know, there is no cross-referencing and so this is not an easy task - even the CAA often finds difficulty in correctly interpreting the Regulations, as has been demonstrated by the repeated revision of CAP 804 and various Information Notices.

FOK avers, by implication, that Article 50 of the ANO refers only to student pilots (i.e. those who do not yet hold a licence) but this is incorrect. The Article refers to an 'appropriate' licence, i.e. one that includes the privileges appropriate to the task. FCL.045 makes clear that the privileges of an EASA licence may be exercised only if the relevant ratings contained in it are valid. If the rating has expired, the privileges of the licence may not be exercised, it ceases to be 'appropriate' and Article 50(2) applies.

To renew an expired class or type rating, the holder is required to undertake refresher training at an ATO. Paragraph 1h of Annex II to the Basic Regulation requires that all training must be executed through a training course. In the case of refresher training, the course is developed entirely at the discretion of the ATO and may well include both dual flight instruction and supervised solo flight time. There is nothing in any of the regulations to prevent this.

[FlyingOfficerKite]

Interesting discussion Guys.

I absolutely agree that an individual instructor can't just send a pilot with an expired rating off on a solo; but, if the HoT assesses that solo flying is appropriate then an instructor can send the pilot flying to achieve that.

The AMC provides guidance on what may be required thereafter its up to the HT. In that process solo may be included and is perfectly legal.

To renew an expired class or type rating, the holder is required to undertake refresher training at an ATO. Paragraph 1h of Annex II to the Basic Regulation requires that all training must be executed through a training course. In the case of refresher training, the course is developed entirely at the discretion of the ATO and may well include both dual flight instruction and supervised solo flight time. There is nothing in any of the regulations to prevent this.

... seems to sum it all up!

The emphasis being where the HoT deems 'refresher training' necessary, rather than in the case of a recently lapsed Rating.

Thanks for that and I hope you all have a good Christmas and New Year

FOK :)

[3 Point]

"The emphasis being where the HoT deems 'refresher training' necessary, rather than in the case of a recently lapsed Rating."

I'm not sure what this means FOK. A lapsed rating is a lapsed rating, whether 1 day, 1 year or 1 decade it makes no difference. For renewal, an assessment is always required. Of course, the outcome of the assessment will vary in every case and one factor will be how long since the rating expired but the requirement for the ATO to make an assessment is always in place for an expired rating.

It is permissible for the ATO to assess that no training is required but the assessment is still required. For example, an experienced pilot whose SEP rating expired last week but who has been regularly flying SEP throughout the past two years and who is planning to take the LST today; proably needs no training but he will need an assessment stating "no training required".

It's all clearly shown in CAP 804 and in AMC1 FCL.740(b)(1) to part FCL. Just get CAP 804 open on your computer, search for AMC1 FCL.740(b)(1) then read and enjoy!

Merry Christmas :ok::ok::ok::ok:

[Level Attitude]

In the case of refresher training, the course is developed entirely at
the discretion of the ATOBillieBob,
I agree ATOs have a lot of discretion, but not complete and absolute freedom
to do what they like.

AMC1 FCL.740(b)(1) states:
...an individual training programme that should be based on the initial training
for the issue of the rating....I am unaware of any solo requirement for initial training for Rating (rather
than Licence) issue.

This discussion is all about SEP Class Rating renewal. I have never heard
of Class Rating Instructors authorising solo flight for unqualified pilots, are
you saying they can (provided student has valid Licence and Medical)?

[BillieBob]

Just because a course is 'based on' the initial training, it does not mean that solo flight cannot be included. Solo consolidation of exercises in the class rating syllabus would be perfectly in order. Out of interest, since you say that you are unaware of any solo requirement, can you give me a Part-FCL reference for the minimum training requirements for initial issue of an SEP class rating?

Class Rating instructors may not authorise solo flight by pilots who do not hold an appropriate licence - Article 50 refers specifically to Flight Instructors

[mad_jock]

I would be surprised if there is even a syllabus available for a stand alone SEP class rating.

So the issue of if there is solo required for it or not is pretty much of a zero point unless you can provide one.

[S-Works]

My inquiry of the CAA this morning when asked if it was permitted for a pilot who already holds a licence to do solo training in order to renew the rating resulted in:

"We would not ordinarily expect the holder of a lapsed rating to undertake any solo flights in order to renew a class rating"

I have escalated further to the policy team for a full clarification.

[mad_jock]

Its not the UK CAA you need to speak to, its EASA main office.

The UK CAA can't make policy and even if it is their policy if the law isn't written in such a way to prevent it, they can have what whatever policy they like until its had case law developed through court.

I suspected if they got stroppy about it, you could just say see ya in court and they would slink off. A lawyer would look at the legislation and say there was nothing illegal about it.

They can't just ban things these days because the head of policy doesn't like the idea. All they can do is point you to the legislation that has been quoted.

If they want they can apply to EASA to get the relevant bit changed which they may do for you. But to be honest I think its a mistake as in my experience it is useful tool. And as the any change will have to be put out to consultation I would argue to keep the ability and leave it up to the HOT to decide what is best for the student.

[FlyingOfficerKite]

We would not ordinarily expect the holder of a lapsed rating to undertake any solo flights in order to renew a class ratingHmmm ........

But to be honest I think its a mistake as in my experience it is useful toolWithout any precedence (as far as I am aware in either the UK or European Courts?), in the event of an accident or incident it might take some explaining on the part of a HoT why a qualified pilot without a valid type/class rating was allowed to fly under supervision as PIC (solo) - with all the usual legal/insurance/liability issues that follow on as a natural consequence these days.

Particularly so if CAA policy is as described by Bose-X and there is nothing SPECIFICALLY IN WRITING in the various FCL documents which states that solo flight to regain a Rating can be undertaken as a means of retraining.

The fact that nothing is mentioned does not, in my opinion, allow an HoT to determine that, by omission, it would be acceptable to allow such 'solo' flying (Perhaps I've missed the particular wording?).

These discussions are interesting if only to highlight the lack of certainty when applied to current flying training.

I can't remember 20 years ago anything like the amount of uncertainty and interpretation to be applied to the rules regarding flying instructing. It all seemed so simple then - black and white (or is it just my rose-tinted spectacles clouding the view?!?!).

FOK :)

[S-Works]

MJ, the UK CAA are the voice of EASA. If you contact EASA directly they will refer you back to the UK CAA.

It is the job of the UK CAA to interpret the legislation and set policy as it applies to the regulation. I happen to find them very good at helping with such questions and clarifying how the UK CAA will interpret the policy I regard to UK licence holders and UK training facilities.

As the head of Training of a UK ATO I would be foolish to override their statement of policy because I thought I knew better or read it on a Internet forum...

[mad_jock]

I doud`t it would require any explaining if you stick to the usual rules for signing some one out solo.

If the caa comes out with anything other that its up to the HOT to decide they are over stepping there remit.

There is zero safety case for banning the practise.


If anyone has even a suggestion what is unsafe about the practise please post.

[FlyingOfficerKite]

Reference to the CAA Standards Document 14, version 6, dated September 2012 "Guidance for Examiners and Information for Pilots of Single Pilot Aeroplanes" reveals

Appendix 4 - Renewal of Type, Class and Instrument Ratings: Refresher Training

The objective of the training is to reach the level of proficiency necessary to safely operate the relevant type or class of aeroplane and/or continue to exercise the privileges of an instrument rating. The amount of refresher training needed shall be determined on a case by case basis by the ATO, taking into account the experience of the applicant, the complexity of the aircraft and the amount of time elapsed since the expiry of the validity period of the rating. The following may be taken as guidance when determining the needs of the applicant.

For a class or type rating:

1. Expiry for a period shorter than three months: no supplementary requirements;
2. Expiry for a period longer than three months but shorter than one year: a minimum of two training sessions;
3. Expiry for longer than one year but shorter than three years: a minimum of three training sessions in which the most important malfunctions in the available systems are covered;
4. Expiry for longer that three years: the applicant should again undergo the training required for the initial issue of the rating.

In CAP 804 Part I:

FCL.700 Circumstances in which class or type ratings are required

(a) Holders of a pilot licence for aeroplanes shall not act in any capacity as pilot of an aeroplane unless they have a valid and appropriate class or type rating, except when undergoing skill tests, or proficiency checks for renewal of class or type ratings, or receiving flight instruction

Standards Document 14 is for the guidance of examiners, of which a HoT would be one.

There is no mention here, in these CAA documents, about ‘solo’ flying forming any part of the refresher training. Training for the initial issue of a rating does not normally include any ‘solo’ flying either.

FOK :)

[mad_jock]

Its there except when recieving flight instruction.

Please provide the syllabus for a sep class rating.

I don`t really understand why you are all getting your knickers in a twist about people enjoying going flying under controlled conditions. If you don`t want to do it yourself thats fair enough. There is zero safety case to prevent those that do want to use solo as a confidence booster/ practise/ maintain currency before test.

[S-Works]

It's not about getting our knickers in a twist, it's about making sure that in this day and age we don't get our asses in a sling.

I do not see any need for solo training when doing training to renew a rating. Clearly neither do the authority.

I actually have a syllabus for an SEP class rating that was produced in order to add SEP ratings to the licences of integrated students who ended up only with an MEP/IR. It is also used for adding SEP to licences that only had motor gliders and for pilots on NPPL adding the SSEA.

There is no solo in it. You are confusing the training for the issue of a licence with the training for any class rating. The SEP post licence is just a class rating.

[FlyingOfficerKite]

... which is what I said in the first place.

Happy Christmas one and all.

FOK :)

[mad_jock]

Well some of do see the benefit of solo time to refresh PIC skills and develop confidence for when they get let loose with innocent pax onboard.

There is no question or issue with getting any ones ass in a sling.

I am not confusing the issue. The integrated student has already completed the SEP class rating its just they were never signed off for it by an examiner to allow the class rating to be issued so your only revalidating there training to bring them up to speed for class test.

Clearly neither do the authority. Well if you fire leading questions into them what do you expect. Say yes and he will piss off, leave it for a bit and then do nothing and maybe things on pprune will calm down and people will just continue what they are doing anyway and everyone can be happy.

And There are going to be a couple of single figure exam call signs not happy with it either as I have seen them send and recommend some solo time for students revalidating.

My experience is that it is a useful tool to bring the pilot up to the standard to be safe flying innocent pax. Are we training pilots to pass tests or be safe pilots?

Again I ask what is the safety case for stopping those of us that are happy and willing who believe it is of benefit to the student from doing it.

You have stated that you don't think its worth it so now you are actively trying to get the authority to issue a policy to make others comply with your interpretation.

Pre JAR they had legislated that the student did have to repeat there XC after a period so its not as if there isn't many years of it being prescribed for a class renewal. Yes any idiot can pole the aircraft round a series of exercises. But the PIC side of things needs refreshed as well. Supervised solo time plays a big part in that which is why we have it for license issue. The being on their tod and having to deal with situations themselves is a wake up call some need. Better to do it supervised than by themselves.

Every student is different it is appropriate and required for some others its not required.

[S-Works]

The integrated student has already completed the SEP class rating its just they were never signed off for it by an examiner to allow the class rating to be issued so your only revalidating there training to bring them up to speed for class test.

You just made my point exactly.......


You have stated that you don't think its worth it so now you are actively trying to get the authority to issue a policy to make others comply with your interpretation.

Where do you get that idea? I have asked for clarification thats all.

[mad_jock]

Yes so there is no syllabus for SEP class rating.

No clarification was required, it was just running to the teacher because someone isn't doing what you want them to. And as usual teacher is saying what you want to hear to get rid of you. But I suspect when teacher goes to talk to the deputy head and they look at the rule book they will find they can't do anything about it because as such there is no rule. They can try and make a rule up if they want but then someone will start a complaint procedure. And the whole thing is going to cost time and money for an issue which they haven't had a single safety related incident involving. So keep quite and put nothing in writing and point to wards the relevant legislation I suspect will be the way of dealing with it.

The usual rubbish has been brought up about insurance and AAIB. And as usual it has been dismissed as pish.

For over thirty years it was a requirement under the UK ANO to do solo x-country qualifier if your equivalent of SEP class had been up for more than 5 years.

I say again what is your safety case for stopping the rest of us doing it?

Because that's the first thing that's going to be asked to the CAA for this statement of policy.

And all you can say to the points raised by the supporters is "no it doesn't"

How many lives would banning this practise save "err none"

[nick14]

There is an SEP sea class rating syllabus in the AMCs

[S-Works]

Come on MJ grow up. There was no need for that sort of personal attack.

I have sought clarification on what is acceptable. As it would be the CAA that picked up such activity during routine audit, I would rather not have the discussion that we were doing something wrong. You should have seen the grief I got over a missing first aid kit at the last audit and a missing NOK entry on a student form. Imagine what it would be like if we were interpreting the rules incorrectly because of assurances on PPRune that it was OK?

There is an SEP Class rating course. I have one and its in our approved manuals.

At the end of the day I am not prepared to send people with expired licences solo. However I am open minded enough to seek clarification from the regulator as to whether it is an acceptable thing to do.

[Level Attitude]

I am not prepared to send people with expired licences soloWhy not? No problem at all to do this.
FI authorises solo flight using their privilege (a)

Did you perhaps mean "expired ratings" rather than "expired licences"?

[mad_jock]

As has been said what you are prepared to do is up to you. And if the regulator even says it is allowable you won't be doing it.

The rest of us have been perfectly happy sending them out for years.


And you need to grow up as well because like it or not running to the regulator because people are doing things which you don't like the idea yourself is plain childish. Especially as your not going to allow it anyway at your ATO.

We should be fighting to get people flying as much as they can safely not fighting to keep people on the ground for zero safety benefit.

From my experience you are in the minority not doing it. In fact the first person to suggest it to me for solving a problem student who was 10 years out was a single digit exam call sign. And it worked.

I say again what is your safety case for stopping the practise?

Please answer the question.

And also how many auld farts have you got flying again after 5-15 years not flying?

I had one who the Ministry of Aviation had issued his life time license. He I might add did 15 hours solo time including Nav solos. Not particularly because I wanted him to but because he wanted to. "Best not to be silly about these things young man"

It is crazy that someone that held a license 20 years ago can't do solo work under supervised conditions for exactly the same reasons why we have it in the PPL license. If they don't need it we don't require it. If they want it anyway there is no safety reason to say no you can't.

[S-Works]

It doesn't matter how many times you insult me or bludgeon me with your view of how things should be I will await the response from the CAA.

Asking for clarification on a matter of policy is not 'running to the teacher', it is common sense. The rules are not clear enough to me to convince me to change what we have established and to be frank you trying to bully me into agreeing with you by sling personal insults is not going to change that.

Play the ball not the player mate.....

[RTN11]

Typical thread of the two sides battling it out, neither changing their mind.

The fact is there is nothing in the law to prohibit it.

In law, that is all that matters. In court, that is all that would win the case, open and shut.

If the part fcl said someone who has previously held a licence may not fly solo until that licence is valid once more, fair enough, but it really doesn't say that anywhere.

As head of training you are free not to send people solo, just as others are free to send them off.

[mad_jock]

I am playing the ball. The running to teacher has obviously hit a cord. Its not a matter of policy its a matter of legislation.

So your going to wait for something which is not going to change the way you operate anyway.

Please answer the question.

I say again what is your safety case for stopping the practise?

Anyway we all know that the caa watch the forum so its best they know they are going to have to deal with a load of complaints if they give policy which is in contradiction of the legislation.

So with any luck they will state.

"There is no requirement for solo flight to be taken for renewal of SEP Class rating. But if the head of training deems it beneficial to the student there is nothing in legislation which prevents this."

Then those that don't can continue and those that do can continue. And everyone is happy.

[Meikleour]

This may seem naive but surely a PPL with a lapsed SEP rating but with a valid medical certificate devolves to a Student Pilots Licence with the attendant privileges and restrictions?

Simple!

[Genghis the Engineer]

What's a student pilots license? Never had one if those in the UK at-least. I've been a student loads of times but never needed a licence for it.

G

[Meikleour]

Genghis: When a student first undertakes flying training he has no licence. When dual he is flying with a licenced pilot - the instructor. To be sent off solo under the supervision of the instructor he must be in possession of a valid medical certificate. This is what used to confer privileges and used to be referred to as a Student Pilot Licence. It used to be printed on the back of the certificate. With JAA/EASA land this statement has gone however the principle still applies.

[Level Attitude]

PPL with a lapsed SEP rating but with a valid medical certificate
devolves to a Student Pilots LicenceA Licence gives an individual certain privileges to act as a Pilot.
What those privileges are depends on the level of Licence held, and
remain valid for as long as the Licence remains valid.

The rules do not say that a Licence stops being valid without a Medical;
they say a valid Medical, appropriate to the privileges being exercised,
must be held.
No Medical does not mean no Licence, it means Licence may not be used.

To exercise Licence privileges in a particular aircraft requires a valid Rating
for that aircraft.

An expired Rating has no effect on Licence privileges - think of pilots
with several Ratings, some valid, some not.

Of course, if no valid Ratings are held on a Licence, then it is not possible
to exercise the Licence privileges at all; but that is not the same as saying
the Licence is not valid.

[RTN11]

So, did the CAA ever come back with a definitive answer on this one?

[Whopity]

Of course, if no valid Ratings are held on a Licence, then it is not possible
to exercise the Licence privilegesExcept as a student pilot50 (1) Subject to paragraph (2), a person must not act as a pilot of an EASA aircraft that is
registered in the United Kingdom without holding an appropriate licence granted,
converted or rendered valid under the EASA Aircrew Regulation.
(2) A person may act as a pilot of an EASA aircraft without holding an appropriate licence
granted, converted or rendered valid under the EASA Aircrew Regulation when
undergoing flying training, including solo flying training authorised and supervised by
a flight instructor, in accordance with the EASA Aircrew Regulation as amended from
time to time.
So, did the CAA ever come back with a definitive answer on this one? It is not the CAA's job to give definitave answers; they will simply point you at the regulation.

[RTN11]

True, but I was meaning in response to Bose-x's comments that he had contacted the CAA for clarification, just wondered what the results were.

As you say, I'm sure they just pointed at the rules which clearly show that it is allowed, just wondered what the response from them would have been.

[Level Attitude]

Rightly or wrongly EASA is very specific, a Licence does not cease to be valid just
because no valid medical is held, nor valid rating attached:
FCL.040 Exercise of the privileges of licences
The exercise of the privileges granted by a licence shall be dependent upon the validity
of the ratings contained therein, if applicable, and of the medical certificate.
Quote: 50 (1) Subject to paragraph (2), a person must not act as a pilot of an EASA aircraft
that is registered in the United Kingdom without holding an appropriate licence granted,
converted or rendered valid under the EASA Aircrew Regulation.
(2) A person may act as a pilot of an EASA aircraft without holding an appropriate licence
granted, converted or rendered valid under the EASA Aircrew Regulation when
undergoing flying training, including solo flying training authorised and supervised by
a flight instructor, in accordance with the EASA Aircrew Regulation as amended from
time to time. Whopity,
Your quote (from ANO), your Red, my underline

In the case under discussion the person does hold a valid Licence, so this
exception does not apply. Even if it did, as solo flight is not required for
SEP Rating renewal, I cannot see how that could count as "flying training
in accordance with the EASA Aircrew Regulation"

It would have to rely on the ATO and Instructor deciding that any training
they liked was valid for SEP renewal - and, given that authorising solo
flight is only specifically allowed for Licence training, deciding themselves
which Instructor, presumably an FI, was the most "appropriate".

[Whopity]

In the case under discussion the person does hold a valid Licence Valid to do What? In order to be valid you need to meet all of the requirements, the licence, the ratings, the medical. If you cannot exrercise the privileges then it is not valid. EASA regulataion is not written in such pedantic detail.

Under FCL.040 you cannot exercise the privileges; therefore the licence is invalid. But under Art 50 you can fly without the need to exercise the privileges if supervised by a flight instructor.

We have a load of shambolic regulation, you have to apply a bit of common sense and make the most of it, its not going to get any better.

[RTN11]

I wonder if they knew when they wrote these regulations that they would be debated down to the very word like this :ugh:

Still don't see anything that says it's illegal, so will happily continue to do it.

[3 Point]

Level attitude,

your underlining in the quote above does not say "flying training for the initial issue of ..." It simply says "flying training"; that means any type of training! Could be initial training, refresher training, advanced trainign such as aerobatics etc.

When a pilot has a lapsed SEP rating he requires training in order to renew his rating but the regulation is quite specific that the content of that training is to be determined by an ATO. I am Head of Training at an ATO and, if I consider that solo practice is beneficial to the trainee I am perfectly within my rights to send him solo. There is no regulation which says I can't!

We did this to death before Christmas and, as far as I can see there are no new arguments here so I'm out!

Happy landings

3 Point

[bookworm]

If supervised solo is not permitted for licence holders, how would you interpret FCL.140.A as quoted by ifitaintboeing at post #10?

[Level Attitude]

" If supervised solo is not permitted for licence holders, how would you interpret
FCL.140.A as quoted by ifitaintboeing at post #10?"

Very easily: An LAPL does not contain a Rating, it is the Licence itself
which is no longer valid.

[bookworm]

So you are adamant that

Rightly or wrongly EASA is very specific, a Licence does not cease to be valid just
because no valid medical is held, nor valid rating attached:

yet if the holder of a LAPL does not meet the recency requirements of FCL.140.A, phrased,

FCL.140.A LAPL(A) — Recency requirements
(a) Holders of an LAPL(A) shall only exercise the privileges of their licence when they have completed, in the last 24 months, as pilots of aeroplanes or TMG:

you're claiming that the LAPL is "no longer valid". That's not consistent.

[BillieBob]

JAR-FCL 1.025 used to say, "The validity of the licence is determined by the validity of the ratings contained therein and the medical certificate". The EU Regulation does not include this statement and no mention is made of the validity of licences. Instead, FCL.040 states,"The exercise of the privileges granted by a licence shall be dependent upon the validity of the ratings contained therein, if applicable, and of the medical certificate". The logical conclusion, therefore, is that an EASA licence remains 'valid' unless suspended or revoked by the competent authority but the exercise of its privileges is limited.

It is also significant that FCL.040 refers to "....the ratings contained therein, if applicable....". This is clearly in reference to the LAPL, which does not contain any aircraft ratings. Consequently, an LAPL remains valid even though it does not contain a rating but the right to exercise of its privileges is constrained by the recency requirements of FCL.140.

[Level Attitude]

"....the ratings contained therein, if applicable....". This is clearly in reference to the LAPLNot only to LAPL: A PPL holder with a valid MEP Rating but a lapsed SEP
Rating (for example) may exercise his Licence privileges in an MEP but
not an SEP - validity of ratings contained therein is totally applicable.

you're claiming that the LAPL is "no longer valid". That's not consistent. Understand your point but an LAPL only contains one, specific, Licence privilege. If that
one privilege cannot be exercised then "de facto" the licence is not valid.

We did this to death before ChristmasVery true, but Whopity decided to revive a "Rating" debate using a "Licensing" argument
which I believe is spurious.

One new thing I have just noticed:
FCL.205.A PPL(A) — Privileges
(a) The privileges of the holder of a PPL(A) are to act without remuneration as PIC or co-pilot
on aeroplanes or TMGs engaged in non-commercial operations.

FCL.305 CPL — Privileges and conditions
(a) Privileges. The privileges of the holder of a CPL are, within the appropriate aircraft category, to:
(1) exercise all the privileges of the holder of an LAPL and a PPL;The argument still arises for a PPL holder with a lapsed SEP.
However, it seems, a CPL holder has LAPL privileges which means if they
are within the LAPL currency requirements they can self authorise solo
flight and, if they are not, then an FI could send them solo under FCL.040.

[much2much]

the local fi, has suggested ,solo practice, to a student/pilot in his laa aircraft,the student?has a lapsed ppl sep and current microlight rating,but no medical except a declaration,

is solo practice legal, could it be done under the guise of practice for the issue of ssea?

[Whopity]

is solo practice legal, could it be done under the guise of practice for the issue of ssea? If the aircraft is a Non EASA aircraft then according to Article 52(2) (f) it is legal. If the pilot holds a JAA/EASA licence then a NPPL medical declaration is not valid for use with that licence.

It would seem to me that this pilot should revalidate his SEP which requires a Course Completion Certificate issued by an RF or ATO and a Proficiency Check, what value has solo practice to meet this aim? Hopefully, any FI would fly with a candidate before sending them solo, if the pilot is up to standard all he needs is a test wheras if he is not up to standard, further training is required.

Under FCL.1030 (a) (2) The examiner is required to check that the candidate complies with all the qualification, training and experience requirements for rating issue, revalidation or renewal which will include a valid medical.

[Level Attitude]

...the candidate complies with all the qualification, training and experience requirements for rating issue, revalidation or renewal which will include a valid medical.Even though the CAA choose not to issue Licences (and therefore initial Ratings) unless a valid medical is held - That is not correct (see FEH 2.3.2): Not holding a valid Medical is not a bar to undergoing any Test or Check, nor to Examiners completing the Administrative Process for Renewals or Revalidations.

[Whopity]

Since when did a National guidance document overide the AMC?

[Level Attitude]

Since when did a National guidance document overide the AMC?Which AMC are you referring to? The only reference to Medical that I can see is that 'Solo flight will not be permitted unless an appropriate Medical is held'.

A PPL cannot be issued unless the applicant is at least 17 years old. Would you, therefore, not test a candidate eg one week prior to their 17th birthday on grounds of age alone?

[Whopity]

Its actually in the Regulation not the AMC:
FCL.1030 Conduct of skill tests, proficiency checks and assessments of competence
(a) When conducting skill tests, proficiency checks and assessments of competence, examiners shall:

(2) verify that the applicant complies with all the qualification, training and experience requirements in this Part for the issue, revalidation or renewal of the licence, rating or certificate for which the skill test, proficiency check or assessment of competence is taken; It hinges on whether the medical is a "qualification"!
MED.A.030 requires applicants for licences to hold a valid medical but makes no reference to renewal or revalidation.

[Level Attitude]

Thanks Whopity,

I made one mistake: The CAA are not 'choosing' not to issue Licences without a valid Medical, they are complying with Part-Med (that I had not looked at for a while).

For the rest I think we are in agreement. I (and presumably the CAA) do not see a valid medical as a 'qualification', but rather as a pre-requisite in order to exercise Licence privileges.

Possibly more debatable would be the underage case I mentioned since 'Experience' could mean only 'Flying Experience' (minimum hours) or it could mean all experience, including 'Life Experience' (minimum years)???

[172510]

With a LAPL solo practice under supervision is legal to regain privilege.

[mykul10]

Rightly or wrongly EASA is very specific, a Licence does not cease to be valid just
because no valid medical is held, nor valid rating attached:

Whopity,
Your quote (from ANO), your Red, my underline

In the case under discussion the person does hold a valid Licence, so this
exception does not apply. Even if it did, as solo flight is not required for
SEP Rating renewal, I cannot see how that could count as "flying training
in accordance with the EASA Aircrew Regulation"

It would have to rely on the ATO and Instructor deciding that any training
they liked was valid for SEP renewal - and, given that authorising solo
flight is only specifically allowed for Licence training, deciding themselves
which Instructor, presumably an FI, was the most "appropriate".

The currency requirements for a LAPL (on a rolling 24 month basis) can be met by flying solo under the supervision of an FI. So logic would say that the Sam would be true for SEP on a PPL. But then again, we re talking EASA not LOGIC!