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Emkay
15th Feb 2015, 19:34
Does the 12 hours of fight time required to revalidate a PPL single engine rating include time flying dual with another pilot, even if I am not P1?

Revalidate a SEP Aeroplane Class Rating | Private Pilots | Personal Licences and Training (http://www.caa.co.uk/application.aspx?catid=2685&pagetype=65&appid=54&mode=detail&appproc=30)

b.a. Baracus
15th Feb 2015, 19:42
No. You can't log P2 in a SEP. The 12 hours can be comprised of P1 or P/UT.

PA28181
15th Feb 2015, 21:20
flying dual with another pilot, even if I am not P1?

You don't really mean as a passenger do you???




Max 6 hours dual I think inc 1hr "instructional" rest must be P1.

englishal
16th Feb 2015, 07:25
https://dl.dropboxusercontent.com/u/66162937/20150215-Reval_by_Exp_Table_v2.bmp
Courtesy of someone on the Flyer forums.

And no, passenger hours don't count for anything, unless it is a multi pilot aeroplane (not many SEPs are MP I would have thought).

DaveW
16th Feb 2015, 09:00
I am that 'someone on the Flyer forums', and I would counsel great care in using that table just for the moment.

It is a work in progress, and the Flyer forum thread is to crowd-source critique of it so that it ends up being correct; that process hasn't finished yet.

Thanks, Al, for posting it here though. If anybody has constructive criticism ("Don't like the colours" doesn't count :} ), please comment on the Flyer thread (http://forums.flyer.co.uk/viewtopic.php?f=1&t=93872) - NOT here.

Many thanks.

Dave

Mach Jump
16th Feb 2015, 09:58
...within the 12 months before the expiry date of the rating, complete 12 hours of flight time in the relevant class, including:

6 hours as PIC;
12 take-offs and 12 landings; and

a training flight of at least 1 hour with a flight instructor (FI) or a class rating instructor (CRI).

I remember, when this wording was introduced, thinking that an interesting question with regard to the meaning of the phrase 'flight time' could be raised, and this is the first time since then I have seen it brought up.

In theory, as it does not specify what form the 'flight time' that is not PIC must take, one could log passenger time, without claiming any crew function, as 'flight time'.


MJ:ok:

ChickenHouse
16th Feb 2015, 10:47
@MJ: absolutely correct. When doing the regulations they missed to define "flight time" - which opened up the old local hero CAA game ... nobody knows but everybody has a opinion. If stretching to the limits, one could even log airline pax time ...

Back to the somehow reasonable things. You can of course log all times you want to, some use their flight book as diary story book and leave the "what counts for x" issue to later. I am writing down my RSF, if I was in control for me to remember and do exclude these hours in claiming flight time for license reasons.

And, to be picky - there is no P2 in a single pilot SEP ... you can log PIC or PUT for license revalidation, plus note PAX for all other flights. In the end it may depend even on your FI/CFI/FE what he/she is going to sign off. BUT, I would always suggest to do FE training flight if you are down or close to minimum hours anyways.

DaveW
16th Feb 2015, 11:32
There are several licensing definitions that are confusing (and getting that table above right, believe me, would convince anybody of that fact :* )

However, I find it difficult to believe the definition of flight time in this context is hardto understand. The issue is obviously to do with personal experience to retain currency, which must obviously be flight time undertaking a role that is both legal (as P2 in a SEP isn't) and credibly provides that experience.

How a reasonable person could ever convince themselves that acting as a piece of talking airfreight is loggable experience for licensing purposes is beyond me.

To suggest that the regulatory authorities should be pinning down the definition of "flight time" in this context to such an extent is simply farcical.

And if they tried they'd likely screw it up, anyway.

PA28181
16th Feb 2015, 11:39
How a reasonable person could ever convince themselves that acting as a piece of talking airfreight is loggable experience for licensing purposes is beyond me.

To suggest that the regulatory authorities should be pinning down the definition of "flight time" in this context to such an extent is simply farcical.

And if they tried they'd likely screw it up, anyway.

I couldn't believe that either, that anyone would consider claiming pax time in CAT could possibly have any bearing on their "Flight Time" required under the 12 hour/2nd year rule.

DaveW
16th Feb 2015, 12:07
Pax time in CAT was so daft as to be something I hadn't considered. It's pax time in GA that was getting my goat!

ChickenHouse
16th Feb 2015, 12:08
However, I find it difficult to believe the definition of flight time in this context is hardto understand. The issue is obviously to do with personal experience to retain currency, which must obviously be flight time undertaking a role that is both legal (as P2 in a SEP isn't) and credibly provides that experience.

In principle I tend to agree as a first reaction, but get immediately into trouble when defining borders. If a right seat pilot takes control he/she gains more experience then a left seat PIC staring at the autopilot for hours. Consequently one must exclude hours under A/P from being logged as PIC time, or would A/P cruise not qualify, but on APP or in traffic circle yes? I do see the strict regulation PIC in single pilot GA equals to exactly and one pilot only from T/O to LDG as a reasonable way out (let "you take control" totally regardless for logging hours - even if you are "in control" the PIC stays "in command").

PA28181
16th Feb 2015, 12:12
I refer to one of my previous comment "don't make it complicated"

In principle I tend to agree as a first reaction, but get immediately into trouble when defining borders. If a right seat pilot takes control he/she gains more experience then a left seat PIC staring at the autopilot for hours. Consequently one must exclude hours under A/P from being logged as PIC time, or would A/P cruise not qualify, but on APP or in traffic circle yes?

you are tying yourself up in knots with this.

On that assumption re: A/P operation then many flying instructors have grossly over logged their claimed hours also. sitting in RHS twiddling their thumbs while stude gets on with it.

Mach Jump
16th Feb 2015, 12:25
To suggest that the regulatory authorities should be pinning down the definition of "flight time" in this context to such an extent is simply farcical.

Dave, I disagree totally.

We all have our own ideas when it comes to what's sensible, but Regulatory Authorities must make the rules clear and unambiguous. THAT'S THEIR JOB.

And if they tried they'd likely screw it up, anyway.

They already have!



MJ:ok:

Ps. Airline passenger time wouldn't count in this case, as 'flight time in the relevant class' is specified.

PA28181
16th Feb 2015, 12:35
Ps. Airline passenger time wouldn't count in this case, as 'flight time in the relevant class' is specified.

But your not saying pax time in the relevant class counts are you?

DaveW
16th Feb 2015, 12:39
In this instance the rules ARE absolutely clear and unambiguous already. There are things you can log for experience, and things (P2 in SEP, Pax...) that you can't.

People who cannot interpret these things (actually they can; they're just trying to get something for nothing IMO) should not be pandered to by the regulator by defining things like "flight time" any further than they already have.

It's adding on words to specifically deal with these misinterpretations that will cause the problem by causing even more (inadvertent) obfuscation and potential for deliberate (or otherwise) misunderstanding.

On reflection, I retract and apologise for my final snarky comment of earlier; I'd been spending the last day or so digging down into the confusion that really does exist in EASA and National licensing and had generalised from that.

In other words, MJ - you are quite correct and I agree with you.

Mach Jump
16th Feb 2015, 12:47
But your not saying pax time in the relevant class counts are you?

If any of us think it should count or not, is neither here nor there.

If someone chose to count it, I can't see how it could be excluded, given the use of the term 'flight time' without any further definition.


MJ:ok:

PA28181
16th Feb 2015, 12:52
Is all this "flight time" talk from a CAA "CAP" or from the only relevant document the ANO?

DaveW
16th Feb 2015, 12:53
...and there, MJ, I DON'T agree with you. :}

Mach Jump
16th Feb 2015, 13:02
and things (P2 in SEP, Pax...) that you can't.

You can't claim P2 in any SEPs, because there are no SEPs , that I know of, that require 2 pilots.

You can, however, put 'passenger time' in your logbook, so long as you don't claim it under any of the 'Crew' titles.

I think that we do agree on the original intention of the requirement here Dave, but if Regulatory Authorities don't write things down clearly, they should expect that some people will push the text as far as it will go.

Is all this "flight time" talk from a CAA "CAP" or from the only relevant document the ANO?

What we used to call the ANO has been a CAA CAP for a long time. (CAP393)

MJ:ok:

Ps. Dave: Fantastic job with the Table above!:D

PA28181
16th Feb 2015, 13:22
I think you will find that it is "contained" in CAP 393 but the opening page say's it all.

Air Navigation: The Order and Regulations
Published for the use of those concerned with air navigation,
but not to be treated as authoritative (see Foreword)
CAP
393

I believe no CAA "CAP" has any legal standing at all?

(Standby for major thread drift alert...........)

DaveW
16th Feb 2015, 13:24
It seems we disagree on what has been written down clearly by the regulator here. I consider it to be absolutely clear and unambiguous that "flight time" cannot include pax time.

In other news: Twenty-three.

That is the number of angels that can dance on the head of a pin.

Mach Jump
16th Feb 2015, 13:31
I consider it to be absolutely clear and unambiguous that "flight time" cannot include pax time.

Well, I think the onus is on you then Dave, to show us where it is made clear.


MJ:ok:

Ps. Just playing Devil's Advocate here. I don't think it should be included either, but I can't see where it's excluded.

DaveW
16th Feb 2015, 13:40
Well, I think the onus is on you then Dave...

Dream on: Life's too short.

Why it doesn't matter: A reasonable person would not even be considering any other interpretation.

Mach Jump
16th Feb 2015, 13:46
A reasonable person would not even be considering any other interpretation.

If everyone was 'reasonable' we wouldn't need Regulations.

Personally, I don't think we need this one anyway. All this periodic experience nonsense should be done away with altogether, and just the 'flight with an Instructor' kept to qualify for Revalidation.

Dave's excellent table shows just how absurdly complex this area of Licence/Rating validity has become. I seriously doubt that more than half the Pilots in the UK even bother to keep track of their Licence/Rating validity any more, or that the CAA could successfully prosecute anyone for having an invalid Licence/Rating.


MJ:ok:

ChickenHouse
16th Feb 2015, 14:07
The old devil's advocate game ... I think we are far too close to reality to judge our regulators. Yes, it is their job to define things clear and unambiguously, but the problem is - the reality is not. There are authorities which are aware of it and know they are partly perpendicular to reality - these are the ones to deal nicely with, and there are authorities, which did forget this fact and are consequently almost brain dead and a waste of time to talk to.

I insist, you are able to log all you want in your log book - let it PAX in CAT time or whatever you want, you could even possess a pilot log book without being a pilot ! - but which part you are able to present for a revalidation of a license is a different animal. You can be nice to your FE and only write down things which can be counted for license renewal, or you can write a diary where the FE will kill you for the time he/she needs to dig through your mud of lines.

I can not account for all future possible needed categories in my flight book, so I tend to over document, which was quite nice when I had to add my X-Country experience according to FAA definition "flight hours in flights departing from airport A to full-stop land at airport B with a direct line distance of over 50 nautical miles" - do YOU track this in your flight records for the case FAA needs it for a validation?

For the sake of simplicity I also vote to throw all that complicated experience-based lying to the waste bin of history and go for a simple 1h FE flight every 24 month.

PA28181
16th Feb 2015, 14:15
I don't think I fully understood a word of that...............

BillieBob
16th Feb 2015, 16:59
What we used to call the ANO has been a CAA CAP for a long time. (CAP393)No, what we used to call the ANO is still called the ANO (SI 2009 No.3015). An edited copy of the ANO is included as Section 1 of CAP393 but it is only the SI itself that has any legal standing.

The definition of flight time is included in FCL.010 but does not help resolve the issue of whether, for the purposes of revalidation, passenger time may be counted. If anyone really thinks that it is reasonable to count passenger time, I suggest they should go ahead and try to find an FE who will sign the revalidation certificate on that basis.

Mach Jump
16th Feb 2015, 18:17
No, what we used to call the ANO is still called the ANO (SI 2009 No.3015). An edited copy of the ANO is included as Section 1 of CAP393 but it is only the SI itself that has any legal standing.

Thanks, BB

If anyone really thinks that it is reasonable to count passenger time, I suggest they should go ahead and try to find an FE who will sign the revalidation certificate on that basis.

I don't think any of us think it's reasonable, BB.

The question is, as an FE, on what basis could you refuse?


MJ:ok:

Pete O'Tewbe
16th Feb 2015, 20:07
From Article 7 of Regulation (EC) No 216/2008:

2. 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.

From Commission Regulation (EU) No 1178/2011:

Pilots involved in the operation of certain aircraft, as well as flight simulation training devices, persons and organisations involved in training, testing or checking of those pilots, have to comply with the relevant essential requirements set out in Annex III to Regulation (EC) No 216/2008. According to that Regulation pilots as well as persons and organisations involved in their training should be certified once they have been found to comply with essential requirements.

Note: Annex III referred to above covers essential requirements for pilot licencing referred to in Article 7

From Annex 1 to Commission Regulation (EU) No 1178/2011:

FCL.700
(a) Except in the case of the LAPL, SPL and BPL, holders of a pilot licence shall not act in any capacity as pilots of an aircraft 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.

It is my opinion that the quotations above amount to the requirement for, inter alia, a pilot to be properly licenced and rated in order to operate certain (i.e. most) "EASA" aircraft.

From Annex 1 to Commission Regulation (EU) 1178/2011:

FCL.740.A Revalidation of class and type ratings — aeroplanes

(a) [..]

(b) Revalidation of single-pilot single-engine class ratings.

(1) Single-engine piston aeroplane class ratings and TMG ratings. For revalidation of single-pilot single-engine piston aeroplane class ratings or TMG class ratings the applicant shall:

(i) within the 3 months preceding the expiry date of the rating, pass a proficiency check in the relevant class in accordance with Appendix 9 to this Part with an examiner; or

(ii) within the 12 months preceding the expiry date of the rating, complete 12 hours of flight time in the relevant class, including:

— 6 hours as PIC,

— 12 take-offs and 12 landings, and

— a training flight of at least 1 hour with a flight instructor (FI) or a class rating instructor (CRI). Applicants shall be exempted from this flight if they have passed a class or type rating proficiency check or skill test in any other class or type of aeroplane.

(2) When applicants hold both a single-engine piston aeroplane-land class rating and a TMG rating, they may complete the requirements of (1) in either class, and achieve revalidation of both ratings.

(3) [..]

From Annex 1 to Commission Regulation (EU) No 1178/2011:

FCL.050 Recording of flight time
The pilot shall keep a reliable record of the details of all flights flown in a form and manner established by the competent authority.

From AMC and GM to Part-FCL:

AMC1 FCL.050 Recording of flight time

(a) The record of the flights flown should contain at least the following information:

(1) [..]

(2) [..]

(3) [..]

(4) details on pilot function, namely PIC, including solo, SPIC and PICUS time, co-pilot, dual, FI or FE;

Anyone see any mention of the recording of time spent as a passenger being acceptable for the purposes of licencing?

Mach Jump
16th Feb 2015, 21:27
Thanks, Peter. I appreciate the time, and effort that must have taken.

The fact remains though, that nothing there excludes the possibility that flight time as a passenger is included within the term 'flight time'.

AMC1 FCL.050 Recording of flight time

(a) The record of the flights flown should contain at least the following information:
(1) [..]

(2) [..]

(3) [..]

(4) details on pilot function, namely PIC, including solo, SPIC and PICUS time, co-pilot, dual, FI or FE;

Unless, on closer examination, we can take this as a de facto definition of the term 'flight time'?



MJ:ok:

PA28181
16th Feb 2015, 21:36
The fact remains though, that nothing there excludes the possibility that flight time as a passenger is included within the term 'flight time'.

A hard reality check maybe in order.

From the dictionary:

Reality is the conjectured state of things as they actually exist, rather than as they may appear or might be imagined. In a wider definition,

Mach Jump
16th Feb 2015, 22:22
(4) details on pilot function, namely PIC, including solo, SPIC and PICUS time, co-pilot, dual, FI or FE;

Ok. I'm convinced.

Although it's not as elegant as a specific definition, I accept that (4) above amounts to the same thing, in that it effectively limits 'flight time' to some form of crew function.

Thanks for everyone's input, particularly as it's such an obscure point.

I hope the OP appreciates everyone's efforts.

MJ:ok:

dera
17th Feb 2015, 01:02
I'm not sure about EASA aircraft, but AN-2 is a SEP that needs 2 pilots :)

Mach Jump
17th Feb 2015, 01:08
...but AN-2 is a SEP that needs 2 pilots

Really? I didn't know that. In that case, if it's minimum crew is 2 pilots, you could log P2.


MJ:ok:

TheOddOne
17th Feb 2015, 07:43
I seriously doubt that more than half the Pilots in the UK even bother to keep track of their Licence/Rating validity any more, or that the CAA could successfully prosecute anyone for having an invalid Licence/Rating.

MJ,

I'm not sure I totally agree with that, but you might be right about the latter.
Personally, I feel the need to satisfy a far more onerous body than our regulator, namely the insurance company. Believe me, they go through validity with a fine-tooth comb. For this reason, I keep a meticulous record of all flights I'm responsible for.

TOO

Whopity
21st Feb 2015, 10:41
but AN-2 is a SEP that needs 2 pilotsIn which case it would qualify for a Type rating and would not be SEP!

englishal
21st Feb 2015, 11:11
What would be best is if they delegated the 2 yearly flight completely to a FI who then endorses the logbook saying that the requirements had been met, without the need for a FE.

Otherwise you might just as well do the flight with a FE in the first place and be done with it. There are more FIs or CRIs available than FEs, and anyone who is not part of a flying club or at an airfields with an FE has to go out and find one.

nick14
21st Feb 2015, 11:30
Flight time is defined for all aircraft categories:

For aeroplanes, touring motor gliders and powered lift, it means the total time from the moment an aircraft first moves for the purpose of taking off until the moment it finally comes to rest at the end of the flight.

So that means brakes off to brakes on. As you cannot be p2 in an SEP, it leads to the fact that there is only two capacities, PUT and PIC.

All this musing is nonsense and people should not try to find sneaky ways to get round the law.

Mach Jump
21st Feb 2015, 12:00
In which case it would qualify for a Type rating and would not be SEP!

I'm sure you meant 'not SPA', Whopity.;)


MJ:ok:

DaveW
21st Feb 2015, 16:35
Here's the issued version of the draft table englishal posted earlier in the thread.

https://dl.dropboxusercontent.com/u/66162937/Posted_Files/20150219-Reval-by-Experience-800pxl-Issue1-1.bmp

PDF version here (https://dl.dropboxusercontent.com/u/66162937/Posted_Files/20150219-Reval-by-Experience-ISSUE_1-1.pdf).

Please don't post images larger than 800 x 800 - Mods

Well, you could have resized it - or PM'd me asking me to do it - rather than peremptorily deleting it. It's supposed to be useful for people.

Whopity
21st Feb 2015, 18:08
AMC1 FCL.050 Recording of flight time(b) Logging of time:

(1) PIC flight time:

(i) the holder of a licence may log as PIC time all of the flight time during which he or she is the PIC;

(4) instruction time: a summary of all time logged by an applicant for a licence or rating as flight instruction, instrument flight instruction, instrument ground time, etc., may be logged if certified by the appropriately rated or authorised instructor from whom it was received;
etc

I'm sure you meant 'not SPA', No, if an aircraft is deemed to be complex enought to require two pilots it would not be certificated as SEP!

Mach Jump
21st Feb 2015, 23:12
Well, you could have resized it - or PM'd me asking me to do it - rather than peremptorily deleting it. It's supposed to be useful for people.

Dave:

Regardless of the size, which we all know isn't that important, thanks for the huge effort that this table must have taken to compile.

I'm sure it will be of use to many people.

No, if an aircraft is deemed to be complex enough to require two pilots it would not be certificated as SEP!

I'm intrigued by this.

Has anyone on PPRune got an AN2 Type Rating?


MJ:ok:

DaveW
21st Feb 2015, 23:20
Thank you, Mach Jump - that's appreciated. I had a fair amount of help!

flybymike
21st Feb 2015, 23:41
No, if an aircraft is deemed to be complex enough to require two pilots it would not be certificated as SEP!
I would have thought that a single engine piston aircraft was a single engine piston aircraft no matter how many crew were required, and there is certainly plenty of controversy here about whether it is a single pilot or multi crew aircraft.
http://www.pprune.org/private-flying/418656-antonov-2-multi-pilot-plane.html

Level Attitude
21st Feb 2015, 23:45
Any aircraft that is thrust forward by a propeller powered by one, piston driven, engine is by definition an SEP.

However not all SEPs fall in to the EASA 'SEP Class' - The 'TMG Class' for example.

Given the context of this Thread I am sure that when whopity said "SEP" he was simply abbreviating 'SEP Class'

I wonder what Class an aircraft driven by a Wankel engine falls in to? :)


I'm not sure about EASA aircraft, but AN-2 is a SEP that needs 2 pilotsIf it needs two pilots it does not fall within the 'SEP Class'.

The 'SEP Class' means Non-High Performance, Single Pilot, SEPs. Any other SEP (which is not a TMG) would need a Type (or possibly an HP Class) Rating that would only be valid for one year and could not be revalidated by experience.

Revalidating an SEP Class Rating by experience requires that experience to have been obtained in an 'SEP Class' - with certain possible exceptions (eg valid experience gained in a TMG) which are stated in the regulations.

Since it is a Single Pilot Rating I cannot see that any Multi Pilot flying experience could be counted towards the revalidation requirements of an SEP Rating.

BillieBob
21st Feb 2015, 23:48
According to the AN-2 flight manual:

The minimum number of airplane crew are two persons with current authorisation for performing aviation operations.

Depending on the type of flight the airplane crew shall consists of:

- in flights according to VFR rules - two pilots or pilot and navigator or pilot and flight engineer;

- in flights acc. to IFR rules - two pilots or pilot and navigator;

- in agricultural flights - two pilots or pilot and flight engineer.

Since, in every case, there is the option not to carry two pilots, the AN-2 cannot be classified as a MPA and being below 5700kg MTOW, therefore, can be flown with an SEP class rating, as I occasionally have.

Mach Jump
21st Feb 2015, 23:58
The 'SEP Class' means Non-High Performance, Single Pilot, SEPs. Any other SEP (which is not a TMG) would need a Type (or possibly an HP Class) Rating

Funny, twelve or so years ago, when The CAA took away my Group A and B Ratings, and replaced them with JAA SEP, and MEP Class Ratings, and I complained bitterly about the privileges I lost in the process, they they said that in exchange for losing all my turbine privileges, I could now fly any piston engine aircraft, of any size I wanted!:*

...and being below 5700kg MTOW,

No weight limit now since JAA, BB


MJ:ok:

Level Attitude
22nd Feb 2015, 00:09
To be flown on an SEP Rating it is not that the AN2 is not an MPA it is that it must be an SPA.

Part-FCL Definitions: ‘Single-pilot aircraft’ means an aircraft certificated for operation by one pilot.Guess it depends on whether the above means 'one pilot by themselves' or 'one pilot even if they need other non-pilot crew to help them'.

I don't know the answer, but I would look to see how EASA has classified this particular aircraft?

chrisbl
24th Feb 2015, 01:09
What would be best is if they delegated the 2 yearly flight completely to a FI who then endorses the logbook saying that the requirements had been met, without the need for a FE.

Otherwise you might just as well do the flight with a FE in the first place and be done with it. There are more FIs or CRIs available than FEs, and anyone who is not part of a flying club or at an airfields with an FE has to go out and find one.

From the 8th April this will be the case

http://www.caa.co.uk/docs/33/InformationNotice2014188.pdf

hoodie
24th Feb 2015, 08:01
Not just any old FI, though - they will need to be individually authorised to do this.

2.10 Revalidation of SEP and TMG ratings by FI(A) and CRI(A)
A new paragraph FCL.945 is to be added to make provision for instructors who conduct the training flight for SEP or TMG revalidation by experience to be individually authorised by the Competent Authority to endorse the revalidation page of the pilot’s licence. This will enable the CAA to introduce a Part-FCL equivalent to the “Revalidation Examiner Certificate”
previously issued under national rules. Only instructors with the privileges to instruct for the SEP and/or TMG rating will be eligible to be authorised.

I'm not quite sure why that Para 2.10 refers to CRI(A); individuals with only that qualification can't instruct for the SEP/TMG Ratings, so surely are ineligible.

S-Works
24th Feb 2015, 08:10
A CRI(A) with SEP and TMG can conduct the training flight for those ratings. Where a person also holds a licence and wishes to add either of those ratings the CRI(A) can also can conduct the training.

In fact the very purpose of a CRI(A) is to add ratings to a licence......

hoodie
24th Feb 2015, 11:56
OK, thanks - I wasn't aware that a CRI could instruct for TMG if student holds a current SEP Rating (and vice versa). Then again, I suppose the clue is in the name...

Of course, there are many other Ratings a CRI can't instruct for: Night, Aeros (?), IR(R) etc.

nick14
24th Feb 2015, 14:05
Aeros they can if so qualified and signed off, as they can for a towing rating.

S-Works
24th Feb 2015, 14:36
They can also add an IRI(A) and teach for both the IR(A) and the IRR(A) or IMCr..... ;)

hoodie
24th Feb 2015, 22:10
If they have at least 800 hours under IFR first.

They can also add an ATPL, and fly 600 pax to Dubai.

Neilix
2nd Mar 2015, 19:17
Hi,


I hold a PPL(A) on an EASA licence. My question relates to the currency of my licence. The expiry date on my SEP(L) class rating indicates it expired on the 30th June 2014. However, on the 30th June 2014 I had met all the requirements of the "revalidation by experience" ie number of hours, t/o & landings, P1 hours, etc., including an IR(A) revalidation (>1hr and flown ie not sim) in September 2013. Happy I was current, I assumed my licence was still valid. An instructor, however, suggested that my licence is not current as it lacks a sign-off from an examiner, specifically for the purpose of SEP(L) revalidation. Naturally, the IR(A) reval. was passed and endorsed, so no issues with my flying (that was spotted anyway!).


A quote from the UK CAA's website states...


"In this example, to make sure that an SEP(land) rating does not expire and continues for another 2 year period, it can be revalidated by:


completing 12 hours of flight time in SEP(land) aircraft including 6 hours as pilot in command, 12 take-off and 12 landings, and up to three training flights totalling of at least 1 hour with a flight instructor or class rating instructor (or passed a class or type rating proficiency check or skills test in any other class or type of aeroplane) in the 12 months before the rating expires."...



No mention of a sign-off is made.
Anyone have a view as to whether I actually have a valid licence?
Thanks.

BEagle
3rd Mar 2015, 06:42
If a Class Rating in your licence has passed its validity expiry date, you may not fly as PIC on that class of aeroplane.

You will need to renew your SEP Class Rating by passing a renewal Proficiency Check with an Examiner; the licence may not be signed retrospectively.

Are you really admitting that you haven't had a valid SEP Class Rating in your licence since June 2014?

The fact that you held a valid IR(A) until (I assume) Sep 2014 is irrelevant; a Part-FCL licence has no expiry date, whereas ratings and certificates contained therein certainly do.

Wasn't this covered during your Air Law and Op. Procs theoretical knowledge study?

Mach Jump
3rd Mar 2015, 08:25
No mention of a sign-off is made.
Anyone have a view as to whether I actually have a valid licence?
Thanks.

Hi Neilix. Welcome to PPRune.

I'm afraid you have fallen for an all too popular misconception.

The minimum experience requirements for Revalidation by Experience of an SEP Class Rating are just the minimum you need to have in your logbook to enable you to revalidate the rating without a Flight Test.

Once you have completed the minimum requirements, an Authorised Person must endorse your licence to extend the validity of your SEP Class Rating for a further 2 years. Although other EASA National Authorities require you to send it to them for endosement, for UK issued EASA Licences, the UK CAA have authorised UK Flight Examiners to do this on their behalf.

As BEagle says, even if you met the minimum requirements before the expiry date of the Rating, it cannot be endorsed retrospectively and your SEP Class Rating has been invalid since 30th June 2014.

Your SEP Class Rating must now be 'Renewed' rather than 'Revalidated'.

To Renew, you must visit an ATO/RF (Flying School) and have the Head of Training there assess what, if any, training you will require to enable you to take the Flight Test (Proficiency Check). Once you have completed any required training, you will be given a Course Completion Certificate (CCC) which you will need to present to the Examiner before taking the Proficiency Check.

On sucessful completion of the Proficiency Check, The Examiner will Endorse your Licence to renew your SEP Class Rating from the date of the Test, for another 2 years.


MJ:ok:

Level Attitude
3rd Mar 2015, 12:23
MJ covers it very well but it is worth re-emphasising some points as a lot of (especially new) pilots seem confused.
I hold a PPL(A) on an EASA licenceNO - You don't.
You hold an EASA PPL on which there are Ratings.

Although it needs a valid Medical to be used, The Licence does not expire. The Ratings (that you have mentioned) do.

When you pass a Medical exam you have met the requirements to be issued a with Medical Certificate. But you do not actually have a valid Medical until you have been given the signed piece of paper.

When you applied for your PPL you had met the requirements to be issued with a Licence but you did not have a PPL until you had received the piece of paper and signed it yourself.

Rating Revalidation is the same:
For SEP(Land) there are two methods of meeting the requirements:
a) Passing a Proficiency Check with an Examiner
or
b) Having the required experience (as you correctly stated)
Once the requirements are met, that entitle you to Revalidate, you still need to actually Revalidate (in this case get an Examiner to complete the entry in the Ratings section of your Licence)

No Examiner entry = No Revalidation

BillieBob
3rd Mar 2015, 14:21
But you do not actually have a valid Medical until you have been given the signed piece of paper......and have signed it yourself.

Level Attitude
3rd Mar 2015, 15:12
But you do not actually have a valid Medical until you have been given the signed piece of paper. .....and have signed it yourself. True enough but my AME won't actually give me (he won't let go of) the piece of paper until I have signed it.

Neilix
3rd Mar 2015, 18:16
Thanks to all for taking the time to respond.

In answer to your question BEagle, yes, I'm admitting that I haven't had a valid SEP Class Rating in my licence since June 2014...then again, neither have I flown since then. The reference I made regarding my IR(A) renewal in September 2013 was only to illustrate that I had met the criteria of having completed >1hr with an instructor in the preceeding 12 months prior to expiry.



Whilst a number of responses have said that the revalidation (by experience) endorsement must be made prior to expiry, I can't find anything on the CAA website that states that. Neither can I find any reference to it in an old version of LASORS. Can anybody point me to a relevant clause in anything official?

Cheers.

Mach Jump
3rd Mar 2015, 21:06
Whilst a number of responses have said that the revalidation (by experience) endorsement must be made prior to expiry, I can't find anything on the CAA website that states that. Neither can I find any reference to it in an old version of LASORS. Can anybody point me to a relevant clause in anything official?

Although I cannot find the specific wording you seek, the following quote from Part.FCL makes it clear that, once expired, Class and Type Ratings cannot be 'Revalidated' but must be 'Renewed'.


FCL.740 Validity and renewal of class and type ratings

(a) The period of validity of class and type ratings shall be 1 year, except for singlepilot single-engine class ratings, for which the period of validity shall be 2 years, unless otherwise determined by the operational suitability data, established in accordance with Part-21

(b) Renewal. If a class or type rating has expired, the applicant shall:

(1) take refresher training at an ATO, when necessary to reach the level of
proficiency necessary to safely operate the relevant class or type of
aeroplane; and

(2) pass a proficiency check in accordance with Appendix 9 to Part-FCL.


MJ:ok:

BillieBob
3rd Mar 2015, 21:15
I can't find anything on the CAA website that states that.That is not surprising since the CAA is no longer a rulemaking body (much as they might like to think otherwise). It might be better to consult the EU Regulation, as MJ has done.

Level Attitude
3rd Mar 2015, 22:40
Neither can I find any reference to it in an old version of LASORS. Can anybody point me to a relevant clause in anything official?LASORS is well out of date, it is superceded by CAP804 which itself quotes from Part-FCL in respect of EASA Licensing:

Part-FCL Page 9
FCL.010 Definitions

‘Renewal’ (of, e.g. a rating or certificate) means the administrative action taken after a rating or certificate has lapsed for the purpose of renewing the privileges of the rating or certificate for a further specified period consequent upon the fulfilment of specified requirements.

‘Revalidation’ (of, e.g. a rating or certificate) means the administrative action taken within the period of validity of a rating or certificate which allows the holder to continue to exercise the privileges of a rating or certificate for a further specified period consequent upon the fulfilment of specified requirements.Many people use the terms "Renewal' and 'Revalidation' interchangeably - this is wrong as they have specific, different meanings.

the revalidation (by experience) endorsement must be made prior to expiryAlthough we know what you mean, this sentence is wrong.

It should be: "Revalidation (of a Rating) must be made prior to expiry"
- Doesn't matter how the requirements were met
- A revalidation is not 'endorsed'. It is the (administrative) action of an Examiner a) Filling out the line in your Ratings' section, b) Completing the required form and c) Sending the form to the CAA that is the Revalidation.

NB: I know MJ used the term "endorsed" first, and most pilots don't care about the forms as Examiners usually take care of these (as they are required to do).

Neilix
4th Mar 2015, 16:46
Thanks again to all, for your informative comments.


Neil