Sorry, it's another JAR>EASA revalidation question...

[tmmorris]

Currently I hold a JAR PPL (expires 2016) with SEP and IMC ratings. SEP expires 13 Aug, IMC expires 15 Aug. I had hoped to revalidate both by taking the IMCR test but for aircraft serviceability reasons this looks unlikely by 15th, though not impossible. As I write I qualify for revalidation of the SEP by experience and I was going to take my logbook and licence to a friendly examiner this afternoon for a signature and complete form SRG1119B. I wasn't going to worry about the IMCR as if it lapses I can just retake the test anyway.

What I can't work out is:

a. Can I revalidate the SEP rating by experience without applying for a licence reissue as EASA? Difference web pages on the CAA site contradict each other.
b. If not, what happens with the IMCR? If it's not valid when they process the paperwork will I lose it?
c. How do I apply for the IMCR to be transferred to IR(R)? The application form for reissue as EASA doesn't include any mention of IMCR though of course the IR is mentioned. Do I simply state I have an IR? [after all as my licence is 'deemed' EASA presumably I already do!]

If the answer to a. is no, and b. is yes, then I need to get the IMCR revalidated urgently so it doesn't lapse and might need to go to another club to do so, hence the urgency!

[Mach Jump]

Don't be sorry! := We all struggle to keep track of this.

a. Can I revalidate the SEP rating by experience without applying for a licence reissue as EASA? Difference web pages on the CAA site contradict each other.

Yes. SRG 1119E is the form you need for that. 1119B is the form you use if you are sending your logbook and Licence to the CAA for Revalidation, rather than having a Field Examiner do it.

b. If not, what happens with the IMCR? If it's not valid when they process the paperwork will I lose it?

If you apply for re-issue in EASA format with an expired IMC, you will loose it, but it will be put on the back of the new Licence to show that you once had it. It can still be Renewed in the normal way by a Test, but you then have to apply to the CAA to make it valid again, (with a fee, of course) and have it transferred onto the front of the Licence.

c. How do I apply for the IMCR to be transferred to IR(R)? The application form for reissue as EASA doesn't include any mention of IMCR though of course the IR is mentioned. Do I simply state I have an IR? [after all as my licence is 'deemed' EASA presumably I already do!]

EASA recognise the IMCR as an IR(R) (Instrument Rating Restricted) and that is why there is no mention of IMC on the form. Just claim a valid IR(R) and they will add it to your EASA licence.


MJ:ok:

Ps.
I had hoped to revalidate both by taking the IMCR test...

Maybe I misunderstood what you typed there, but the IMCR Test doesn't count as an SEP Revalidation Proficiency check.

MJ

[tmmorris]

Thanks, very helpful. The plan was to use the IMCR test as the flight with an instructor, which is what I've done before. Instead, I did a type conversion onto the club's new Firefly (which was useful, as I'd got very lazy about practising PFLs and was rightly brought up short by the instructor who made me do several).

So I will do the revalidation of the SEP using SRG1119E, and arrange the IMCR test when the aircraft have been fixed (annoyingly the club's two nicely instrumented aircraft are both u/s at the same time though A and C is working on both...)

Just to check - I am right that letting the IMCR lapse only means I can't use the IMCR privileges until I've taken the test? (Assuming the lapse is only a week or two.) No retraining required?

[Mach Jump]

Just to check - I am right that letting the IMCR lapse only means I can't use the IMCR privileges until I've taken the test? (Assuming the lapse is only a week or two.) No retraining required?

Yes, that's correct.

Instead, I did a type conversion onto the club's new Firefly

That's ok, so long as it was at least an hour, and the Instructor countersigned the entry in your logbook.

MJ:ok:

[tmmorris]

Thanks, affirm to both!

[DaveW]

... and the Instructor countersigned the entry in your logbook.

MJ, do you have chapter & verse for the regulation that requires an Instructor to countersign the entry you intend to use for Reval by Experience?

I've never been able to find it.

[Mach Jump]

Under JAA there was never any requirement to sign the entry, it was just something the CAA invented in their efforts to 'gold plate' the 'training flight of at least 1 hour' into a Test.

Under EASA, all training flights have to be countersigned by the Instructor, whatever their purpose, or they don't count.


MJ:ok:

Ps. I can't, for the moment, remember where this is stated, but I'll try to find it and come back with the reference, unless someone beats me to it!

MJ

[Whopity]

do you have chapter & verse for the regulation that requires an Instructor to countersign the entry you intend to use for Reval by Experience?
AMC1 FCL.050 instruction time:
(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;

[tmmorris]

...and thanks to advice above, SEP now revalidated and form on its way to the CAA

[DaveW]

Thanks MJ and Whopity.

However, that AMC quote refers to "a summary", and specifically for a licence or rating. It doesn't appear to relate to normal logbook entries.

[Mach Jump]

DaveW:

As I recall, the AMC quoted by Whopity was introduced to allow a relaxation of the requirement to sign every entry, in circumstances where a course of training was being undertaken, in which case, a series of flights with a particular instructor could be signed for as a summary.

I haven't yet been able to find the original requirement to sign every entry. I'll let you know when I do.


MJ:ok:

[DaveW]

Thanks, MJ: Appreciated.

[BillieBob]

AMC1 FCL.050(i)(10)

"column 12: the 'remarks' column may be used to record details of the flight at the holder's discretion. The following entries, however, should always be made:

(iv) signature of instructor if flight is part of an SEP or TMG class rating revalidation"

[DaveW]

Thanks, BillieBob. I see it's "should" not "must", which allows for later nomination of a PUT flight as the revalidation hour.

[Mach Jump]

Yes. Thanks, BB. That answers DaveW's question about the Revalidation, but I still haven't been able to find a reference in Part.FCL, or the AMCs that supports my statement that all instruction should be signed for. So I'll continue to search for that.

On the Revalidation flight, though, as long as instruction is signed for, you can then pick any hour of instruction that falls within the prescribed period to use for revalidation. It doesn't have to be nominated as such at the time of the flight.


MJ:ok:

[DaveW]

On the Revalidation flight, though, as long as instruction is signed for...

MJ, this is exactly my question. I haven't yet seen anything that says it absolutely has to be signed for in the logbook.

There needs to be certification* if the training is for licence or rating, that's clear - and if summarised in the logbook, then AMC1 FCL.050 says the logbook needs to be certified accordingly.

But if it's NOT training for a licence or rating, as many instructional flights will be, then my question stands: Must the logbook be signed?


*But not necessarily in the logbook itself - that's what (e.g.) the Head of Training declaration on the relevant SRG forms when applying for licence/rating does.

[Mach Jump]

Let's not confuse the issue with HoT Certification. :eek:

AMC1 FCL.050 instruction time:
Quote:
(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;

This wording only makes sense as an alleviation of an overall requirement for Instructors to sign for each flight.

I'm convinced that I have read that requirement, but, so far, I can't find it.

I wouldn't put it past EASA to have amended Part.FCL to delete that bit, and forgot to delete the modifying bit of the AMC!

I'll spend some time tomorrow looking for the relevant reference.


MJ:ok:

[BillieBob]

I see it's "should" not "must", which allows for later nomination of a PUT flight as the revalidation hour.Only if there is an approved Alternative Means of Compliance in existence that allows it.

[DaveW]

I'm clearly missing something, as I don't understand that, BB.

The existing AMC recommends but doesn't demand a logbook signature (i.e. it says "should" not "must").

Why would there need to be an additional AMC statement to deal with the situation where the current AMC recommendation ("should") is not taken up?

The situation is surely in practice anyway covered by the Form 1119x asks for the date of the nominated Revalidation flight, which is in the logbook (along with Instructor name as P1) for the Examiner to see when signing for Reval by Exp.

(The above assumes that MJ or anyone else doesn't find an over-riding requirement for all instructional flights to be signed for every time, which it appears may not exist).

The reason this is interesting to me is that in the last year or so I have trained for 3 Ratings/Certificates and engaged with 3 different training organisations. None of them have had their instructors sign every logbook entry.

(Edit: Actually, it is 4 training organisations, as the lack of logbook signatures hasn't been queried by the examiner who signed my Cert of Reval.)

[BillieBob]

EU legislation is split into 'hard' law (the regulations) and 'soft' law (the AMCs). Where only one AMC is published, that is the only means of complying with the associated Regulation. It is open to anyone to propose to their competent authority an alternative means of compliance with the Regulation but, until this is accepted, there remains only one means of compliance.

Take, for example, the requirement for a minimum of 100 hours of theoretical knowledge instruction for the PPL that exists in AMC1 FCL.210; FCL.215. Until the UK proposed to EASA an alternative means of compliance, all ATOs had to ensure that a minimum of 100 hours TK instruction was completed prior to taking the last of the PPL examinations. There is now no minimum amount of PPL TK instruction required in the UK but 100 hours remains the minimum in the rest of Europe.

In the case of FCL.050, there is no AltMoC in the UK and so the only way to comply with the Regulation is to comply with the AMC. You can propose an AltMoC to remove the requirement that all flights used to revalidate a SEP class rating are countersigned but until then it remains 'soft' law.

[DaveW]

Yes - but because it says "should" (i.e. not mandatory) it is apparently still possible to comply with the AMC without having every PUT entry in a logbook signed.

[Mach Jump]

Well, I have searched in vain for the reference requiring Instructors to sign every logbook entry, so, unless anyone can come up with anything, I'm going to assume that it no longer exists.

However, DaveW's comments about the difference between 'should' and 'must' notwithstanding, I would advise pilots to ask the Instructor to sign the logbook entries for any instruction they receive between Revalidations, if only because most Examiners will require it for Revalidation.


MJ:ok:

[DaveW]

Thanks for taking the time to search, MJ.

[BillieBob]

I never suggested that it was necessary to have every dual flight countersigned, merely those that were to be used to comply with FCL.740.A(b)(1)(ii).

[DaveW]

OK. But I still maintain that's just daft, and is anyway not mandatory as written.

And why is it written anyway? Why do some Examiners "require" it (not all do)? What's the logic behind it, particularly since you as the pilot may not know until later that you wish to nominate that particular flight as your revalidation hour? There is no requirement to pre-nominate.

Some may say that we are discussing number of angels on pin heads here - but I say not. This is just one more pointless EASA "rule" that makes a PPL's life unnecessarily complex and difficult to understand.

What's so unfashionable about "simple and unambiguous"?