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thing
4th Oct 2016, 20:50
Hi all, I have a EASA full fat PPL (A). Due to recent medical problems I can now only get a LAPL medical (which I got from my AME the other day) unless I want to do several expensive tests to verify my fitness for a class II. The only thing I can see that is different between the PPL and LAPL is I won't be able to use my IR(R) anymore. I don't fly anything bigger than a four seater.

My question is this, I'm off for a check flight soon as I haven't flown for a while. I have my EASA license but now with a LAPL medical folded up inside it. Do I need to convert the EASA PPL license to a LAPL one before I can take passengers up and if so is there a form that I need to fill in and does anyone have a link for it!

I did have a poo brown JAR PPL before I converted it to an EASA. Some people that know more about licensing than me have suggested that as I held a poo brown one then I would be OK to fly on the LAPL medical until april next year, or maybe 2018.

Hopefully someone can point me in the correct (legal) direction as I don't want to have a prang and then find out I wasn't legally supposed to be flying.

BEagle
4th Oct 2016, 21:24
In order to exercise LAPL privileges, you must re-grade your Part-FCL PPL to a Part-FCL LAPL using http://publicapps.caa.co.uk/docs/33/SRG1190Issue04enabled.pdf and paying the relevant fee. You cannot simply use a PPL restricted to LAPL-level privileges with a LAPL medical certificate.

The CAA has also introduced some totally baffling 'self-certification' medical scheme, but the legality of using it for anything other than for flying non-EASA aircraft on a legacy NPPL or UK PPL (not a JAR-FCL PPL) is open to doubt - even the CAA isn't sure...:rolleyes: In your case, I'd recommend you forget about it and just take the LAPL route.

thing
4th Oct 2016, 21:40
Thank you Beags. They only want a mere £214...:hmm: I think I'll have a look and see how much those extra medical tests are going to cost me first.

BEagle
5th Oct 2016, 08:05
Re-grading a Part-FCL PPL to a LAPL isn't an initial issue and shouldn't cost the figure you quote.

Their stupidly confusing scheme of charges doesn't specifically include 'Re-grade of Part-FCL PPL to LAPL', but on the website they quote £40 for 'Conversion from UK issued JAR licence to a LAPL', so I cannot see it costing any more for re-grade of a Part-FCL PPL to a LAPL....

ifitaintboeing
5th Oct 2016, 08:56
At the moment, you are permitted to validate your EASA PPL(A) with a medical self-declaration (http://publicapps.caa.co.uk/modalapplication.aspx?appid=11&mode=detail&id=7493) (not LAPL medical) which will allow you to exercise privileges in accordance with the ANO. See CAP 1441 (http://publicapps.caa.co.uk/docs/33/CAP1441MedicalLicenceTable210916.pdf) for more details. When using this combination, you are limited to the privileges of a LAPL holder and UK airspace.

This will allow you to fly until you submit your PPL for a LAPL re-grade. Since you are only allowed to hold one EASA licence for each category of aircraft, you will have to forfeit your EASA PPL when you apply for a LAPL. The gotcha is that the only route back to a PPL is via the training course and PPL Skill Test, so if it's a temporary downgrade of your medical I would recommend using the self-declaration or NPPL route.

ifitiaint...

BEagle
5th Oct 2016, 12:25
ifitaint, as you well know that's an uncertain option whilst the CAA itself cannot yet agree.

It states quite clearly in section IX of page 3 of every Part-FCL licence that 'The privileges of the licence shall only be exercised if the holder has a valid medical certificate for the required privilege.' A self-declaration is NOT a medical certificate as defined in the Aircrew Regulation, because that has to be issued either by an AME or, where permitted under national law, a GP.

CAP1441 doesn't even concur with the CAA's own website, clubs are refusing to rent aircraft to 'self certified' pilots and we are now hearing that insurers are refusing cover.

So if I were you, thing, I'd avoid this self-certification nonsense and opt for the LAPL, where there is no doubt.

Oh and The gotcha is that the only route back to a PPL is via the training course and PPL Skill Test is incorrect, I've been advised - it'd only be a simple paperwork exercise.

thing
5th Oct 2016, 17:25
Re-grading a Part-FCL PPL to a LAPL isn't an initial issue and shouldn't cost the figure you quote.


I did the online application and there is no option other than to apply for an initial issue of LAPL, although when I put my CAA number in it asked whether I wanted to add my night rating...so it must know my licence history. I haven't paid for it yet and have shot an e-mail off to CAA asking for clarification. I expect an answer, er, sometime. I'm not so bothered about pootling around with an instructor (who is also a pal so we can go off for the day and I can put him down as instructing) it's taking up non pilot passengers where I want to be squeaky clean as you can imagine.

ifitaintboeing
5th Oct 2016, 23:13
is incorrect, I've been advised - it'd only be a simple paperwork exercise.

Can you point us to the published reference for that? Can't seem to find it in CAP 804 or on the CAA website.

CAP1441 doesn't even concur with the CAA's own website, clubs are refusing to rent aircraft to 'self certified' pilots and we are now hearing that insurers are refusing cover.

ANO 2016 renders an EASA Part-FCL licence with medical self-declaration valid as if it were a national licence for use in UK airspace. The CAA have published their interpretation of the legislation in CAP 1441 which permits this. Whatever internal discussions might or might not be going on, I just don't see the problem with exercising privileges as published by the CAA.

Which insurer(s) has/have refused cover?

ifitaint...

Whopity
6th Oct 2016, 07:08
ANO 2016 renders an EASA Part-FCL licence with medical self-declaration valid as if it were a national licence for use in UK airspace.Now that would be possible for a UK Registered Annex II aircraft but to do so for an EASA aircraft is saying the ANO now trumps the EASA Regulation!

BEagle
6th Oct 2016, 07:44
Indeed, Whopity! But there's a syllogistic argument at the CAA which is attempting to claim that, because they've allowed Part-FCL licences to be used to fly non-EASA aircraft, then they've been deemed directly equivalent to national licences, hence all regulations applicable to national licences apply equally. "A dog has 4 legs, 4-legged creatures include cats, therefore my dog is a cat....:rolleyes:"

The wise heads at the CAA are with you and me, Whopity - to exercise the privileges of a Part-FCL licence on an EASA aircraft, you must hold a Part-MED medical certificate. This might also be true for non-EASA aircraft:

The holder of a UK-issued Part-FCL compliant EU Pilotís Licence may take advantage of the Medical Declaration, but only exercising their privileges flying non-EASA aircraft. If they wish to operate an EASA aircraft they must hold a valid medical certificate appropriate to the privileges being exercised.

But others disagree....

The legitimacy of CAP 1441 cannot be assured as it doesn't support the CAA's own website statements - so anyone relying on it does so at their own considerable risk.

Incidentally, ifitaint, there are more than a few matters which you won't find in print. Give me a ring and I'll tell you why....

Mickey Kaye
6th Oct 2016, 08:03
I can't quite understand this.

Isn't this development a positive move and is being introduced on that fact that their is no evidence for medical for type of flying this declaration is for.

I would of thought that organisations such as AOPA would welcome such a move which many of their members and the wider GA community as a whole see as a positive move. As it reduces the cost if flying and yet has no impact on safety.

Now maybe there is some areas where aspects are not optimal but can't organisations such as AOPA/LAA/BMAA work with the CAA et al to smooth these areas out?

ifitaintboeing
6th Oct 2016, 08:18
Now that would be possible for a UK Registered Annex II aircraft but to do so for an EASA aircraft is saying the ANO now trumps the EASA Regulation!

A derogation exists (http://publicapps.caa.co.uk/modalapplication.aspx?catid=1&pagetype=65&appid=11&mode=detail&id=7351) which allows a licence granted or rendered valid under UK legislation to be used in EASA aircraft within UK airspace and within the privileges of a LAPL holder. This is what currently permits a UK PPL and NPPL holder to exercise their licence privileges in EASA aircraft. A Part-FCL licence with a self declaration is rendered valid within the UK ANO under Article 150(7).

Which insurer(s) has/have refused cover?

ifitaint...

Whopity
6th Oct 2016, 08:24
MK: the CAA is a regulator, their task is to ensure organisations and individuals comply with the Law. They cannot make Law or grant exemptions to EU Regulations; they can issue exemptions to some parts of the UK ANO where safety is not compromised.

It seems they are now well outside the box and making it up as they go along.
Nobody is disputing the concept of a Medical Dec, just the way they are going about it, which ultimately leaves the individual in a position where a court could rule they are acting unlawfully, with all associated consequences.

BEagle
6th Oct 2016, 09:38
MK, there is no evidence to support the view that pilots without medicals have had accidents in the past, because that option hasn't existed hitherto! Perhaps they haven't had accidents because they've held valid medicals?

The original NPPL Medical Declaration system was fine and worked well for many years, but has now been ruined by this new system. Many pilots who used to be able to obtain a medical declaration with their GP will now have to visit an AME who won't know them from Adam.

Whopity, you are right about 'making it up as they go along'. Some of the recent conversations I've had have been very revealing...

And no, sorry ifitiaint but the topic of insurers came up in conversation and I wasn't told the name of the company. But I certainly know that clubs are refusing to rent aircraft to pilots without at least an NPPL medical declaration or a Part-MED medical.

Instead of wasting precious staff time on nonsense such as 90-day rules and medical self-declarations, the CAA should have used the time to update CAP804 contemporaneously with the ANO and Aircrew Regulation changes - things which actually matter!

ifitaintboeing
6th Oct 2016, 10:31
And no, sorry ifitiaint but the topic of insurers came up in conversation and I wasn't told the name of the company.

So, you can't substantiate your claim that an insurer has actually refused insurance cover on this basis.

But I certainly know that clubs are refusing to rent aircraft to pilots without at least an NPPL medical declaration or a Part-MED medical.

Aren't you merely confirming that clubs are acting on advice which you have issued? This doesn't really confirm anything other than the confusion which has been introduced due to lack of clarity in CAA-issued documentation.

ifitiaint...

BEagle
6th Oct 2016, 10:39
As I cannot state precisely which insurers are refusing to cover self-declaration medicals, you are entirely at liberty to consider my statement as hearsay.

I have never advised any club to refuse to rent an aircraft to a pilot who does not hold at least an NPPL medical declaration. It's up to them, but I can see their concern whilst the situation remains unresolved.

However, I have certainly advised individuals to steer clear of the self-declaration system (except for legacy UK PPL / NPPL holders flying non-EASA aircraft) at least until the CAA has clarified the actual legal situation, rather than the syllogistic assumptions in which some believe.

thing
6th Oct 2016, 14:12
Just to put you all in the picture should someone else be in the same boat as me at your flying club; according to FCL (only took me an hour to get through!), fill in the paper application form for a LAPL and instead of putting x squillion pounds for a initial application in the fee box put £40, or £46 pounds for courier service. It would help I think to put a covering letter just in case explaining that you are converting from EASA PPL to EASA LAPL.

The downside is that it is now taking, according to the nice gentleman I spoke to, at least 45 working days to process licensing applications. So basically if you apply now you might be lucky and have a licence before Christmas.

BEagle
6th Oct 2016, 15:28
CAA Policy Lead - Licensing has just advised me that the 'self-declaration' scheme is not available to holders of Part-FCL licences who wish to fly EASA aircraft.

The CAA GA Unit will be amending CAP1441 accordingly.

Broadlands
6th Oct 2016, 16:31
BEagle
I hope they issue that doc soon. I was advised by the GA unit that it was valid. I know there was a disagreement between the departments but to get two completely opposite interpretations is really frustrating.
Am I correct in that Policy is the higher level for decision making?

BEagle
6th Oct 2016, 18:07
Broadlands, yes - the licensing policy lead advised me that the legal position is as I've stated.