Training Rejection Conundrum...

[S-Works]

I am facing an interesting problem with the Spanish CAA and can't find a route to escalate it for resolution.

I have a pilot who works for us with a Type Rating on a Twin Turboprop. Flew around 4,000hrs on type and then took a job flying the A320 which resulted in the Turboprop Type Rating expiring in December last year. September I was asked to renew it. I carried out an assessment under Part FCL.740 and decided that as he was current on the A320 and therefore current on ME handling as well as the prior time on type that he should do a days ground school and an LPC. This was done and the LPC passed without fault.

The Spanish CAA rejected this as said that he must do at least two "training sessions". I did not agree but capitulated and did two further training sessions and then another examiner did another LPC which he again passed without fault.

So student has done a 1hr LPC originally which now becomes a PUT training flight, a further flight of 1:30 then another flight of 1:00hr plus 5hrs of grand school and another 1hr LPC.

I issued a course completion certificate for 3:30hrs of training and 5hrs of ground school which equates to 4 "training sessions" and they have now rejected this saying the original LPC can't be counted as a training session and the course completion certificate does not cover the content of the training sessions.

I was under the impression that Part FCL.740 specifically delegates the authority to decide what training is required to the ATO and that issue of a course completion certificate indicates that those training requirements set have been fulfilled. The training records are of course fully available for audit and as we train in Spain our ATO is audited by the UK CAA accompanied by a Spanish Inspector who has never raised an issue with our process or paperwork.

Given the above, have a missed something?

I have now hit a brick wall with this and could do with an idea of how to escalate a complaint. The woman processing the paperwork won't even tell me who her line manager is!!!

[Manual Reversion]

I have done two or three LST's for the Spanish CAA. Despite my best efforts each batch of paperwork has been rejected for various reasons that in a 'grown up' society would be considered puerile. A couple of rejections were simply down to a difference in interpretation of the syntax used on the forms.
It has been explained to me that the people issuing the ratings are simple pen pushers who follow an inflexible algorithm.
Good luck with them, and perish the thought a drop of 'tippex' should adorn the form!
If you know someone at a Spanish ATO who could mediate on your behalf, that can facilitate the progress of the paperwork.

[Level Attitude]

I issued a course completion certificate for 3:30hrs of training and 5hrs of ground school which equates to 4 "training sessions" and they have now rejected this saying the original LPC can't be counted as a training session and the course completion certificate does not cover the content of the training sessions.
Sounds like they might just be requiring a 'correct' paper trail for themselves so that, if questioned, they can prove compliance with EASA.

Just wondering whether they are not allowing a 'paperwork' assessment of Training Required, but are requiring a flight to so do?

Original LPC becomes the Assessment of Training Required - Although PUT it cannot count towards the Training Course as that had not yet been decided upon.

Possibly resubmit same paperwork, but with a new Course Completion Certificate showing just the 2 x Training Flights (including content) and the 5 Hours Ground School that "you assessed" as being required following the first flight (LPC)?
Second LPC then valid as done after all Training Required completed?

No idea if the above would work, but it shouldn't cost any money to find out.

[S-Works]

The paper trail is correct in accordance with our ATO approvals. The UK CAA have confirmed that I was correct on both occasions.

The frustrating thing is the Spanish won't actually say what they want of us.

One thing is for certain, I won't train or employ another Spanish licence holder. They will be given the option to SOLI to another state or not get a job.

[SpannerInTheWerks]

Sounds like the 'Brexit factor' is having it's effect already ... ?!

It was bad enough in the day having to hold for 40 minutes over Barcelona with nothing on the radar only to witness THREE Spanish airliners gradually appear inbound and given priority to land ahead of us ... !!!

Anybody who thinks that Brexit is going to be made easy and that Britain will be accommodated with open arms needs to seriously think again (in my opinion, of course).

[BillieBob]

Nothing whatever to do with Brexit (yet more pathetic scaremongering) - Spanish ATC has been utterly incompetent for at least 40 years to my certain knowledge. AENA is the ultimate bureaucracy - the only reason for their existence is to perpetuate their existence.

Bose-X, your solution is wise - avoid anything Spanish (except, perhaps, a good Fino which, incidentally, will continue to be available after Brexit).