Pre 2012 UAS flying hours

[HaselFreda]

Hi,

While on a University Air Squadron / UAS (from 2004 to 2006) I flew 58:15 dual (as pupil) and 9:00 solo. All of these hours and sorties were with (or for solo, under the supervision of) RAF Qualified Flying Instructors and were logged and signed for by the CFI, in the RAF FORM 414 (UAS) Log Book. I completed the whole Elementary Flying Training (EFT) course bar the formation flying and Final Handling Test (the EFT course was abruptly cut from UAS flying at the time).

I didn't end up applying to the RAF and I didn't have the funds to carry on flying privately.

A couple of weeks ago (almost twelve years after my last flight), I decided I want to start flying again and get a private pilots licence.

Having done some research, I now understand the following:

it is difficult to get credit for training carried out pre- September 2012 towards a Part-FCL PPL(A)
formal flying training at a UAS (such as mine) shall receive full accreditation towards a NPPL(A) (SSEA)
NPPL(A) (SSEA) licences issued after to April 2018 may not be converted into a Part-FCL LAPL(A) / Part-FCL PPL(A)
NPPL(A) (SSEA) can only fly EASA Aircraft until April 2019, after which time will essentially be useless (can only fly Annex II Aircraft)
Can anyone advise how I might get (some) credit towards a useful private pilots licence for the nearly 70 hours previously flown?

After speaking to a Royal Air Force Flying Clubs Association (RAFFCA) flying club, I have emailed the CAA requesting a custom "credit report" for credit towards issuing Part-FCL licences as described in the Commission Regulation (EU) No 1178/2011, Article 9 (Credit for training commenced prior to the application of this Regulation):

Article 9
Credit for training commenced prior to the application of this Regulation
1. In respect of issuing Part-FCL licences in accordance with Annex I, training commenced prior to the application of this Regulation in accordance with the Joint Aviation Authorities requirements and procedures, under the regulatory oversight of a Member State recommended for mutual recognition within the Joint Aviation Authorities’ system in relation to the relevant JAR, shall be given full credit provided that the training and testing were completed by 8 April 2016 at the latest.
2. Training commenced prior to the application of this Regulation in accordance with Annex 1 to the Chicago Convention shall be given credit for the purposes of issuing Part-FCL licences on the basis of a credit report established by the Member State in consultation with the Agency.
3. The credit report shall describe the scope of the training, indicate for which requirements of Part-FCL licences credit is given and, if applicable, which requirements applicants need to comply with in order to be issued with Part-FCL licences. It shall include copies of all documents necessary to demonstrate the scope of the training and of the national regulations and procedures in accordance with which the training was commenced.

Does anyone know if I am likely to be successful, or if I have misunderstood the regulations, or if the above Article 9 is out of date? I will of course wait for a reply from the CAA, but based on their automated email reply, I could be waiting some time as it is likely to get referred to their Technical Staff. I would like to know where I stand so I can take advantage of the weather and daylight during the summer months, if I am in deed likely to get some credit for previous flying experience.

Any help or advice would appreciated.

Thanks,

[Genghis the Engineer]

This document.

http://www.nationalprivatepilotslicence.co.uk/NPPL%20XC%20REV%2011.pdf

Page 5.

G

[RTN11]

As GtE gives reference to above, you could be credited an NPPL(A), but as you state in your post this will not be any use to fly EASA aircraft, and the route to upgrading this to an EASA FCL licence is closed.

The only credit you would get is on an LAPL(A):

FCL.110.A LAPL(A) — Experience requirements and crediting

(a) Applicants for an LAPL(A) shall have completed at least 30 hours of flight instruction on aeroplanes or TMGs, including at least:

(1) 15 hours of dual flight instruction in the class in which the skill test will be taken;

(2) 6 hours of supervised solo flight time, including at least 3 hours of solo cross-country flight time with at least 1 cross-country flight of at least 150 km (80 NM), during which 1 full stop landing at an aerodrome different from the aerodrome of departure shall be made.

(b) Specific requirements for applicants holding an LAPL(S) with TMG extension. Applicants for an LAPL(A) holding an LAPL(S) with TMG extension shall have completed at least 21 hours of flight time on TMGs after the endorsement of the TMG extension and complied with the requirements of FCL.135.A(a) on aeroplanes.

(c) Crediting. Applicants with prior experience as PIC may be credited towards the requirements in (a).

The amount of credit shall be decided by the ATO where the pilot undergoes the training course, on the basis of a pre-entry flight test, but shall in any case:
(1) not exceed the total flight time as PIC;
(2) not exceed 50 % of the hours required in (a);
(3) not include the requirements of (a)(2)

So the only credit would be on your 9 hours solo, which at the discretion of an ATO you could count towards the 15 hours dual instruction. You would still need to do the 6 hours solo including cross country solo, and if you want a full PPL(A) you would then need to do the conversion course and further skills test at a later date.

Shame you didn't get the paperwork in before the deadline, as you could have been credited a NPPL(A), converted that to an LAPL(A), and then only had to do the conversion course to upgrade to full PPL(A). The deadline has passed on this avenue, so it is no longer available unfortunately.

[HaselFreda]

Thanks RTN11, so if that worked, then the minimum hours to get a LAPL(A) would be 21 hours (30 hours less 9 hours PIC credit). Then minimum hours to convert a LAPL(A) to PPL(A) is an additional 15 hours. Therefore, minimum flying requirement to get PPL(A) is 36 hours (note: two cross-country flights and two skills tests). Although, I'm still not confident that the 9 hours PIC credit would be given for pre 2012 hours?

To clarify my original post (I know para 1 says April 2016), I read Article 9 as the following:

para 1: FULL credit provided that the training and testing were completed by April 2016 - this IS NOT applicable to me as my testing was not completed in this time frame
para 2. Training prior to the Regulation shall be given (partial) credit for the purposes of issuing Part-FCL licences on the basis of a (subjective) credit report written by the CAA - this IS applicable to me as my training is prior to the Regulation
para 3. The credit report shall describe the credit awarded towards the requirements of Part-FCL licences, and which requirements applicants need to comply with in order to be issued with Part-FCL licences - describes the contents of the credit report

I also note, that Article 10, para 2 and 3 of the same Regulation may also be applicable to University Air Squadron flying??

[rudestuff]

The FAA will recognise everything and grant you an FAA PPL in minimum hours. You can get one in a few weeks and convert it later, although the CAA will validate it for life for £45, so you won't need to.

[HaselFreda]

Yeah, thanks rudestuff, that's certainly an option. I suppose I would need to go to the US (cost of flights / accommodation and time off work) unless there are FAA training centres and examiners in the UK? Maybe I could train in the UK and just go over when I'm ready, familiarise myself with the area and take the skills test?

I think I'd need over 100 total hours and take another skills test to convert an FAA PPL to Part-FCL? I'm on 69 hours, so I would need a further 31 hours, plus a skills test (plus the direct / indirect costs of going to the US).

hmm...

[airpolice]

As GtE gives reference to above, you could be credited an NPPL(A), but as you state in your post this will not be any use to fly EASA aircraft, and the route to upgrading this to an EASA FCL licence is closed.

The only credit you would get is on an LAPL(A):



So the only credit would be on your 9 hours solo, which at the discretion of an ATO you could count towards the 15 hours dual instruction. You would still need to do the 6 hours solo including cross country solo, and if you want a full PPL(A) you would then need to do the conversion course and further skills test at a later date.

Shame you didn't get the paperwork in before the deadline, as you could have been credited a NPPL(A), converted that to an LAPL(A), and then only had to do the conversion course to upgrade to full PPL(A). The deadline has passed on this avenue, so it is no longer available unfortunately.


but as you state in your post this will not be any use to fly EASA aircraft

That ain't necessarily so. The NPPL(A) allows the holder to fly EASA Aircraft, certainly until April next year and possibly forever. If Brexit results in the UK leaving EASA then the NPPL will be what it is today, a licence to fly a C172 or PA28 VANS RV and similar types. Remember they are only EASA aircraft in the eyes of people who go along with EASA.

Even if the CAA do not "leave EASA" they have allowed us NPPL holders to fly those aircraft up till now. On that basis I think they will continue to allow it.

As for the OP, I think the 12 year gap is more important than whether or not you can get credit for the hours. You should get along to your local RAFFCA flying club and get an NPPL at reduced prices, then build up hours doing cheap flying.


This Exemption is required to meet an operational need of limited duration to reduce the significant regulatory burden that will be placed on the UK General Aviation (GA) sector due to the delay in publishing of the latest Amendment to the Aircrew Regulation. This amendment will make provision for a further extended opt out in respect of LAPLs subject to Subpart B of Part-FCL. This Exemption will permit the continued use of UK National pilot licences to fly UK registered aeroplanes or helicopters or TMG’s with an EASA Certificate of Airworthiness or EASA Permit to Fly without the need for pilots to convert to Part-FCL pilot licences before the LAPL opt out is made available and adopted by the UK. 2.

The way I read that, and I am happy to be corrected, is that the CAA expect the Opt Out to be enshrined in law by next April and the NPPL to live forever and be good for G-registered EASA & AnnexII (for want of a better way to describe the two groups of airframes) that we fly.

See my thread on The NPPL Lives.

[airpolice]

Yeah, thanks rudestuff, that's certainly an option. I suppose I would need to go to the US (cost of flights / accommodation and time off work) unless there are FAA training centres and examiners in the UK? Maybe I could train in the UK and just go over when I'm ready, familiarise myself with the area and take the skills test?

I think I'd need over 100 total hours and take another skills test to convert an FAA PPL to Part-FCL? I'm on 69 hours, so I would need a further 31 hours, plus a skills test (plus the direct / indirect costs of going to the US).

hmm...

Or, get an NPPL here in about the same hours.

[BEagle]

airpolice wrote: The way I read that, and I am happy to be corrected, is that the CAA expect the Opt Out to be enshrined in law by next April and the NPPL to live forever and be good for G-registered EASA & AnnexII (for want of a better way to describe the two groups of airframes) that we fly.

Very highly speculative. EASA invited MS to develop their own exemptions pending the Basic Regulation amendment, which might include an extension to the existing LAPL opt-out clause until 2020.

There has been no plebiscite concerning the UK leaving EASA. If that were to happen, you can expect a trebling of all GA licensing fees to cover the cost of the additional personnel needed to cover the manning requirements which the CAA would need to take over from EASA.

[HaselFreda]

Just to update anyone interested, I explored all avenues with both the CAA and RAF to get my hours credited towards an EASA licence but have had no luck.

[David Balfour]

Thanks for the update. I might be following the same process soon. But the American route seems a possibility.