Revalidation of Irish SEP rating by UK(EASA)FI with FCL945 privileges?

[Stampe]

Many of my former colleagues have moved their UK licences to the Irish CAA at the behest of their employer.I have been contacted by one of my flock to carry out the Biennial dual flight on a UK registered SEP and sign their licence under FCL945 with them meeting the experience requirements.I can find no guidance on the ICAA website re gaining an approval to do this.At the moment I am inclined to offer to conduct the hours dual but suggest the licence is signed by one of his many ICAA examiner qualified colleagues.Past experience tells me many airline examiners are under confident in signing SEP ratings due lack of knowledge.Given the mass exodus of UK Airline crew to alternative SOLI I think this will become a frequent problem.Your thoughts colleagues please?
Regards Stampe.

[citabria06g]

https://www.iaa.ie/docs/default-source/publications/advisory-memoranda/personnel-licensing-advisory-memoranda-(plam)/examiner-authorisation-to-endorse-the-revalidation-or-renewal-of-a-rating-page-in-an-iaa-issued-flight-crew-licence-(fcl).pdf?sfvrsn=7aa90df3_6

3.IAA POLICY - Revalidation and Renewal of a Type, Class or IR Rating

3.2 Revalidation of Rating in a PART-FCL Licence.
The IAA intends to continue the policy outlined above for revalidation and, therefore, any Examiner Certified in accordance with PART-FCL is authorised by the IAA for the purpose of revalidating a Type, Class or Instrument rating in an IAA-issued PART-FCL Licence according to their Examiner privileges.


The way I read it any EASA FE can sign, but when it comes to FIs it's only for IAA licence holders.

[Whopity]

I am inclined to offer to conduct the hours dual The hours dual as you put it changed its format some time ago. The requirement stated in FCL.740A is now:
refresher training of at least 1 hour of total flight time with a flight instructor (FI) or a class rating instructor (CRI).
So the training could comprise of any number of flights with more than one instructor.

I agree with the previous comments regarding Examiners and non IAA instructors.

[BEagle]

Only an IAA-authorised FE may sign the Certificate of Revalidation for revalidation of an SEP Class Rating included in an IAA licence if that has been achieved by experience. Other Part-FCL examiners may sign only for revalidation achieved through Proficiency Check and compliance with IAA requirements as stated in the EASA Examiner Differences Document.

If a UK FI / CRI conducts the refresher flight training, it would be up to the applicant to furnish the relevant information to an IAA FE for signature of the Certificate of Revalidation. Alternatively, an Irish FI/CRI with FCL.945 privileges should be able to sign.

[Whopity]

Alternatively, an Irish FI/CRI with FCL.945 privileges should be able to sign.
A FI/CRI may ony sign if they completed the final dual flight with the candidate.

[BEagle]

A FI/CRI may only sign if they completed the final dual flight with the candidate.

Quite so - and the applicant must also have completed all other revalidation by experience requirements before the final refresher training flight, if the FI/CRI is to exercise FCL.945 privileges.

[citabria06g]

Only an IAA-authorised FE may sign the Certificate of Revalidation for revalidation of an SEP Class Rating included in an IAA licence if that has been achieved by experience. Other Part-FCL examiners may sign only for revalidation achieved through Proficiency Check and compliance with IAA requirements as stated in the EASA Examiner Differences Document.

Source? This is the UK CAA's view, as stated in their emails to foreign Examiners, authorising them to proceed with a LPC on a UK candidate.

It appears the IAA is more liberal - see above document. There is nothing there about a limitation when revalidating by experience.

[BEagle]

It is NOT simply the UK CAA's view - see Chapter 2 of the EASA Examiner Differences Document.

I queried this with EASA and the answer was an emphatic NO! Only revalidation by Proficiency Check was permitted by an FE whose certificate was issued by a different MS to the applicant's - and strictly in accordance with the EDD requirements pertaining to the State of Licence Issue of the applicant.

[citabria06g]

I don't doubt what you're saying, however I wonder whether the person you spoke to was misinformed.

Revalidations by experience are NOT a test or assessment of competence - they are merely admin tasks (from the FE's point of view). Therefore they are outside the scope of the EASA Examiner Differences Document (https://www.easa.europa.eu/sites/default/files/dfu/Examiner%20Differences%20Document_version_11-2019%20%282%29.pdf).

2.1.1. Purpose of the Examiner Differences Document

This document [...] is intented for use by examiners with a Part-FCL examiner certificate conducting a test, check or assessment of competence on a Part-FCL licence holder whose licence was issued by a competent authority (CA) other than their own.

Furthermore I point you to the Irish Examiner Briefing Document (https://www.iaa.ie/docs/default-source/publications/advisory-memoranda/personnel-licensing-advisory-memoranda-(plam)/guidance-to-iaa-certified-examiners-and-non-iaa-certified-examiners-conducting-tests-on-pilots-who-hold-a-licence-issued-by-the-iaa.pdf?sfvrsn=caa90df3_14) which reiterates the blanket authorisation to foreign FEs:

11. An Examiner certified in accordance with PART-FCL is authorised by the IAA for the purposes of revalidating a Type, Class or Instrument ratings in an IAA-issued PART-FCL Licence according to the Examiner’s privileges.

and then goes on to list exceptions:

12. The renewal of an expired Type, Class or Instrument rating, must be endorsed by the IAA, except where an Examiner is specifically authorised by the IAA to do so.

13. The Revalidation or Renewal of an Instructor or Examiner certificate shall always be endorsed by the IAA.

If the IAA wishes to exclude revalidations by experience, they should have written so.

[BEagle]

Sorry, but you're talking nonsense. My discussion with EASA was with a senior rulemaker at an official EASA FCL meeting.

[BizJetJock]

From many years of experience, I'd say its just as likely the "senior rulemaker" is talking nonsense. If it's written in the official published guidance, then that's what is correct. Someone telling you what they think they wanted it to say is totally irrelevant.

[timprice]

That's it boys a level playing field which any idiot can interpret, I like the FAA system it's written in concrete in FAR AIM, why don't we have a simple book like that in Europe none of these difference's etc:ugh:

[Stampe]

Well as OP thank you for all your input.I plan to either conduct the hours dual in a G registration aircraft (in as many individual sectors as my colleague desires) and then get an ICAA examiner of which we have access to plenty to sign the revalidation in his licence.Or as my colleague is regularly having LPCs on one of Boeings finest using that as a substitute for my instructional skills.Hopefully problem solved and my colleague continues to enjoy the delights of light aviation.I am sure George Orwell would have found inspiration for another book in the world of European bureaucracy ! Thank you again.
Regards Stampe

[Whopity]

FCL.945 Obligations for instructors
Upon completion of the training flight for the revalidation of an SEP or TMG class rating in accordance
with FCL.740.A (b)(1) and only in the event of fulfilment of all the other revalidation criteria required
by FCL.740.A (b)(1) the instructor shall endorse the applicant's licence with the new expiry date of the
rating or certificate, if specifically authorised for that purpose by the competent authority responsible
for the applicant's licence.
So unless the IAA have specifically authorised it, you cannot sign!

[BEagle]

The senior rulemaker was assuredly not 'talking nonsense'! The meeting was at EASA in Cologne, attended by around 40 representatives of national aviation authorities, industry and associations. It was emphasised that, while an MS might have knowledge of FEs from other MS and would accept their tests, checks or assessments if conducted in accordance with the EDD, they would not accept revalidations 'by experience' from those of whom they had no knowledge or oversight. Some MS stated that they might perhaps be persuaded to accept 'experience', but the vast majority stated that they would not - some even went as far as stating that they would only accept tests, checks or assessments conducted by their own examiners.

The agreed conclusion was that the clause limiting non-national examiners to conducting tests, checks or assessments of competence would not be amended.

When FCL.945 appeared, again it was stated that the privileges would only extend to holders of licences, ratings or certificates issued by the same MS as that of the instructor.

The EDD is far from perfect, but it took a fair bit of persuasion to convince EASA that it was reasonable for examiners of one MS to examine applicants of another, provided that national limitations were observed.

However, there must be quite a few IAA examiners working for Ryanair in various MS who could make their colleagues aware that they are available for signing Certificates of Revalidation for IAA licence holders.

[Consol]

Quote:
FCL.945 Obligations for instructors
Upon completion of the training flight for the revalidation of an SEP or TMG class rating in accordance
with FCL.740.A (b)(1) and only in the event of fulfilment of all the other revalidation criteria required
by FCL.740.A (b)(1) the instructor shall endorse the applicant's licence with the new expiry date of the
rating or certificate, if specifically authorised for that purpose by the competent authority responsible
for the applicant's licence.'
'So unless the IAA have specifically authorised it, you cannot sign!'

I'm an IAA licenced FI with FCL 945 privileges on my licence. You do have to be authorised and said privilege is printed in your licence.

If you read the above legislation quotation then you will see that nowhere does it say that the signing FI must have flown the hour with the SEP holder, simply that they can only sign the revalidation after the hour has been completed.

Remember most profession licence holders are except anyway by virtue of having completed their last IR in a simulator or any other IAA flight test in the last year.

It is a revalidation not a skills test. You are confirming that revalidation criteria have been met.

For the OP, plenty of IAA examiners and a few FI with 945, ask around at your operator.

[Whopity]

Upon completion of the training flight the instructor shall
It does not say "an instructor!" It says "the instructor" and in my book that can only be the instructor associated with that training flight.

[Consol]

It does not say "an instructor!" It says "the instructor" and in my book that can only be the instructor associated with that training flight.

'The Instructor' is the instructor who is checking the docs and signing the revalidation. It does not say it is the instructor who carried out the one hour flight.
Anyone I signed for had done an IR anyway so instructor flight excempt, please explain how the signing instructor would have done a refresher flight that the SEP was excempt from and so hadn't done?
Did the required IAA briefing in it's HQ. Seem to remember being awake the whole time.
To assist the OP, an IAA FI with 945 can only sign Irish licences and even the signing should 'normally' take place in Ireland. You can of course present yourself in the licencing office in Dublin with all relevant docs and ID and request an IAA FCL officer to sign your SEP.
It's a revalidation not an exam or skills test.

[Whopity]

Another exampleof two different States applying totally different criteria. Under the UK CAA only the instructor completing the dual flight may sign using FCL.945 privileges.
In the absense of any meaningful instructions from the CAA one Training Provider provided the following guidance. (https://www.ontrackaviation.com/FCL945_info_sheet.pdf)
This has been endorsed by the UK CAA.

[Level Attitude]

I would agree with Whopity that the IAA's interpretation is wrong - but if it is working 'Why rock the boat?'

Previously only Examiners could sign off Revalidations. Which meant that, for Revalidation by Experience, having completed their DUAL requirements with an Instructor, applicants would then have to find an Examiner to complete their paperwork. FCL.945 meant that duly authorised Instructors could now also complete the paperwork at the end of the (last required) DUAL flight.

FCL.945 Obligations for instructors (my underline)
Upon completion of the training flight...

To me, from the above, it is obvious that it is the Instructor who has to complete the training flight (with the SEP Holder) in order to complete the paperwork.
NB: I wish it had been written as Privilege rather than Obligations.

Anyone I signed for had done an IR anyway so instructor flight excempt, please explain how the signing instructor would have done a refresher flight that the SEP was excempt from and so hadn't done?Without having completed the training flight, I do not see how an Instructor is authorised to do this, and an Examiner is required (why not the one who conducted the IR test/check?).

If an Examiner had conducted a SEP Proficiency Check for Revalidation, but had 'forgotten' to complete the paperwork in the candidate's Licence. Another Examiner (in theory) could sign their SEP Rating. Could an Instructor with 945 Privileges?

[Kemble Pitts]

You've got to admit, its all a load of bollox isn't it.

The requirement is 12 hours plus a one hour flight with an instructor - really quite simple. The rest is just petty/self-important people trying to create problems in the admin side of things. Is it the 'Judean People's Front' or 'The Popular Front for Judea'?

Why the hell can't any EASA FI(A) or FE(A) carry out the one hour flight for any EASA PPL(SEP) and sign his licence and log-book? Surely that is what a pan-European set of regulations is all about. A standard form, signed by the FI, sent by the PPL to his NAA would be enough for the NAA to track whose licence was valid at any one time.

[Whopity]

The requirement is 12 hours plus a one hour flight with an instructor Even that has changed! Its now a total of one hour with any number of instructors!

[Kemble Pitts]

Yeah, yeah, I know but... my point still stands.

[Whopity]

The standard forms are all in the AMC!

[BEagle]

The original idea was to make it easier for a pilot who'd met all other revalidation criteria, but just needed to complete refresher flying training, to have his/her licence signed off immediately after the flight - rather than having to find an examiner.

But clever-devil barrack room lawyer idiots have conspired to confuse the intention of EASA's FCL.945.....:mad:

[Mickey Kaye]

The standard forms are all in the AMC!

I have to say using this standard forms would make things a lot easier. Has anyone tried it? Does the NAA have to except them?