FCL.060 90 days restriction

[busav8r]

EASA FCL.060 says: A pilot shall not operate an aircraft in commercial air transport or carrying passengers:
(1) as PIC or Co-pilot unless he/she has carried out, in the preceding 90 days, at least 3 take-offs, approaches and landings in an aircraft of the same type or class or an FFS representing that type or class. The 3 take-offs and landings shall be performed in either multi-pilot or single-pilot operations, depending on the privileges held by the pilot;

Can anyone clarify if these 3 take-off, approaches and landings must be done as PF or it is irrelevant who actually does them, as long as the pilot (PIC or Co-pilot) occupies a pilot seat? Does it count no matter if the pilot is acting as PF or PM? Or does it count only for the pilot who actually lands the plane?
Thanks.

[568]

I do believe that you must perform these 3 take offs and landings in the seat you would normally occupy (PIC or FO). Having the required level of simulator and being validated by the respective NAA will ensure currency.
If I am incorrect then someone will be along to correct. Good luck,

[READY MESSAGE]

Must be PF to count the three

[Meester proach]

I’m sure they’ll have to find some dispensation , as half the world’s airline pilots would need a sim trip otherwise

[Denti]

For most of us section (c) is quite important, which increases the 90 days to 120 days if the three landings are done under supervision of a TRI or TRE.

(c) Specific requirements for commercial air transport:
(1) In the case of commercial air transport, the 90-day period prescribed in subparagraphs (b)(1) and (2) above may be extended up to a maximum of 120 days, as long as the pilot undertakes line flying under the supervision of a type rating instructor or examiner.

[FlyingStone]

Extension to 120 days can be a bit tricky, as not all TRI/TREs are able to do it.

[Journey Man]

Must be PF to count the three

As monitoring pilot, you're part of the active crew for a multi pilot aeroplane. Is there a reference to sole manipulator of the controls for recency on a MPA?

[C195]

Extension to 120 days can be a bit tricky, as not all TRI/TREs are able to do it.

There are basically 3 levels of TRI under EASA:

1. TRI(A)(Simulator Only)

2. TRI(A) (Restricted “No instruction for abnormal/emergency procedures to be undertaken in an aircraft")

3. TRI(A) (Unrestricted)

The TRI would need to hold number 2 or 3 in order to supervise the takeoffs and landings required.

[Denti]

There are basically 3 levels of TRI under EASA:

1. TRI(A)(Simulator Only)


Wouldn't that be a SFI ?

[FlightDetent]

No, just a TRI not authorized to perform real-life base trainings. Train the trainer for this is costly and many airlines and ATOs can do without using ZFTT.

SFI I thinks is for colleagues without medical or without valid TR (activation of which requires getting physically airborne as well).

[Denti]

Interesting, have never experienced that one. The qualification (train the trainer course) was the same, except the additional base training for the TRI of course, same for SFE and TRE. Well, you live and learn.

Found it in FCL, it is labelled as "restricted TRI", therefore of course the above quote is still correct, any unrestricted TRI should be able to extend the 90 days to 120 days.

[repulo]

The subject is a little more complicated since EU 2019/1747 has been published. Not all authorities have already adopted the new licensing rules. The TRI rating needs further specifications, e.g. LIFUS or Landing Training. If you use the old nomenclature a TRI (A) will be required.

Thats the relevant part from EU 2019/1747:FCL.910.TRI Restricted privileges
(1)
LIFUS, provided that the TRI training course has included the training specified in point FCL.930.TRI(a)(4)(i);

(2)

landing training, provided that the TRI training course has included the training specified in point FCL.930.TRI(a)(4)(ii); or

(3)

the training flight specified in point FCL.060(c)(2), provided that the TRI training course has included the training referred to in points (a)(1) or (a)(2).

(a)
General. If the TRI training is carried out in FSTDs only, the privileges of TRIs shall be restricted to training in FSTDs. This restriction shall however include the following privileges for conducting, in the aircraft:

And it is „on controls“

[FlyingStone]

As monitoring pilot, you're part of the active crew for a multi pilot aeroplane. Is there a reference to sole manipulator of the controls for recency on a MPA?

There isn't, however your CAA will likely interpret this as a requirement to be PF for those 3 takeoffs and landings and in most cases this is what will be written in Operations Manual as well.

[Journey Man]

HI FlyingStone, that's a lot of nebulous referals with very little evidence. Could you give some examples, i.e. which NAAs interpret the recency requirement for MPA to be the sole manipulator of the flight controls, and an example of a company that has that stated in their OMs?

[sonicbum]

Do You honestly think it makes sense to fly 3 takeoff / landings as PM ? Recency training is made because the regulator wants to ensure you remember how to takeoff and land an aircraft.

[McBruce]

The wording says “carried out” you don’t carry out the TO and LDG as PM.

[FlightDetent]

Come on. Pilot flying and pilot monitoring (a.k.a. PNF), anything unclear about these? The acting-observing pilot does not carry out the landing, no confusion here.

FAA: https://www.law.cornell.edu/cfr/text/14/121.439

[sonicbum]

No, just a TRI not authorized to perform real-life base trainings. Train the trainer for this is costly and many airlines and ATOs can do without using ZFTT.

SFI I thinks is for colleagues without medical or without valid TR (activation of which requires getting physically airborne as well).

Almost. The main difference between an SFI rating and a TRI (besides real aircraft training) is the fact that you don't need a minimum amount of sectors/hours flown on the aircraft to take the course. If tomorrow you get your type rating on, let's say, the A380 or anything you like, you can become an SFI with 0 hours on the actual aircraft but you will need a LOFT sim session IIRC before starting the course.

[FlightDetent]

Eye of the beholder, probably. I understand the difference better through the requirement that SFI does not need a valid licence nor recency in the real thing.

An applicant for an SFI certificate shall:
(a) hold or have held a CPL, MPL or ATPL in the appropriate aircraft category;
(c) (2) completed, as a pilot or as an observer, within the 12 months preceding the application, at least:(i) 3 route sectors on the flight deck of the applicable aircraft type; or(ii) 2 line-orientated flight training-based simulator sessions conducted by qualified flight crew on the flight deck of the applicable type. These simulator sessions shall include 2 flights of at least 2 hours each between 2 different aerodromes, and the associated pre-flight planning and de-briefing;
An applicant for a TRI certificate shall:
(a) hold a CPL, MPL or ATPL pilot licence on the applicable aircraft category;
(b) (2) have completed, within the 12 months preceding the date of application, 30 route sectors, including take-offs and landings, as PIC or co-pilot on the applicable aeroplane type, of which 15 sectors may be completed in an FFS representing that type;

[Meikleour]

Journey Man: If you take your reasoning to it's extreme then do you think it would make sense to be considered "current" by only doing PM sectors for ever!!?

[FlyingStone]

HI FlyingStone, that's a lot of nebulous referals with very little evidence. Could you give some examples, i.e. which NAAs interpret the recency requirement for MPA to be the sole manipulator of the flight controls, and an example of a company that has that stated in their OMs?

First of all, in 99.9% of normal MPA operation, pilot flying is always "the sole manipulator of the flight controls" anyway.

Second, UK CAA and most EASA CAT OMs that I have seen. Unfortunately, EASA's wording has lost a bit in translation. ICAO Annex 6, Part I paints a much clearer picture:

9.4.1 Recent experience — pilot-in-command and co-pilot
9.4.1.1 The operator shall not assign a pilot-in-command or a co-pilot to operate at the flight controls of a type or
variant of a type of aeroplane during take-off and landing unless that pilot has operated the flight controls during at least three
take-offs and landings within the preceding 90 days on the same type of aeroplane or in a flight simulator approved for the
purpose.

Or are we going to start counting flaps as flight controls now?

[busav8r]

If you mind, please read the entire FCL.060. Please take a special look at the paragraph (2), where it says "...has carried out in the preceding 90 days at least 1 take-off, approach and landing at night as a pilot flying ...".
In paragraph (1) it does not specify that those take-offs, approaches and landings must be done as PF. Or maybe I'm lost in translation...


A pilot shall not operate an aircraft in commercial air transport or carrying passengers:
(1) as PIC or co-pilot unless he/she has carried out, in the preceding 90 days, at least 3 take-offs, approaches and landings in an aircraft of the same type or class or an FFS representing that type or class. The 3 take-offs and landings shall be performed in either multi-pilot or single-pilot operations, depending on the privileges held by the pilot; and
(2) as PIC at night unless he/she:(i) has carried out in the preceding 90 days at least 1 take-off, approach and landing at night as a pilot flying in an aircraft of the same type or class or an FFS representing that type or class; or(ii) holds an IR;(3) as cruise relief co-pilot unless he/she:(i) has complied with the requirements in (b)(1); or(ii) has carried out in the preceding 90 days at least 3 sectors as a cruise relief pilot on the same type or class of aircraft; or(iii) has carried out recency and refresher flying skill training in an FFS at intervals not exceeding 90 days. This refresher training may be combined with the operator’s refresher training prescribed in the relevant requirements of Part-ORO.(4) When a pilot has the privilege to operate more than one type of aeroplane with similar handling and operation characteristics, the 3 take-offs, approaches and landings required in (1) may be performed as defined in the operational suitability data established in accordance with Part-21.(5) When a pilot has the privilege to operate more than one type of non- complex helicopter with similar handling and operation characteristics, as defined in the operational suitability data established in accordance with Part-21, the 3 take-offs, approaches and landings required in (1) may be performed in just one of the types, provided that the pilot has completed at least 2 hours of flight in each of the types of helicopter, during the preceding 6 months.

[FlightDetent]

Fair call?

[DooblerChina]

I can’t be bothered reading all of that argument, I thought I would just add that my company are scheduling sim sessions in June literally for 3 TO/LDGs. we can expect to be in for a few minutes a time.

[jondoyle]

For Corporate Pilots;
3 Touch and go Landings on the company aircraft is probably a lot cheaper than what the some of the sim companies will charge for doing it.
They will insist on charging for minimum of one hour.
Even though you could do it in the SIM in 7/8 minutes with 3 take-offs and re-positions.

One hour sim for a mid sized corporate aircraft: approx £1500-£2000 K.

[hans brinker]

I can play in the A320 SIM my company rents for training for $500/hr......
Also, get 6 pilots and do them all in a one hour session.

[ReturningVector]

The aviation authority in our country (Netherlands) has stated that PM landings in a multi crew environment also count towards the 3 takeoffs and landings under EASA rules.

The EASA wording being “carried out”. ICAO does mention flight controls, but we fly by EASA rules in Europe.

[FlyingStone]

What a joke.

[golfyankeesierra]

3 Touch and go Landings
It is my understanding that a touch and go only counts as a landing, not a take off (exactly as you wrote it).
You’ll probably have to make full stops. Means you will get some taxi practice as well😀

[Duchess_Driver]

Why would you not want to?

I know I am rusty, and it isn’t 90 days for me!

[lederhosen]

I don't fly for a week I notice, two weeks and the copilot notices, three weeks and the passengers notice as the old saying goes. Personally I think three sectors in a front seat with at least one landing would be the minimum if not optimal, particularly for our long haul colleagues. But I think most people will need a session in the sim, which frankly behaves a bit differently for the landing. Still it is better than nothing.

[Salto]

What a joke.

So, a multi-crew aircraft becomes suddenly a single-pilot-aircraft when being close to the ground such as for landing and take-off? I thought that PM is very often more challenging then just working the stick and rudders...

[FlyingStone]

OK, a practical case. In EASA land, one can go 9 months between simulator checks. So 8 months and 29 days later, after only watching the other pilot do it 50 times in the meanwhile, you finally get to do it for real when it's 30 knots across on a short wet runway at night. Would you be comfortable landing the aircraft?

Landing is a predominantly a motor skill and needs to be practiced. Just as a student pilot will learn the skill to some extent by watching an instructor demonstrate the landing, they will need to do it themselves again and again to master it. Same applies to recency.

[ReturningVector]

Those requirements are bare minimums. Your personal requirements can be stricter and it is our own responsibility to safeguard those personal requirements.

[sonicbum]

OK, a practical case. In EASA land, one can go 9 months between simulator checks. So 8 months and 29 days later, after only watching the other pilot do it 50 times in the meanwhile, you finally get to do it for real when it's 30 knots across on a short wet runway at night. Would you be comfortable landing the aircraft?

Landing is a predominantly a motor skill and needs to be practiced. Just as a student pilot will learn the skill to some extent by watching an instructor demonstrate the landing, they will need to do it themselves again and again to master it. Same applies to recency.

100% agree.
It is like being a very experienced coach of a tennis player ; you notice the details from the bench and call it out in order for the player to correct his movements.
Now if the coach - whose last game was 20 years before - takes the racket and starts playing against Nadal, what is going to happen ?
Landings need the theory first and then practice, practice and practice.

[Salto]

@ FlyingStone: you can easily fly regularly and do countless landings, without any "30 knots across on a short wet runway at night" landings at all. And having done x-landings within x-days as PF does not necessarily mean that you are proficient with regard to your personal performance. It simply means that you are legal. And yes, I would be comfortable. Because in EASA land the qualification requirments of PM is still different than within the FAA world, it has always to be a fully qualified and rated pilot.

I think your statement is valid, but referring to a different issue. And the regulation does not cover "personal performance" as such, it is, as RV said, a bare minimum requirement. However, not all of those requirements make sense, just to say.

[sonicbum]

But since, as You say, it is a bare minimum then how would you expect to fulfil this minimum as PM ?

[Salto]

... by performing your multi-crew duties as a type rated pilot, including handling of the (secondary-) flight controls as appropriate 👍

[FlyingStone]

And yes, I would be comfortable. Because in EASA land the qualification requirments of PM is still different than within the FAA world, it has always to be a fully qualified and rated pilot.

So you'd be comfortable landing the aircraft at its demonstrated crosswind limit after 9 months without a single landing as PF, just because you have a full type rating?

Hats off, sir. I wouldn't be.

[Salto]

No, I would not. And I never said something alike. I would not go to any limit just because I have my 3/90 landings either. My personal requirements might be different than yours as ReturningVector mentioned earlier above, this was never the point of this thread and never the point of the argument why PM might be accepted by some authorities.

But I will leave it as it is, it became almost a private chat.