Revalidating pre-JAR brown CAA licence

[gbovis]

Hi there. I’m the holder of a pre JAR brown CAA licence (believe type A rather than SEP but need to look) and am thinking of starting up flying again. Am I correct in my understanding (as I recall) that my licence whilst not current is a lifetime licence and as such I simply need to renew my radiotelephony certificate, obtain medical and then undergo flight training as required before a check ride with an examiner who stamps log and signs licence? I’ll be brushing up on theory obviously but understand I don’t need to retake ground exams either?

[trevs99uk]

I also fly on my old Brown CAA licence as you say its a life time licence.
However things changed last year when the CAA stopped allowing old Licence holders to fly EASA type aircraft. (basically aircraft with a EASA type certificate like Pipers and Cessnas etc etc)
Now we are out of the EU and EASA, aircraft designated as EASA type are now called Part 21 aircraft. So we are waiting on the CAA to say we can fly these type aircraft again on our old brown licences.

I also believe your Old RT licence is also a lifetime licence.
Ref medicals you can now do a PMD. ie a self declared medical but there are restrictions. see below..

Ref Flight Training and exams etc best go speak to an Instructor as they will have all the details on what is required.



Recent changes to the PMD Medical requirements.

Details are here: https://www.caa.co.uk/general-aviation/pilot-licences/medical-requirements/medical-requirements-for-private-pilots/

You have to scroll down to find the bit extracted below. Note that as a student pilot you need a full medical of some form, you can only convert to a PMD once you have your licence.

Once you have a licence, if you only want to fly UK (G) registered aircraft in UK airspace you can use the online Pilot Medical Declaration (PMD).

A medical declaration (from 25th August 2016) is an affirmation of your medical ‘fitness to fly’ and may be used to exercise the privileges of a:

• UK Part-FCL Private Pilot Licence (PPL) to fly UK (G) registered Part 21 and non-Part 21 aircraft;
• UK Part-FCL Light Aircraft Pilots Licence (LAPL) to fly UK (G) registered Part 21 and non-Part 21 aircraft;
• UK Part-SFCL Sailplane Pilot Licence (SPL) to fly UK (G) registered Part 21 and non-Part 21 aircraft;
• UK Part-BFCL Balloon Pilot Licence (BPL) to fly UK (G) registered Part 21 and non-Part 21 aircraft but restricted to private and commercial operation only (excluding commercial passenger ballooning, commercial operation only if commercial operation rating held).
• NPPL (NPPL) to fly UK (G) registered non-Part 21 aircraft;
• UK PPL to fly UK (G) registered non-Part 21 aircraft; and
• A UK Commercial Pilot Licence (CPL) Balloons that is restricted to commercial operation and the privileges of a UK PPL (Balloons and Airships).

It is valid for flying with the following operational conditions;
• With not more than three passengers on board;
• in aircraft with a Maximum Take-Off Mass (MTOM) of 5700kg or less
• In Visual Meteorological Conditions (VMC) or when exercising the privileges of an Instrument Meteorological Conditions (IMC)/Instrument Rating (Restricted). The privileges of a full Instrument Rating (IR) are not applicable.
• by day or night when exercising the privileges of a Night Rating provided that colour safety has previously been checked by an AME.
• PMDs are not valid outside of UK airspace, as it is not an internationally-recognised medical standard, unless permission has been granted by the State of the airspace you are flying in.

[Fl1ingfrog]

Trevs99uk much of what you say is incorrect and misleading.

G-BOVIS you should check your licence for an expiry date. There was a short period when they were issued with such and I have come across a number of them. If there is not an expiry date in the licence then it will be a lifetime licence. You will have to undergo such training that the ATO or DTO that you choose so decides plus undertake the, new to you, PPL Skill test. Your renewed PPL will give you full international privileges unless you choose to have an alternative licence. Assuming you successfully pass your Class 2 medical then why not have the full ICAO compliant licence equal to the privileges of your already held licence.

The examiner will decide whether you will need to do the full Skill Test or an abridged one. The ATO/DTO will advise. You will not have to renew your RT licence even if it shows an expiry date. Having previously held one then it is enough under current rules and you will be credited with the RT privileges as part of the new up to date life time UK licence. You will be issued with the SEP class rating. The main difference for you is that we now have a licence plus a type and/or a class rating.

An examiner cannot issue or renew a licence following the skill test. They can only re-validate or renew a rating when applicable, in your case it is not. The CAA will therefore issue your new licence in the current format and additionally the applicable rating.

[Whopity]

There was a short period when they were issued with such That period was from 1 July 1999 to 31 Dec 2000. If the licence is lifetime you only need training as required and a Prof Check to revalidate it. The Skill test is never taken again. The FRTOL may have been issued for life, or it may have had a 10 year validity in which case it will have to be reissued. An ELP will be required which requires an SRG 1199 from an Examiner, this has become a performance now that it is online, instead of taking 5 minutes the last one took me over 2 hours!

[Fl1ingfrog]

Whopity thanks, the required dreaded language proficiency I omitted. As to the skill test- but we don't call it that, the Proficiency Check; I would assess, because of the long lay off, in practice it will not be different save the paperwork.

With regard to the RT.

....or it may have had a 10 year validity in which case it will have to be reissued.

Now just over a month ago he would, most likely, be applying for a UK issued EASA compliant licence with no loss of privileges. In that instance he would not need to have a RT licence reissued even if the old RT licence had expired. Has that changed, I didn't think so, other than the letters EASA are now removed from the cover?

[BillieBob]

One further small point of clarification. It is not a PPL proficiency check that is required (there is no such thing) but a class rating proficiency check. A proficiency check is used for revalidation or renewal and, since the PPL is a non-expiring licence, there is no reason for a proficiency check to exist.

[Whopity]

Some FRTOLs were issued for the length of the pilot licence to which they were attached, whilst others were issued for the lifetime of the holder and a small number were issued for 10 years. I have one of each. If the FRTOL has expired then it needs to be re-issued. All pilot licences that were valid were reissued with ELP Level 4 for free, but licences that were not on record as being valid were not replaced. The original licence will need to be re-issued with ELP regardless. It can be converted to a UK Air Regulation Licence or could be reissued as a UK National licence or both. Stay on the high ground, renew the Class Rating at a DTO then apply for a UK Air Regulation Licence and ask for a UK National licence as well by ticking the box on SRG1104.

[Fl1ingfrog]

Whopity, you come to this from a background of considerable experience and knowledge. With regard to the ELP it is of course a ICAO requirement not a EASA initiative so all worldwide international valid licenses require it. It was a EASA decision to not include the UK requirement for a FRTOL stand alone licence for licenced pilots. Most states already included the privileges into a pilot licence. The separate FRTOL was, after all, very much a UK thing. It has been my belief and also my experience that where an applicant for a UK EASA compliant licence had previously held a UK FRTOL (expired or not); then they had satisfied the requirements for the RT privileges to be included in the UK EASA licence. I have never had an application rejected due to an expired FRTOL.

[Whopity]

It has been my belief and also my experience that where an applicant for a UK EASA compliant licence had previously held a UK FRTOL (expired or not); then they had satisfied the requirements for the RT privileges to be included in the UK EASA licence. In the main that has been true however; where the pilot holds a National licence, if the FRTOL has an expiry date then because the FRTOL is a seperate licence it has to be renewed. Prior to the ICAO ELP requirement, the CAA would normally re- issue a pilot licence together with a matching FRTOL.

In 2006 the CAA authorised RTF Examiners to issue a level 6 ELP to all candidates who demonstrated fluent English at the RTF test to get ahead of the game. In 2008 the CAA reissued all pilot licences to incorporate ELP; it did not indicate a level or validity period and it was assumed that anyone who held a FRTOL would be at least Level 4 which is only valid for 3 years.

Whilst there is no requirement to endorse a FRTOL with ELP, the CAA made it mandatory to have at least level 4 ELP before issuing or renewing a FRTOL. Anyone who didn't have Level 4 English would not be able to pass the RTF test anyway, but the Examiner could only issue a Level 6, not a great problem as most candidates are fluent English speakers.

Things then started to get into a muddle, the CAA seemed to have no idea who had level 6 based upon either the initial RTF Test or a subsequent flight test or revalidation with an Examiner, or perhaps they just can't be bothered to trawl through the records to find out. The result is that anyone who has a FRTOL that reaches its end of validity cannot get it reissued without a new ELP. Those who were actually awarded a Level 6 are now being charged to upgrade their presumed Level 4 to a 6 even though their initial assessment may have been at Level 6. All the effort to head off the problem by early preparation seems to have been thwarted by slovenly record keeping. It seems that ELP is now much more important than correct phraseology.

The requirements for the issue of a FRTOL come from the ITU General Radio Regulations; the UK is a signatory to the ITU but EASA is not.

[Fl1ingfrog]

where the pilot holds a National licence, if the FRTOL has an expiry date then because the FRTOL is a seperate licence it has to be renewed.

The CAA changed the UK National Licence into the same format as the EASA license: e.g.. Section XII Flight Radiotelephony Operators privileges. 'The holder of this licence has demonstrated competence to operate R/T equipment on board aircraft in English.' XIII Remarks 'Language Proficiency English Level 6. Valid for life'. The wording in my National licence is identical to that in my EASA licence and does not require an additional RT licence to be held.

I remember well the CAA reissuing licenses, without application, to include section XIII but providing only 'Level 4'. The CAA under a lot of pressure defended by saying that Level 4 was all that was required internationally for any purpose although limited to the three years. They also claimed this was satisfactory in the first instance because all ratings were issued for periods for one or two years and therefore all licence holders would need to see an examiner within the three years. The examiners were authorized to assess level 6 if appropriate during the course of revalidating/renewing ratings, without formality, and the relevant form included a section to do so. They also commented that it had never before been a requirement to demonstrate English proficiency for the issue of a UK pilots licence. It was likely therefore that many who would not be at level 6. Another hiccup was that the CAA never informed examiners of this and so pilots when revalidating/renewing were not always informally assessed and upgraded to level 6.

To add to the confusion many at the CAA were not properly briefed either. One fuming PPL having been sent to me in hope stormed into my office saying that the CAA had told him that he was required to attend a CAA approved language school to be assessed for level 6. "I spent 22 years in her Majesties Royal Air Force, retired as a Sqn. Ldr, and some bloody bureaucrat says i can't speak the Queens English". The incorrect advice given to this man was widely repeated by CAA staff at the time.

A Level 4 candidate should be able to pass a R/T licence test in my view.

[Whopity]

A Level 4 candidate should be able to pass a R/T licence test in my view. Thats my point, anyone who is capable of a pass in the RTF Test is at least level 4, but the examiner cannot award it, only a level 6.

From Art 37 of the ITU Radio Regulations:

37.1 The service of every aircraft station and every aircraft earth station shall be
controlled by an operator holding a certificate issued or recognized by the government to which the
station is subject.

37.4 4) Nevertheless, in the service of aircraft stations and aircraft earth stations
operating radiotelephony solely on frequencies above 30 MHz, each government shall decide for
itself whether a certificate is necessary and, if so, shall define the conditions for obtaining it.

37.30 2) For aircraft radiotelephone stations and aircraft earth stations operating on
frequencies allocated exclusively to the aeronautical mobile service or the aeronautical mobilesatellite
service, each administration may itself fix the conditions for obtaining a radiotelephone
operator’s restricted certificate, provided that the operation of the transmitter requires only the use
of simple external switching devices.

37.31 A radiotelephone operator’s certificate shall show whether it is a general
certificate or a restricted certificate and, in the latter case, if it has been issued in conformity with
the provisions of No. 37.30.


There are still people operating with National licences in the old format with stand alone FRTOLs and they do expire. To get it back, the priority is ELP not proficiency in operating the radio.

37.19 2) Administrations should take whatever steps they consider necessary to
ensure the continued proficiency of operators after prolonged absences from operational duties.

[shorehamite]

My candidate has this FRTOL, a lifetime licence, do i still need to send in a 1199 and state they are level 6, or is that not necessary, thanks.

[Whopity]

If they don't have a valid ELP on their pilot licence then you need to submit a 1199 for ELP. Its not simply a case of sending in the form any more, you have to do it online and it requires you to submit an ELP Certificate, in most cases that would have been the SRG1199! They then want a certified copy of the old licence and of course they will charge for it. What was a 5 minute job took me over 2 hours the last time I did it.

[shorehamite]

Thanks Whopity, ive found a paper version of 1199, i'll fill that in, sounds the easier option!

[gbovis]

Apologies and sincere thanks to all. I had completely forgotten about this question. To answer I got the licence in 1995 and it does say it remains valid for the holders lifetime unless revoked or varied so I assume it’s a lifetime licence. That said I appreciate things have likely changed again. Unfortunately I haven’t been in a position to move forward with revalidation but hopefully soon.

[Whopity]

Your best bet is to go to a Flying School now called a DTO, do training as required to pass a Proficiency Check. Then apply for a new Part FCL Licence. SRG1104. You will need a sign off for English Language Profficiency (ELP) the examiner can do that. You can keep your old licence by ticking a box and it will be reissued in the latest format. You will need a Class 2 medical to obtain a new licence but once you have it you can revert to a Medical Declaration.