flying Solo on expired Class rating

[1968]

I am preparing to renew my expired SE class rating. An examiner has told me I can fly solo with a current medical even though the rating has expired to prepare for the LST. This doesn't sound right. Is it correct? I presume the thinking is that you are flying with student pilot status.

[Whopity]

What he has not told you is that such a flight would require you to be authorised by an instructor as you status is now student pilot. If you have not flown for a while no instructor would authorise you to fly solo without first flying with you dual.

[selfin]

It's EASA's position that a PPL can be exercised up to the privileges of a LAPL by complying with the LAPL rolling currency requirement. Has the UK CAA taken a different view?

[BEagle]

It's EASA's position that a PPL can be exercised up to the privileges of a LAPL by complying with the LAPL rolling currency requirement. Has the UK CAA taken a different view?

No it isn't. A PPL can be exercised within LAPL limits if the LAPL element of the Part-MED certificate is still valid, but the licence holder must still comply with Class Rating revalidation criteria. LAPL 'rolling validity' only applies to genuine LAPLs, not to PPLs restricted by virtue of Part-MED certificate validity.

[selfin]

EASA has expressly stated the opposite in one of the CRDs.

[selfin]

Comment #655 by: UK CAA
Page No: 46
Paragraph No: FCL.205.A (a) - see also the UK CAA comment on FCL.040, page 34

Comment: It is understood that the intent of the change is to allow the PPL(A) to be used as a LAPL(A) if the pilot’s medical standard reduces from Class 2 to LAPL. However, there is a problem in that the ratings on a PPL have expiry dates, whereas the privileges of the LAPL do not, they have a rolling validity based upon recency.

The UK CAA does not believe that these two systems can or should be mixed. Whilst it is accepted that the holder of a PPL(A) should be able to exercise the privileges of the LAPL with a LAPL medical, it is suggested that the PPL(A) holder must continue to comply with the requirements for the revalidation or renewal of the aircraft ratings in accordance with FCL.740.A(b).

The same amendment should be made to the CPL(A) and ATPL(A) (but not the MPL(A)) - and also to the PPL(H), CPL(H) and ATPL(H) as these should also be usable as LAPLs.

Justification: To avoid confusion. Type and class ratings must be revalidated and renewed according to the rules that apply to those ratings.

Proposed Text: Amend FCL.205.A (a) to read: ‘…. and exercise the privileges of the holder of a LAPL(A) provided they have a valid Class Rating in accordance with FCL.740.A(b).” In addition, the equivalent text for the CPL(A), ATPL(A), PPL(H), CPL(H) and ATPL(H) should also be amended.

EASA RESPONSE

Not accepted

Thank you for your comment. The reason behind this amendment was made is that any additional burden for competent authorities or pilots should be avoided. Furthermore, it was considered that what works for the CPL should also be possible for PPL holders. It is clear that a pilot who holds a PPL and uses it as LAPL has to comply with all requirements for the LAPL as well and there it is not important if the licence was issued physically or not.

EASA CRD 2014-29(A), comment no. 655, pp 106-107. https://www.easa.europa.eu/en/document-library/comment-response-documents/crd-2014-29a

[Whopity]

Interesting comment and made before Brexit so it should apply to the Withdrawl Regulation!
They clearly haven't considered the possibility that by the same token you could exercise the privileges on a TMG as well as a SEP if no class rating is required!

[BillieBob]

I presume the thinking is that you are flying with student pilot status.That is not the CAA's view - you cease to be a student pilot as soon as you are in receipt of your licence. The current guidance on solo flights after completing the skill test is here (https://www.caa.co.uk/general-aviation/pilot-training-organisations/flights-after-completing-a-skill-test/) and, in particular, para 6. states:
Once the student pilot is in receipt of their licence, unless the licence is a Light Aircraft Pilot Licence (LAPL) or otherwise instructed by the UK CAA, they are not permitted to be authorised solo by the Flight Instructor for future flights. Which seems to say that you cannot be authorised to fly solo in preparation for the class rating proficiency check.

[Whopity]

The Guidance is an appalling document: Para 2 States:
The Flight Instructors and training organisations authorising the solo flights must be sure that the student pilot has made application to the UK CAA for the issue of the licence.
The simple fact is, if they havent received a licence, they are still a student; if they haven't applied for one they are definately a student.
Para 6 says:
Once the student pilot is in receipt of their licence, unless the licence is a Light Aircraft Pilot Licence (LAPL) But all licences now include LAPL privileges!
Para 4 states:
All authorised solo flights must be conducted in accordance with relevant legislation and the Approved Training Organisation’s (ATO) approved manuals or the Registered Training Facilities (RF) - Flying Order Book.
RTFs are long gone and never required a FOB neither does a DTO.

It is Guidance not Regulation and very poorly worded guidance!

[ifitaintboeing]

That is not the CAA's view - you cease to be a student pilot as soon as you are in receipt of your licence....Which seems to say that you cannot be authorised to fly solo in preparation for the class rating proficiency check.

The SEP Class Rating Training Programme (https://www.airpilots.org/file/7d4aaef9f84a7c3569da98e47db1315f/sep-programme-v1.pdf) in the Honourable Company of Air Pilots syllabus, as approved by the UK CAA, has solo at lesson A3.

It is Guidance not Regulation and very poorly worded guidance!

It's also only guidance for "Flights after completing a skill test but prior to receipt of a licence", which is the title of the page quoted, so would not be applicable in this case.

ifitaint...