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Complex Non-High Performance

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Complex Non-High Performance

Old 14th Mar 2012, 16:22
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Complex Non-High Performance

Hello,

while working my way through the EASA Part-FCL I came across complex / non-complex, non high performance aircraft, however I couldn't find a definition of which aircraft would be in which category.

I'm wondering which aircraft I can actually excercise my rights as CRI / CRE on.

Any help to point me in the right direction is much appreciated.

FR
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Old 14th Mar 2012, 18:08
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Thanks for your input da-20 monkey, however I'm looking for the EASA definition.

I'm aware of the FAA definition, but EASA probably has something different in mind. With JAR-FCL we already had HPA High Performance Aircraft defined in the CR / TR list, but the complex / non-complex is new to me. I can find all sorts of items or restrictions regarding ratings and licenses, but nowhere can I find a definition of what EASA means by complex and high performance.

Cheers,
FR
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Old 14th Mar 2012, 20:44
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For EASA, a complex aircraft is any aircraft that
- has higher than 5,700 kg MTOW
- has more than 19 passenger seats
- is a multi-pilot aircaft
- is a Jet
- is a twin Turboprop

If at least one of the above is met, it is complex.
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Old 14th Mar 2012, 22:57
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On the other hand, rather than just making it up like Cobalt, we can go to the regulations.

Originally Posted by LASORS 2010
Complex type An aeroplane certificated for the carriage of at least four persons, having a variable pitch
propeller and retractable landing gear
(Section A, Appendix A, page 34)

(LASORS elsewhere differentiates between "complex SEP" and "complex MEP" - although I can't think of many, if any, non-complex MEP.)

You can of-course only teach on complex types, if you are rated on them themselves. But anybody with a JAR CPL is by definition, because they had to do part of the CPL and pass the skill test on a complex type. If you are a PPL/CRI without complex, then you can't teach on complex.

"Non-high performance" is anything not listed by EASA as "HPA" or "High Performance Aeroplane". If you look at the list here; if a type has "HPA" next to it, then it's High Performance. If the type isn't listed, or doesn't have HPA next to it, then it isn't.

Fiddly, but the information is all there if you know where to look for it. And don't just make it up!

G
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Old 15th Mar 2012, 02:06
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What cobalt has described is all aircraft requiring a type rating Genghis if you loose the twin from infront of turboprop.
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Old 15th Mar 2012, 08:52
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Genghis,

Cobalt is not making it up. This is the meaning of "complex motor-powered aircraft" as defined by EASA in Basic Regulation 3(j).

It is unfortunate that they chose the word complex as it creates confusion with the common understanding of VP+RG+flaps. However it is important to understand the new definition as it has implications on Ptf, maintenance requirements, etc.

Sources:
EASA proposal to hit FAA licensed pilots in Europe
http://hub.easa.europa.eu/crt/docs/viewnpa/id_100
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Old 15th Mar 2012, 08:57
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What I think we are actually talking about is what a CRI will be able to train on and. CRE test on. It is my understanding that a CRI will be able to teach anything that does not require a HPA rating. If its a type rated aircraft that requires HPA (or an ATPL exam pass) then its going to needle a TRI/TRE going forward.

Now what interesting is how you become a TRI/TRE on SPA types under the new rules.
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Old 15th Mar 2012, 17:22
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To take someone to task for not referring to the regulations and then to refer to LASORS is, to say the least, something of an own goal. LASORS is most emphatically not a regulatory document and has nothing whatever to say about EU regulation (as opposed to current JAA Requirements), which was the subject of the original question.

The thing to remember when dealing with EU regulation is that you cannot consider one element (e.g. Part-FCL) in isolation but have to consider the whole regulatory structure - in the case of aircrew licensing, for example, you need to consult the Basic Regulation (Regulation (EC) 218/2008), the Aircrew Regulation (Regulation (EU) 1178/2011) and its annexes (Part-FCL, etc.) and the associated AMCs and GM in order to get the full picture.

The definition of a complex motor powered aircraft is in Article 3 of the Basic Regulation and cobalt was pretty close in his paraphrasing. The use of the term 'complex' in relation to the aircraft used in the CPL(A) course is incorrect - neither JAR-FCL1 nor Part-FCL uses the term in this context, both referring, in full, to "an aeroplane certificated for the carriage of at least four persons [with] a variable pitch propeller and retractable landing gear". It could be said that the 'unfortunate' thing is not that EASA chose to properly define the word 'complex' but that pilots had previously chosen to use the term incorrectly.

A high performance aircraft is one that is so defined in the EASA class and type rating list. Consequently, a CRI/CRE may exercise his privileges on any type that is not defined as either HPA or a complex motor powered aircraft.

The requirements for a TRI(SPA) certificate are to be found in Part-FCL at FCL.915.TRI
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Old 15th Mar 2012, 22:26
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Well I would have referred to either JAR-1 or EASA-definitions, but neither document contains the word "complex".

LASORS did seem to me a sensible document to refer a (probably) UK based CRI trying to work out what he's able to do, given the absense of anything else particularly coherent.

G
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Old 15th Mar 2012, 22:53
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Well I would have referred to either JAR-1 or EASA-definitions, but neither document contains the word "complex".
And neither is relevant to Part-FCL (the subject of the original question)
LASORS did seem to me a sensible document to refer a (probably) UK based CRI trying to work out what he's able to do, given the absense of anything else particularly coherent.
Were the original question about the JAA requirements for CRI/CRE, that might have been relevant, unfortunately it was not.

Time to wake up, guys, the EU Regulation is law in 3 weeks and 3 days.
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Old 15th Mar 2012, 23:50
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EASA basic regulation Art 3(j)



complex motor-powered aircraft shall mean:

(i) an aeroplane:


with a maximum certificated take-off mass exceeding

5 700 kg, or


certificated for a maximum passenger seating configuration


of more than nineteen, or



certificated for operation with a minimum crew of at least

two pilots, or


equipped with (a) turbojet engine(s) or more than one

turboprop engine, or


(ii) a helicopter certificated:


for a maximum take-off mass exceeding 3 175 kg, or

for a maximum passenger seating configuration of more

than nine, or

for operation with a minimum crew of at least two pilots,

or

(iii) a tilt rotor aircraft;



Well done Cobalt. Making it up indeed!

Further EASA definitions are found in Annex I to EU regulations for operators and in this respect I have some sympathy for Genghis as EASA were 'forced' by the commission to spread definitions across several documents after intervention by two large EU states. Not ideal.

Posting regulatory advice based on assumption is a little shabby.
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Old 16th Mar 2012, 07:37
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So, I was unfair in my criticism of Cobalt. Sorry about that old chap.

However, going back to the OPs question, which definition applies to a CRI / CRE ? It seems to me that it probably is anything not requiring a type rating?

G
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Old 16th Mar 2012, 16:00
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No probs, Gengis - and your point that I should have referred to the regs is a good one, I just happened to know that one off the cuff because a couple of days ago I had a discussion with a King Air operator what being subject to regs for "Complex" aircraft under EASA will mean.


Number and verse on CRI and TRI - There are actually three distinctions:
  • Complex / Non-Complex - as defined in the basic regulation
  • High Performance - as classified by EASA for type rating purposes
  • Single-Pilot / Multi-Pilot - as classified during certification
A CRI can only instruct on Non-Complex, Non-High-Performance, Single-Pilot - FCL.905.CRI (a) (1).

Some of them might require a type rating, such as a low-end turboprop that is not classified high performance, so a CRI can instruct for these type ratings

A CRE, however, can examine for anything single-pilot except Complex High-Performance, so can examine on low-performance complex (I guess a Turbine Islander is one) and high-performance non-complex (TBM 700 and suchlike), but not on a Mustang or King Air
(see FCL.1005.CRE)


Interestingly enough, he needs a "CRI for the applicable class or type" (FCL.1010.CRE (b)), which is impossible for high-performace non-complex, so probably one of the many errors in this mess.
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Old 17th Mar 2012, 10:20
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Thank you all for your input. The mist is beginning to clear.

In the beginning I felt quite sheepish thinking I was missing something. I'm just glad I'm not the only one ...

By the way, the aircraft in question is a Dornier 228, MTOM 6400kgs.
From the information I got so far this makes it a single pilot, complex, non-high performance aircraft; and CRI / CRE will still be sufficient.

Cheers,
FR
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Old 17th Mar 2012, 11:32
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Yes, it is complex by virtue of its MTOM and also since it is a twin turboprop. (BTW - the EASA type rating list is here. Anythig marked HPA is high performance, otherwise it is not.


If you look at the exact wording, a CRI is NOT sufficient, because it is limited to non-HP non-complex single pilot

Originally Posted by EASA FCL.905.CRI (a) (1)
(a) The privileges of a CRI are to instruct for:

(1) the issue, revalidation or renewal of a class or type rating for non-complex non-high performance single-pilot aeroplanes, when the privileges sought by the applicant are to fly in single-pilot operations;

(2) a towing or aerobatic rating for the aeroplane category, provided [... exact conditions removed]

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Old 18th Mar 2012, 19:37
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CRI or TRI, that is the question

Cobalt, you seem to be quite on top of things. Thank you very much for your help so far.

Having gone through the Basic Regulation I returned to the FCL:

As you quote the CRI may instruct for SP non-complex non-HPA.
FCL.905.TRI states that:
The priviliges of a TRI are to instruct for:
[...]
(c) in case of the TRI for single-pilot aeroplanes:
(1) the issue, revalidation and renewal of type ratings for single-pilot high performance single pilot aeroplanes [...]

Since EASA states it so explicitly, who's going to instruct for non-complex HPA or complex non-HPA?

Best regards,
FR
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Old 19th Mar 2012, 12:33
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I only know it because I did look at the differences between instructor ratings JAA --> EASA in detail to decide what to do myself (I went for FI).

An FI can do this - it says
 

 
Originally Posted by EASA FC 905.FI
(b) class and type ratings for single-pilot, single-engine aircraft, except for single-pilot high performance complex aeroplanes ...
(b) single-pilot multi-engine class or type ratings, except for single-pilot high performance complex aeroplanes


I have no idea if it is intentional that there is no TRI for "single-pilot high-performance non-complex" nor for "single-pilot non-high-performance complex" aeroplanes.

It looks like that someone decided to limit the CRI, and forgot to make the CRE consistent or think about whether that should mean a TRI should be able to do this.

FoxRomeo, what are you actually after? If you are a CRI and have been instructing on a DO 228, I would write a letter to the CAA and ask them in what way your current privileges will be transferred once EASA comes into force - they came up with an answer for IMC rating holders (national licence with anational rating), perhaps there will be a pragmatic solution at least until 2014, which will work as long as you use it in the UK.
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Old 20th Mar 2012, 13:33
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Hello Cobalt,

your comment with the FI did the trick. I was probably using to narrow an approach to the whole thing. As I'm a FI I will be able to continue regardless of whether they call me a CRI or a TRI.

Unfortunately it's not the UK and our CAA is even thinking about opting out of the entire EASA-FCL which doesn't make it much easier getting any comment from them. Then all of a sudden they realize that some regulations are actually in force since who knows when and every thing you did was wrong. Has happened before.

Thanks very much for your input.
Cheers,
FR
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