SEP(Sea) Revalidation by Experience
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As I read the FCL.740.A - 12 hrs flying amphibian would probably satisfy Land and sea class revalidation requirements. However 6 hours required as pilot in command, this is a difficulty for those of us new to seaplane flying as insurance for Pilot in command requires more hours on type.
Its amazing that touring motor glider time can satisfy requirements for both classes yet seaplanes do not get a mention in EASA land.
I wonder if P1s will satisfy the PIC requirement?
If not I think its a case of save my money till 3 months prior to expiry then do a short work up for skills test. A case of the regulations deterring real recency.
Its amazing that touring motor glider time can satisfy requirements for both classes yet seaplanes do not get a mention in EASA land.
I wonder if P1s will satisfy the PIC requirement?
If not I think its a case of save my money till 3 months prior to expiry then do a short work up for skills test. A case of the regulations deterring real recency.
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I picked this up some time ago and submitted a rule change request for it.
This is currently going to NPA to restore it to the way it was.
You ate incorrect, amphib time is still not counted, the requirements are 12hrs in each class at the moment.
This is currently going to NPA to restore it to the way it was.
You ate incorrect, amphib time is still not counted, the requirements are 12hrs in each class at the moment.
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Thanks for the reply Bose, why would amphibian time not satisfy both requirements as it is both classes by definition.
Good to see that the rule will change back again due to your efforts however. Thank you.
Good to see that the rule will change back again due to your efforts however. Thank you.
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That was exactly my point, why should amphib time not count? It will satisfy the time requirements. For each class! So as the rule stands you would need to do 24hrs in the same aircraft to meet the requirements! Stupid!
The CAA and EASA agreed that we had a problem hence the rule change request. As I understand it, this was an unintentional transposition from JAA to EASA as user JAA there were no clear rules in pace and each NAA implemented there own rules. The UK CAA implemented a very pragmatic rule and its that which we are seeking to reinstate. In fact actually a slightly lighter touch if that original rule.
The CAA and EASA agreed that we had a problem hence the rule change request. As I understand it, this was an unintentional transposition from JAA to EASA as user JAA there were no clear rules in pace and each NAA implemented there own rules. The UK CAA implemented a very pragmatic rule and its that which we are seeking to reinstate. In fact actually a slightly lighter touch if that original rule.
Last edited by S-Works; 25th Mar 2013 at 08:08.
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Thanks for the explanation Bose, lets hope that the pragmatic approach is reinstated.
F900- Neil Gregory at Loch Earn Scotland is perhaps the most popular choice for a sea plane rating in the UK.
Also try a search for GDRAM - a cessna 172 amphib based at Prestwick. The owner is also a Seaplane Class Instructor I believe.
Another option is in Northern Ireland I think its called the Amphibious Flying Club, that was pretty expensive when I last looked, operating a Maule.
Hope that helps
F900- Neil Gregory at Loch Earn Scotland is perhaps the most popular choice for a sea plane rating in the UK.
Also try a search for GDRAM - a cessna 172 amphib based at Prestwick. The owner is also a Seaplane Class Instructor I believe.
Another option is in Northern Ireland I think its called the Amphibious Flying Club, that was pretty expensive when I last looked, operating a Maule.
Hope that helps
Interesting thread - maybe there should be a sticky thread on "regulatory absurdities".
My current one is that although I have current MEP and SET ratings, I am not allowed to fly a SEP...
My current one is that although I have current MEP and SET ratings, I am not allowed to fly a SEP...
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Has there been any progress on revalidation by experiehce using an Amphibian?
I am still confused, i see no reason to do more than 12 hours in an amphibian which would satisfy both land SEP and sea SEP. Anybody revalidated by experience recently?
I am still confused, i see no reason to do more than 12 hours in an amphibian which would satisfy both land SEP and sea SEP. Anybody revalidated by experience recently?
The issue is now with FCL.002.
However, their NPA isn't due until the end of this year, at the earliest. Then it goes to consultation, after which they produce a comment response document. Following a period within which reactions can be made to the CRD, EASA then drafts an 'opinion'. Which then has to be voted upon at 'comitology' within the European Commission - after which it is moved to the European Parliament for MEPs to debate and to decide whether or not to introduce it into law.
So don't expect rapid movement. Mañana is a concept deemed far too urgent for EASA to adopt!
However, their NPA isn't due until the end of this year, at the earliest. Then it goes to consultation, after which they produce a comment response document. Following a period within which reactions can be made to the CRD, EASA then drafts an 'opinion'. Which then has to be voted upon at 'comitology' within the European Commission - after which it is moved to the European Parliament for MEPs to debate and to decide whether or not to introduce it into law.
So don't expect rapid movement. Mañana is a concept deemed far too urgent for EASA to adopt!
Last edited by BEagle; 10th May 2013 at 13:17.
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Aero Club Como in Italy ,on the lake of Como ( 25 km north of Milan, 4 km from Swiss boerder) operates a mixed fleed of Lake Anphibian, C172 (sea) , C206 (anphib-sea) C172 XP (Anphib) , PA 18 (180 HP , anphib), L19 (float) and a 'new' SeaBee just arrived from USA
Many instructors, wonderful area, you can convert or receive primary seaplane/anphib instruction - they instruct continuosly from 1932 !
D_11000
Many instructors, wonderful area, you can convert or receive primary seaplane/anphib instruction - they instruct continuosly from 1932 !
D_11000
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Thanks Beagle - so this state of confusion will continue.
I have just re - read IN 13/2013 which states:
nts are as follows:
FCL.740.A “(b) Revalidation of single-pilot single-engine class ratings.
(1) Single-engine piston aeroplane class ratings and TMG ratings. For revalidation of single-pilot single-engine piston aeroplane class ratings or TMG class ratings the applicant shall:
(i) within the 3 months preceding the expiry date of the rating, pass a proficiency check in the relevant class in accordance with Appendix 9 to this part with an examiner; or
(ii) within the 12 months preceding the expiry date of the rating, complete 12 hours of flight time in the relevant class, including: - 6 hours as PIC, - 12 take-offs and landings, and - a training flight of at least 1 hour with a flight instructor (FI) or class rating instructor (CRI). Applicants shall be exempted from this flight if they have passed a class or type rating proficiency check or skill test in any other class or type of aeroplane.
(2) When applicants hold both single-engine piston aeroplane-land class rating and a TMG rating, they may complete the requirements of (1) in either class, and achieve revalidation of both ratings.”
3.2 As the above requirements specify relevant class, and the SEP(Land) and SEP(Sea) are separate class ratings, this means that applicants wishing to revalidate by experience both SEP(Land) and SEP(Sea) have to meet the experience requirements in full for both class ratings. i.e. The revalidations and renewals of the two ratings must now be independent; there is no credit from one to the other.
I just do not understand why and how the class ratings can be revalidated independently of each other on an amphibian.
Eg
12 hours flying amphibian including 6hr p1 -and a 12 to and landings water and 12 to and landing land. Plus the hour with a FI or another relevant test complete.
So what gets signed off by experience? Land or Sea?
The answer has to be both, they cannot be independent of each other as the aircraft class is both.
FCL seem to have a lack of understanding of the meaning of amphibian.
Indeed when I completed my SEP land renewal and SEP Sea initial rating last year on the same flight they initially refused the application stating that they had to be on different aircraft. It took several emails to them to explain that an amphibian is by definition both land and sea and that requirements of both skills tests had been met.
In conclusion, I think the IN is only considering sea planes and land planes independently however the statement in para 3.2 makes it difficult for an examiner to sign any revalidations by experience on an amphibian.
FCL740.A is not the problem for amphibians - the incorrect interpretation in the IN is!
This can be sorted overnight IMHO by the CAA issuing an IN that considers the case of amphibians and interprets FCL 740.A with due regard amphibians.
I have just re - read IN 13/2013 which states:
nts are as follows:
FCL.740.A “(b) Revalidation of single-pilot single-engine class ratings.
(1) Single-engine piston aeroplane class ratings and TMG ratings. For revalidation of single-pilot single-engine piston aeroplane class ratings or TMG class ratings the applicant shall:
(i) within the 3 months preceding the expiry date of the rating, pass a proficiency check in the relevant class in accordance with Appendix 9 to this part with an examiner; or
(ii) within the 12 months preceding the expiry date of the rating, complete 12 hours of flight time in the relevant class, including: - 6 hours as PIC, - 12 take-offs and landings, and - a training flight of at least 1 hour with a flight instructor (FI) or class rating instructor (CRI). Applicants shall be exempted from this flight if they have passed a class or type rating proficiency check or skill test in any other class or type of aeroplane.
(2) When applicants hold both single-engine piston aeroplane-land class rating and a TMG rating, they may complete the requirements of (1) in either class, and achieve revalidation of both ratings.”
3.2 As the above requirements specify relevant class, and the SEP(Land) and SEP(Sea) are separate class ratings, this means that applicants wishing to revalidate by experience both SEP(Land) and SEP(Sea) have to meet the experience requirements in full for both class ratings. i.e. The revalidations and renewals of the two ratings must now be independent; there is no credit from one to the other.
I just do not understand why and how the class ratings can be revalidated independently of each other on an amphibian.
Eg
12 hours flying amphibian including 6hr p1 -and a 12 to and landings water and 12 to and landing land. Plus the hour with a FI or another relevant test complete.
So what gets signed off by experience? Land or Sea?
The answer has to be both, they cannot be independent of each other as the aircraft class is both.
FCL seem to have a lack of understanding of the meaning of amphibian.
Indeed when I completed my SEP land renewal and SEP Sea initial rating last year on the same flight they initially refused the application stating that they had to be on different aircraft. It took several emails to them to explain that an amphibian is by definition both land and sea and that requirements of both skills tests had been met.
In conclusion, I think the IN is only considering sea planes and land planes independently however the statement in para 3.2 makes it difficult for an examiner to sign any revalidations by experience on an amphibian.
FCL740.A is not the problem for amphibians - the incorrect interpretation in the IN is!
This can be sorted overnight IMHO by the CAA issuing an IN that considers the case of amphibians and interprets FCL 740.A with due regard amphibians.
Last edited by CLOUD999; 11th May 2013 at 09:58.
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Have this situation improved since this 2013-thread?
I will need to revalidate my SEP SEA in August and I don't have 12 hours this season, have plenty on land though.
I'm considering to change my license to a country that accepts land hours towards sea renewal unless UK CAA now also accepts this? I did send them an email but it will take some time to get the reply.
I will need to revalidate my SEP SEA in August and I don't have 12 hours this season, have plenty on land though.
I'm considering to change my license to a country that accepts land hours towards sea renewal unless UK CAA now also accepts this? I did send them an email but it will take some time to get the reply.
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isn't it easier to let the rating expire, and then do it again?. the course consists of 8 hours and no solo time, so it will be cheaper and better refresher than the 12 hours incl. 6h PIC
keenpilot, the requirements of FCL.740.A(b) were amended by Commission Regulation (EU) 2015/445 as follows:
Sorry I didn't see your post in time - hope that your Examiner was aware of the change.
When applicants hold both a single-engine piston aeroplane-land class rating and a single-engine piston aeroplane-sea class rating, they may complete the requirements of (1)(ii) in either class or a combination thereof, and achieve the fulfilment of these requirements for both ratings. At least 1 hour of required PIC time and 6 of the required 12 take-offs and landings shall be completed in each class.
