Solo supervision Lapsed SEP
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I still feel common sense should apply.
This isn't a one size fits all discussion. Some people go to renew a recently lapsed rating, do the training, pass the test, job done.
For others, the whole reason they let the rating lapse was due to a total lack of confidence and a fear of going off on their own, beyond the fold on their map, for whatever reason.
For these people, some supervised and constructive solo before a test is of great benefit, something which perhaps the law doesn't cater for, but at the same time doesn't definitely say is prohibited.
This isn't a one size fits all discussion. Some people go to renew a recently lapsed rating, do the training, pass the test, job done.
For others, the whole reason they let the rating lapse was due to a total lack of confidence and a fear of going off on their own, beyond the fold on their map, for whatever reason.
For these people, some supervised and constructive solo before a test is of great benefit, something which perhaps the law doesn't cater for, but at the same time doesn't definitely say is prohibited.
Probably not, but that would be the decision of the Authority (CAA) - not the flying instructor or examiner.
After 30 years I'm sure the CAA would require 're-training' in order to 'regain' his/her licence.
How can you possibly have a Rating?
You haven't got a licence to include it in!!!
You haven't got a licence to include it in!!!
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Sorry FOK, we will have to continue to disagree.
Whopity beat me to the keyboard, Under EASA Part FCL it is nothing to do with the CAA what training a pilot requires to renew his rating, even in the extreme example I created above. It is for the HoT to assess the training requirements and it is entirely his purgative to include solo flying if he feels that is appropriate.
BillieBob summarized it very nicely and in particular his reference to FCL.740(b)(1) is the key. This is the law; no more, no less! I absolutely agree that an individual instructor can't just send a pilot with an expired rating off on a solo; but, if the HoT assesses that solo flying is appropriate then an instructor can send the pilot flying to achieve that.
I think this discussion has just about run it's course. I'm quite confident that I understand the rules as they exist today and I'll carry on working on that premise.
Merry Christmas to all and many happy landings in 2014
3 Point
Whopity beat me to the keyboard, Under EASA Part FCL it is nothing to do with the CAA what training a pilot requires to renew his rating, even in the extreme example I created above. It is for the HoT to assess the training requirements and it is entirely his purgative to include solo flying if he feels that is appropriate.
BillieBob summarized it very nicely and in particular his reference to FCL.740(b)(1) is the key. This is the law; no more, no less! I absolutely agree that an individual instructor can't just send a pilot with an expired rating off on a solo; but, if the HoT assesses that solo flying is appropriate then an instructor can send the pilot flying to achieve that.
I think this discussion has just about run it's course. I'm quite confident that I understand the rules as they exist today and I'll carry on working on that premise.
Merry Christmas to all and many happy landings in 2014
3 Point
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I'm quite confident that I understand the rules as they exist today and I'll carry on working on that premise.
It's very easy to sit in an armchair at home and create hypothetical legal problems that just don't exist, the fact is that if you phone the CAA seeking guidance, they will clear it right up, as would any insurance company.
The few on here are free to not send these students solo.
For the rest of us, we'll carry on doing so, and noone will stop us, as it isn't illegal to do so.
It is always convenient to take sentences or parts of sentences out of context in order to make a point, no matter how flawed that point may be. Unfortunately, the whole EASA Regulation (i.e. the Basic Regulation, the relevant Enabling Regulation, the relevant Annex and its AMCs and GM and, in some cases, other regulations) has to be understood if the context of an individual requirement is to be correctly interpreted. As we know, there is no cross-referencing and so this is not an easy task - even the CAA often finds difficulty in correctly interpreting the Regulations, as has been demonstrated by the repeated revision of CAP 804 and various Information Notices.
FOK avers, by implication, that Article 50 of the ANO refers only to student pilots (i.e. those who do not yet hold a licence) but this is incorrect. The Article refers to an 'appropriate' licence, i.e. one that includes the privileges appropriate to the task. FCL.045 makes clear that the privileges of an EASA licence may be exercised only if the relevant ratings contained in it are valid. If the rating has expired, the privileges of the licence may not be exercised, it ceases to be 'appropriate' and Article 50(2) applies.
To renew an expired class or type rating, the holder is required to undertake refresher training at an ATO. Paragraph 1h of Annex II to the Basic Regulation requires that all training must be executed through a training course. In the case of refresher training, the course is developed entirely at the discretion of the ATO and may well include both dual flight instruction and supervised solo flight time. There is nothing in any of the regulations to prevent this.
FOK avers, by implication, that Article 50 of the ANO refers only to student pilots (i.e. those who do not yet hold a licence) but this is incorrect. The Article refers to an 'appropriate' licence, i.e. one that includes the privileges appropriate to the task. FCL.045 makes clear that the privileges of an EASA licence may be exercised only if the relevant ratings contained in it are valid. If the rating has expired, the privileges of the licence may not be exercised, it ceases to be 'appropriate' and Article 50(2) applies.
To renew an expired class or type rating, the holder is required to undertake refresher training at an ATO. Paragraph 1h of Annex II to the Basic Regulation requires that all training must be executed through a training course. In the case of refresher training, the course is developed entirely at the discretion of the ATO and may well include both dual flight instruction and supervised solo flight time. There is nothing in any of the regulations to prevent this.
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Interesting discussion Guys.
... seems to sum it all up!
The emphasis being where the HoT deems 'refresher training' necessary, rather than in the case of a recently lapsed Rating.
Thanks for that and I hope you all have a good Christmas and New Year
FOK
I absolutely agree that an individual instructor can't just send a pilot with an expired rating off on a solo; but, if the HoT assesses that solo flying is appropriate then an instructor can send the pilot flying to achieve that.
The AMC provides guidance on what may be required thereafter its up to the HT. In that process solo may be included and is perfectly legal.
To renew an expired class or type rating, the holder is required to undertake refresher training at an ATO. Paragraph 1h of Annex II to the Basic Regulation requires that all training must be executed through a training course. In the case of refresher training, the course is developed entirely at the discretion of the ATO and may well include both dual flight instruction and supervised solo flight time. There is nothing in any of the regulations to prevent this.
The emphasis being where the HoT deems 'refresher training' necessary, rather than in the case of a recently lapsed Rating.
Thanks for that and I hope you all have a good Christmas and New Year
FOK
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"The emphasis being where the HoT deems 'refresher training' necessary, rather than in the case of a recently lapsed Rating."
I'm not sure what this means FOK. A lapsed rating is a lapsed rating, whether 1 day, 1 year or 1 decade it makes no difference. For renewal, an assessment is always required. Of course, the outcome of the assessment will vary in every case and one factor will be how long since the rating expired but the requirement for the ATO to make an assessment is always in place for an expired rating.
It is permissible for the ATO to assess that no training is required but the assessment is still required. For example, an experienced pilot whose SEP rating expired last week but who has been regularly flying SEP throughout the past two years and who is planning to take the LST today; proably needs no training but he will need an assessment stating "no training required".
It's all clearly shown in CAP 804 and in AMC1 FCL.740(b)(1) to part FCL. Just get CAP 804 open on your computer, search for AMC1 FCL.740(b)(1) then read and enjoy!
Merry Christmas
I'm not sure what this means FOK. A lapsed rating is a lapsed rating, whether 1 day, 1 year or 1 decade it makes no difference. For renewal, an assessment is always required. Of course, the outcome of the assessment will vary in every case and one factor will be how long since the rating expired but the requirement for the ATO to make an assessment is always in place for an expired rating.
It is permissible for the ATO to assess that no training is required but the assessment is still required. For example, an experienced pilot whose SEP rating expired last week but who has been regularly flying SEP throughout the past two years and who is planning to take the LST today; proably needs no training but he will need an assessment stating "no training required".
It's all clearly shown in CAP 804 and in AMC1 FCL.740(b)(1) to part FCL. Just get CAP 804 open on your computer, search for AMC1 FCL.740(b)(1) then read and enjoy!
Merry Christmas
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In the case of refresher training, the course is developed entirely at
the discretion of the ATO
the discretion of the ATO
I agree ATOs have a lot of discretion, but not complete and absolute freedom
to do what they like.
AMC1 FCL.740(b)(1) states:
...an individual training programme that should be based on the initial training
for the issue of the rating....
for the issue of the rating....
than Licence) issue.
This discussion is all about SEP Class Rating renewal. I have never heard
of Class Rating Instructors authorising solo flight for unqualified pilots, are
you saying they can (provided student has valid Licence and Medical)?
Just because a course is 'based on' the initial training, it does not mean that solo flight cannot be included. Solo consolidation of exercises in the class rating syllabus would be perfectly in order. Out of interest, since you say that you are unaware of any solo requirement, can you give me a Part-FCL reference for the minimum training requirements for initial issue of an SEP class rating?
Class Rating instructors may not authorise solo flight by pilots who do not hold an appropriate licence - Article 50 refers specifically to Flight Instructors
Class Rating instructors may not authorise solo flight by pilots who do not hold an appropriate licence - Article 50 refers specifically to Flight Instructors
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I would be surprised if there is even a syllabus available for a stand alone SEP class rating.
So the issue of if there is solo required for it or not is pretty much of a zero point unless you can provide one.
So the issue of if there is solo required for it or not is pretty much of a zero point unless you can provide one.
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My inquiry of the CAA this morning when asked if it was permitted for a pilot who already holds a licence to do solo training in order to renew the rating resulted in:
"We would not ordinarily expect the holder of a lapsed rating to undertake any solo flights in order to renew a class rating"
I have escalated further to the policy team for a full clarification.
"We would not ordinarily expect the holder of a lapsed rating to undertake any solo flights in order to renew a class rating"
I have escalated further to the policy team for a full clarification.
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Its not the UK CAA you need to speak to, its EASA main office.
The UK CAA can't make policy and even if it is their policy if the law isn't written in such a way to prevent it, they can have what whatever policy they like until its had case law developed through court.
I suspected if they got stroppy about it, you could just say see ya in court and they would slink off. A lawyer would look at the legislation and say there was nothing illegal about it.
They can't just ban things these days because the head of policy doesn't like the idea. All they can do is point you to the legislation that has been quoted.
If they want they can apply to EASA to get the relevant bit changed which they may do for you. But to be honest I think its a mistake as in my experience it is useful tool. And as the any change will have to be put out to consultation I would argue to keep the ability and leave it up to the HOT to decide what is best for the student.
The UK CAA can't make policy and even if it is their policy if the law isn't written in such a way to prevent it, they can have what whatever policy they like until its had case law developed through court.
I suspected if they got stroppy about it, you could just say see ya in court and they would slink off. A lawyer would look at the legislation and say there was nothing illegal about it.
They can't just ban things these days because the head of policy doesn't like the idea. All they can do is point you to the legislation that has been quoted.
If they want they can apply to EASA to get the relevant bit changed which they may do for you. But to be honest I think its a mistake as in my experience it is useful tool. And as the any change will have to be put out to consultation I would argue to keep the ability and leave it up to the HOT to decide what is best for the student.
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We would not ordinarily expect the holder of a lapsed rating to undertake any solo flights in order to renew a class rating
But to be honest I think its a mistake as in my experience it is useful tool
Particularly so if CAA policy is as described by Bose-X and there is nothing SPECIFICALLY IN WRITING in the various FCL documents which states that solo flight to regain a Rating can be undertaken as a means of retraining.
The fact that nothing is mentioned does not, in my opinion, allow an HoT to determine that, by omission, it would be acceptable to allow such 'solo' flying (Perhaps I've missed the particular wording?).
These discussions are interesting if only to highlight the lack of certainty when applied to current flying training.
I can't remember 20 years ago anything like the amount of uncertainty and interpretation to be applied to the rules regarding flying instructing. It all seemed so simple then - black and white (or is it just my rose-tinted spectacles clouding the view?!?!).
FOK
Last edited by FlyingOfficerKite; 20th Dec 2013 at 19:10.
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MJ, the UK CAA are the voice of EASA. If you contact EASA directly they will refer you back to the UK CAA.
It is the job of the UK CAA to interpret the legislation and set policy as it applies to the regulation. I happen to find them very good at helping with such questions and clarifying how the UK CAA will interpret the policy I regard to UK licence holders and UK training facilities.
As the head of Training of a UK ATO I would be foolish to override their statement of policy because I thought I knew better or read it on a Internet forum...
It is the job of the UK CAA to interpret the legislation and set policy as it applies to the regulation. I happen to find them very good at helping with such questions and clarifying how the UK CAA will interpret the policy I regard to UK licence holders and UK training facilities.
As the head of Training of a UK ATO I would be foolish to override their statement of policy because I thought I knew better or read it on a Internet forum...
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I doud`t it would require any explaining if you stick to the usual rules for signing some one out solo.
If the caa comes out with anything other that its up to the HOT to decide they are over stepping there remit.
There is zero safety case for banning the practise.
If anyone has even a suggestion what is unsafe about the practise please post.
If the caa comes out with anything other that its up to the HOT to decide they are over stepping there remit.
There is zero safety case for banning the practise.
If anyone has even a suggestion what is unsafe about the practise please post.
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Reference to the CAA Standards Document 14, version 6, dated September 2012 "Guidance for Examiners and Information for Pilots of Single Pilot Aeroplanes" reveals
Appendix 4 - Renewal of Type, Class and Instrument Ratings: Refresher Training
The objective of the training is to reach the level of proficiency necessary to safely operate the relevant type or class of aeroplane and/or continue to exercise the privileges of an instrument rating. The amount of refresher training needed shall be determined on a case by case basis by the ATO, taking into account the experience of the applicant, the complexity of the aircraft and the amount of time elapsed since the expiry of the validity period of the rating. The following may be taken as guidance when determining the needs of the applicant.
For a class or type rating:
1. Expiry for a period shorter than three months: no supplementary requirements;
2. Expiry for a period longer than three months but shorter than one year: a minimum of two training sessions;
3. Expiry for longer than one year but shorter than three years: a minimum of three training sessions in which the most important malfunctions in the available systems are covered;
4. Expiry for longer that three years: the applicant should again undergo the training required for the initial issue of the rating.
In CAP 804 Part I:
FCL.700 Circumstances in which class or type ratings are required
(a) Holders of a pilot licence for aeroplanes shall not act in any capacity as pilot of an aeroplane unless they have a valid and appropriate class or type rating, except when undergoing skill tests, or proficiency checks for renewal of class or type ratings, or receiving flight instruction
Standards Document 14 is for the guidance of examiners, of which a HoT would be one.
There is no mention here, in these CAA documents, about ‘solo’ flying forming any part of the refresher training. Training for the initial issue of a rating does not normally include any ‘solo’ flying either.
FOK
Appendix 4 - Renewal of Type, Class and Instrument Ratings: Refresher Training
The objective of the training is to reach the level of proficiency necessary to safely operate the relevant type or class of aeroplane and/or continue to exercise the privileges of an instrument rating. The amount of refresher training needed shall be determined on a case by case basis by the ATO, taking into account the experience of the applicant, the complexity of the aircraft and the amount of time elapsed since the expiry of the validity period of the rating. The following may be taken as guidance when determining the needs of the applicant.
For a class or type rating:
1. Expiry for a period shorter than three months: no supplementary requirements;
2. Expiry for a period longer than three months but shorter than one year: a minimum of two training sessions;
3. Expiry for longer than one year but shorter than three years: a minimum of three training sessions in which the most important malfunctions in the available systems are covered;
4. Expiry for longer that three years: the applicant should again undergo the training required for the initial issue of the rating.
In CAP 804 Part I:
FCL.700 Circumstances in which class or type ratings are required
(a) Holders of a pilot licence for aeroplanes shall not act in any capacity as pilot of an aeroplane unless they have a valid and appropriate class or type rating, except when undergoing skill tests, or proficiency checks for renewal of class or type ratings, or receiving flight instruction
Standards Document 14 is for the guidance of examiners, of which a HoT would be one.
There is no mention here, in these CAA documents, about ‘solo’ flying forming any part of the refresher training. Training for the initial issue of a rating does not normally include any ‘solo’ flying either.
FOK
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Its there except when recieving flight instruction.
Please provide the syllabus for a sep class rating.
I don`t really understand why you are all getting your knickers in a twist about people enjoying going flying under controlled conditions. If you don`t want to do it yourself thats fair enough. There is zero safety case to prevent those that do want to use solo as a confidence booster/ practise/ maintain currency before test.
Please provide the syllabus for a sep class rating.
I don`t really understand why you are all getting your knickers in a twist about people enjoying going flying under controlled conditions. If you don`t want to do it yourself thats fair enough. There is zero safety case to prevent those that do want to use solo as a confidence booster/ practise/ maintain currency before test.
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It's not about getting our knickers in a twist, it's about making sure that in this day and age we don't get our asses in a sling.
I do not see any need for solo training when doing training to renew a rating. Clearly neither do the authority.
I actually have a syllabus for an SEP class rating that was produced in order to add SEP ratings to the licences of integrated students who ended up only with an MEP/IR. It is also used for adding SEP to licences that only had motor gliders and for pilots on NPPL adding the SSEA.
There is no solo in it. You are confusing the training for the issue of a licence with the training for any class rating. The SEP post licence is just a class rating.
I do not see any need for solo training when doing training to renew a rating. Clearly neither do the authority.
I actually have a syllabus for an SEP class rating that was produced in order to add SEP ratings to the licences of integrated students who ended up only with an MEP/IR. It is also used for adding SEP to licences that only had motor gliders and for pilots on NPPL adding the SSEA.
There is no solo in it. You are confusing the training for the issue of a licence with the training for any class rating. The SEP post licence is just a class rating.
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Well some of do see the benefit of solo time to refresh PIC skills and develop confidence for when they get let loose with innocent pax onboard.
There is no question or issue with getting any ones ass in a sling.
I am not confusing the issue. The integrated student has already completed the SEP class rating its just they were never signed off for it by an examiner to allow the class rating to be issued so your only revalidating there training to bring them up to speed for class test.
Well if you fire leading questions into them what do you expect. Say yes and he will piss off, leave it for a bit and then do nothing and maybe things on pprune will calm down and people will just continue what they are doing anyway and everyone can be happy.
And There are going to be a couple of single figure exam call signs not happy with it either as I have seen them send and recommend some solo time for students revalidating.
My experience is that it is a useful tool to bring the pilot up to the standard to be safe flying innocent pax. Are we training pilots to pass tests or be safe pilots?
Again I ask what is the safety case for stopping those of us that are happy and willing who believe it is of benefit to the student from doing it.
You have stated that you don't think its worth it so now you are actively trying to get the authority to issue a policy to make others comply with your interpretation.
Pre JAR they had legislated that the student did have to repeat there XC after a period so its not as if there isn't many years of it being prescribed for a class renewal. Yes any idiot can pole the aircraft round a series of exercises. But the PIC side of things needs refreshed as well. Supervised solo time plays a big part in that which is why we have it for license issue. The being on their tod and having to deal with situations themselves is a wake up call some need. Better to do it supervised than by themselves.
Every student is different it is appropriate and required for some others its not required.
There is no question or issue with getting any ones ass in a sling.
I am not confusing the issue. The integrated student has already completed the SEP class rating its just they were never signed off for it by an examiner to allow the class rating to be issued so your only revalidating there training to bring them up to speed for class test.
Clearly neither do the authority.
And There are going to be a couple of single figure exam call signs not happy with it either as I have seen them send and recommend some solo time for students revalidating.
My experience is that it is a useful tool to bring the pilot up to the standard to be safe flying innocent pax. Are we training pilots to pass tests or be safe pilots?
Again I ask what is the safety case for stopping those of us that are happy and willing who believe it is of benefit to the student from doing it.
You have stated that you don't think its worth it so now you are actively trying to get the authority to issue a policy to make others comply with your interpretation.
Pre JAR they had legislated that the student did have to repeat there XC after a period so its not as if there isn't many years of it being prescribed for a class renewal. Yes any idiot can pole the aircraft round a series of exercises. But the PIC side of things needs refreshed as well. Supervised solo time plays a big part in that which is why we have it for license issue. The being on their tod and having to deal with situations themselves is a wake up call some need. Better to do it supervised than by themselves.
Every student is different it is appropriate and required for some others its not required.