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3 in 90 rule exceeded - 120+ and counting.......

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3 in 90 rule exceeded - 120+ and counting.......

Old 3rd Mar 2016, 08:07
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3 in 90 rule exceeded - 120+ and counting.......

Can anyone clarify? In the last 125+ days I have performed 4 take offs, and 2 landings, A321(due Captain only landing) as company tries to save money..... There is no way to extend my currency at this stage other than a simulator session with 3 take off and 3 landings. Am I correct??
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Old 3rd Mar 2016, 20:05
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Do you have a current SEP rating? You could do it in that? Or you could even do your 3 landings in SEP without a rating but as PuT with an instructor if you are sufficiently current to be sole manipulator of the controls.
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Old 4th Mar 2016, 08:04
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Do you have a current SEP rating? You could do it in that? Or you could even do your 3 landings in SEP without a rating but as PuT with an instructor if you are sufficiently current to be sole manipulator of the controls.

I'm not sure how that would help the OP.


From Commission Regulation (EU) No 1178/2011 (my underlining):


FCL.060 Recent experience

(a) [..]

(b) Aeroplanes, helicopters, powered-lift, airships and sailplanes. A pilot shall not operate an aircraft in commercial air transport or carrying passengers:
(1) as PIC or co-pilot unless he/she has carried out, in the preceding 90 days, at least 3 take-offs, approaches and landings in an aircraft of the same type or class or an FFS representing that type or class. The 3 take-offs and landings shall be performed in either multi-pilot or single-pilot operations, depending on the privileges held by the pilot; and

(2) [..]

(3) [..]
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Old 4th Mar 2016, 12:07
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You can extend from 90 to 120 by flying with a TRI/TRE, after 120 its back to the sim for 3 take-offs and landings.
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Old 4th Mar 2016, 19:20
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As ATC said...

Extract from my company OM Part D... (refers to legal requirements rather than the stricter company-specific requirements which are limited to 3 TO/LDGs in last 60 days or a red alert will flash up on crewing computers)


"It is a legal requirement... ...engaged in Public Transport, must have carried out three take-offs and
three landings in the aircraft type... ...previous 90 days... ...may be extended to 120 days... ...flying under the supervision of a Type Rating
Instructor/Type Rating Examiner...
The 90-day requirement... ...may be carried out in an approved simulator of the type..."


The wording doesn't specifically mention it, but as it also doesn't specifically prohibit it my interpretation of that is if you are out of 90-day currency but less than 120-day, you could do a 4-sector day or two 2-sector days with a TRI/TRE to get your 3 takeoffs and landings done and reset the 90 day counter.
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Old 4th Mar 2016, 20:08
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Originally Posted by Mustapha Cuppa
I'm not sure how that would help the OP.


From Commission Regulation (EU) No 1178/2011 (my underlining):
Errrr, yes.....can't argue......still not committed all of 1178 to memory...
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Old 5th Mar 2016, 09:19
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Interesting question as to what qualification that TRI must have, LIFUS/aircraft/sim only?

An on going debate here.
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Old 6th Mar 2016, 07:01
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Thanks all.
Have been pulled from my remaining flights to wait for sim....
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Old 6th Mar 2016, 07:50
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Originally Posted by nick14
Interesting question as to what qualification that TRI must have, LIFUS/aircraft/sim only?

An on going debate here.
Its very simple, TRI/TRE on the type, for the aircraft and current so they can occupy either the left or right seat during line ops as a crew member.
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Old 6th Mar 2016, 19:48
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Most TRIs will be simulator only (for us anyway) and therefore in my eyes not qualified for this task. TRE has nothing to do with training and I know of very few TREs that have aircraft privileges.

Personally it's either sim or line flight with a line training captain or TRI with aircraft privileges.
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Old 8th Mar 2016, 07:50
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Re Qualifications, crewing advised (rightly or wrongly) that after I exceeded 90 days, it would need to be a TRE, and not a TRI to use the 120 day extension, however they couldn't find one.
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Old 8th Mar 2016, 08:47
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Re Qualifications, crewing advised (rightly or wrongly) that after I exceeded 90 days, it would need to be a TRE, and not a TRI to use the 120 day extension, however they couldn't find one.
From Commission Regulation (EU) No 1178/2011 (my underlining):

FCL.060 Recent experience

(a) [..]

(b) [..]

(c) Specific requirements for commercial air transport:
(1) In the case of commercial air transport, the 90-day period prescribed in subparagraphs (b)(1) and (2) above may be extended up to a maximum of 120 days, as long as the pilot undertakes line flying under the supervision of a type rating instructor or examiner.

(2) When the pilot does not comply with the requirement in (1), he/she shall complete a training flight in the aircraft or an FFS of the aircraft type to be used, which shall include at least the requirements described in (b)(1) and (2) before he/she can exercise his/her privileges.
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Old 15th Jul 2016, 11:09
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The suggestion to renew my 90 day requirement via a SEP, I wasn't aware of.
So, if I understand you correctly you're saying that I can nip down to my local aero club do three take off and landings in a 172 and that will satisfy the 90 day rule for my Challenger 300? Surely, I have misunderstood you.
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Old 15th Jul 2016, 22:18
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You may wish to reread this thread, particularly my first post.
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Old 17th Jul 2016, 01:12
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(1) as PIC or co-pilot unless he/she has carried out, in the preceding 90 days, at least 3 take-offs, approaches and landings in an aircraft of the same type or class or an FFS representing that type or class
Just wanting to know why, since EASA do not specify it, everyone seems to assume that, for multi-crew operations, the requirement is only met as 'Pilot Flying'?
Is not 'Pilot Monitoring' carrying out their required crew function?

Note: Since my question concerns EASA and the wording of Part-FCL, no answer invoking "common sense" is admissable.
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Old 17th Jul 2016, 08:54
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Even EASA requires that today's Children of the Magenta must maintain a minimum level of handling skill to enable them to take-off and land safely. Of course this cannot be maintained in a light aircraft - the recency requirement clearly refers to the actual type of aircraft on which recency needs to be maintained.

Which is probably just as well - as otherwise many co-piglets could well find themselves acting purely as the sorcerer's apprentice, with perhaps the odd sector offered to them if they promise not to break anything...

The other money-saving 'pleasure' which certain airlines seem content to inflict on their passengers these days is flight training for very new pilots on actual route flying. I had the misfortune to have to fly from that wretched airport in Essex recently (the one next to the M11) - on return in perfect weather we were treated to quite the worst landing I've ever experienced in a commercial airliner.
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Old 18th Jul 2016, 11:25
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The answer saying that you can do it with a SEP is just ... Cant describe.

How would you maintain the "type" of a A380 for example doing 3 take offs and landings with a C-172? I mean, I would never think even near of that, just impossible.
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Old 25th Jul 2016, 21:17
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Beagle,

We all get it wrong occasionally, training or not they don't always go to plan.

There are plenty of airlines that conduct line training with pax on board, nothing wrong with that, even BA and Virgin now!
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Old 26th Jul 2016, 08:31
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Beagle

Civil ops a bit different to unlimited cost RAF training.
All airlines do line training on route flying.
A relative of mine did some circuit bashing in an empty Voyager after her conversion course on a Level D sim.
Never happen in the airlines, as long as you have previous jet experience, no base training required.
My first flight in a a real B747- 400 was with a full load of pax to Jo Burg. Training Capt. in RH seat of course. Cant remember what my landing was like!!
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Old 27th Jul 2016, 15:32
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TRE has nothing to do with training ...
An interesting comment, but don't forget a TRE must hold a TRI rating as a pre-requisite so, in effect, the statement about flying with a TRI or a TRE is saying the same thing - it is not the examiner element that is being used (to meet the requirement).
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