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EASA Uprt-Loc update

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Old 12th Dec 2019, 14:01
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Originally Posted by markkal
there is nothing specific in the whole very long and bureaucratic legalese written document: ORO.FC.220&230
ORO.FC.220&230 deal with operator conversion training and checking and with recurrent training and checking. These include simulator UPRT but are not relevant to on-aircraft UPRT.

The on-aircraft advanced UPRT information is given at FCL.745.A and the associated instructor training at FCL.915(e)

Last edited by Rivet gun; 12th Dec 2019 at 14:26.
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Old 13th Dec 2019, 14:31
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Originally Posted by Rivet gun

(d) Aeroplanes used in this course should be:
(1) appropriately certified and operated by the ATO in a manner that takes into account the effects of repeated training manoeuvres on airframe fatigue life; and
(2) provide sufficient safety margins to cater for student and instructor errors.

My emphasis in bold face. I don't see how a CS23 normal cat aircraft can meet these requirements.

I understand it was once intended that the training should be 3 hours actual training not counting taxi, take off, climb and recovery. However the way Part-FCL is written the minimum is 3 hours from the moment an aircraft first moves for the purpose of taking off until the moment it finally comes to rest at the end of the flight.
.
Sadly there remains a substantial amount of confusion for a regulation that becomes mandatory one week from today.

I participated in EASA RMG.0581 that ended up writing FCL.715.A. I completely agree that the psychological objectives of the on-aircraft UPRT programme cannot be met in anything other than an aerobatic aircraft. People are completely missing the point if they attempt the training in a non-aerobatic platform.

And yes, the intention was AND STILL IS that the training should be 3 hours of actual training - I wrote the original requirement along with a member of the APS team. The way Part-FCL has been written is misleading; EASA have subsequently confirmed to me - which I have relayed to the CAA - that the requirement IS 3 hours of actual training.

With one week to implementation, my understanding is that the CAA have yet to approve any FCL.915(e) courses that qualify FIs to deliver FCL.745.A, which will make life interesting. Our course was submitted 8 months ago for approval; heard this week that it's 'being worked on'.

Last edited by greeners; 13th Dec 2019 at 15:32.
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Old 13th Dec 2019, 14:46
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Originally Posted by markkal
ONow I have stated previously in this post that a big ATO I know will use Diamond DA20 trainers with its standard instructors ( Nothing has been said about extra training for these instructors as per the broad lines set by regulation, we will see in january) And they will only show nose high / nose low, incipient stall, as they say, to "keep it safe"

I also must note that same ATO in its SOP's has modified all reference speeds for landing increasing them by 15% for "Safety", so the aircraft Flight manual and the school's SOP differ. Therefore there is a set "Buffer" to "feel" safe added in the SOP's, For the same reason the HT of the school will limit UPRT training the nose/high/nose low/incipient stall to keep a " Safety buffer" which is part of the schools philosophy.

The end result is that we have Training facilities like APS or Ultimate High offering a wholly comprehensive course with dedicated aircrafts and all envelope instructors,
And ATO's which will use utility category aircrafts, with their own atpl instructors which at most will follow a generic unspecific training for which EASA has defined very broad lines only.
EASA clearly states that FIs delivering FCL.745.A Advanced on-aircraft UPRT MUST be qualified through FCL.915(e). NAAs are allowed to make local exemptions for suitably experienced FIs, who may for example have substantial experience in delivering similar training.

And any ATO that adds a random buffer to OEM guidelines is not one that I would choose to send my students to!
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Old 13th Dec 2019, 19:11
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Originally Posted by greeners
And yes, the intention was AND STILL IS that the training should be 3 hours of actual training - I wrote the original requirement along with a member of the APS team. The way Part-FCL has been written is misleading; EASA have subsequently confirmed to me - which I have relayed to the CAA - that the requirement IS 3 hours of actual training.
Is that confirmation, or equivalent clarification, available publicly anywhere please?
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Old 16th Dec 2019, 13:18
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Originally Posted by greeners
Sadly there remains a substantial amount of confusion for a regulation that becomes mandatory one week from today.

And yes, the intention was AND STILL IS that the training should be 3 hours of actual training - .
Given the confusion on this I e mailed the CAA asking for clarification of exactly how the 3 hours of dual instruction specified at FCL.745.A (a) (3) is to be measured. This is the response from the CAA licensing support technical team.

"Refer to AMC1 FCL.050 Recording of flight time

(g) Flight time is recorded:

(1) for aeroplanes, touring motor gliders and powered-lift aircraft, from the moment an aircraft first moves to taking off until the moment it finally comes to rest at the end of the flight

Note: 3 hours is a minimum not a target"

So there it is unless the CAA change their minds in the next 4 days.

Last edited by Rivet gun; 16th Dec 2019 at 16:05.
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Old 16th Dec 2019, 18:43
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Exactly. Why do some think that a loss of control doesn't happen during start up, taxi, take-off, climb and during the approach/landing phase. The same people also seem to think that turning people upside down and doing suddenlies (a really great way to teach safety skills, yippee! here we go - man or mouse) is a good idea.

Last edited by Fl1ingfrog; 16th Dec 2019 at 21:55.
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Old 17th Dec 2019, 13:52
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Hot off the press:

Information Update

Issued: 17 December 2019

8 month extension of deadline for compliance with CS-FSTD(A) issue 2 for Air Operator UPRT exercises


Following further consultations and review, EASA decided to extend the deadline for eight months, until 20 August 2020, instead of the initially foreseen four months.

A Decision by the Executive Director of EASA (‘ED Decision’) to this effect will be published within the next days.

Operators need to ensure that the devices used for the relevant UPRT elements will be in full compliance with the applicable requirements by 20 August 2020, at the latest.

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Old 17th Dec 2019, 22:10
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Originally Posted by Rivet gun
(1) for aeroplanes, touring motor gliders and powered-lift aircraft, from the moment an aircraft first moves to taking off until the moment it finally comes to rest at the end of the flight

Note: 3 hours is a minimum not a target"

So there it is unless the CAA change their minds in the next 4 days.
Sigh. With the greatest of respect to our illustrious regulators, left hand, meet right hand. EASA have confirmed in an email to me that it is supposed to be 3 hours of ACTUAL UPRT (exactly as specified when I wrote the original requirement as part of EASA RMG.0581) and I relayed this to our ATO Inspector directly. I will re-engage - thanks for the feedback, appreciated.
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Old 17th Dec 2019, 22:13
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Originally Posted by Fl1ingfrog
Exactly.
Sorry. Exactly - what?
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Old 18th Dec 2019, 07:24
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greeners, I concur. In a similar vein, we requested clarification regarding flight time for the aerobatic rating. This was confirmed as 5 hrs of actual aerobatic instruction; taxy, take-off, climb, descent and landing were not included.

(However, IFR time is counted from chock-to-chocks, whereas instrument flight time is actual time flown by sole reference to instruments.... )
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Old 18th Dec 2019, 10:45
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greeners, can you define for me how the working group has defined the point at which it is said UPRT is commenced and similarly when it has ended? Examples will help. How is the flight time outside of these specific times to be logged?

I note from an earlier post that the training is to satisfy the pilot's psychological need. This is an expertise way outside of the flight instructor's knowledge. What input to the working group was gained from qualified psychologists who are considered experts in this field?
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Old 18th Dec 2019, 13:15
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Hi,
Does anybody knows where is this training endorsed?
Is it on licence, logbook or other papers? How to prove that I went through this training?
I tried to have a look around but I didn't find anything..

Cheers
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Old 18th Dec 2019, 15:24
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FCL.745.A
(b) Upon completion of the UPRT course, applicants shall be issued with a certificate of completion by the ATO.
In the case of the integrated ATPL(A) course, there is no independent evidence. It is assumed that UPRT has been completed as without it the course would not have been approved.
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Old 19th Dec 2019, 04:20
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Originally Posted by TheSkylander
Hi,
Does anybody knows where is this training endorsed?
Is it on licence, logbook or other papers? How to prove that I went through this training?
I tried to have a look around but I didn't find anything..
As a specialist UPRT provider, we will issue a Certificate of FCL.745.A completion and endorse the logbook - as per the EASA requirement.
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Old 2nd Jan 2020, 10:19
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Guys, I might be missing something obvious here as I have not drank my coffee yet, but:

previously the BIFM modules of CPL and IR were the same and we could cross credit them with the BIFM certificate.
Now that CPL BIFM includes basic UPRT, and the IR BIFM remained the same (in regulation), we cant cross credit them anymore?
Or we can cross credit those 10h from IR when starting CPL but do the extra basic UPRT part?

Edit: upon closer inspection it seems like CPL can still be credited with 10h BIFM from IR (as stated in appebdix 3), but how can that be if that does not include basic uprt.
I must be missing something very simple here.

Last edited by yxcvmnb; 2nd Jan 2020 at 10:38.
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Old 13th Jan 2020, 00:59
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Yet more cash to fork out.

Definitely becoming a Rich Geezer’s game.
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Old 12th Apr 2020, 14:00
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Originally Posted by greeners
Sigh. With the greatest of respect to our illustrious regulators, left hand, meet right hand. EASA have confirmed in an email to me that it is supposed to be 3 hours of ACTUAL UPRT (exactly as specified when I wrote the original requirement as part of EASA RMG.0581) and I relayed this to our ATO Inspector directly. I will re-engage - thanks for the feedback, appreciated.
Have they joined hands yet?
I’ve been looking around online at courses and I see quite a few (not greeners’ naturally) that are 3 hrs in an aeroplane rather than 3 of actual UPRT.

I’m interested in seeing this clarified for all but I don’t see it?
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Old 12th Apr 2020, 17:29
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Originally Posted by Rivet gun
Was it this one by any chance?

https://www.youtube.com/watch?v=PdLCfVYDV9A
Personally I think the Extra 300 is the worst possible airplane to teach UPRT. I have a few hours in one and can state that it does not fly like any "normal" aircraft. The controls are an order of magnitude more powerful than a normal category aircraft. If you are upside down you can be right side up in about 1/3 of a second. No skill required just slam the stick to one side and immediate centralize it. It is also perfectly symmetrical . The level flight attitude inverted is the same as erect flight

A much better UPRT aircraft IMO is something like a Zlin 242. It has side by side seating, a leisurely roll rate, pretty heavy controls and will have a high inverted descent rate inverted unless a significant nose high attitude is maintained.

In any case UPRT only has lasting benefit if the "push and roll" reflex is automatic. When Iast asked to do an informal UPRT for a PPL who was not interested in aerobatics but had been scared by a wake turbulence encounter the majority of the course concentrated on 2 things, a review of stall recognition and recovery and recovery from more than 90 deg's of bank. After about 3 hours of training we did a "test" flight. No talking from me just me putting the aircraft in random unusual attitudes and having him recover. After that flight we both felt comfortable he could safely deal with any upset. However I told him the true test would be to come back in a year and do the test over to see if the training stuck. I never saw him again, so I have no idea if he in fact still has the muscle memory to save himself.

Like in aerobatics it doesn't matter how good you used to be, it only matters how good you are now. Without regular practice I think a lot of pilots, and regulators are fooling themselves if they think they still have the skills necessary.....
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Old 14th Apr 2020, 12:45
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Originally Posted by djpil
Have they joined hands yet?
I’ve been looking around online at courses and I see quite a few (not greeners’ naturally) that are 3 hrs in an aeroplane rather than 3 of actual UPRT.

I’m interested in seeing this clarified for all but I don’t see it?
No confirmation as yet I'm afraid. I appreciate that despite the response I received directly from the EASA RMG Project Manager confirming that the requirement SHOULD be 3 hours of actual UPRT, we need to get formal confirmation from the CAA.

In the interim we will sadly continue with the uncomfortable and non-level playing field that currently exists. As I understand it, right now Ultimate High (for transparency, my company), CRM Aviation and FPT (the three longest standing UPRT providers) all ensure that their FCL.745.A courses deliver 3 hours of actual UPRT. On-Track, Skyborne, Aviation South West and the BAA show only 3 hours airborne on their website; Leading Edge doesn't specify the flight time. L3H and BCFT insist on 3 hours of actual UPRT, I'm not sure how CAE or Aeros are planning on meeting the 745 requirement yet.

It will be great to get what should be a very straightforward issue resolved prior to professional flight training getting back off the ground.
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Old 14th Apr 2020, 13:39
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Originally Posted by Big Pistons Forever
Personally I think the Extra 300 is the worst possible airplane to teach UPRT. I have a few hours in one and can state that it does not fly like any "normal" aircraft. The controls are an order of magnitude more powerful than a normal category aircraft.
Completely agree - which is why our school doesn't use our Extra 300L for UPRT.

Just as critically, UPRT should ONLY be delivered in an aircraft which has side-by-side seating. Ideally the environment needs to be as similar as possible to the airline cockpit as possible, especially with respect to the CRM aspects of UPRT.
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