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COVID-19 Recovery Phase: Revalidation of Class Ratings ORS4 No 1418

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COVID-19 Recovery Phase: Revalidation of Class Ratings ORS4 No 1418

Old 24th Mar 2021, 16:19
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Question COVID-19 Recovery Phase: Revalidation of Class Ratings ORS4 No 1418

Can someone clarify the SEP revalidation requirements given in the general exemption ORS4 No 1418?

The reduction in second year hours exemption to revalidate a SEP rating is clear enough. However, what I have been unable to confirm is whether the exemption also extends to the instructional flight requirement. That is to say if a SEP rating is due to run out on 31 March and the holder has the requisite second year hours for revlaidation, as long as that person flies the requisite time with an instructor before 30 April, their SEP may be revalidated. The confusion comes in because the exemption refers to havng a valid class rating. I take that as meaning a class rating that was valid prior to 30 April but that the holder was unable to fly with an instructor because of COVID-19 restrictions. But I could be wrong.....!
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Old 24th Mar 2021, 21:21
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h)Licence holders who took advantage of the extension to their privileges in ORS 4 No.1378orORS4 No.1414(or subsequent replacements) extending validity to 22 November 2020, will have a subsequent class rating validity expiry date of 30 November 2022.i)

Normal class rating validity expiry dates will apply for other licence holders.
This ORSA 1418 doesn't deal with the extension of validity periods published elsewhere, but only the exemptions against the requirements within the normal periods. So, you must have completed the relevant requirements shown in the table 1 within the validity periods of the rating dates that are annotated in the licence.

See Safety Notice: SN-2021/009

Last edited by Fl1ingfrog; 24th Mar 2021 at 21:34.
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Old 24th Mar 2021, 22:19
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Originally Posted by Fl1ingfrog View Post
This ORSA 1418 doesn't deal with the extension of validity periods published elsewhere, but only the exemptions against the requirements within the normal periods. So, you must have completed the relevant requirements shown in the table 1 within the validity periods of the rating dates that are annotated in the licence.

See Safety Notice: SN-2021/009
Thanks for your response which is pretty much what I expected. The problem seems to be that the CAA had not anticipated another lockdown and thus far seems to have made no provision for the extension of SEP rating validity for those pilots whose ratings lapsed during the most recent lockdown but were not able to fly an instructional flight becuase of the lockdown restrictions.

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Old 25th Mar 2021, 00:58
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I am somewhat frustrated by all this and I am sure that I am not alone. I hold a UK-issued EASA PPL. Its validity expires on 31 March 2021 (ie end of second year). I have not flown for a year and so consider that I need some refresher training with an instructor before my next solo flight. In normal circumstances I would have expected to have taken a proficiency check before the expiry date but as this has to be within 3 months of expiry and we have been in lockdown for the whole of this period, I have not achieved it. Moreover to start any flying with an instructor and to prepare and undertake the check will not be possible until mid April, after the expiry date. From the CAA documentation it would seem that anyone who has had an expiry date since November is in the same position.

As I see it, if the CAA does not extend the expiry date, I will have to follow the renewal rules; i.e. be assessed by an ATO, undertake a designated course of instruction with a written outcome to present to an examiner for a proficiency check and that all the paperwork, including the individualised training course details will have to be submitted to the CAA. On the other hand, if the validity is extended I will be able to follow the normal revalidation process, albeit with the revised hour requirements, provided I can achieve this within the extension period.

Am I correct in this?
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Old 25th Mar 2021, 06:42
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That's how we're interpreting it.
You make it sound very complicated, which it doesn't need to be.
You also have the option to go to a DTO, usually a local friendly flying club, with a tame examiner and a CFI who will go through the paperwork with you.
If you haven't flown for a year, a couple of hours brush-up and a LPC with an examiner would be a really good idea, anyway.

TOO
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Old 25th Mar 2021, 08:29
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Ditto

You're not alone mabmac, There'll be PPLs by the boatload doing this over the spring and summer. Also, it's unlikely to cost you anywhere near how much you've saved by not flying and you'll most likely end up safer.
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Old 25th Mar 2021, 13:47
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I am somewhat frustrated by all this and I am sure that I am not alone. I hold a UK-issued EASA PPL. Its validity expires on 31 March 2021 (ie end of second year).
The licence is valid for life. Presumably you mean that the expiry date of your SEP Class Rating is 31 Mar 2021?

I have not flown for a year and so consider that I need some refresher training with an instructor before my next solo flight.
Very sensible - if your Class Rating is valid. Unfortunately the current DfT guidance precludes that before 12 Apr 2021.

In normal circumstances I would have expected to have taken a proficiency check before the expiry date but as this has to be within 3 months of expiry and we have been in lockdown for the whole of this period, I have not achieved it.
There is NO such '3 month' requirement! If you choose to revalidate by Proficiency Check and do so more than 3 months before your Class Rating validity expiry date, then the new validity expiry date will be 2 years from the date of the Proficiency Check.
Moreover to start any flying with an instructor and to prepare and undertake the check will not be possible until mid April, after the expiry date. From the CAA documentation it would seem that anyone who has had an expiry date since November is in the same position.
In which case it'll be a Renewal Proficiency Check rather than a Revalidation Proficiency Check. No difference in content; however, your ATO/DTO will need to include a document stating what refresher training was deemed necessary before you took the Check. Which can in many cases be "No training required".
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Old 26th Mar 2021, 09:21
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No difference in content; however, your ATO/DTO will need to include a document stating what refresher training was deemed necessary before you took the Check. Which can in many cases be "No training required".
If a SEP Class Rating is expired by three years or less, FCL.740 now allows a stand-alone instructor to complete the training and sign the CCC so no ATO/DTO involvement required.

ifitaint...
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Old 26th Mar 2021, 21:01
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If a SEP Class Rating is expired by three years or less, FCL.740 now allows a stand-alone instructor to complete the training and sign the CCC so no ATO/DTO involvement required.
Have you a reference for this? I can't find it.
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Old 27th Mar 2021, 07:21
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I've never heard of that either.
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Old 27th Mar 2021, 08:18
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FCL.740(b)(2)(ii), which came into effect in 2019:

[...]The applicant may take the (refresher) training [...] at a DTO, at an ATO or with an instructor, if the rating expired no more than three years before and the rating concerned a non-high-performance single-engine piston class rating or a TMG class rating.
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Old 27th Mar 2021, 10:36
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complete the training ........................ so no ATO/DTO involvement required.
Thanks for the link which is very helpful. Is the instructor working alone also required to asses the 'training required', in accordance with the same guidance provided to a ATO/DTO but without reference to a ATO/DTO?

sign the CCC so no ATO/DTO involvement required.
Reference for this will also be helpful please.

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Old 27th Mar 2021, 10:51
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AMC1 FCL.740(b) Validity and renewal of class and type ratings
ED Decision 2018/009/R
(d) After successful completion of the training, the ATO, the DTO or the instructor, as applicable, should issue the applicant with a training completion certificate or another document specified by the competent authority, describing the evaluation of the factors listed in (a), the training received, and a statement that the training has been successfully completed. The training completion certificate should be presented to the examiner prior to the proficiency check. Following the successful renewal of the rating, the training completion certificate or the other document specified by the competent authority and the examiner report form should be submitted to the competent authority.
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