Often the mere threat of a Reg 6 appeal will cause an immediate capitulation. The CAA's success rate at Reg 6 hearings approximates Saudia Arabia's performance in Olympic bobsleigh. Consequently, judicial review is hardly ever necessary. The problem is that most potential appellants are, quite justifiably, fearful of the vindictive retaliation that inevitably follows a successful appeal.
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It matters not what Whopity might think. It also doesn't matter what has been discussed in various meeting rooms, nor what the CAA have told Beagle. What does count is what the regulations state, along with any official guidance material - and nowhere is it currently written that a Night Rating can not be completed within a PPL course of instruction. Therefore any refusal to issue a Licence/Night Rating in such circunstances would be overturned on appeal. Now it may be that Part-FCL wording is planned to be changed from "shall have completed at least 45 hours of flight instruction in aeroplanes" to "shall have completed at least 45 hours of flight instruction in aeroplanes by day" or similar - but it has not happened yet. The CAA have promised not to Gold Plate any EASA Regulations so, the least they can do, should they wish to interpret the rules in a more stringent way is to issue an IN informing all in the aviation community of their interpretation and hence requirement. If they expect the rules to be changed in the future (due to the current discussions mentioned by Beagle) then they should also issue an IN warning of impending change so that Instructors/Students can take that in to account. |
Personally I do see the point of this discussion. You have to be IMO, an exceptional student to be fully competent at the PPL level with just the bare minimum 45 hrs. Diluting that with training towards the night rating is not a good idea.
Also there is a significant amount of unique to night flying pilot decision making training required in a properly done night rating. All of builds on the PPL fundamentals which need to get taught first. |
BPF,
There is certainly a discussion to be had on the wisdom of conducting training for the Night Rating at the same time as for a PPL and, if you look at Post 2, you will see that I probably agree with your sentiments. However, I believe, this discussion has been about Aviation Authorities writing and promulgating Laws, Rules, Regulations and Guidance Materials for the aviation community but then deciding not to abide by these themselves, without even informing anyone - not a way any organisation should be operating. |
Before:
JAR–FCL 1.125 (…) (c) Night qualification. If the privileges of the licence are to be exercised at night, at least five additional hours flight time .... The word additional was construed, at least in France (I don't know about other JAR countries), as meaning that the total training had to be 45 + 5 = 50 hours. Now: FCL.810 Night rating (...) (1) If the privileges of an LAPL or a PPL for aeroplanes, TMGs or airships are to be exercised in VFR conditions at night, applicants shall have completed a training course at an ATO. There are 45 hours in the PPL course, I don't think that anything forbids you to train your student at night for part (maybe all?) of the 45 hours. Nevertheless, I understand a training course as meaning another course than the PPL course, from which I conclude that the total training should be 45 + 5 = 50 hours. |
Level Attitude, the CAA didn't 'tell' me anything.
This was a formal EASA meeting attended by NAAs, EASA and Industry members. The topic was raised by Austria and the conclusion was that night rating training may not be included in the core PPL course. But hey, you barrack room lawyers with your Reg 6 and judicial review nonsense, please feel free to know better, should you so wish....:rolleyes: |
There are 45 hours in the PPL course shall have completed at least 45 hours of flight instruction in aeroplanes It matters not how the French or anyone care to interpret it, in legal terms it can be done and should be upheld by a court if an Authority fails to comply with the regulation. |
Level Attitude, the CAA didn't 'tell' me anything. "Night Rating training may not be included in the 'other 10', so we were told." "His former employers are adamant that training for the night rating may not be included in the PPL course." "I tried to argue against this, but the CAA were adamant." The topic was raised by Austria and the conclusion was that night rating training may not be included in the core PPL course. Unlike on PPRuNE a decision was made, BUT that decision has no force unless, and until, those affected by it (ATOs, Examiners, Instructors, Students) are informed of it via official means (preferably unambiguously and in writing). |
The CAA's GA Unit is currently drafting an IN to confirm the position stated at the meeting.
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The CAA's GA Unit is currently drafting an IN to confirm the position stated at the meeting |
Does this still mean you will be allowed to use a night rating as part of the 10 hours nppl/lapl to ppl course?
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Have just heard of one person doing all the 5 hours of "training" in one night!
Surprised this is allowed. |
I had a cunning plan to fly to a 24-hour airfield, takeoff from base just before twilight to do the 'transition from day to night' exercise, dual circuits, land, brief and solo circuits (total 3.5 hours flyong). Night stop, then take off again at sunrise -2 hours for the night navex, fly back to base and land after the end of official night (we've no lights). All seems perfectly legal, with 8 hours sleep between flights can't see the problem. Yet to achieve it, though.
TOO |
I had a cunning plan to fly to a 24-hour airfield, takeoff from base just before twilight to do the 'transition from day to night' exercise, dual circuits, land, brief and solo circuits (total 3.5 hours flyong). Night stop, then take off again at sunrise -2 hours for the night navex, fly back to base and land after the end of official night (we've no lights). All seems perfectly legal, with 8 hours sleep between flights can't see the problem. Yet to achieve it, though. Just wondered where you'd be fitting in any of the ground briefing? |
Why would you be surprised that completing in a single night was allowed?
There's no limit on daily flying hours for the PPL course and associated ratings that I'm aware of, or is there? It depends on the individual and what you're trying to teach them, but I find that 2 or 3 hours a day is an achievable amount for most trainees. That's probably plenty for circuits, but if someone's doing their "QXC" (if I can still call it that), with a dual checkout beforehand, then you can easily be up at 4 hours. We've done a few single night NRs, works quite well if you prepare for it, get some sleep. Also I think it's best to try and get the 5 solo circuits done as early as you can, then finish off with the dual nav. Pretty much as TOO said. You can get the bulk of the briefings done beforehand. |
What is "legal" isn't necessarily best practice.
Do you want a quick (night) pilot or a good (night) pilot? Why all the rush? 5 solo circuits |
Indeed not, I don't disagree.
Quick and good aren't always mutually exclusive though, sometimes an "intensive" course is the best solution for the individual concerned. There's not usually a rush, we do more NRs in the traditional, hour or two a night manner. However, the customer might find it easier to be available for a single whole night, rather than several part nights. A couple of times we've had someone heading for a CPL need it done in a hurry in Summer. You presume correctly. |
I had a cunning plan to fly to a 24-hour airfield, takeoff from base just before twilight to do the 'transition from day to night' exercise, dual circuits, land, brief and solo circuits (total 3.5 hours flyong). Night stop, then take off again at sunrise -2 hours for the night navex, fly back to base and land after the end of official night (we've no lights). All seems perfectly legal, with 8 hours sleep between flights can't see the problem. Yet to achieve it, though. XO |
Sorry to revise an old topic, but any new guidance on this subject regarding allowance of NF training within the 45 hours and also if it can be started before/after the 10 hours of solo.
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Booker are still advertising it as optional part of PPL course but interestingly night flying is not included in the syllabus for PPL(A) in the AMC/GM to PART-FCL. But wierdly it is for PPL(H)!
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