Whatever the best intentions of RMG.0581, the unpalatable fact is that the Regulation states only that "3 hours of dual flight instruction" is required on the advanced UPRT course. It really doesn't matter what individual competent authorities think, they are not able to change the Regulation. The UK CAA is quite correct in its interpretation and the inept framing of the requirement means that 3 hours of flight time, as defined by FCL.050, is compliant, if inadequate. This issue demonstrates clearly the fundamental weakness of a system that values bureaucratic pedantry and legal nit-picking above technical expertise. I maintain that EASA represents the biggest threat to flight safety that I have encountered in my 52 years in the aviation industry.

The argument over the 3 hours airbourne instruction vs flight time is specious, it matters little. The syllabus content, poorly prescribed, is more of concern in my view. A maximum duration is not laid down of course. The instructor can and should take the necessary time to ensure that the ATO syllabus in completed fully and the knowledge and skills required are achieved satisfactorily, as with all elements of all training.

You are not alone.