Type Renewal according to AMC1 FCL.740(b)
 

Hello folks,

as per the above mentioned section last revision August 2020 the renewal program shall be established by the ATO/DTO according to the amount of time elapsed since the privileges of the rating were last used, the experience of the applicant and so on.
I have recently contacted a couple of ATOs to renew an expired rating (6 years from last LPC) and both are still mentioning the "3 years expiry rule" as the cutoff point between a tailored program and a full type rating course. Is that an internal decision just to keep it simple from the point of view of programs designing or am I missing something here ?

Thanks !

If you read the AMCs etc you’ll see it is full of “should”s and “may”s rather than “shall” and “must”which gives the implication of options and choice by the ATO.

The HT should then draw up a training plan for the individual appropriate to what experience, recency etc which should be submitted for approval by the appropriate CA. Depending on the HT and ATO this often falls into the “too much work/too difficult” category and what’s written becomes policy.

To be fair if you’ve been out for 6 years it would probably be the sensible option to do the full course again.

Hi,

thanks for the reply.
Very true, i mistyped shall rather than should, however the point I was trying to bring across is that some ATOs are still using the “old” 3 years rule whereas things have changed last year. It doesn’t really make a big difference in the end it’s true as ATOs can just copy/paste a full type rating program as a “tailored” training for expiries greater than 3 years.

The issue with tailored programs such as you require is finding a suitable partner. Whilst it may seem the ATO is being either lazy or difficult, it really is quite impractical to develop one offs

AMCs do not use the words 'shall' or 'must', because they are 'soft law' means of compliance with the 'hard law' of the Aircrew Regulation. Alternative Means of Compliance ('AltMoCs) may be proposed, but they have to meet the equivalent safety standards of the EASA or UK AMC.

After considerable lobbying of EASA, AMC1 FCL.740(b) was amended to its current form under Annex II to ED Decision 2018/009/R in 2018; there is no 'three year' rule.

ATOs should be deciding on the amount of refresher training needed on a case-by-case basis. Of course it would be in their financial interest to require an applicant to take the full TR training course and anyone facing such an attitude should challenge the ATO to explain itself - or walk away and find another ATO more prepared to respect the amended AMC!

Hi there,

This is what I did in 2019.

Type rating lapsed by 4 years (3+>Y)

Type Rating on G-V expired (lapsed 2015). 500+H on type
Type Rating on GVI current. 500+H on type
Total Time 8000+H

The UK ATO decided that a standard G-V type rating recurrent training course (2d ground school, 3 sim sessions (6H)) was sufficient for the G-V renewal.
It should be mentioned that the G-V recurrent training course was preceded by a standard GVI recurrent training course.

Hope this is helpful.