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Currency requirements for carrying pax
That's really quite an interesting way of achieving the requirements, I'd never even thought of doing it like that. It might not work very well with club aircraft, due to club rules regarding PiC being handling pilot and which seat they occupy, but for sole owners or maybe groups, it could work I suppose.
However, in doing so I'm not sure how they would be complying with the second paragraph of the extract from LASORS below (my colour, for emphasis). I know LASORS isn't an authoratitive source, particularly perhaps the 2010 edition it would seem :ugh: and the ANO doesn't seem to contain the requirements to be either PiC or with a FI, which would otherwise seem to preclude people using the method you suggest. LASORS 2010 Section F Carriage of Passengers Pilots not operating in accordance with JAR-OPS or EU-OPS’ are required to meet recent experience criteria to carry passengers. A pilot shall not operate an aeroplane or helicopter carrying passengers as pilot-incommand or co-pilot unless that pilot has carried out at least three take-offs and three landings as pilot flying (sole manipulator of the controls) in an aeroplane or helicopter of the same type/class or flight simulator of the aeroplane type/class or helicopter type to be used in the preceding 90 days. If the flight is to be carried out in an aeroplane at night, one of these take-offs and landings must have been at night, unless a valid instrument rating is held. If the flight is to be carried out in a helicopter at night, 3 take-offs and landings must have been at night, unless a valid instrument rating (helicopters) is held. A pilot who has not met the experience criteria above will be required to complete the above requirements either as Pilot-in-Command of aeroplanes/helicopters as appropriate or with a flight instructor, providing that the instructor does not influence the controls at any time. The carriage of a safety pilot is not permitted to satisfy this requirement. |
and the ANO doesn't seem to contain the requirements to be either PiC or with a FI, (2) The holder may not— (g) fly as pilot in command of such an aeroplane carrying passengers unless— (i) within the preceding 90 days the holder has made at least three take-offs and three landings as the sole manipulator of the controls of an aeroplane of the same type or class; The problem with flying with another "qualified pilot" in a SPA is that the minute the unqualified pilot takes over control, he becomes PIC and the former PIC reverts to being a passenger, because there is no "operating capacity" that fits the situation. This is an interpretation of the law given by the CAA; if you wish to chance a court giving a different ruling then it is always possible. |
Whopity,
I'm not saying that I think DFC's suggested way of getting 3 take-offs & landings in the last 90 days, is a good or sensible way to go about it. My point was, that LASORS says if a pilot does not have 3/90, then they have to get their 3 as either PiC or with an FI, not just as the handling pilot/sole manipulator, with another PPL as PiC. This would seem to me to make DFC's reported way of doing it not allowable. I couldn't and still can't, find a reference in the ANO for this particular requirement, not to have 3/90 to carry pax, but once outside 3/90 to meet the criteria as PiC (alone) or to fly with a FI. The problem with flying with another "qualified pilot" in a SPA is that the minute the unqualified pilot takes over control, he becomes PIC and the former PIC reverts to being a passenger, because there is no "operating capacity" that fits the situation. This is an interpretation of the law given by the CAA; if you wish to chance a court giving a different ruling then it is always possible. |
I don't really go along with some of the rule interpretations I have read above, in fact I think it is almost 'bending' for the sake of it. I think the 3 in 90 as PIC and sole-manipulator is perfectly 'reasonable' and believe that that was the intention of CAA FCL when they wrote the rules.
I do a number of these 90-day checks in my (multi-aircraft) group and I do wonder why members cannot make that extra little bit bit of effort to do 3 in 90 to keep it all simple for everybody. It only takes 20 minutes. |
The problem with flying with another "qualified pilot" in a SPA is that the minute the unqualified pilot takes over control, he becomes PIC and the former PIC reverts to being a passenger, because there is no "operating capacity" that fits the situation. The words "sole manipulator of the controls" in JAR-FCL was very carefully chosen so that there would be no requirement for the person doing the manipulating to be PIC or even SIC. They simply have to be something other than PICif they don't have the required number of take-off and landings. In this respect, a passenger will be good enough. Yes it may be a good idea to fly with an instructor. In fact having only 3 in the last 90 while making one legal does not make one current. However, the law simply requires that the pilot in command have completed the required take-off and landings as sole manipulator. As Whopity says: The ANO is quite specific LASORS has no legal standing and is simply a pocket guide that has certain uses not all related to aviation!! :) |
About 10 years ago, an attractive single mother with a two year old child got permission to strap him into his baby seat on the back seat of a Cessna 172 while she was instructing a student. The little lad happily chewed on a rusk while his mother pattered stalling and circuits etc. The CFI was a kind individual who sympathised with the young mother's dilemma. On her paltry junior instructor hourly wage she was unable to afford a baby sitter and thus could not work. But she was an excellent instructor with a good clientele. The CFI realised this and gave the idea a go.
10 years later, the now mature woman is a highly experienced pilot flying an A330. That is what I call doing the hard yards - and full marks to both her and her old CFI who gave her a go. :ok: |
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