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Bought a type rating? Let it go uncurrent? You're screwed
Just want to point out something to you guys that I found on another thread ... an EASA law change that's come in in the last few weeks regarding type rating and IR renewals
SUBPART G — INSTRUMENT RATING — IR AMC1 FCL.625(c) IR — Validity, revalidation and renewal RENEWAL OF INSTRUMENT RATING: REFRESHER TRAINING (a) Paragraph (b)(1) of FCL.740 determines that if the instrument rating has lapsed, the applicant shall go through refresher training at an ATO, to reach the level of proficiency needed to pass the instrument element of the skill test prescribed in Appendix 9 to Part-FCL. The amount of refresher training needed should be determined on a case-by-case basis by the ATO, taking into account the following factors: (1) the experience of the applicant. To determine this, the ATO should evaluate the pilot’s log book, and, if necessary, conduct a test in an FSTD. (2) the amount of time lapsed since the expiry of the validity period of the rating. The amount of training needed to reach the desired level of proficiency should increase with the time lapsed. In some cases, after evaluating the pilot, and when the time lapsed is very limited (less than 3 months), the ATO may even determine that no further refresher training is necessary. The following may be taken as guidance when determining the needs of the applicant: (i) expiry for a period shorter than 3 months: no supplementary requirements; (ii) expiry for longer than 3 months but shorter than 1 year: a minimum of one training session; (iii) expiry for longer than 1 year but shorter than 7 years: a minimum of three training sessions; (iv) expiry for longer than 7 years: the applicant should undergo the full training course for the issue of the IR. (b) Once the ATO has determined the needs of the applicant, it should develop an individual training programme, which should be based on the initial training for the issue of instrument ratings and focus on the aspects where the applicant has shown the greatest needs. (c) After successful completion of the training, the ATO should give a certificate to the applicant, to be submitted to the competent authority when applying for the renewal. Quote: SUBPART H — CLASS AND TYPE RATINGS AMC1 FCL.740(b)(1) Validity and renewal of class and type ratings RENEWAL OF CLASS AND TYPE RATINGS: REFRESHER TRAINING (a) Paragraph (b)(1) of FCL.740 determines that if a class or type rating has lapsed, the applicant shall take refresher training at an ATO. The objective of the training is to reach the level of proficiency necessary to safely operate the relevant type or class of aircraft. The amount of refresher training needed should be determined on a case-by-case basis by the ATO, taking into account the following factors: (1) the experience of the applicant. To determine this, the ATO should evaluate the pilot’s log book, and, if necessary, conduct a test in an FSTD; (2) the complexity of the aircraft; (3) the amount of time lapsed since the expiry of the validity period of the rating. The amount of training needed to reach the desired level of proficiency should increase with the time lapsed. In some cases, after evaluating the pilot, and when the time lapsed is very limited (less than 3 months), the ATO may even determine that no further refresher training is necessary. When determining the needs of the pilot, the following items can be taken into consideration: (i) expiry shorter than 3 months: no supplementary requirements; (ii) expiry longer than 3 months but shorter than 1 year: a minimum of two training sessions; (iii) expiry longer than 1 year but shorter than 3 years: a minimum of three training sessions in which the most important malfunctions in the available systems are covered; (iv) expiry longer than 3 years: the applicant should again undergo the training required for the initial issue of the rating or, in case of helicopter, the training required for the ‘additional type issue’, according to other valid ratings held. (b) Once the ATO has determined the needs of the applicant, it should develop an individual training programme that should be based on the initial training for the issue of the rating and focus on the aspects where the applicant has shown the greatest needs. (c) After successful completion of the training, the ATO should give a certificate, or other documental evidence that the training has been successfully achieved to the applicant, to be submitted to the competent authority when applying for the renewal. The certificate or documental evidence needs to contain a description of the training programme. They snuck this in on the first of September with no prior warning, a few people who've gone to do renewals recently have just gotten a very nasty surprise. This is having a huge effect on us professionals who went overseas to fly 'bus and Boeing for middle east and asian airlines ... turns out under EASA law we no longer have a type rating and have to resit basic training in the type we have been flying every day in another country :hmm: but I can see it also having a very large effect on the market for those fresh from school who casually purchase type ratings. |
Good news for real pilots who don't pay for type ratings tho!
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So how do non-EASA aviation authorities treat EASA type ratings? I would be very surprised if you could walk into an office in all of those and get your EASA type rating transferred onto a non-EASA license without any training or scrutiny, let alone a rating that has expired...
The idea behind having a current type rating is that it is current through compliance with the relevant rules (i.e. an annual LPC and recency requirements). Under the new rules a type rating stays on your license beyond the previous 7-year limit, but to revalidate it requires training and the rules have been sharpened. That in itself is not unreasonable. If you bought a type rating thinking that it would take no effort or cost to keep it current: very naive. If you went to work abroad (by choice or by necessity) one must be mindful of the possible consequences of flying under a different jurisdiction. This is one of them: experience and ratings have never been easily transferable between all aviation authorities (anyone remember the days before JAA and EASA came about?). If you're flying a type every day in a far-away country it is reasonable to get credit for the hours on type, which is still the case although subject to scrutiny, but seven years without an LPC in any jurisdiction seems a long time to me. |
Mate ... it's not about conversion from a foreign licence, it's about renewal of the thing I've already got!
I've got a UK issued ATPL with a UK issued A320 rating and about 2000 hours airbus time logged with a UK airline, that was after the several years I spent as a turboprop captain in Scotland. Then I went to the sandpit and been in continuous practice on the same aircraft for the last 5 years, during which time I have flown in and out of the UK and Europe on a regular basis. I have 5 and a bit thousand hours on the narrowbody and widebody airbus family, 700 hours in the last 12 months and I last flew the aircraft this morning ... I think it's slightly unreasonable for them to expect me to complete basic instrument rating training and type rating training again prior to renewing my UK licence don't you? There are a number of UK / European captains, instructors and examiners with some of the best operators on earth i.e. Cathay, Emirates, Singapore, who are in the same boat - without any warning we have totally lost our UK licences and aircraft ratings, and will be chucked in the same boat as the 200 hour nubs on a full type rating training course for the very aircraft we already fly, should we wish to return to Europe. I'm all in favour of anything that makes it difficult for people to buy speculative type ratings, but on a personal basis I'm pissed off with this :mad: |
If I read the regulation correctly, someone doing an EASA conversion for the first time (regardless if it is with a type and 500 on type, or an IR etc) has less training to do than someone who has been actively flying on type overseas.
Another excellent rule by EASA to increase air safety! ... Not |
Luke,
In no way do I want to discredit your experience and proficiency or that of any pilot who works outside of EASA-land. There is a bit of a jurisdiction and reciprocity issue, though... You have not lost your license or rating, nor will you under the new rules. Only to make a rating CURRENT again the rules have tightened somewhat. So here's a question: if you were to leave the sandpit for three years and later on decided go back, would you be able to get a local license with the ratings you hold on your EASA license without having to do training and a skill test? Or would the sandpit-CAA accept a skill test carried out by an EASA-examiner who is not an examiner under sandpit-FCL rules? The basic idea (under any jurisdiction) has always been that you keep a rating valid, and that it expires after a year. A lot of people let their ratings expire thinking that 'they could always revalidate it with a skill test within 7 years'. Credit for licenses, ratings and experience between different jurisdictions has always been an issue. In the days before JAA even between neighboring countries in Europe. That has now largely, but not completely, ended which goes some way in leveling the playing field in Europe. I can understand your frustration, though. |
Luke, looking at your posting history do I have this right? You flew the A320 in the UK and then went to the Middle East, got a A330 rating and are currently flying the A330 in Vietnam?
Do you also currently fly the A320, or are you saying that your A330 time should keep your A320 rating current? Admittedly, I don't fly Airbus but I understand the A330 and A320 to be distinct and seperate ratings, albeit with a shorter conversion course between the two types. If you're current on the A320 the new EASA rules shouldn't affect you, if you are not current on the A320, well... |
Currently on 330, starting my command training on 320 in the next few weeks.
And yes the new EASA rules affect everyone who's abroad no matter what they are flying or whether they changed types or not, if they haven't done a renewal in Europe in the last three years they're stuffed. It doesn't matter which of the two ratings I attempted to renew I couldn't do it now, I can't get my UK licence back without doing my full ATPL theory subjects, full basic course of IR training and now a full type rating course :mad: It used to be a seven year allowance from the time the rating went uncurrent and they've taken that away from us with no prior warning, that's my main gripe. I was planning to do a renewal next summer to keep it all legal and now I can't. It's not really about my personal set of predicaments though, we expats are bitching about this on another thread over on the middle east forums if you want to check it out, we're planning to take them to court over it anyway. What I really wanted to do was give a heads up / start a discussion amongst the inhabitants of this forum who are all hell bent on buying type ratings fresh out of school, give them the heads up that a potentially very large expense of multiple sim sessions awaits them should they fail to find employment within a very short space of time after completing their rating training. |
I think the angel is in the wording:
The objective of the training is to reach the level of proficiency necessary to safely operate the relevant type or class of aircraft. The amount of refresher training needed should be determined on a case-by-case basis by the ATO, taking into account the following factors |
Luke,
I commend your intention, however it won't change anything I suspect. This is an issue for expat pilots like yourself, possibly looking to keep an option open with regards to returning back home at some stage. Those working in the industry do all they can to 'advise' wanabees. SSTRs, PTF, flexiscrew, pseudo self employment, paid by the hour contracts. The aviation industry in Europe is a dead dog with the largest two lo-cos no longer expanding. Yet still people are queuing round the corner to sign up for licences and type ratings, all based on marketing dupe and false promises. |
Originally Posted by Luke SkyToddler
What I really wanted to do was give a heads up / start a discussion amongst the inhabitants of this forum who are all hell bent on buying type ratings fresh out of school, give them the heads up that a potentially very large expense of multiple sim sessions awaits them should they fail to find employment within a very short space of time after completing their rating training.
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I have just renewed my JAA to a EASA atpl and my B737 rating which expired 4 years ago is no longer on the licence, it is over the page under the section ratings previously held:{ Bit of a nasty shock which means that if I have now to do the whole course my job prospects have just taken a nosedive. I have 4500 B737 time.
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You would think that if this rule was going to be implemented firstly a heads up would of been given.
2. It would give a date or even say with immediate effect. And finally 3. Given grandfather rights to those who are expatriate and still within the 7 year rule then from their next renewal the new EASA rules apply. The EU is a cash generating machine, soon every country will go bankrupt at least once to a debt that does not exist. |
Isnt everything suppose to come from ICAO. If someone was flying on a foreign license with a type rating that has a multi crew IR. You would think they could do a LST on their EASA license and get it added back or similar.
Flying schools could take advantage of those trying to renew IR's in light twins and those flying abroad wont want to resit 7 ATPL exams after a few years of their last IR either. Its bad for those who cannot find employment, those working abroad and airlines who require people that may have an expired rating with experience. Eventually their will be a shortage of type rated crews. Is BALPA or any of those affected abroad getting together to legally challenge the the IR and type rating rule changes? Perhaps everyone should go FAA, including the European airlines operating here :) |
Bit of a nasty shock which means that if I have now to do the whole course my job prospects have just taken a nosedive. I have 4500 B737 time. EASA, - Working to make working in Aviation even harder! |
Is BALPA or any of those affected abroad getting together to legally challenge the IR and type rating rule changes? And I like this: EASA, - Working to make working in Aviation even harder! |
Having just looked at the caa uk website and CAP 804, i didnt see any amendment to the 17th sept one.
The 7 year year rule is mentionned (loss of ir theory) and the 3 months limit to ir proficiency. There is no mention on the 3 year rule... |
I think this also affects some people who were flying in other countries using a UK or European license as a validation too.
On some of the other threads in Middle East and similar, I think some pilots were or associations in Hong Kong were getting together to try some sort of legal challenge. |
So as long as I don't let my TR go invalid I have nothing to worry about?
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No suprise, probably this regulation was written by the T.R.T.O. together with the european commisars.
They need money, your money. :D |
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