Motorgliding - BGA or CAA directly controlled maintenance and instructors?

[Prop swinger]

Squawking 7700 summed up the differences between MGIR & FI(SLMG) nicely here. See also this BGA web page. People get confused because the BGA run the courses but the rating is issued by the CAA.

Forget about JAR licences, they are no longer issued. You could fly with every instructor known to the CAA & none of those hours would count towards the issue of a JAR licence because no-one is going to issue one. Counting hours towards an EASA licence is also irrelevant, as the CAA are not yet issuing LAPL(A)s for TMGs (AFAIK.) They are still issuing NPPL SLMGs; the holder of an NPPL SLMG has until April 2015 to convert this into an EASA LAPL(A) for TMGs.

If you want to fly a Cub you will need an NPPL SSEA or EASA PPL or LAPL. The NPPL can be used in France if backed up by an EASA class 2 medical. You can add an SSEA rating to an NPPL SLMG & (eventually) add SEP rights to an LAPL(A) for TMGs. Or you could go for the appropriate licence straight away.

AIUI the requirement for a type certified engine stems from the conditions of an AOC. You don't need to have an AOC to be an ATO.

[David Roberts]

EASA FCL: Annex II aeroplanes for training?

One aspect of the "motor-gliding" thread has got me racking my memory for something that I clarified with EASA sometime ago (2 years or so). The question of what aeroplane one can be trained on to get an EU licence. Before I provide the rationale, it is clear that, for maintaining validity of an EU PPL(A) or LAPL(A) licence for an aeroplane (obviously), hours clocked on an Annex II aeroplane count. This was confirmed a long time ago by EASA and has also been confirmed by the UK CAA. In FCL.140.A the recency requirements refer only to 'aeroplanes', not 'aeroplanes within the scope of EASA regulation.' See the definition of aeroplane, which interestingly does not specify it has to be type certified!

So, now what about hours on an Annex II aeroplane to get an EU licence? I quote from the EU Air Crew Regulation (EC 1178/2011) as regards the LAPL(A):
FCL.035 crediting of flight time
Unless otherwise specified in this Part, flight time to be credited for a licence, rating or certificate shall have been flown in the same category of aircraft for which the licence or rating is sought.
[Note 'categories of aircraft' = aeroplane, sailplane, balloon, helicopter.]
FCL.105
(b) Conditions. Applicants for the LAPL shall have fulfilled the requirements for the relevant aircraft category and, when applicable, for the class or type of aircraft used in the skill test.
[Note that category = aeroplane in this example. Then it is 'class' or 'type'.]
FCL.110.A
(a) Applicants for an LAPL(A) shall have completed at least 30 hours of flight instruction on aeroplanes or TMGs, including at least: (1) 15 hours of dual flight instruction in the class in which the skill test will be taken (2) 6 hours of supervised solo flight time, including at least 3 hours of solo cross-country flight time... etc
FCL.135.A Extension of privileges to another class or variant of aeroplane
(a) The privileges of an LAPL(A) shall be limited to the class and variant of aeroplanes or TMG in which the skill test was taken. This limitation may be removed when the pilot has completed in another class the requirements below:
(1) 3 hours of flight instruction, including:
(i) 10 dual take-offs and landings; and
(ii) 10 supervised solo take-offs and landings.
(2) Skill test.....
(b) Before the holder of an LAPL can exercise the privileges of the licence on another variant of aeroplane than the one used for the skill test, the pilot shall undertake differences or familiarisation training.....

Again, the references to 'aeroplane' are generic, not specific to 'EASA aeroplanes'.

The text also covers the TMG extension to the LAPL(S).

Unless I have missed another relevant clause, it seems to me that one could train in an ATO on your own Tiger Moth (Annex II) and get your EU licence providing you take the skill test on the Tiger Moth or the same CLASS of aeroplane. Thereafter, if you want to fly something different you need to comply with FCL.135.A

No doubt someone will prove me wrong. Or maybe this has been clarified already by someone else.

[bookworm]

Unless I have missed another relevant clause, it seems to me that one could train in an ATO on your own Tiger Moth (Annex II) and get your EU licence providing you take the skill test on the Tiger Moth or the same CLASS of aeroplane. Thereafter, if you want to fly something different you need to comply with FCL.135.A

ORA.ATO.135 Training aircraft and FSTDs
(a) The ATO shall use an adequate fleet of training aircraft or FSTDs appropriate to the courses of training provided.

AMC1 ORA.ATO.135 Training aircraft and FSTDs
ALL ATOs, EXCEPT THOSE PROVIDING FLIGHT TEST TRAINING
(a) The number of training aircraft may be affected by the availability of FSTDs.
(b) Each training aircraft should be:
(1) equipped as required in the training specifications concerning the course in which
it is used;
(2) except in the case of balloons or single-seat aircraft, fitted with primary flight
controls that are instantly accessible by both the student and the instructor (for
example dual flight controls or a centre control stick). Swing-over flight controls
should not be used.

(c) The fleet should include, as appropriate to the courses of training:
(1) aircraft suitably equipped to simulate instrument meteorological conditions (IMC)
and for the instrument flight training required. For flight training and testing for
the instrument rating, an adequate number of IFR-certificated aircraft should be
available;
(2) in the case of aeroplanes and sailplanes, aircraft suitable for demonstrating
stalling and spin avoidance;
(3) for the flight instructor (FI) training courses on aeroplanes and sailplanes,
aircraft suitable for spin recovery at the developed stage;
(4) in the case of helicopters, helicopters suitable for autorotation demonstration;
(5) in the case of a non-complex ATO, one aircraft fulfilling all the required
characteristics for a training aircraft might be sufficient;
(6) each FSTD should be equipped as required in the training specifications
concerning the course in which it is used.

FCL.013 includes a "review of AMC1 ORA.ATO.135 and possibly develop an additional GM to clarify what is meant by ‘adequate fleet of training aircraft’; to include training aircraft requirements for additional ratings under development;"

Subject to that AMC/GM, it will be up to individual NAAs to decide what aircraft can be approved for training under ORA.ATO.135. There is no prohibition on Annex II aircraft, nor is there an EASA requirement to permit their use.

[BillieBob]

There were a lot of comments from industry at the time of the original NPA for Part-FCL, which did not allow time gained on other than an EASA aircraft to count towards the issue of a licence or the issue or revalidation of a class rating. This resulted in a change to allow prior experience as PIC to be counted towards the experience requirements for issue of the LAPL(A). In the explanatory note that accompanied this change it was stated:

Another issue that deserved a lot of comments was the issue of crediting, specifically the crediting of previous experience acquired in aircraft included in Annex II to the Basic Regulation, and therefore outside of the EASA system. Since these aircraft were excluded from the scope of EU competence and remain therefore fully within the competence of Member States, it is not possible to establish in EU law a system where credit would be given for something that is not known or controlled on the EU level. Therefore, a system that would credit a certain number of hours based on experience acquired flying those aircraft could not be included in Part-FCL.

This is the basic premise, based on Article 4 of the Basic Regulation, that the EASA implementing rules relate only to EASA aircraft and so, unless it is specifically stated otherwise, when the term 'aeroplane' (as opposed to 'Annex II aeroplane', for example) is used it means an EASA aeroplane.

[bookworm]

Fortunately BillieBob, an explanatory note to a CRD is not law.

In Article 4:

1. Aircraft, including any installed product, part and appliance, which are:
(a) designed or manufactured by an organisation for which the Agency or a Member State ensures safety oversight; or
(b) registered in a Member State, unless their regulatory safety oversight has been delegated to a third country and they are not used by a Community operator; or
(c) registered in a third country and used by an operator for which any Member State ensures oversight of operations or used into, within or out of the Community by an operator established or residing in the Community; or
(d) registered in a third country, or registered in a Member State which has delegated their regulatory safety oversight to a third country, and used by a third-country operator into, within or out of the Community

shall comply with this Regulation.

2. Personnel involved in the operations of aircraft referred to in paragraph 1(b), (c) or (d) shall comply with this Regulation.

3. Operations of aircraft referred to in paragraph 1(b), (c) or (d) shall comply with this Regulation.

4. Paragraph 1 shall not apply to aircraft referred to in Annex II.

So the word 'aircraft' clearly encompasses both aircraft that are required to comply with the regulation and aircraft that are not.

And there is nothing in COMMISSION REGULATION (EU) No 1178/2011 (the Aircrew Regulation) that restricts the definition of 'aircraft' or 'aeroplane'. Indeed:

FCL.010
‘Aeroplane’ means an engine-driven fixed-wing aircraft heavier than air which is supported in flight by the dynamic reaction of the air against its wings

‘Aircraft’ means any machine which can derive support in the atmosphere from the reactions of the air other than the reactions of the air against the earth’s surface.

The scope of the Aircrew Regulation is defined by its Article 3:

Pilot licensing and medical certification
Without prejudice to Article 7, pilots of aircraft referred to in Article 4(1)(b) and (c) and Article 4(5) of Regulation (EC) No 216/2008 shall comply with the technical requirements and administrative procedures laid down in [Part-FCL] and [Part-MED].

This limits the applicability of the regulation to pilots of EU-registered and -resident aircraft. It does not constrain the scope of the word 'aircraft' in Part-FCL.

[Lima Juliet]

It is important to emphasise that the 'old guy flying a Slingsby Venture on his own doing tuition' is in fact a highly regarded commercially qualified instructor and examiner for a variety of aircraft types, whose reputation is above reproach. He has been in business for decades and his company should not be confused with the 'other' club, which only started operating in mid 2011.

Well said. Any implication that this individual is anything but "highly regarded" should be followed by an immediate apology.

As for the original poster...I too suspect he is something to do with another Club at the same airfield that cannot match the pricing of doing a NPPL on a Motorglider

There are many Grob 109s in military service and also HM Armed Forces Gliding Clubs - they are incredibly cheap to operate (~£40-50 per hour solo) because they don't burn as much AVGAS as normal Group As.


LJ