NPPL SLMG Grandfather rights for EASA Licensing.

[kevkdg]

Hi,

I currently hold an NPPL (SLMG) and have about 150 hours total time, mostly in a Venture T61F TMG.

I have asked a similar question to this before, but never really got a definative answer.

Looking at the latest version of CAP804, it would seem that one can directly convert an NPPL(A) SLMG to:

(a) Non-ICAO equivelant 'EASA LAPL(A) with TMG Restriction' (As per pages 494 & 495)

OR

(b) Full ICAO 'EASA PPL(A) TMG Only' (Pages 502 & 503).

In terms of cross crediting (grandfather rights) for me personally, I would need to do the following:

Option (a) - Obtain the new style LAPL GP medical... that's it!

Option (b) - Obtain a class 2 medical (should not be a problem).

BUT, as my original supervised qualifying cross country flight for my NPPL(A) SLMG was 100 nm (not 150 nm) with two full stop landings (as required for NPPL SLMG), I guess I would need to undergo another supervised solo cross country of 150nm with 2 full stop landings - seems a pain considering I've done this many time under the privs of my NPPL license (i.e. not supervised).

Is this a possible typing error in CAP804, as it is not aligned with the NPPL SLMG requirement of a 100nm cross country, BUT is aligned with the NPPL SSEA requirement of a 150nm cross country.

I am considering option (b), as in the future this might allow me to add an FI rating so I can instruct on TMG's (as deduced from page 144). Or have I misunderstood?

It seems easier to convert an NPPL(A) SLMG to a full EASA PPL (TMG only) than it did to convert an NPPL(A) SLMG to a JAR or was it JAA PPL (TMG only). So I am suspicious I have misinterpreted.

[Prop swinger]

It's not the NPPL requirements that matter, it's EASA's - the LAPL(A) 'navex' is only 80nm, the EASA PPL one is 150nm. Since you will be applying for a PPL, you need to show that your training syllabus is/was equivalent to the EASA PPL syllabus.

You can add an FI rating to an LAPL, although you can't be paid & you can only instruct for the issue of an LAPL.

[kevkdg]

Thanks Prop Swinger.

So I'll need to undetake a "supervised" 150nm X country with two landings at airfields other than my home airfield. Should not be an issue.

If I also add an SSEA rating to my NPPL before I apply for my EASA PPL(A) license, then it would seem I could have a full ICAO EASA PPL(A) without the TMG restriction for a lot less hassle than it would ever have been to upgrade an NPPL to a JAR/JAA PPL as I seem to recall, for NPPL hours to count towards a JAR/JAA PPL upgrade route, your NPPL intructor also had to be a JAR/JAA instructor, which not all SLMG instructors were. There is no mention of this requirment on the cross crediting info I can find for an NPPL(SLMG) to full ICAO EASA PPL(A) TMG only route.

It all seems a little too easy!!

[David Roberts]

Prop Swinger,

Your comment about adding an FI rating to a LAPL is incorrect if you mean LAPL(A), as this was kicked out by the EASA Committee (comitology) a while back when scrutinising Part FCL. You can however add the FI rating to a PPL (i.e. PPL is for aeroplane, as distinct from helicopter, sailplane or balloon).

However, someone with a LAPL(S) can obtain an FI(S) for instructing for the LAPL(S) or someone with a LAPL(B) can obtain an FI(B) for instructing for the LAPL(B) due the wording in Part FCL subpart J FCL 915(a)(1) and FCL 905.

There may be an opportunity in the next year or two to get the lack of FI rating for the LAPL(A) addressed.

[kestrel539]

David Roberts,

I hold an SLMG (FI) rating on my UK PPL, and mainly teach NPPL conversion from GPL. Any feel for how that will convert, given that the SLMG will disappear in the next couple of years?
Cheers

[Whopity]

So I'll need to undetake a "supervised" 150nm X country with two landings at airfields other than my home airfield. Should not be an issue.

What a quaint and ridiculous suggestion! As the holder of a pilot licence you are entitled to make such a flight within the privileges of your licence. There is no legal process by which a third party may interfere or supervise such a flight!

FCL.035 Crediting of flight time
(a) Crediting of flight time
(1) 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.
(2) Pilot-in command or under instruction.
(i) An applicant for a licence, rating or certificate shall be credited in full with all solo, dual instruction or PIC flight time towards the total flight time required for the licence, rating or certificate.

Therefore; so long as you can prove (log book) that you have met the requirement it qualifies under FCL-035. There is no validity period, so any flight that meets the requirement should suffice.

Most former Group A pilots did not complete a 150 nm X Country either, prior to 1 July 1999, the UK requirement was to have completed a flight which landed at two alternative aerodromes, one of which had to be 50 nm from the point of departure. Typically, this was around 130 nm and had to be completed within 9 months of the licence application. It could not be conducted until the Navigation Flight Test had been successfully completed consequently, this flight was usually conducted after all training and testing, had been completed and was referred to as the "Qualifier" for which CAP53 required a certificate of completion. This requirement ceased on 1 July 1999, the "Qualifier" was replaced by the 150 nm ICAO requirement, which now formed part of the training, and in any event was a precursor to the skill test. There has never been a JAA or EASA requirement for a separate certificate for this flight. The pre-JAA AOPA Certificate continued to be used for a number of years and was finally copied by the CAA who produced another unnecessary piece of paper. I can no longer find it on the CAA website, so they may have finally realised CAP53 died 14 years ago however; it is still referred to in SRG 1105.

Article 4 of Regulation 1178 includes an interesting statement:

7. A Member State may authorise a student pilot to exercise limited privileges without supervision before he/she meets all the requirements necessary for the issuance of an LAPL under the following conditions:
(a) the privileges shall be limited to its national territory or a part of it;
(b) the privileges shall be restricted to a limited geographical area and to single-engine piston aeroplanes with a maximum take-off mass not exceeding 2 000 kg, and shall not include the carriage of passengers;
(c) those authorisations shall be issued on the basis of an individual safety risk assessment carried out by an instructor following a concept safety risk assessment carried out by the Member State;

This of course keeps the French Brevet de Base alive after it was rejected from the original draft.

[David Roberts]

Kestrel 539
Can't think of the answer right now but I'll PM you with who can.

[kevkdg]

Thanks Whopity.

Still unclear how I meet the requirment outlined in section 5(ii) below, from page 503 in CAP804.

Would my 100nm supervised solo qualifying x country suffice, or do I need to go an fly a 150nm flight fulfilling the requirement, albeit unsupervised.

The above glitch aside, as far as I can tell, provided I get a class 2 medical I can obtain an EASA PPL(A) TMG Only, even though many of my hours logged under training were NOT with a JAR Rated Intructor.

5. Provide documentary evidence of having 45
hours flying experience in SLMGs that are
TMGs including, (to comply with
FCL.210.A(a)(1) and (2)), the following:
(i) at least 25 hours dual flight instruction; and
(ii) 10 hours of supervised solo flight time,
including at least 5 hours of solo crosscountry
flight time with at least 1 crosscountry
flight of at least 270 km (150 NM),
during which full stop landings at 2
aerodromes different from the aerodrome
of departure were made;
Experience in SLMGs that are powered
sailplanes other than TMGs cannot be counted

towards meeting the requirements

[Prop swinger]

Originally Posted by David Roberts

Your comment about adding an FI rating to a LAPL is incorrect if you mean LAPL(A), as this was kicked out by the EASA Committee. . . . . There may be an opportunity in the next year or two to get the lack of FI rating for the LAPL(A) addressed.

Thanks David, good luck with that.

Kevkdg,
I don't think you can turn an NPPL SSEA into an EASA PPL by piggybacking on the SLMG to TMG conversion & you may be asking for trouble. They can't give you an LAPL(A) for SEP & a PPL(A) for TMG as you can only hold one (A) licence. Basically you would be asking the regulator to either upgrade your SEP privileges or downgrade your TMG privileges.

Post conversion, I think that FCL.725 applies; you can add SEP to your PPL by doing training as required & a skills test.

[kevkdg]

Prop Swinger.

You can hold two A licences, as you can hold an EASA LAPL(A) or EASA PPL(A) and if you want to fly microlights you'd need an NPPL(A) also.

I too cannot see a direct conversion from NPPL with SLMG and SSEA to a PPL(A) with no restrictions.

Seeing as LAPL medicals now require an exam, the cost and frequency of these seems almost the same as a Class 2 medical.

On that basis alone, it makes so much sense to get a full ICAO PPL(A) TMG only. This way, am I correct in assuming I could remove the TMG only restriction in the future by differences training and skills test on SEP, and then also add FI ratings and indeed fly N registered aircraft in the UK etc.

[Prop swinger]

Originally Posted by kevkdg

This way, am I correct in assuming I could remove the TMG only restriction in the future by differences training and skills test on SEP . . .

That's how I interpret FCL.725.

From FCL.015:

(c) A person shall not hold at any time more than one licence per category of aircraft issued in accordance with Part-FCL.

So you can hold separate aeroplane, sailplane, balloon, helicopter etc licences but only one EASA licence for a particular category. Obviously you can have as many non-EASA licences as you like.

[kevkdg]

Called the CAA today for some advice.

Asked how much it would cost to transition my NPPL(A) SLMG to the PPL(A) TMG only.

I was told £185... which is the price for a new application!!

looking at page 4 of the CAA Official Record Series 5 - CAA Scheme of charges (Personnel Licensing), section 3.1, Table 1, entry (b) > (ii), I make it a charge of £65. (£41 to transition from NPPL to LAPL).

The chap was not even aware there was a conversion/transition route for NPPL to PPL.

Asked a few other questions too, but no joy in getting any sensible answers.

The application form SRG1104 states it does not require any further supporting documentation other than:

Certified Copy of Certificate of Revalidation page and medical.

It states in the guidance notes you only need to send your log book if completing section 7 which is for additional ratings, for example Glider Towing, Aerobatics etc.

How on earth can they ascertain that my SLMG hours were on TMG's as per CAP804!!

[kevkdg]

Eventually got my reply from the CAA around the solo x country. Looks like it will need to be supervised:

Dear Mr ******,

It appears that your query has been overlooked for which I apologise, and I have answered your questions in the main body of the text.
Regards,
***********
Policy Co-ordinator
Licensing & Training Standards

I have more than the 10 hours supervised solo flight time required, of which at least 5 hours are from cross country flights, so would I need to simply fly a 150nm cross country landing at two aerodromes or would my 100nm NPPL supervised Cross Country flight landing at 2 aerodromes be sufficient.– You would need to complete a 150nm cross country during which full stop landings at two aerodromes would be required.

If it is required, I can do this unsupervised within the privileges of my NPPL licence, so am confused whether I need to do this at all and whether log book evidence suffice.– The cross country should be supervised and for information we will be amending CAP 804 to clarify these requirements.

[Whopity]

Eventually got my reply from the CAA around the solo x country. Looks like it will need to be supervised:

Supervision implies some level of responsibility for your actions and the authority to determine whether you fly or not! I suggest you ask them how this is legally possible! If you are a qualified and current pilot, as PIC it is you that is subject to the law not the supervisor, you cannot delegate such responsibility neither can anyone assume responsibility on your behalf. You should try asking the CAA for an Exemption from your responsibilities in order to meet their requirements and see what happens.

[BEagle]

Whopity, if you harp on about that too much, the alternative would be that NO recognition would be given.....and that the applicant might only be credited for previous PIC time....

The PPL(A)/(H) requirement is for a 150nm/2 landaway X-C, whereas the LAPL(A)/(H) requirement is for an 80nm/1 landaway X-C. When I asked the CAA whether a LAPL(A)/(H) applicant (or NPPL applicant), who had elected to fly a 150nm/2 landaway X-C instead during his/her LAPL course, would be credited this requirement during LAPL-to-PPL conversion, I was told that it wouldn't.... Rather than argue with them, I will now take the issue to the next FCL Implemenation Forum and recommend that an AMC should be raised which does indeed allow such credit.

[Whopity]

Article 4 Para 7 allows unsupervised solo:

7. A Member State may authorise a student pilot to exercise limited privileges without supervision before he/she meets all the requirements necessary for the issuance of an LAPL under the following conditions:

They seem to miss the point that the only reason for "supervised solo" is because the pilot does not hold a licence and this is the way its made legal. If the pilot holds a licence, the flight is legal. Solo is solo end of story.

The provision in Para 7 is the way the French can use their Brevet de Base to get around the same problem; if they can do it so can we, but the whole point is there is no need to get around anything other than bureaucratic stupidity!

[Prop swinger]

I imagine the requirement for supervision is because they are not prepared to accept a pilot's uncorroborated word when it comes to a qualifying flight for the purposes of a grant of a licence. So although kevkdg may be a qualified pilot & able to undertake the flight on his own authority, the authorities will expect the flight to be verified in the same way as an unlicenced pilot's 150nm flight.

I've been scratching my head over Article 4 (7) for a while. I can't work out whether para (b) limits the whole idea to SEP aeroplanes (excluding helicopters, TMGs, sailplanes etc) or is it that, if flown in an aeroplane, only SEP is allowed?

[Level Attitude]

I cannot imagine anyone undertaking a modular CPL course who would do
a supervised 300nm XC - they would just do it using their existing
PPL privileges.

Both the current PPL and CPL Application Forms only ask for the date
of a 150nm/300nm XC flight - no mention of supervision.
(Although the PPL does ask for original XC certificate to be enclosed
with the application; I am unaware of any existing Licence Holder
who has done so - and they have all had their Part-FCL PPLs issued
without problem)

I was told £185... which is the price for a new application!!

Includes the price of a new (Part-FCL) Licence?



Addendum to my initial response:

NB: All above were existing ICAO compliant PPLs (ie FAA).

Looking again at the Conversion requirements listed:

5. Provide documentary evidence of having 45
hours flying experience in SLMGs that are
TMGs including,

(ii) 10 hours of supervised solo flight time,
including at least 5 hours of solo cross country
flight time with at least 1 cross country
flight of at least 270 km (150 NM),
during which full stop landings at 2
aerodromes different from the aerodrome
of departure were made;

It does read to me as if the 150nm XC is part of the requirements of the
min 5 hours solo Nav which, in turn, is part of the requirement of
min 10 hours supervised solo flight.

Hence for converting/upgrading a sub-ICAO Licence to an ICAO Licence the
XC flight is required to be supervised.

[kevkdg]

I already have 10 hours plus supervised solo flight time, of which just over 5 hours were x country flights!! So I fulfill that criteria.

It is simply I am short 50nm on the x country front.

[kevkdg]

Latest reply from CAA regarding my follow up query about supervised QXC:

From: FCLWEB [mailto:[email protected]]
Sent: 17 April 2013 09:21
To:
Subject: RE: FAO ******* - CAP804 Query

Dear Mr ******,

Further to your email, approved training must be under the supervision of an Instructor and as I mentioned in my previous correspondence CAP 804 will be amended to reflect this.

I hope that this clarifies the situation for you.
Regards,
*************
Policy Co-ordinator
Licensing & Training Standards

From:
Sent: 11 March 2013 11:58
To: FCLWEB
Subject: FAO ********** - CAP804 Query
Importance: High

Hi ******,

Thanks for your reply,

However, with regards to the "supervision" element, I've been asked to clarify the following:

Supervision implies some level of responsibility by someone else for my actions, and the authority to determine whether I fly or not, which when applied to an ab-initio or someone with a lapsed licence certainly makes sense.

However...

Is this now legally possible as I am a qualified and current pilot, as PIC it is myself that is subject to the law not the supervisor OR can such responsibility be delegated and can anyone (instructor/examiner) assume responsibility on my behalf given that I hold a licence.

Otherwise I can see no reason why the flight needs to be supervised when I can simply undertake the required flight under my own authority.

Kind Regards