SEP revalidation 7 weeks after expiration
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SEP revalidation 7 weeks after expiration
Hello guyz
The EASA rule says, the pilot has to prove 12 h incl training flight with FI, everything done during the last 12 months before expire date of the ratings.
I have a confirmation from the EASA, that there is intentionally NO requirement that the revalidation itself has to be made within the same period. It can be 5 weeks after expiration date or even 4,5 month.
One of the reasons is, that the pilot has the right do do all of 12 hours within 12 months.....that means he may do the 12 th in the last evening before expiration. So we can take the 12 months rule seriously.
My ratings expired and I applied 3 month after, because I was looking like crazy for an approved FI who could revalidate by exp. . I gave up after 2 months.
NOW, the CAA does not want to confirm what the EASA officers confirm
So, the want me to do some refreshing hours plus prof check.
What is your experience? Do I really have to meet an lawyer in european airlaw?
thx for an advice
TomTom
(Switzerland)
The EASA rule says, the pilot has to prove 12 h incl training flight with FI, everything done during the last 12 months before expire date of the ratings.
I have a confirmation from the EASA, that there is intentionally NO requirement that the revalidation itself has to be made within the same period. It can be 5 weeks after expiration date or even 4,5 month.
One of the reasons is, that the pilot has the right do do all of 12 hours within 12 months.....that means he may do the 12 th in the last evening before expiration. So we can take the 12 months rule seriously.
My ratings expired and I applied 3 month after, because I was looking like crazy for an approved FI who could revalidate by exp. . I gave up after 2 months.
NOW, the CAA does not want to confirm what the EASA officers confirm
So, the want me to do some refreshing hours plus prof check.
What is your experience? Do I really have to meet an lawyer in european airlaw?
thx for an advice
TomTom
(Switzerland)
Last edited by TomTomClub; 4th Mar 2017 at 09:33.
The UK CAA is applying the regulation as written
Therefore at the end of the 2 year period if not revalidated, the rating has expired.
How can EASA interpret that differently?
FCL.740 Validity and renewal of class and type ratings
(a) The period of validity of class and type ratings shall be 1 year, except for single-pilot single-engine class ratings, for which the period of validity shall be 2 years,
(a) The period of validity of class and type ratings shall be 1 year, except for single-pilot single-engine class ratings, for which the period of validity shall be 2 years,
(b) Renewal. If a class or type rating has expired, the applicant shall:
(1) take refresher training at an ATO, when necessary to reach the level of proficiency necessary to safely operate the relevant class or type of aircraft; and
(2) pass a proficiency check in accordance with Appendix 9 to this Part.
(1) take refresher training at an ATO, when necessary to reach the level of proficiency necessary to safely operate the relevant class or type of aircraft; and
(2) pass a proficiency check in accordance with Appendix 9 to this Part.
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thx
Of course they are expired. So let them expire.....why not. You think, you need a renewal now (?).
But you just fulfilled the requirement of your 12 hours perfectly within the 12 months.. This is the only requirement to hold the right of revalidation in ur hand. You are not yet a candidate for a renewal. You are a candidate for revalidation. A candidate for a renewal cannot prove the 12 h, done within the 12 months before expiration. Do you see the point? Most nations follow this EASA rule, but a couple dont.
TomTom
Of course they are expired. So let them expire.....why not. You think, you need a renewal now (?).
But you just fulfilled the requirement of your 12 hours perfectly within the 12 months.. This is the only requirement to hold the right of revalidation in ur hand. You are not yet a candidate for a renewal. You are a candidate for revalidation. A candidate for a renewal cannot prove the 12 h, done within the 12 months before expiration. Do you see the point? Most nations follow this EASA rule, but a couple dont.
TomTom
Last edited by TomTomClub; 4th Mar 2017 at 09:32.
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(1) take refresher training at an ATO, when necessary (my underlining)
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can be you were told....but the legal basis is missing, if you take a look at the EASA rule
Just supposed, your rating is good from 1. January to 31. December....and you have the right to prove 12 h within these 12 months. Then logically your last flight may be on the 31.Dec.
Wether you think, the revalidation must be done within the validity, then your time period to prove your 12 h is how long? Do you guess it is 7 months in reality? Or is it nine, or even 10,5 months? The Easa says, it is full 12 months.
Hey...I am fighting
Often there is a difference between beeing right and getting the right judgement
Just supposed, your rating is good from 1. January to 31. December....and you have the right to prove 12 h within these 12 months. Then logically your last flight may be on the 31.Dec.
Wether you think, the revalidation must be done within the validity, then your time period to prove your 12 h is how long? Do you guess it is 7 months in reality? Or is it nine, or even 10,5 months? The Easa says, it is full 12 months.
Hey...I am fighting
Often there is a difference between beeing right and getting the right judgement
Last edited by TomTomClub; 4th Mar 2017 at 09:31.
So let them expire.....why not. You think, you need a renewal now (?).
"Revalidation" (of, e.g. a rating or certificate) means the administrative action taken within the period of validity of a rating or certificate which allows the holder to continue to exercise the privileges of a rating or certificate for a further specified period consequent upon the fulfilment of specified requirements.
"Renewal" (of, e.g. a rating or certificate) means the administrative action taken after a rating or certificate has lapsed for the purpose of renewing the privileges of the rating or certificate for a further specified period consequent upon the fulfilment of specified requirements.
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Thank you
I am lookin like crazy for the sentence "means the administrive action taken within the period of validity..."
The sentence "If it has lapsed, expired, was not revalidated within the period of validity, then:" seems to be your own sentence, isnt it?
Pls, do me the favour and show me the link. FCL.010 ist a list of abbreviations. I know this list.
TomTom
I am lookin like crazy for the sentence "means the administrive action taken within the period of validity..."
The sentence "If it has lapsed, expired, was not revalidated within the period of validity, then:" seems to be your own sentence, isnt it?
Pls, do me the favour and show me the link. FCL.010 ist a list of abbreviations. I know this list.
TomTom
Last edited by TomTomClub; 4th Mar 2017 at 09:35.
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@MrAverage
well, I am asking for facts and an official easa document. Some points of view are nice to read.
If a police officer keeps your driver licence, you probably wanna check the legal basis written in an offical document instead of his oral opinion.
No ? Would you accept his point of view without checking the law? Come on--> you would not))
I dont wanna seem rude, but Im for sure very emotional for 3 days
Thanx so far guyz...I ll let you know how I get forward with the CAA
TomTom
well, I am asking for facts and an official easa document. Some points of view are nice to read.
If a police officer keeps your driver licence, you probably wanna check the legal basis written in an offical document instead of his oral opinion.
No ? Would you accept his point of view without checking the law? Come on--> you would not
))I dont wanna seem rude, but Im for sure very emotional for 3 days
Thanx so far guyz...I ll let you know how I get forward with the CAA
TomTom
Last edited by TomTomClub; 4th Mar 2017 at 12:14.
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well, I am asking for facts and an official easa document. Some points of view are nice to read.
FCL.010 ist a list of abbreviations. I know this list.
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That is not FCL.010. It is GM1 FCL.010 (guidance material)
You need to look at the regulation, not the guidance material.
I'll give you a clue. The regulation is Commission Regulation (EU) No 1178/2011.
You need to look at the regulation, not the guidance material.
I'll give you a clue. The regulation is Commission Regulation (EU) No 1178/2011.
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The EASA "officers" have guided you incorrectly. It is also down to the NAA to interpret the regulation. The UK CAA have interpreted and made a decision. Game over, do an LPC.
Professional Student
TomTomClub,
After two months of being told 'no, you need an LPC' (I assume) by FIs, and being told the same on here, prehaps you might consider that it's not a point of view, it's regs.
Unfortunately you've missed the window. You'll need to do an LPC, as bose says....
After two months of being told 'no, you need an LPC' (I assume) by FIs, and being told the same on here, prehaps you might consider that it's not a point of view, it's regs.
Unfortunately you've missed the window. You'll need to do an LPC, as bose says....
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Just phoned my Danish CAA on the subject. The answer (my translation): "If the FCL.740.A (b)(1) conditions were met on the day of expiry, of course no problem. Come by and I'll put the new SEP rating date in your certificate right away."
This has to my knowledge been practiced here since the JAR days before EASA Part-FCL, and sensibly still works.
This has to my knowledge been practiced here since the JAR days before EASA Part-FCL, and sensibly still works.
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Each NAA can interpret the regulation as they see fit. They have to justify it to the EASA audit team at audit time.
The UK CAA have made a decision on how they interpret this and not matter how many other CAAs you quote doing things differently it will not change the response from the UK. My understanding of the OPs post is that he is dealing with the UK CAA or maybe another that interprets it the same way. So its game over, LPC is required.
The UK CAA have made a decision on how they interpret this and not matter how many other CAAs you quote doing things differently it will not change the response from the UK. My understanding of the OPs post is that he is dealing with the UK CAA or maybe another that interprets it the same way. So its game over, LPC is required.
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Without for a moment disagreeing with the advice on this thread....
I can't think of a good reason why the CAA should take the position that they have - that is why it is a good thing to insist on a test if the revalidation isn't signed off within the period. Can anyone enlighten me?
If there is no good reason, then maybe it would be a good idea to lobby the CAA to change their position on this - if it's down to the NAA.
Paul
I can't think of a good reason why the CAA should take the position that they have - that is why it is a good thing to insist on a test if the revalidation isn't signed off within the period. Can anyone enlighten me?
If there is no good reason, then maybe it would be a good idea to lobby the CAA to change their position on this - if it's down to the NAA.
Paul
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Flying with an invalid document?
Let's assume the rating has expired, you fly to another country, get ramp checked, how do you prove you are legal to fly?
We get ramped checked all the time at work. The people checking are generally customs, they are not there to be experts on Licencing regulations, they are to check all your documents are valid and in date. The do that simply by checking the date. Let's see you get smart arguing a point with a French customs officer that you are legal but just did not bother to get a required signature......
Let's assume the rating has expired, you fly to another country, get ramp checked, how do you prove you are legal to fly?
We get ramped checked all the time at work. The people checking are generally customs, they are not there to be experts on Licencing regulations, they are to check all your documents are valid and in date. The do that simply by checking the date. Let's see you get smart arguing a point with a French customs officer that you are legal but just did not bother to get a required signature......