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Revalidation of SEP

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Revalidation of SEP

Old 17th Sep 2019, 16:20
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Revalidation of SEP

According to EASA docs:

(b) Revalidation of single-pilot single-engine class ratings. (1) Single-engine piston aeroplane class ratings and TMG ratings. For revalidation of singlepilot single-engine piston aeroplane class ratings or TMG class ratings the applicant shall:
...
(ii) within the 12 months preceding the expiry date of the rating, complete 12 hours of flight time in the relevant class, including: — 6 hours as PIC, — 12 take-offs and 12 landings, and — refresher training of at least 1 hour of total flight time with a flight instructor (FI) or a class rating instructor (CRI). Applicants shall be exempted from this refresher training if they have passed a class or type rating proficiency check, skill test or assessment of competence in any other class or type of aeroplane.


My question is about the flight with CRI or FI: does this flight needs to be done with ATO and specific document within this same ATO regarding refresher training?
In EASA document it isn't mentioned anything but FI/CRI, thus if you fly with random FI or CRI this should work, especially if your purpose of flight is exactly refresher training?Isn't this similar to the flight review according to FAA regulations? There you can do it with random CFI.

The need of ATO role in this eventual scenario is what I am interested in specifically.
And in regards to all of the above, which is the best way to contact EASA directly with this specific question if the need arises?
Thank you!
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Old 17th Sep 2019, 19:09
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The way this has been implemented in The Netherlands, the answer is no, you don't need an ATO. Any FI or CRI can do this flight with you, fill in the form stating that the flight has been carried out, and if in possession of FCL.945 privileges, can sign off your licence as long as you meet the other requirements for revalidation. I cannot be sure that other countries use the same system of course, whereabouts in the EU are you operating?
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Old 17th Sep 2019, 19:34
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No ATO involvement required provided the FI is not restricted. An FI that is restricted needs to work under the supervision of another instructor and therefore is usually “attached” to an ATO.

It doesn’t need to be one flight either, so long as the total duration is an hour or more.

If all all the other requirements are met and the instructor has 945 on their licence then he can sign the revaluation sheet for you.
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Old 17th Sep 2019, 23:00
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Just adding to the good advice already given
The need of ATO role in this eventual scenario is what I am interested in specifically.
And in regards to all of the above, which is the best way to contact EASA directly with this specific question if the need arises?
Thank you!
An ATO is only required if no current Rating is held, ie Initial Issue or Renewal.
No need to contact EASA as Part-FCL is quite specific on this:

For Renewal: FCL.740 (abbreviated for ease of reading): "(b) Renewal. If a class or type rating has expired, the applicant shall:
(1) take refresher training at an ATO" (my underline).

For Revalidation (whether by Proficiency Check or by Experience) no ATO involvement is required.
For Revalidation by Experience: FCL.740.A (abbreviated for ease of reading): "a training flight of at least 1 hour with an FI or a CRI."
No mention of ATOs at all
And, as
Duchess_Driver has already mentioned, it only has to be a total of 1 hour DUAL - not necessarily a one hour flight
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Old 18th Sep 2019, 07:15
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Thank you very much for the answers!
To be more specific:
The hours needed are present.
The take offs and landings as well.
The person who did the flight as FI is also an approved examiner by the local CAA.
The flight itself was organized as a refresher training with the sole purpose of get up to speed with the skills if eventual checkride /the other way of revalidation/ happens.
On top of that in this particular case, the local CAA has a direct contact with the FI in question and they can easily ask him if the flight was done as a refresher or not.

The next week or so the aircraft currency expired.
Based on that and many other factors, logbook with the info was submitted in the CAA, who, on their behalf refused the revalidate the license because according to their perception, ATO was "self-explanatory" part of that part of the document:
- refresher training of at least 1 hour of total flight time with a flight instructor (FI) or a class rating instructor (CRI). Applicants shall be exempted from this refresher training if they have passed a class or type rating proficiency check, skill test or assessment of competence in any other class or type of aeroplane.

The eventual contact with EASA is to get a written confirmation that ATO is not needed so to present it to the local CAA.
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Old 18th Sep 2019, 12:09
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But did you complete the paperwork? Having flown with the FI, the next step would be to fill in a declaration together, stating that the requirements were met and the training flight took place. Then, either that FI (if FCL.945 authorised, or on his own FE authorisation) or a tame FE could revalidate your licence by filling in the details on the back and signing it. Send the paperwork to the authorities and you're done.

I suspect that the authorities are being difficult because you didn't complete the paperwork in time, thereby letting the rating lapse, and this has put you into the situation where an ATO is required. If all the paperwork was completed prior to the expiry date of the rating, then something else is amiss but I don't know what it could be.
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Old 18th Sep 2019, 14:06
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Originally Posted by Jhieminga View Post
But did you complete the paperwork? Having flown with the FI, the next step would be to fill in a declaration together, stating that the requirements were met and the training flight took place. Then, either that FI (if FCL.945 authorised, or on his own FE authorisation) or a tame FE could revalidate your licence by filling in the details on the back and signing it. Send the paperwork to the authorities and you're done.

I suspect that the authorities are being difficult because you didn't complete the paperwork in time, thereby letting the rating lapse, and this has put you into the situation where an ATO is required. If all the paperwork was completed prior to the expiry date of the rating, then something else is amiss but I don't know what it could be.
Nothing has expired yet, that is the good news.
However, they didn't ask for no paperwork, they insisted that according to EASA document ATO was suggested.
When asked where is that in writing, the answer was: it is self-explanatory.
That is not the case probably.
First time an info about such declaration comes up actually.
Any help with suggestion how to get in touch with EASA directly?
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Old 18th Sep 2019, 16:57
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Sporty123 Care to name which country this is?

The reason ATOs are specified for Initials and Renewals is so that they can furnish the required Course Completion Certificate prior to Test/Check.

There is no training course for Revalidation, so no need for ATO involvement.
As long as it is logged as DUAL, the 1 Hour refresher training required for Revalidation by Experience can consist of anything you like - even just 'How to admire the view'

Your Competent Authority is wrong. However, if you only have limited time left before your SEP expires I would recommend you do the following:
-Contact the FE with whom you did your 1 Hour Flight training and ask him if he would consider/be able to making that a successful Proficiency Check.
or
-Take a Proficiency Check

Later, or if you have time prior to expiry, I would contact EASA for their guidance:
https://www.easa.europa.eu/can-we-help-you
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Old 19th Sep 2019, 00:59
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ask him if he would consider/be able to making that a successful Proficiency Check.
or
cough, cough...

Not the best plan... tests should be pre-notified to the authority...
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Old 19th Sep 2019, 07:21
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I had the same problem of regulation interpretation by the CAA but with regards to another subject.

I kindly emailed EASA legal department, responsible for the drafting via their link stressing that I was in a deadlock and needed their clarification in writing

It was concerning a Fcl.800 rating done at an ATO by a british FE, to be transcribed on an italian licence. At the time Fcl.800 rating compliance kept being delayed by italian CAA.

To no avail was my insistence, backed by the ATO, that posessing an EASA licence would entitle me to have an EASA rating transcribed regardless of whether it was still pending in the country issuing the licence. This rating would then be accepted in those already compliant EASA countries in what was then a transition period.

I got a polite answer from EASA that they would not interefere and could not clarify the issue. Any complaint would have to be adressed directly to the EU (European Union) legal department via a link they provided to me.

I gave up, getting involved with the intricacies and biblical processing times of the immensely complicated EU legal system would take ages, better waiting for italy being compliant which I did.
Needless to say that if there are issues involving consequences likely to impair the career or jobs of pilots, it would be another story, EASA appears not to back up what it has drafted.

I would be delighted to have a follow up of your issue

Last edited by markkal; 19th Sep 2019 at 07:36.
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Old 19th Sep 2019, 09:52
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Something often not realised with revalidations is FCL.050
[QUOTE](b) Logging of time:
(4) instruction time: a summary of all time logged by an applicant for a
licence or rating as flight instruction, instrument flight instruction,
instrument ground time, etc., may be logged if certified by the
appropriately rated or authorised instructor from whom it was received;
[
/QUOTE]

So the proof of the dual training is certified in the candidates log book!
If the person conducting the dual instruction was an Examiner and all other requirements were met, he could have completed the revalidation, no need for any NAA involvement.
The Examiner should know more about this than an invisible clerk at EASA

Sadly, there is growing evidence of totally different interpretations of the Regulation by different States, and generally eminating from individuals who have minimal knowledge of the processes involved.
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Old 19th Sep 2019, 10:46
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Originally Posted by Duchess_Driver View Post


cough, cough...

Not the best plan... tests should be pre-notified to the authority...
Which is why I did not use the word "test"

A Skill Test, for Initial Issue, requires pre-authorisation of the Examiner
A Proficiency Check, for Renewal or Revalidation, does not (at least in the UK)
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Old 19th Sep 2019, 10:57
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Based on that and many other factors, logbook with the info was submitted in the CAA
Sounds like the problem is this particular CAA doesn't allow the paperwork to be completed "in the field"; and it will be an office clerk, with no great understanding of the rules, who gets to decide whether everything is in order or not.
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Old 19th Sep 2019, 15:07
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Well, since the license isn't expired and flight with FI who is also approved FE by that same CAA was conducted with the purpose of refresher training, it shouldn't be a problem in my opinion.
However, that CAA /which is Eastern European by the way, and that is all that I would like to share at the moment/ and the person responsible for the licenses are firm with their belief that this is a procedure that involves ATO.
I hope that this : https://www.easa.europa.eu/can-we-help-you might help with a response that confirms the opinion about ATO not needed in the case.
That should be enough to prove a point if not else.
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Old 23rd Sep 2019, 18:58
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In SEP Revalidation, is it necessary for the Pilot to have 6hours PIC in those 12 hours in previous 12 months.? Will it be suffice if the Pilot do all the 12 hours dual with the instructor?
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Old 23rd Sep 2019, 19:56
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Originally Posted by Duchess_Driver View Post
No ATO involvement required provided the FI is not restricted. An FI that is restricted needs to work under the supervision of another instructor and therefore is usually “attached” to an ATO.

It doesn’t need to be one flight either, so long as the total duration is an hour or more.

If all all the other requirements are met and the instructor has 945 on their licence then he can sign the revaluation sheet for you.
Only if a UK licence holder. the UK is the only country to implement .945 and with our imminent departure from EASA it will be a chocolate teapot privilege.

But to answer the original question assuming I am correct in the original poster being non UK then you meet the 12/12 with 6hrs P1. Fly a 1hr Instructional flight total duration with an FI or CRI and the find an examiner from the same authority that issued your licence to to do the revalidation paperwork. There is no ATO involved.
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Old 23rd Sep 2019, 19:58
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Originally Posted by Duchess_Driver View Post


cough, cough...

Not the best plan... tests should be pre-notified to the authority...
Again, not quite correct. Revalidation's with MOST authorities are not notifiable. You have to read the Examiners Differences document to find out what applies to the specific licence your are revalidating......
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Old 23rd Sep 2019, 23:50
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Originally Posted by StOrMsCaTcHeR View Post
In SEP Revalidation, is it necessary for the Pilot to have 6hours PIC in those 12 hours in previous 12 months.? Will it be suffice if the Pilot do all the 12 hours dual with the instructor?
Provided he logs six of them as PIC yes.
Whether the instructor might agree to this would be open to debate with him.
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Old 24th Sep 2019, 09:27
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Originally Posted by S-Works View Post
the UK is the only country to implement .945 ...
I'll respectfully disagree, I have FCL.945 privileges on my Dutch (EASA) license. Available since 2017 if my memory is correct.

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Old 24th Sep 2019, 13:32
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Originally Posted by Jhieminga View Post
I'll respectfully disagree, I have FCL.945 privileges on my Dutch (EASA) license. Available since 2017 if my memory is correct.

Fair enough. I was told the UK was the only country to implement it to date. It should also be remembered that FCL.945 only allows the revalidation of licences from the SAME state not other EASA states.
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