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EASA SEP revalidation by exp. microlights

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EASA SEP revalidation by exp. microlights

Old 22nd Nov 2020, 09:57
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EASA SEP revalidation by exp. microlights

Apologies if this has been answered previously. I can't find it on the forum.

I'm looking for the specific EASA documents that state that 3 axis microlights can now be used to fulfil hourly requirements for SEP revalidation. So far, I have discovered the following in but I am confused by the emboldened (condition a). How does this mean that the aircraft used can be a "microlight"!? Help much appreciated.

From Annex I to ED Decision 2020/005/R AMC and GM to Part-FCL — Issue 1, Amendment 9
AMC1 FCL.140.A; FCL.140.S; FCL.740.A(b)(1)(ii) Recency and revalidation requirements All hours flown on aeroplanes or sailplanes that are subject to a decision as per Article 2(8) of the Basic Regulation or that are specified in Annex I to the Basic Regulation should count in full towards fulfilling the hourly requirements of points FCL.140.A, FCL.140.S, and FCL.740.A(b)(1)(ii) under the following conditions: Annex I to ED Decision 2020/005/R Page 7 of 61 (a) the aircraft matches the definition and criteria of the respective Part-FCL aircraft category, class, and type ratings; and (b) the aircraft that is used for training flights with an instructor is an Annex-I aircraft of type (a), (b), (c), or (d) that is subject to an authorisation specified in points ORA.ATO.135 or DTO.GEN.240.
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Old 22nd Nov 2020, 11:41
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From the CAA website;

Single-engine piston rating for aeroplanes

Requirements for issue of a single-engine piston rating for aeroplanes in single-pilot operations

Single Engine Piston (SEP) and Touring Motor Glider (TMG)


For pilots with these ratings to revalidate by experience, you must fly a certain amount of hours in the 12 months before the rating expires. This can be made up of flight time as pilot in command or dual. There is a minimum number of take offs and landing that must be as pilot in command.


The guidance from EASA means that you can now include flight time in non-EASA aircraft (apart from weightshift microlights); flight experience is now considered to be part of the definition of hourly requirements.


There is also a requirement for a refresher training flight with an instructor and this cannot be conducted in a microlight aircraft of any configuration. In addition, the aircraft used must be subject to an authorisation by the ATO or DTO (ORA.ATO.135 or DTO.GEN.240).


Pilots can use hours flown from 18 March 2020 towards meeting the recency or revalidation requirements. The use of this Acceptable Means of Compliance is not compulsory, as this is one of a number of means to comply with the regulation, so licence holders do not have to use non-EASA aircraft if they do not want to.


The hours flown in non-EASA aircraft cannot be used to obtain a Part-FCL licence, rating, or certificate or towards meeting their prerequisites.


All of these requirements only apply to non-EASA Sailplanes, Single-Engine Piston (SEP) Aeroplanes and Touring Motorgliders (TMGs).


Annex I (non-EASA aircraft 1) is defined in the Basic Regulation (Regulation (EU) 2018/1139) as;


1(a) Historical aircraft,
1(b) Research, experimental and or scientific aircraft,
1(c) Homebuilt aircraft,
1(d) Former military aircraft,
1(e) Microlight aircraft (as defined)


Last edited by Fl1ingfrog; 22nd Nov 2020 at 12:05.
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Old 22nd Nov 2020, 16:36
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EASA has subordinated ultralights to the national authorities, they cannot and won't mention them for themselves. It is for the national CAA's to decide the degree to which they accept ultralight hours for PPL revalidation. As neatly illustrated above.

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Old 22nd Nov 2020, 18:25
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"The hours flown in non-EASA aircraft cannot be used to obtain a Part-FCL licence, rating, or certificate or towards meeting their prerequisites."
That's interesting. Hours in a Jodel DR1050 etc don't count towards the minimum hours for anything. (My bold.)
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Old 22nd Nov 2020, 19:21
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"The hours flown in non-EASA aircraft cannot be used to obtain a Part-FCL licence, rating, or certificate or towards meeting their prerequisites."
My reading of the extract is that only the hours flown in a 'EASA type' may be counted toward the requirements for the initial issue of a licence or rating or when any course of training is required: i.e. a training requirement for renewal of a EASA rating or an examiners certificate. I take that to mean explicitly that a prescribed course for a EASA licence, rating or certificate must be completed wholly in a EASA recognised aircraft. Nothing to do with the hours experience required for revalidation of a certificate of experience though.

Last edited by Fl1ingfrog; 22nd Nov 2020 at 19:59.
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Old 22nd Nov 2020, 22:59
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This all stems from the complete nonsense EASA has made with regard to acceptance of flight time in Annex 1 aircraft.

Back in 2014, the intention was that flight time in Annex 1 (a) - (e) aircraft could be counted towards SEP revalidation. As the legal cogs slowly ground away in EASA, evntually that was agreed...

But at no time was the intention that such flight time could ONLY be used for that purpose!

Meanwhile, a different EASA group looked at the use of Annex 1 (a) - (d) aircraft for flight instruction - eventually this was agreed; Annex 1(e) aircraft ('microlights') could NOT be used for this purpose.

There are some idiots now at EASA who cannot understand that it is quite OK to do a PPL course on something like a Piper Cub, including the Skill Test (assuming the examiner is happy). One such person even thought that the FI who taught on a non-EASA aircraft could count the hours towards his/her SEP Class Rating revalidation, but NOT towards his/her FI certificate revlidation....Where do they find these people?? There was even a suggestion that a pilot would have to keep EASA and non-EASA flight time in separate log books.

Anyway, as far as the UK is concerned you can use flight time in non-EASA 'annex 1 (a)-(d)' aircraft for training on anything issued by the CAA (provided that the aircraft has been deemed to be OK by the CAA) and it will also count towards revalidation. Annex 1(e) 3-axis microlight flight time can be used for revalidation, but not for the refresher training flying requirements.

To resolve this utter dog's breakfast, AOPA (UK) drafted an AltMoC for the CAA to pass to the DfT; however, due to the UK/EU exit situation that had to be shelved. The draft AltMoC was sent to IAOPA and any national AOPA is welcome to submit it to their NAA.

When the UK leaves EASA, the problem will go away in the UK as we won't have 'EASA' and 'non-EASA' aircraft any more.
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Old 23rd Nov 2020, 19:58
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Thanks Beagle.
My aircraft is an Annex 1 (LAA Permit) Bolkow BO208C. Most such aircraft are EASA.
.
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Old 24th Nov 2020, 13:22
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Originally Posted by BEagle View Post
When the UK leaves EASA, the problem will go away in the UK as we won't have 'EASA' and 'non-EASA' aircraft any more.
Quite right we will have Part 21 and Annex 1 aircraft.
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Old 24th Nov 2020, 13:50
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Part 21 whether it is ICAO, EASA or FAA etc applies to all aircraft certification whatever its use or capability. Annex 1 is a EASA construct and will not be applicable after we have left EASA.
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Old 29th Jan 2021, 11:54
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The bit that I find confusing in the AMC1 (highlighted) is point (a). How can an ultralight be in the same category, class and type as a SEP? Can anyone help me out?
.
All hours flown on aeroplanes or sailplanes that are subject to a decision as per Article 2(8) of the Basic Regulation or that are specified in Annex I to the Basic Regulation should count in full towards fulfilling the hourly requirements of points FCL.140.A, FCL.140.S, and FCL.740.A(b)(1)(ii) under the following conditions: (a) the aircraft matches the definition and criteria of the respective Part-FCL aircraft category, class, and type ratings; and (b) the aircraft that is used for training flights with an instructor is an Annex-I aircraft of type (a), (b), (c), or (d) that is subject to an authorisation specified in points ORA.ATO.135 or DTO.GEN.240.
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Old 29th Jan 2021, 19:08
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It is impossible to separate the handling of a three axis ultralite, microlite etc from those aircraft registered in the other three axis categories. The handling characteristics of the many very different types, although within the same category, demonstrate this.
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Old 2nd Feb 2021, 11:36
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I suppose the question is, can a microlight be an SEP?
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Old 2nd Feb 2021, 15:50
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I suppose the question is, can a microlight be an SEP?
No. A 'microlight' is an Annex 1(e) aircraft. In the case of a 3-axis 'microlight', it falls under the ICAO of an aeroplane:

A power-driven heavier-than-air aircraft, deriving its lift in flight chiefly from aerodynamic reactions on surfaces which remain fixed under given conditions of flight.
So although flight time in Annex 1(e) aircraft is recognised towards the revalidation of an SEP/TMG Class Rating by experience (as may flight time in Art.2(8) 'opt-out' sub-600kg aircraft), dual refresher training with an instructor must be flown either in an EASA aircraft or, if it has been approved for training by the NAA, an Annex 1(a)-(d) aircraft.
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Old 2nd Feb 2021, 18:00
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We must somehow stop referring to "EASA" aircraft. Very hard though when trying to explain things.
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Old 2nd Feb 2021, 23:15
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Unless EASA has adopted the term 'Part 21' for other than Annex1 or Art.2(8) aircraft, it is simpler for those outside the UK to continue to term them as 'EASA' aircraft, in my view.
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Old 2nd Feb 2021, 23:57
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Well, they are not "EASA" so to term is incorrect. "ICAO" compliant perhaps goes someway to distinguish them from Microlight, home builds, permit and those aircraft on a national C of A. etc. Whatever is the choice they are not EASA any longer and everyone must come to terms with that. Over the coming months all references to EASA will have been removed.

Last edited by Fl1ingfrog; 3rd Feb 2021 at 00:18.
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Old 3rd Feb 2021, 08:51
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Originally Posted by BEagle View Post
No. A 'microlight' is an Annex 1(e) aircraft. In the case of a 3-axis 'microlight', it falls under the ICAO of an aeroplane:



So although flight time in Annex 1(e) aircraft is recognised towards the revalidation of an SEP/TMG Class Rating by experience (as may flight time in Art.2(8) 'opt-out' sub-600kg aircraft), dual refresher training with an instructor must be flown either in an EASA aircraft or, if it has been approved for training by the NAA, an Annex 1(a)-(d) aircraft.
Well then I am really very confused. How on earth can a Microlight comply with the required AMC point "(a) the aircraft matches the definition and criteria of the respective Part-FCL aircraft category, class, and type ratings;"

This, to me plainly states that can only count hours flown in an SEP towards revalidation by experience. An ultralight does not match the definition and criteria.

Longer quote of the AMC text for context:
All hours flown on aeroplanes or sailplanes that are subject to a decision as per Article 2(8) of the Basic Regulation or that are specified in Annex I to the Basic Regulation should count in full towards fulfilling the hourly requirements of points FCL.140.A, FCL.140.S, and FCL.740.A(b)(1)(ii) under the following conditions: (a) the aircraft matches the definition and criteria of the respective Part-FCL aircraft category, class, and type ratings; and (b) the aircraft that is used for training flights with an instructor is an Annex-I aircraft of type (a), (b), (c), or (d) that is subject to an authorisation specified in points ORA.ATO.135 or DTO.GEN.240.
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Old 4th Feb 2021, 09:43
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There was an article in Flyer May 2020 (Dave Calderwood, 28/5/2020) I cannot post the URL as new PRUNE member. In short it indicates that 3 axis hours can be counted towards renewal. I have flown a Skyranger since 2006 and always revalidated by proficiency check to maintain my full PPL. I can recall at the last renewal one examiner believed that my 3 axis time counted but the other was not convinced. I therefore did the prof check to be certain. I am now under the impression that I can renew on hours +the one hour instructor flight.
Google search of microlight/hours/flyer soon found the article.

Hope this helps

rob
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Old 4th Feb 2021, 17:10
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You cannot renew an SEP Class Rating by flying a Proficiency Check in a microlight.

You can count flight time in a microlight towards revalidation of an SEP Class Rating by experience, but the minimum hour of refresher flight training with an insructor may not be flown in a microlight. Neither may a revalidation Proficiency Check be flown in a microlight.
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Old 4th Feb 2021, 17:44
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Just to clarify. All my revalidation flights were in a warrior. I was aware that they could not be carried out in my skyranger
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