PPL SEP - 12 hours of flight time - need clarification
 

Does the 12 hours of fight time required to revalidate a PPL single engine rating include time flying dual with another pilot, even if I am not P1?

Revalidate a SEP Aeroplane Class Rating | Private Pilots | Personal Licences and Training

No. You can't log P2 in a SEP. The 12 hours can be comprised of P1 or P/UT.

You don't really mean as a passenger do you???




Max 6 hours dual I think inc 1hr "instructional" rest must be P1.

https://dl.dropboxusercontent.com/u/...p_Table_v2.bmp
Courtesy of someone on the Flyer forums.

And no, passenger hours don't count for anything, unless it is a multi pilot aeroplane (not many SEPs are MP I would have thought).

I am that 'someone on the Flyer forums', and I would counsel great care in using that table just for the moment.

It is a work in progress, and the Flyer forum thread is to crowd-source critique of it so that it ends up being correct; that process hasn't finished yet.

Thanks, Al, for posting it here though. If anybody has constructive criticism ("Don't like the colours" doesn't count :} ), please comment on the Flyer thread - NOT here.

Many thanks.

Dave

I remember, when this wording was introduced, thinking that an interesting question with regard to the meaning of the phrase 'flight time' could be raised, and this is the first time since then I have seen it brought up.

In theory, as it does not specify what form the 'flight time' that is not PIC must take, one could log passenger time, without claiming any crew function, as 'flight time'.


MJ:ok:

@MJ: absolutely correct. When doing the regulations they missed to define "flight time" - which opened up the old local hero CAA game ... nobody knows but everybody has a opinion. If stretching to the limits, one could even log airline pax time ...

Back to the somehow reasonable things. You can of course log all times you want to, some use their flight book as diary story book and leave the "what counts for x" issue to later. I am writing down my RSF, if I was in control for me to remember and do exclude these hours in claiming flight time for license reasons.

And, to be picky - there is no P2 in a single pilot SEP ... you can log PIC or PUT for license revalidation, plus note PAX for all other flights. In the end it may depend even on your FI/CFI/FE what he/she is going to sign off. BUT, I would always suggest to do FE training flight if you are down or close to minimum hours anyways.

There are several licensing definitions that are confusing (and getting that table above right, believe me, would convince anybody of that fact :* )

However, I find it difficult to believe the definition of flight time in this context is hardto understand. The issue is obviously to do with personal experience to retain currency, which must obviously be flight time undertaking a role that is both legal (as P2 in a SEP isn't) and credibly provides that experience.

How a reasonable person could ever convince themselves that acting as a piece of talking airfreight is loggable experience for licensing purposes is beyond me.

To suggest that the regulatory authorities should be pinning down the definition of "flight time" in this context to such an extent is simply farcical.

And if they tried they'd likely screw it up, anyway.

I couldn't believe that either, that anyone would consider claiming pax time in CAT could possibly have any bearing on their "Flight Time" required under the 12 hour/2nd year rule.

Pax time in CAT was so daft as to be something I hadn't considered. It's pax time in GA that was getting my goat!

In principle I tend to agree as a first reaction, but get immediately into trouble when defining borders. If a right seat pilot takes control he/she gains more experience then a left seat PIC staring at the autopilot for hours. Consequently one must exclude hours under A/P from being logged as PIC time, or would A/P cruise not qualify, but on APP or in traffic circle yes? I do see the strict regulation PIC in single pilot GA equals to exactly and one pilot only from T/O to LDG as a reasonable way out (let "you take control" totally regardless for logging hours - even if you are "in control" the PIC stays "in command").

I refer to one of my previous comment "don't make it complicated"

you are tying yourself up in knots with this.

On that assumption re: A/P operation then many flying instructors have grossly over logged their claimed hours also. sitting in RHS twiddling their thumbs while stude gets on with it.

Dave, I disagree totally.

We all have our own ideas when it comes to what's sensible, but Regulatory Authorities must make the rules clear and unambiguous. THAT'S THEIR JOB.

They already have!



MJ:ok:

Ps. Airline passenger time wouldn't count in this case, as 'flight time in the relevant class' is specified.

But your not saying pax time in the relevant class counts are you?

In this instance the rules ARE absolutely clear and unambiguous already. There are things you can log for experience, and things (P2 in SEP, Pax...) that you can't.

People who cannot interpret these things (actually they can; they're just trying to get something for nothing IMO) should not be pandered to by the regulator by defining things like "flight time" any further than they already have.

It's adding on words to specifically deal with these misinterpretations that will cause the problem by causing even more (inadvertent) obfuscation and potential for deliberate (or otherwise) misunderstanding.

On reflection, I retract and apologise for my final snarky comment of earlier; I'd been spending the last day or so digging down into the confusion that really does exist in EASA and National licensing and had generalised from that.

In other words, MJ - you are quite correct and I agree with you.

If any of us think it should count or not, is neither here nor there.

If someone chose to count it, I can't see how it could be excluded, given the use of the term 'flight time' without any further definition.


MJ:ok:

Is all this "flight time" talk from a CAA "CAP" or from the only relevant document the ANO?

...and there, MJ, I DON'T agree with you. :}

You can't claim P2 in any SEPs, because there are no SEPs , that I know of, that require 2 pilots.

You can, however, put 'passenger time' in your logbook, so long as you don't claim it under any of the 'Crew' titles.

I think that we do agree on the original intention of the requirement here Dave, but if Regulatory Authorities don't write things down clearly, they should expect that some people will push the text as far as it will go.

What we used to call the ANO has been a CAA CAP for a long time. (CAP393)

MJ:ok:

Ps. Dave: Fantastic job with the Table above!:D

I think you will find that it is "contained" in CAP 393 but the opening page say's it all.

I believe no CAA "CAP" has any legal standing at all?

(Standby for major thread drift alert...........)

It seems we disagree on what has been written down clearly by the regulator here. I consider it to be absolutely clear and unambiguous that "flight time" cannot include pax time.

In other news: Twenty-three.

That is the number of angels that can dance on the head of a pin.

Well, I think the onus is on you then Dave, to show us where it is made clear.


MJ:ok:

Ps. Just playing Devil's Advocate here. I don't think it should be included either, but I can't see where it's excluded.

Dream on: Life's too short.

Why it doesn't matter: A reasonable person would not even be considering any other interpretation.

If everyone was 'reasonable' we wouldn't need Regulations.

Personally, I don't think we need this one anyway. All this periodic experience nonsense should be done away with altogether, and just the 'flight with an Instructor' kept to qualify for Revalidation.

Dave's excellent table shows just how absurdly complex this area of Licence/Rating validity has become. I seriously doubt that more than half the Pilots in the UK even bother to keep track of their Licence/Rating validity any more, or that the CAA could successfully prosecute anyone for having an invalid Licence/Rating.


MJ:ok:

The old devil's advocate game ... I think we are far too close to reality to judge our regulators. Yes, it is their job to define things clear and unambiguously, but the problem is - the reality is not. There are authorities which are aware of it and know they are partly perpendicular to reality - these are the ones to deal nicely with, and there are authorities, which did forget this fact and are consequently almost brain dead and a waste of time to talk to.

I insist, you are able to log all you want in your log book - let it PAX in CAT time or whatever you want, you could even possess a pilot log book without being a pilot ! - but which part you are able to present for a revalidation of a license is a different animal. You can be nice to your FE and only write down things which can be counted for license renewal, or you can write a diary where the FE will kill you for the time he/she needs to dig through your mud of lines.

I can not account for all future possible needed categories in my flight book, so I tend to over document, which was quite nice when I had to add my X-Country experience according to FAA definition "flight hours in flights departing from airport A to full-stop land at airport B with a direct line distance of over 50 nautical miles" - do YOU track this in your flight records for the case FAA needs it for a validation?

For the sake of simplicity I also vote to throw all that complicated experience-based lying to the waste bin of history and go for a simple 1h FE flight every 24 month.

I don't think I fully understood a word of that...............

No, what we used to call the ANO is still called the ANO (SI 2009 No.3015). An edited copy of the ANO is included as Section 1 of CAP393 but it is only the SI itself that has any legal standing.

The definition of flight time is included in FCL.010 but does not help resolve the issue of whether, for the purposes of revalidation, passenger time may be counted. If anyone really thinks that it is reasonable to count passenger time, I suggest they should go ahead and try to find an FE who will sign the revalidation certificate on that basis.

Thanks, BB

I don't think any of us think it's reasonable, BB.

The question is, as an FE, on what basis could you refuse?


MJ:ok:

From Article 7 of Regulation (EC) No 216/2008:

From Commission Regulation (EU) No 1178/2011:

Note: Annex III referred to above covers essential requirements for pilot licencing referred to in Article 7

From Annex 1 to Commission Regulation (EU) No 1178/2011:

It is my opinion that the quotations above amount to the requirement for, inter alia, a pilot to be properly licenced and rated in order to operate certain (i.e. most) "EASA" aircraft.

From Annex 1 to Commission Regulation (EU) 1178/2011:

From Annex 1 to Commission Regulation (EU) No 1178/2011:

From AMC and GM to Part-FCL:

Anyone see any mention of the recording of time spent as a passenger being acceptable for the purposes of licencing?

Thanks, Peter. I appreciate the time, and effort that must have taken.

The fact remains though, that nothing there excludes the possibility that flight time as a passenger is included within the term 'flight time'.

Unless, on closer examination, we can take this as a de facto definition of the term 'flight time'?



MJ:ok:

A hard reality check maybe in order.

From the dictionary:

Ok. I'm convinced.

Although it's not as elegant as a specific definition, I accept that (4) above amounts to the same thing, in that it effectively limits 'flight time' to some form of crew function.

Thanks for everyone's input, particularly as it's such an obscure point.

I hope the OP appreciates everyone's efforts.

MJ:ok:

I'm not sure about EASA aircraft, but AN-2 is a SEP that needs 2 pilots :)

Really? I didn't know that. In that case, if it's minimum crew is 2 pilots, you could log P2.


MJ:ok:

I seriously doubt that more than half the Pilots in the UK even bother to keep track of their Licence/Rating validity any more, or that the CAA could successfully prosecute anyone for having an invalid Licence/Rating.

MJ,

I'm not sure I totally agree with that, but you might be right about the latter.
Personally, I feel the need to satisfy a far more onerous body than our regulator, namely the insurance company. Believe me, they go through validity with a fine-tooth comb. For this reason, I keep a meticulous record of all flights I'm responsible for.

TOO

In which case it would qualify for a Type rating and would not be SEP!

What would be best is if they delegated the 2 yearly flight completely to a FI who then endorses the logbook saying that the requirements had been met, without the need for a FE.

Otherwise you might just as well do the flight with a FE in the first place and be done with it. There are more FIs or CRIs available than FEs, and anyone who is not part of a flying club or at an airfields with an FE has to go out and find one.

Flight time is defined for all aircraft categories:

For aeroplanes, touring motor gliders and powered lift, it means the total time from the moment an aircraft first moves for the purpose of taking off until the moment it finally comes to rest at the end of the flight.

So that means brakes off to brakes on. As you cannot be p2 in an SEP, it leads to the fact that there is only two capacities, PUT and PIC.

All this musing is nonsense and people should not try to find sneaky ways to get round the law.

I'm sure you meant 'not SPA', Whopity.;)


MJ:ok:

Here's the issued version of the draft table englishal posted earlier in the thread.

https://dl.dropboxusercontent.com/u/...l-Issue1-1.bmp

PDF version here.

Please don't post images larger than 800 x 800 - Mods

Well, you could have resized it - or PM'd me asking me to do it - rather than peremptorily deleting it. It's supposed to be useful for people.