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 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)

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.

"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.)

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.

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.

Thanks Beagle.
My aircraft is an Annex 1 (LAA Permit) Bolkow BO208C. Most such aircraft are EASA. :rolleyes:
.

Quite right we will have Part 21 and Annex 1 aircraft.

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.

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?

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.

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:

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.

We must somehow stop referring to "EASA" aircraft. Very hard though when trying to explain things.

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.

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.

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:

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

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.

Just to clarify. All my revalidation flights were in a warrior. I was aware that they could not be carried out in my skyranger

Bump. Can anbody help me out with the problem of clause "(a) the aircraft matches the definition and criteria of the respective Part-FCL aircraft category, class, and type ratings;"?

How can a microlight match the definition of an SEP?

Perhaps this is simple, but this is very clause is being used as the reason I am being told by a Spanish AESA instructor that I cannot use a microlight to build hours for revalidation of my PPL SEP rating. She is telling me in no uncertain terms that a microlight aircraft does not match the criteria of the class/type of my SEP rating. I think she is wrong by shear dint of numbers of people telling me otherwise, but I would like a clear, rational explanation and clarification of this clause!

Many thanks to anybody who is willing to help!

There is no difference between a fixed wing Microlight (Uitralite) and a ICAO recognized type (Part - 21). A microlight is differentiated in being constrained by its permissible maximum take off weight and the maximum scheduled stall speed at that weight, nothing else. However some are confused (your Spanish instructor) because owing to history most Microlights had flexible cloth wings and were operated by weight shift, they are still popular. This is why authorities stipulate 'three-axis' to count towards SEPL experience. There is no logical reason why a NAA should differentiate between a three axis fixed wing microlight and a ICAO SEPL aircraft for refresher training/test but they do, they just like to draw a line somewhere. It is worth noting that a pilots annual proficiency check in a Boeing 777 exempts them from the dual flight prescribed with an instructor to maintain their SEPL. You might well argue that that makes even less sense. It is also bizare that a current SEPL Flight Instructor with thousands of hours of instructing in SEPL is also required to have a training flight with another instructor, who may have only a dozen hours instructing, to maintain their SEPL.

No one I'm sure would compare a Cessna 150 with a Cessna 210 or even a Piper Malibu Mirage as being the same but the authorities lump them together as a SEPL class aircraft. So, a flight in a Cessna 150 covers you for the lot. Once again a product of history.

Hi guys,My LAPL and medical expire in March,I have more than 12 hours PIC on a three axis microlight in the last 12 months but because of covid restrictions I haven't been able to do the hour with an instructor,will I be grounded until I can eventually fly with an instructor or are there any CAA exemptions regarding this?. With regard to the medical,are there any extentions for LAPL medicals? I am aware that AME's aren't doing class 2/LAPL medicals at the moment, I have made equiries with the CAA but the link regarding exemptions confused me a little

Thanks for any replies,

W

The LAPL does not expire. The experience requirement is a rolling assessment. The minimum of 1 hour training with an instructor is a total. This total is to be completed within the 24 month period before flying. There is no set date. So prior to flight you must look back to check whether you comply with each requirement. You can avoid all this by undertaking a flight with an examiner.

There is a lot that can happen between now and the end of March. All we can do is hold our breath. At the moment 'private flight' is not allowed. Expect little from the CAA on the LAPL, other national Licenses and the private grade medicals until there is a government announcement relaxing things. Now that the UK LAPL is a wholly UK licence restricted to UK airspace perhaps they may allow the use of a Medical Declaration. The same as the national PPL and the NPPL. They will have to do something with the massive backlog of Class 2 and LAPL medicals accruing. Note: the medical expiry date is the last day of the month.

Thanks FL1ingfrog,my problem is obviously the hour with instructor bit,sounds like there is no way round it and I will have to get in line with everyone else for the 'essential' hour with an instructor.When I was forced to convert my old 1990's ppl I was advised the LAPL would be the cheaper route if nothing else other than the medical was likely to become a self certify set up,I'm hoping it goes that way soon,oh for the simpler days of 1990's general aviation!

You didn't convert your 1990s ICAO UK PPL to obtain a LAPL. In the past the CAA have been guilty of stating that it was a conversion but they were wrong to do so. If they took your PPL and didn't return it to you then ask for it back. It was issued to you for life. Hopefully you will still have your old PPL. If so you can solve the medical issue by making a 'Self Declaration'. The PPL privileges you should hold gives you all and more than the LAPL so why not. You will, of course, have to do a renewal test to reactivate your UK ICAO PPL but this will only require one problem to be solved. The Self Declaration is of course free! This saving should cover you renewal test.

The ppl I had was a CAA ppl,obtained in 1994,I had a TMG rating on it and used it with the same privileges as an EASA ppl,but with the EASA juggernaut in full swing I had to replace it with something European two years ago,I think the change over date had been April 2015 but was deferred a couple of times. During my last medical the ame asked what medical I wanted which was when the confusion started, he said he couldn't do a medical for the CAA licence,only a LAPL or EASA ppl,so I went LAPL after we discussed what type of flying I did, we decided an EASA was probably not required and the LAPL medical was going to go self certification at some point, the confusion with Brexit muddied the water a bit so I went the LAPL route which has been fine for me so far...

The LAPL medical requirement is unlikely to change to self certification, for that is not how the EU thinks and requires international agreement. The UK is no longer part of EASA and the UK is left with a pup. The UK LAPL gives no privileges since January 1st over and above the NPPL or the National PPL which you also hold. There is no reason for the CAA to maintain the EASA required restriction against NPPLs and non EASA PPLs. As you fly a Microlight there is no point for you to maintain anything other than self certification for flight within the UK.

I thought I knew where I was after reading this on SkyWise:

"Pilot Medical Declarations: Clarification

Following a rapid review we can today confirm that the less than 2,000kg aircraft category, with its reduced list of disqualifying conditions within a Pilot Medical Declaration (PMD), is still an option for national pilot licence holders (subject to the specified operational conditions). Existing PMDs remain valid for the type of licence(s) and aircraft weight limits specified at the time of a declaration.

Earlier this year, in seeking to resolve a longstanding difference between the advice and options for PMDs offered on our website, and the requirements of the Air Navigation Order (ANO), we aligned our website text and online form to that in the ANO. In hindsight we can see this has caused a lot of confusion and we would like to apologise for this. We have updated our website and are in the process of updating the relevant form. We will also be taking steps to regularise this situation for the benefit of those who use PMD in the GA community by issuing a formal exemption which we will keep under review, as we do with all exemptions.

SW2021/27"

However, having read what FlyingFrog has written and the CAA website, I am now unsure.

Can I continue to fly a UK-registered permit aircraft (non-part 21) in the UK with a UK issued LAPL until my current PMD (for up to 2000kg only) expires at age 70?

Sorry that I mislead you when stating the above but yes you can.

From the CAA website:

A medical declaration (from 25th August 2016) is an affirmation of your medical ‘fitness to fly’ and may be used to exercise the privileges of a:

• UK Part-FCL Private Pilot Licence (PPL) to fly UK (G) registered Part 21 and non-Part 21 aircraft;
• UK Part-FCL Light Aircraft Pilots Licence (LAPL) to fly UK (G) registered Part 21 and non-Part 21 aircraft;

Ok,so I can do the medical declaration for a LAPL?.Could I do a self declaration on my ppl if I got it revalidated,I'd prefer to use the ppl if I can use it to fly a three axis microlight (Eurostar) and count the hours toward revalidation of the ppl though it's not crucial, I could do the revalidation flight with an examinar every two years if I had to,thanks for all your input Fl1ingfrog

Yes you can and therefore maintain both the PPL and the LAPL simultaneously. The dual training flights/test and hours for the SEPL will also satisfy the requirements for the LAPL .

Ok,thanks again,hopefully get the ppl sorted when we are allowed to fly again.

That's how I read it initially too. However, the page you quoted goes on to make a distinction between:

Holders of UK national licences only, to only fly aircraft no greater than 2000 kg MTOM
and
Holders of UK national and Part-FCL Licences, to fly any aircraft less than 5700kg MTOM

So my real question is does a UK issued Part-FCL LAPL now count as a UK national licence?

My reading of the CAA words is this;

If your private licence permits you to fly aeroplanes up to 5.700 Kg then you may continue to do so using a 'Self Declaration'. [a National and an ICAO PPL limit]
If your private licence limits you to fly aeroplanes up to 2000 Kg then you may continue to do so using a 'Self Declaration'. [a NPPL and LAPL limit}

In other words the Self Declaration does not change you licence private privileges for flight within the UK airspace: It is also usable with an IMC and and a Night rating. However, the Self Declaration does not support the IR.

The UK LAPL for the moment is now superfluous, because we already have the NPPL and the LAPL adds nothing more, but the CAA is yet to make an announcement on its future.

Except that a LAPL will allow the holder to fly a Part 21 aircraft in UK airspace, whereas an NPPL or a UK PPL will not.

EASA is no longer recognizing the UK LAPL. The restriction you highlight applies to 'EASA aircraft' not the UK part-21 aircraft, the CAA needs to clarify. The term 'EASA' is removed from the UK ANO.

I emailed the LAA for clarification and to ask about the possibility of revalidating my NPPL (SSEA). The Head of Licensing has commented:

"For the foreseeable future, his LAPL should give him the same privilege of flying G registered aircraft in UK airspace on a Medical Declaration, albeit having to fulfil the slightly higher medical requirements for a PART-21 licence declaration (the sub 5700kg requirements). The LAPL also allows him to fly PART-21 aircraft (previously known as EASA aircraft) which the NPPL currently does not allow."

If this is confirmed, it means that any LAPL holder flying on a sub 2000kg PMD will have to cancel it and make a new sub 5700kg PMD (if able) to fly any aircraft even if (like me) they only wish to continue to fly non-part 21 aircraft up to 2000kg in UK airspace. This is nonsense but before I write a sharp letter to Grant Shapps, does anyone have any comments?

Of course, some LAPL holders will have (like me) the option to revalidate their NPPL and continue to fly on a sub 2000kg PMD.

However, if (like me) they have not had their NPPL rating validity page signed by an examiner every two years, they can only renew their NPPL by a General Skills Test with an examiner and if it has expired by more than 5 years (like me), that Test includes an oral theoretical knowledge examination.

And this appears to apply even if (like me!) they have satisfied all the normal NPPL (SSEA) rating flight time and training flight with an instructor validity conditions in SEPs on a LAPL(A).


"

No you don't, the word "sub" is not used.

No they don't. The wording isn't sub 2000 kg or sub 5700 kg, the wording is: Holders of UK national licenses only, to only fly aircraft no greater than 2000 kg MTOM. The wording is the same for the "no greater than" 5700 kg aircraft.

The LAPL and NPPL privileges provide for flying no greater than 2000 kg MTOM aircraft. The self declaration for the no greater than 2000 kg aircraft is therefore all that is required.

OK, thanks. Apologies for repeating his/her use of the word SUB. I should have stuck to the usual up to or no greater than. And as you point out, the LAPL is only valid in aircraft up to 2000kg so the LAA's advice does not sound correct!

However, I still do not understand why the CAA website makes a distinction when

Self-declaring your medical fitness using the Pilot Medical Declaration

between

Holders of UK national licences ONLY, to only fly aircraft no greater than 2000 kg MTOM
and
Holders of UK national and Part-FCL Licences, to fly any aircraft less than 5700kg MTOM

(My emphasis on first ONLY)

So I pose this question again: Does a UK issued Part-FCL LAPL now count as a UK national licence?

Thank you for all your input F1F.