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FCL.060 90 days restriction

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FCL.060 90 days restriction

Old 18th May 2020, 16:01
  #21 (permalink)  
 
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Originally Posted by Journey Man View Post
HI FlyingStone, that's a lot of nebulous referals with very little evidence. Could you give some examples, i.e. which NAAs interpret the recency requirement for MPA to be the sole manipulator of the flight controls, and an example of a company that has that stated in their OMs?
First of all, in 99.9% of normal MPA operation, pilot flying is always "the sole manipulator of the flight controls" anyway.

Second, UK CAA and most EASA CAT OMs that I have seen. Unfortunately, EASA's wording has lost a bit in translation. ICAO Annex 6, Part I paints a much clearer picture:

9.4.1 Recent experience — pilot-in-command and co-pilot
9.4.1.1 The operator shall not assign a pilot-in-command or a co-pilot to operate at the flight controls of a type or
variant of a type of aeroplane during take-off and landing unless that pilot has operated the flight controls during at least three
take-offs and landings within the preceding 90 days on the same type of aeroplane or in a flight simulator approved for the
purpose.
Or are we going to start counting flaps as flight controls now?
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Old 18th May 2020, 21:40
  #22 (permalink)  
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If you mind, please read the entire FCL.060. Please take a special look at the paragraph (2), where it says "...has carried out in the preceding 90 days at least 1 take-off, approach and landing at night as a pilot flying ...".
In paragraph (1) it does not specify that those take-offs, approaches and landings must be done as PF. Or maybe I'm lost in translation...


A pilot shall not operate an aircraft in commercial air transport or carrying passengers:
(1) as PIC or co-pilot unless he/she has carried out, in the preceding 90 days, at least 3 take-offs, approaches and landings in an aircraft of the same type or class or an FFS representing that type or class. The 3 take-offs and landings shall be performed in either multi-pilot or single-pilot operations, depending on the privileges held by the pilot; and
(2) as PICat night unless he/she:
(i) has carried out in the preceding 90 days at least 1 take-off, approach and landing at night as a pilot flying in an aircraft of the same type or class or an FFS representing that type or class; or
(ii) holds an IR;
(3) as cruise relief co-pilot unless he/she:
(i) has complied with the requirements in (b)(1); or
(ii) has carried out in the preceding 90 days at least 3 sectors as a cruise relief pilot on the same type or class of aircraft; or
(iii) has carried out recency and refresher flying skill training in an FFS at intervals not exceeding 90 days. This refresher training may be combined with the operator’s refresher training prescribed in the relevant requirements of Part-ORO.(4) When a pilot has the privilege to operate more than one type of aeroplane with similar handling and operation characteristics, the 3 take-offs, approaches and landings required in (1) may be performed as defined in the operational suitability data established in accordance with Part-21.
(5) When a pilot has the privilege to operate more than one type of non- complex helicopter with similar handling and operation characteristics, as defined in the operational suitability data established in accordance with Part-21, the 3 take-offs, approaches and landings required in (1) may be performed in just one of the types, provided that the pilot has completed at least 2 hours of flight in each of the types of helicopter, during the preceding 6 months.
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Old 18th May 2020, 22:05
  #23 (permalink)  

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Fair call?
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Old 18th May 2020, 23:18
  #24 (permalink)  
 
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I can’t be bothered reading all of that argument, I thought I would just add that my company are scheduling sim sessions in June literally for 3 TO/LDGs. we can expect to be in for a few minutes a time.
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Old 24th Jun 2020, 15:32
  #25 (permalink)  
 
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For Corporate Pilots;
3 Touch and go Landings on the company aircraft is probably a lot cheaper than what the some of the sim companies will charge for doing it.
They will insist on charging for minimum of one hour.
Even though you could do it in the SIM in 7/8 minutes with 3 take-offs and re-positions.

One hour sim for a mid sized corporate aircraft: approx £1500-£2000 K.
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Old 24th Jun 2020, 22:18
  #26 (permalink)  
 
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I can play in the A320 SIM my company rents for training for $500/hr......
Also, get 6 pilots and do them all in a one hour session.
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Old 25th Jun 2020, 01:59
  #27 (permalink)  
 
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The aviation authority in our country (Netherlands) has stated that PM landings in a multi crew environment also count towards the 3 takeoffs and landings under EASA rules.

The EASA wording being “carried out”. ICAO does mention flight controls, but we fly by EASA rules in Europe.
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Old 25th Jun 2020, 07:15
  #28 (permalink)  
 
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What a joke.
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Old 25th Jun 2020, 07:54
  #29 (permalink)  
 
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3 Touch and go Landings
It is my understanding that a touch and go only counts as a landing, not a take off (exactly as you wrote it).
You’ll probably have to make full stops. Means you will get some taxi practice as well😀
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Old 25th Jun 2020, 08:13
  #30 (permalink)  
 
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Why would you not want to?

I know I am rusty, and it isn’t 90 days for me!
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Old 25th Jun 2020, 09:00
  #31 (permalink)  
 
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I don't fly for a week I notice, two weeks and the copilot notices, three weeks and the passengers notice as the old saying goes. Personally I think three sectors in a front seat with at least one landing would be the minimum if not optimal, particularly for our long haul colleagues. But I think most people will need a session in the sim, which frankly behaves a bit differently for the landing. Still it is better than nothing.
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Old 25th Jun 2020, 09:03
  #32 (permalink)  
 
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Originally Posted by FlyingStone View Post
What a joke.
So, a multi-crew aircraft becomes suddenly a single-pilot-aircraft when being close to the ground such as for landing and take-off? I thought that PM is very often more challenging then just working the stick and rudders...
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Old 25th Jun 2020, 09:15
  #33 (permalink)  
 
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OK, a practical case. In EASA land, one can go 9 months between simulator checks. So 8 months and 29 days later, after only watching the other pilot do it 50 times in the meanwhile, you finally get to do it for real when it's 30 knots across on a short wet runway at night. Would you be comfortable landing the aircraft?

Landing is a predominantly a motor skill and needs to be practiced. Just as a student pilot will learn the skill to some extent by watching an instructor demonstrate the landing, they will need to do it themselves again and again to master it. Same applies to recency.
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Old 25th Jun 2020, 09:19
  #34 (permalink)  
 
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Those requirements are bare minimums. Your personal requirements can be stricter and it is our own responsibility to safeguard those personal requirements.
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Old 25th Jun 2020, 09:34
  #35 (permalink)  
 
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Originally Posted by FlyingStone View Post
OK, a practical case. In EASA land, one can go 9 months between simulator checks. So 8 months and 29 days later, after only watching the other pilot do it 50 times in the meanwhile, you finally get to do it for real when it's 30 knots across on a short wet runway at night. Would you be comfortable landing the aircraft?

Landing is a predominantly a motor skill and needs to be practiced. Just as a student pilot will learn the skill to some extent by watching an instructor demonstrate the landing, they will need to do it themselves again and again to master it. Same applies to recency.
100% agree.
It is like being a very experienced coach of a tennis player ; you notice the details from the bench and call it out in order for the player to correct his movements.
Now if the coach - whose last game was 20 years before - takes the racket and starts playing against Nadal, what is going to happen ?
Landings need the theory first and then practice, practice and practice.
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Old 25th Jun 2020, 09:42
  #36 (permalink)  
 
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@ FlyingStone: you can easily fly regularly and do countless landings, without any "30 knots across on a short wet runway at night" landings at all. And having done x-landings within x-days as PF does not necessarily mean that you are proficient with regard to your personal performance. It simply means that you are legal. And yes, I would be comfortable. Because in EASA land the qualification requirments of PM is still different than within the FAA world, it has always to be a fully qualified and rated pilot.

I think your statement is valid, but referring to a different issue. And the regulation does not cover "personal performance" as such, it is, as RV said, a bare minimum requirement. However, not all of those requirements make sense, just to say.
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Old 25th Jun 2020, 09:55
  #37 (permalink)  
 
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But since, as You say, it is a bare minimum then how would you expect to fulfil this minimum as PM ?
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Old 25th Jun 2020, 14:55
  #38 (permalink)  
 
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... by performing your multi-crew duties as a type rated pilot, including handling of the (secondary-) flight controls as appropriate 👍
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Old 25th Jun 2020, 16:28
  #39 (permalink)  
 
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And yes, I would be comfortable. Because in EASA land the qualification requirments of PM is still different than within the FAA world, it has always to be a fully qualified and rated pilot.
So you'd be comfortable landing the aircraft at its demonstrated crosswind limit after 9 months without a single landing as PF, just because you have a full type rating?

Hats off, sir. I wouldn't be.
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Old 25th Jun 2020, 19:01
  #40 (permalink)  
 
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No, I would not. And I never said something alike. I would not go to any limit just because I have my 3/90 landings either. My personal requirements might be different than yours as ReturningVector mentioned earlier above, this was never the point of this thread and never the point of the argument why PM might be accepted by some authorities.

But I will leave it as it is, it became almost a private chat.


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