FCL.060 90 days restriction

[busav8r]

EASA FCL.060 says: 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;

Can anyone clarify if these 3 take-off, approaches and landings must be done as PF or it is irrelevant who actually does them, as long as the pilot (PIC or Co-pilot) occupies a pilot seat? Does it count no matter if the pilot is acting as PF or PM? Or does it count only for the pilot who actually lands the plane?
Thanks.

[568]

I do believe that you must perform these 3 take offs and landings in the seat you would normally occupy (PIC or FO). Having the required level of simulator and being validated by the respective NAA will ensure currency.
If I am incorrect then someone will be along to correct. Good luck,

[READY MESSAGE]

Must be PF to count the three

[Meester proach]

I’m sure they’ll have to find some dispensation , as half the world’s airline pilots would need a sim trip otherwise

[Denti]

For most of us section (c) is quite important, which increases the 90 days to 120 days if the three landings are done under supervision of a TRI or TRE.

(c) Specific requirements for commercial air transport:
(1) In the case of commercial air transport, the 90-day period prescribed in subparagraphs (b)(1) and (2) above may be extended up to a maximum of 120 days, as long as the pilot undertakes line flying under the supervision of a type rating instructor or examiner.

[FlyingStone]

Extension to 120 days can be a bit tricky, as not all TRI/TREs are able to do it.

[Journey Man]

Originally Posted by READY MESSAGE

Must be PF to count the three

As monitoring pilot, you're part of the active crew for a multi pilot aeroplane. Is there a reference to sole manipulator of the controls for recency on a MPA?

[C195]

Originally Posted by FlyingStone

Extension to 120 days can be a bit tricky, as not all TRI/TREs are able to do it.

There are basically 3 levels of TRI under EASA:

1. TRI(A)(Simulator Only)

2. TRI(A) (Restricted “No instruction for abnormal/emergency procedures to be undertaken in an aircraft")

3. TRI(A) (Unrestricted)

The TRI would need to hold number 2 or 3 in order to supervise the takeoffs and landings required.

[Denti]

Originally Posted by C195

There are basically 3 levels of TRI under EASA:

1. TRI(A)(Simulator Only)

Wouldn't that be a SFI ?

[FlightDetent]

No, just a TRI not authorized to perform real-life base trainings. Train the trainer for this is costly and many airlines and ATOs can do without using ZFTT.

SFI I thinks is for colleagues without medical or without valid TR (activation of which requires getting physically airborne as well).

[Denti]

Interesting, have never experienced that one. The qualification (train the trainer course) was the same, except the additional base training for the TRI of course, same for SFE and TRE. Well, you live and learn.

Found it in FCL, it is labelled as "restricted TRI", therefore of course the above quote is still correct, any unrestricted TRI should be able to extend the 90 days to 120 days.

[repulo]

The subject is a little more complicated since EU 2019/1747 has been published. Not all authorities have already adopted the new licensing rules. The TRI rating needs further specifications, e.g. LIFUS or Landing Training. If you use the old nomenclature a TRI (A) will be required.

Thats the relevant part from EU 2019/1747:FCL.910.TRI Restricted privileges
(1)
LIFUS, provided that the TRI training course has included the training specified in point FCL.930.TRI(a)(4)(i);

(2)

landing training, provided that the TRI training course has included the training specified in point FCL.930.TRI(a)(4)(ii); or

(3)

the training flight specified in point FCL.060(c)(2), provided that the TRI training course has included the training referred to in points (a)(1) or (a)(2).

(a)
General. If the TRI training is carried out in FSTDs only, the privileges of TRIs shall be restricted to training in FSTDs. This restriction shall however include the following privileges for conducting, in the aircraft:

And it is „on controls“

[FlyingStone]

Originally Posted by Journey Man

As monitoring pilot, you're part of the active crew for a multi pilot aeroplane. Is there a reference to sole manipulator of the controls for recency on a MPA?

There isn't, however your CAA will likely interpret this as a requirement to be PF for those 3 takeoffs and landings and in most cases this is what will be written in Operations Manual as well.

[Journey Man]

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?

[sonicbum]

Do You honestly think it makes sense to fly 3 takeoff / landings as PM ? Recency training is made because the regulator wants to ensure you remember how to takeoff and land an aircraft.

[McBruce]

The wording says “carried out” you don’t carry out the TO and LDG as PM.

[FlightDetent]

Come on. Pilot flying and pilot monitoring (a.k.a. PNF), anything unclear about these? The acting-observing pilot does not carry out the landing, no confusion here.

FAA: https://www.law.cornell.edu/cfr/text/14/121.439

[sonicbum]

Originally Posted by FlightDetent

No, just a TRI not authorized to perform real-life base trainings. Train the trainer for this is costly and many airlines and ATOs can do without using ZFTT.

SFI I thinks is for colleagues without medical or without valid TR (activation of which requires getting physically airborne as well).

Almost. The main difference between an SFI rating and a TRI (besides real aircraft training) is the fact that you don't need a minimum amount of sectors/hours flown on the aircraft to take the course. If tomorrow you get your type rating on, let's say, the A380 or anything you like, you can become an SFI with 0 hours on the actual aircraft but you will need a LOFT sim session IIRC before starting the course.

[FlightDetent]

Eye of the beholder, probably. I understand the difference better through the requirement that SFI does not need a valid licence nor recency in the real thing.

Originally Posted by An applicant for an SFI certificate shall:

An applicant for an SFI certificate shall:
(a) hold or have held a CPL, MPL or ATPL in the appropriate aircraft category;
(c) (2) completed, as a pilot or as an observer, within the 12 months preceding the application, at least:

(i) 3 route sectors on the flight deck of the applicable aircraft type; or

(ii) 2 line-orientated flight training-based simulator sessions conducted by qualified flight crew on the flight deck of the applicable type. These simulator sessions shall include 2 flights of at least 2 hours each between 2 different aerodromes, and the associated pre-flight planning and de-briefing;

Originally Posted by An applicant for a TRI certificate shall:

An applicant for a TRI certificate shall:
(a) hold a CPL, MPL or ATPL pilot licence on the applicable aircraft category;
(b) (2) have completed, within the 12 months preceding the date of application, 30 route sectors, including take-offs and landings, as PIC or co-pilot on the applicable aeroplane type, of which 15 sectors may be completed in an FFS representing that type;

[Meikleour]

Journey Man: If you take your reasoning to it's extreme then do you think it would make sense to be considered "current" by only doing PM sectors for ever!!?