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:

Or are we going to start counting flaps as flight controls now?

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:(3) as cruise relief co-pilot unless he/she:(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.

Fair call?

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.

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.

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.

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.

What a joke.

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😀

Why would you not want to?

I know I am rusty, and it isn’t 90 days for me!

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.

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...

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.

Those requirements are bare minimums. Your personal requirements can be stricter and it is our own responsibility to safeguard those personal requirements.

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.

@ 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.

But since, as You say, it is a bare minimum then how would you expect to fulfil this minimum as PM ?

... by performing your multi-crew duties as a type rated pilot, including handling of the (secondary-) flight controls as appropriate 👍

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.

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.