[G-BLEW]

Yes, JAA, EASA, same old. Any European bureaucratic committee led organisation I would guess.

I don't think it is confined to Europe, although with so many EASA members and so many NAA cultures coming together to legislate it's not really surprising that we got what we did to start with.

The general improvement that we're seeing now is partly down to a new outlook from the likes of Patrick Ky, partly the fact that some of the old guard in the NAAs have moved on, and partly that everyone is getting better at the process.

Ian

[flybymike]

If you are referring to revalidating a SEP(Land) on an EASA PPL, once you have met all of the revalidation criteria you can get it revalidated as soon as convenient. Before the examiner writes anything on your licence, check what the new expiry date will be as it should be a full 2 years after the current expiry date (with the date being the last date of that month), and not all examiners are aware of this and might try to give you an expiry date that is to the end of the current month plus 2 years.

GAF4F makes an excellent point about examiners who are not aware that the expiry date for "early" revalidation should still run for two years from the end of the month of the current two year rating period and not from the date of signature. It's only relatively recently that everyone had to (stupidly) wait for the last three months of the current rating validity before asking for a signature.
And it's only recently that we trained the buggers not to knock a day off revalidations rather than initial issues as well.
Of course, examiners who don't understand the regs either, tells its own story.
(I'm surprised that Dave Philips thought that revalidations had been with us for more than thirty years)

[GolfHotel]

Yes, JAA, EASA, same old. Any European bureaucratic committee led organisation I would guess.

I don't think it is confined to Europe, although with so many EASA members and so many NAA cultures coming together to legislate it's not really surprising that we got what we did to start with.

The general improvement that we're seeing now is partly down to a new outlook from the likes of Patrick Ky, partly the fact that some of the old guard in the NAAs have moved on, and partly that everyone is getting better at the process.

Ian

One of the improvements I would like to see is the removal of the need for revalidation. It appears to be an unjustified set of requirements that have no effect on safety. It is very clear that even those who say it is simple do not quite understand, or at least don't quite define the process correctly.

But what is the point in it all if there is no safety case?

[nickwilcock]

If you are referring to revalidating a SEP(Land) on an EASA PPL, once you have met all of the revalidation criteria you can get it revalidated as soon as convenient.

Not so! An amendment (in bold below) has been proposed (almost 2 years ago now....) which states:

FCL.740 Validity and renewal of class and type ratings.

(a) The period of validity of class and type ratings shall be 1 year, except for single-pilot single-engine class ratings, for which the period of validity shall be 2 years, unless otherwise determined by the operational suitability data, established in accordance with Part-21. If a pilot chooses to fulfil the revalidation requirements earlier than prescribed in FCL.740.(A), FCL.740(H), FCL.740(PL) and FCL.740(As), the new validity period shall commence from the date of the proficiency check.

Incidentally, the reason for the 2 year revalidation period for the NPPL wasn't to align with the JAR-FCL Class Rating period, it was to enable pilots to spread their flying throughout the 2 year period as they saw fit. It was the CAA which later required that at least half had to be in the second year.

[Joe Dell]

What proficiency check? I re-validate by experience. I'm even more confused now.

[PeteM]

This sort of exchange pretty clearly illustrates why internet fora are not the best place to get a definitive answer on topics - particularly anything EASA!

Nick is correct there was a notice of proposed amendment in 2014 for changes to Part-FCL. However - there is no record I can find of Comment Response Documents (CRD) covering these changes. This is the EASA way of implementing these issues - so it might appear to have sunk without trace.

However in the EASA forward work plan there is a proposal to "Update of EASA FCL implementing rules", which was supposed to have a CRD in 2016 and then lead to changes in the regulation by the end of 2017.

So one might be reasonably confident that the comments above Nick's are currently correct and likely to remain so until at least the end of 2017.

Frankly the whole thing is a wonderful mess and simply trying to find the actual enforcing document is a major challenge. Interpreting it is then the second challenge. In my case I also have the complication of flying an Annex II aircraft (oh they are no longer that!) and also complying with ANO 2016 which is another load of old borax.

[muffin]

All this makes me very glad that I switched to an LAPL.

[Dave W]

Which, as Irv tells us, a surprisingly large number of holders don't understand the currecy requirements for either!

[bookworm]

The only proven piece of data shows that the more a pilot flies (within reason) the better they generally are.

Can you point to this "proven piece of data" please? That would at least give this an evidential basis.

[PeteM]

Take your pick, Wilbur Wright started it with 'the more you practice the better you will fly' - or words to that effect at the turn of the last century. Or you could start with the EASA 2016 Safety review, which largely makes the same point.

AOPA Nall report (published annually) has made similar points in the past. there is also a pretty theoretical study done by Embry riddle in 2015 which sort of makes the same point. Given the virtually all flight regulations across the world have currency requirements it would be difficult to argue that currency was not a basic requirement. The only point they vary on is what is the minimum.

[bookworm]

Take your pick, Wilbur Wright started it with 'the more you practice the better you will fly' - or words to that effect at the turn of the last century.

Although I'm a great fan of Wilbur Wright, he had very little experimental data with which to back that up. His key insight was to realise that not staying alive long enough to learn how to fly was what was causing his competitors to fail. That's a bit different from correlating currency to safety performance after the skills have been learnt.

Or you could start with the EASA 2016 Safety review, which largely makes the same point. AOPA Nall report (published annually) has made similar points in the past. there is also a pretty theoretical study done by Embry riddle in 2015 which sort of makes the same point.

Really? Page 52 of the EASA ASR lists "Non‑Commercial Operations Aeroplanes Main Domain Priorities - Top Safety Issues". Neither pilot experience nor recency gets a mention. Similarly I can find nothing in Nall 25. I'd be interested in the Embry Riddle study, do you have a reference?

Given the virtually all flight regulations across the world have currency requirements it would be difficult to argue that currency was not a basic requirement. The only point they vary on is what is the minimum.

Well there's a great deal of stuff in aviation regulation that sets requirements "because that's the way we've always done it". It doesn't actually hold up to any sort of scientific scrutiny. And although the FAA has a 90-day recency requirement for passenger carriage, it doesn't do any of this daft hour counting (12 hours in the last year, 5 hours in 13 month, 10 sectors or whatever). It just has a BFR requirement.

The bottom line is that I'm actually in strong agreement with you that there is little evidence that the FCL requirements for revalidation have a significant effect. Clearly, a large proportion of accidents are caused by human factors of some sort. How we mitigate the HF risk is not quite as obvious.

[flybymike]

If you are referring to revalidating a SEP(Land) on an EASA PPL, once you have met all of the revalidation criteria you can get it revalidated as soon as convenient.

Not so! An amendment (in bold below) has been proposed (almost 2 years ago now....) which states:

FCL.740 Validity and renewal of class and type ratings.

(a) The period of validity of class and type ratings shall be 1 year, except for single-pilot single-engine class ratings, for which the period of validity shall be 2 years, unless otherwise determined by the operational suitability data, established in accordance with Part-21. If a pilot chooses to fulfil the revalidation requirements earlier than prescribed in FCL.740.(A), FCL.740(H), FCL.740(PL) and FCL.740(As), the new validity period shall commence from the date of the proficiency check.

Incidentally, the reason for the 2 year revalidation period for the NPPL wasn't to align with the JAR-FCL Class Rating period, it was to enable pilots to spread their flying throughout the 2 year period as they saw fit. It was the CAA which later required that at least half had to be in the second year.

I submit that it is indeed so!

Your own bold refers to an LPC check not revalidations by experience!

As for whether revalidation instructor flights serve any safety purpose. The CAA safety review said not.

After the introduction of the Joint Aviation Requirement for Flight Crew Licensing (JAR-FCL) in 1999, the revalidation requirements for pilot licences experienced significant change. This study initially summarises these revalidation changes for various ratings. Two sets of data, before and after the introduction of JAR-FCL, are then examined, in order to establish whether its introduction has had any effect on the number of serious incidents and accidents in General Aviation for fixed wing aeroplanes and microlights with a MTOW < 5,700 kg, particularly focusing on training related issues (experience, recency and training).
The main finding of the study is that the changes to revalidation requirements for pilot licences, which JAR-FCL has implemented, have had no significant effect on the number of serious incidents and accidents involving general aviation aircraft in the UK.

I agree with the earlier suggestion that replacing the instructor flight with a seminar directed towards air law, matters of current interest, infringements e.g. would be far more beneficial. Seminars are already well established in the FI revalidation world , so it would not be breaking new ground.

[nickwilcock]

Those who choose to revalidate by proficiency check are currently only permitted to do so in the final 3 months of the rating validity period, thanks to the clumsy way EASA wrote the rules.

That is being addressed in the proposed amendment stated in NPA 2014-29. But the CRD for that still hasn't been released, let alone the draft opinion.

Another quirk - unlike a PPL holder, if a SEP Class Rated CPL holder waits until his/her medical certificate is only within LAPL medical validity, he/she may fly under 'LAPL privileges' embedded within the CPL. But what does that actually mean? Does he/she need to maintain a Class Rating, or fly within LAPL 'rolling validity'? If the latter, would he/she than have to complete a renewal proficiency check once the medical certificate is revalidated?

[flybymike]

Those who choose to revalidate by proficiency check are currently only permitted to do so in the final 3 months of the rating validity period, thanks to the clumsy way EASA wrote the rules.

That's only if they can't meet experience requirements and wish to retain the same expiry date. An early LPC may of course be done with an earlier expiry date, but I still submit that a revalidation by experience in the second year may still be effected as soon as the required hours and instructor flight have been flown, without waiting for the final three month period (which would be idiotic)

If correct, your second "quirk" is a superb example of the ludicrous stage things have reached, although I thought that an LAPL medical could only be used with an LAPL (or UK national) licence and not a full EASA licence.

[nickwilcock]

An early LPC may of course be done with an earlier expiry date

That's the whole problem - under current regulations that option is not available. Which is ridiculous, I agree. No doubt some revalidations have been done this way in all faith, but technically they wouldn't have been valid...

We discussed this at an EASA session earlier this Summer and were told that the 'solution' is the NPA proposal which I posted earlier.

When the arthritic glacier of EASA rulemaking gets round to it, that is....

The draft opinion for amending part-MED, released earlier this year, states that to exercise LAPL privileges, a pilot must hold at least a LAPL medical certificate. More senior medical certificates include lower medical certificate classes within those classes' expiry dates - thus a Class 1 included Class 2 and LAPL, but the expiry dates for each class are different. So a Class 1 might only have valid LAPL medical certificate privileges after the Class 1 and Class 2 dates have passed.

However, to exercise LAPL privileges, the licence itself must also include LAPL privileges under Part-FCL as well as the Part-MED certificate being valid . The only ones which do are the ATPL, CPL and LAPL - a PPL does not.