I have raised this with the CAA (as EASA associates) on a number of occasions, most recently at Sywell last year when I was directed by the CAA rep (can't remember his name but he does the presentations on the new ANO) to Jon Cooke who was going to raise it at a forthcoming visit to Cologne, since then nothing.
The issue sits with implementation of proposals within EASA NPA 2014-29 and not within the EASA Rule Making Task I am involved with. During the ANO Review, the CAA elected to implement crediting of three-axis experience towards class rating revalidation within ANO 2016 in advance of the amended EASA regulation following comments from myself and other stakeholders. However, the question has been asked of EASA and I understand the associated CRD is due at the end of March.
Really? Given that neither the NPPL nor UK PPL will be valid for flying anything except non-EASA aircraft after 7 Apr 2018, how do you draw that conclusion, Cookie?
The national licence itself would be valid for flying all aeroplanes within the SSEA class were it not for the overarching EASA regulation which prevents the pilot from exercising those PIC privileges in EASA aeroplanes beyond 08th April 2018. In any case, the 'one hour with an instructor' is conducted with the licence holder as PUT, and the instructor as PIC so it would only be the instructor who would require an EASA licence in that flight.
When close to the original expiry of this derogation in April 2015, this issue was discussed with the CAA. The problem was then shifted to April 2018 with extension of the existing derogation hence the same issue being raised again now. An EASA aeroplane 2,000kg and under in the SEP class actually falls within the licence holders' SSEA class rating, it's just that European regulation prevents that pilot from exercising PIC privileges!
And while we are on, it's about time that holders of full EASA PPLs were allowed to fly with reduced privileges using an LAPL medical, without the completely unnecessary additional expense of paying for a separate LAPL licence.
That's very much work in progress, and also within NPA 2014-29(A) the CRD for which is belatedly due end of March. LAA submitted a comment (#734) in response to this NPA back in May 2015 to that effect:
The LAA fully support use of the PPL(A) to provide LAPL(A) privileges. A common cause for pilots wishing to exercise LAPL privileges whilst holding a PPL might be a temporary downgrade of their medical certificate from Class 2 medical to LAPL medical. This might be due to a medical condition or through choice by wishing to take advantage of the extended medical validity of a LAPL medical.
This amendment does not address the above issue, where a PPL(A) holder would still have to hold a Class 2 medical in accordance with Part-MED even when exercising LAPL privileges under the proposed amendment to FCL.205.A. We have successfully used a system in the UK for a number of years through an exemption issued by the UK CAA (ORS4 No.995) where a UK national PPL holder, with valid SEP class rating, may exercise the privileges of a National PPL (NPPL) with a valid NPPL Medical Declaration.
In accordance with the above, where a PPL(A) holds a valid LAPL(A) medical, it is suggested the regulations are amended to reflect licence privileges appropriate to the LAPL medical held (FCL.105.A).
It is felt that the current wording of this FCL.205.A amendment may cause confusion about pilot privileges and recency, leading to pilots operating illegally due to not meet the relevant recency and medical criteria.