nickwilcock wrote:1. The original requirement was for a training flight of at least 1 hr.
2. The CAA introduced an AltMoC to relax this to a total of 1 hr minimum, flown with the same FI in no more than 3 flights.
3. A couple of weeks later, after CAP804 had been edited to reflect the CAA AltMoC, Regulation (EU) 2015/445 relaxed the requirement yet further, to allow a total of 1 hr with no other stipulations. See FCL.740.A (b) (1) (ii):
.... at least 1 hour of total flight time with a flight instructor...
4. That trumps the CAA AltMoC as it is 'hard law' and not open to national interpretation.
5. The typical €urobabble leading to the erroneous implication of FCL.945 referring only to a single flight has already been pointed out to EASA. Whether they'll ever find someone who can actually write unambiguous English to correct matters remains to be seen. Don't hold your breath!
Exactly as you say, Nick. The problem first arose because the UK AltMoC (2012-0009: "...a maximum of 3 flights.") was immediately superseded by the reg being amended (in 2015) to "at least 1 hour of total flight time".
Unfortunately, the confusion continued (and continues?) because the 8 April 2015 consolidated version of 1178/2011 (Part-FCL), which was
supposed to be amended by 2015/445 to read "at least 1 hour of total flight time" in fact did
not contain this change - and was the copy in use by the chap who issued the AltMoC, so they didn't see any need to change it ... in fact they still believed it to be a relaxation of the original "training flight of at least 1 hour".
I have today confirmed with Licensing at the CAA (he said I could quote him, but I have withheld the name) that the AltMoC will be submitted for withdrawal and the mismatch with FCL.945 "Upon completion of
the training flight" will again be raised at the next meeting with EASA.
Until it is changed* to reflect FCL.740, CAA Licensing will not apply the erroneous implication of 1 flight in 945, nor will they require the instructor who signs (if authorised as per 945) to be the same one who conducted some or all of the "1 hour of total flight time".
That said, this is a statement from Licensing; what is circulated round the Instructors' and Examiners' groups may vary.
*something like "Upon completion of the
refresher training
required for..."