Primarily for general aviation discussion, but other aviation topics are also welcome.
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By flybymike
#1673275
There has been some discussion in recent weeks on the Facebook GA threads whereby one particular examiner indicated a change in the revalidation requirements to indicate that the biennial one hour of instruction could now be split over any number of flights with any number of instructors rather than a maximum of three flights with the same instructor. Some people pointed out that this was at variance with information still being given on the CAA website which indicated that the original maximum of three flights with the same instructor still applied.
However I note from this;

http://publicapps.caa.co.uk/modalapplic ... c129761490

The following;

There has recently been a subtle change in the wording in FCL.740 A (b) (1) (ii) in the latest version of Part- FCL. Therefore, the change in the wording implies that the ‘refresher training’ can be conducted by several FI (A) or CRI(A)’s. However, the instructor who completes the ‘one hour’ can sign the revalidation certificate if that instructors licence is endorsed with FCL.945.


Which now seems to confirm the new arrangements.
#1673280
They might as well take the S out of EASA.
1) If it is the same instructor, there is really a background duty of care to discuss real safety issues spotted, now there are people who will take a dual circuit with a different instructor 4 times a year, 15 mins each including taxi and power checks, and until it is found at some enquiry (infringement, accident, airprox, etc) no-one will ever discover they can't do anything else but circuits.
2) With all the problems apparently found in preflight planning, notams, performance, all listed in the latest training com... it makes you wonder why there isn't an M against preflight planning in the EASA renewal/reval requirements
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#1673285
It's been that way for several years now.....

It's surprising how the revalidation requirements have been missed by quite so many FIs and FEs,

Whereas before JAR-FCL there were no dual flight checks required for PPL holders to revalidate.
#1673296
Well let's hope all 945-ers are well up with it all as I think the law says they SHALL sign the revalidation if they were the instructor who completed the hour. The problem is whether they were looking at CAA advice or EASA FCL when they all became fully conversant with what they must do.
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#1673301
Ive never known such a disruptive period in Licensing, every time I think I know a regulation it seems to change. It's no wonder two of my colleagues have given up and retired. When renewing my examiners rating I got two different requirements from two different schools, one of them, who was wrong, was pretty big and very well known. I saved around £500 going to someone who actually did know the regulations.
#1673307
@Harry Brown I only put a certain subset of changes on my one-sheet 'what has changed, what is coming' catch up and the number of times I have had to update it is amazing compared to pre 2012... and shrink the font size! When it came out just after JAR, we genuinely believed that when it settled down there was very little to come.... there was perhaps NPPL 2002, change to needing reval signature in final 3 months (ANO change) 2004, SSEA expiry dates (2007), but changes since 2012 seem mind-blowingly accelerating.
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#1673318
Thanks IL

On the subject of lists, a colleague of mine, who just retired from airline flying, just renewed his FI Certificate after 20 years away. He thought he might have got a list of the main changes that had occurred over that period at the Seminar but apparently there is nothing available. Sounds like a reasonably good idea, what do you think?
#1673319
Irv Lee wrote:Well let's hope all 945-ers are well up with it all as I think the law says they SHALL sign the revalidation if they were the instructor who completed the hour. The problem is whether they were looking at CAA advice or EASA FCL when they all became fully conversant with what they must do.


Good reason to refuse to complete the hour if it has been done with multiple others. I certainly shall.
#1673330
Harry Brown wrote:Thanks IL

On the subject of lists, a colleague of mine, who just retired from airline flying, just renewed his FI Certificate after 20 years away. He thought he might have got a list of the main changes that had occurred over that period at the Seminar but apparently there is nothing available. Sounds like a reasonably good idea, what do you think?

Well I ought to mercenary enough to say that if he's interested in teaching for hobby GA, my Masterclass would be a great idea for anyone like him (http://www.higherplane.co.uk/seminars.html - thanks, tenner in the post), or indeed, if he is nowhere near those currently mooted, then my checklist (http://www.higherplane.co.uk/checklist.html - thanks, two quid in the post), but I'm not all that mercenary so I'll try not to mention them and instead
(a) point him at http://www.higherplane.co.uk/bfr-ground.pdf for free to show to any qualified people he rental checks or trains,
and
(b) say that he'd do well to get in with an active club, should not be difficult as there are shortages, and no doubt a good CFI will steer him well, and all the aircraft will already have the right things in them like satellite PLBs whilst in the circuit.
I might be wrong but the most confusing issues tend to be post-licence, most problems before licence issue might be to do with under invested diamond crusted slow bureaucracy (I'm only assuming that, I don't do much pre-PPL, if it's the other way round God help training schools). I'd like to say nav lessons have changed, but there are still places that assume an overworked underskilled infrequent student who hasn't been pre-selected by Officer Selection interviews and being paid to fly every day can solve mental arithmetic geometrical problems when he finds he is exactly z miles off track after x miles on a y mile leg, and even though he will get GPS-ing as soon as he has a licence, the chances are he'll be left to discover GPS issues and fall into any elephant traps once the training has finished.
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By Irv Lee
#1673551
I don't think the legislation has changed more than once, a while back, from something very clear to something completely open to interpretation - but what has changed is suddenly someone wants to interpret it another way.
I think what FCL used to say was very clear: the training flight included in SEP revalidation had to be A training flight with AN instructor. Our CAA came along and said it could consist of up to 3 flights with the same instructor, Pretty clear and useful if you were for example including aero training of 30 minute sorties.
Sometime around a couple of years ago EASA changed it to "refresher training of at least 1 hour of total flight time with a flight instructor"... which was interpreted by CAA advice as 'a flight instructor' being one individual instructor doing all the training.
But now, I don't think that wording has changed, so what has changed is the CAA idea of what it means, and now they seem to be saying it means each individual training flight to be included in revalidation (and no limit to number of flights) needs an instructor (any instructor) on board to be a training flight to count.... well we knew that. EASA could easily have put 'instructed refresher training of at least one hour', or something similar, but it didn't.
So someone or something changed the CAA's mind on interpretation.... new guy in the interpretation slot? Auditor? AOPA pressure?
@nickwilcock What has AOPA's line been on whether this should be one instructor doing all the training or can be a mix of many? Has it been pushing for either the former or the latter?
#1673564
I can’t find the relevant FCL paragraph at the moment but my recollection from when I did see it, is that it was fairly unequivocal in its meaning and is not simply a reinterpretation of the original.
@Sir Morley Steven was involved in the FB discussion and maybe able to shed further light?
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By Irv Lee
#1673575
flybymike wrote:I can’t find the relevant FCL paragraph at the moment but my recollection from when I did see it, is that it was fairly unequivocal in its meaning and is not simply a reinterpretation of the original.

It took me 10 minutes to find it before I posted, and I've copied and pasted it. The change as I said was from one training flight of at least an hour with an instructor (try and misunderstand that if you can) to "refresher training of at least 1 hour of total flight time with a flight instructor"... and that, as Nick says, is not a recent change. The problem lies with "what does 'a' mean?" in this context - the same instructor, or an instructor each flight, but it could be the same one or different ones on flights you want to count to at least an hour. What I am saying changed is the CAA's interpretation of that from one side to the other this year.... so what caused that change?
By johnm
#1673652
refresher training of at least 1 hour of total flight time with a flight instructor


Why does common sense exit stage left when any regulation is interpreted by people in the U.K.?

The above provides for discretion and flexibility, both useful if we have a bit of common gump.

A single hour with a single instructor provides minimum compliance, an instructor who signs off after 4 sets of 15 mins with 4 different people probably shouldn’t hold a ticket.

Someone who has done 2 or 3 short sessions with other instructors might only need half an hour with the signatory for both practicalities and rules to be satisfied.

Why is it hard?
#1673667
Trouble with this ambiguity is that many pilots want the reval system to be as easy and cheap as they can make it, for their own convenience. Which is why they will interpret the rules to suit themselves.
At least one hour with one single instructor isn’t difficult to understand nor afford, it gives the instructor enough time to identify faults and either fix them or recommend further fixing.
What is wrong with that?
I’ve little time for all this rule bending ambiguity krap, and I’ll continue with the one hour/one instructor, preferably one that doesn’t take prisoners. At least I may feel a bit more confident afterwards.

“Rules are made for the obedience of fools etc” . No they’re not , they are “made by fools to be interpreted as required by other fools”.

My opinion only! Other opinions are also valid!
#1673672
Another conundrum is that perhaps the CAA were allowing several flights to add up to the checked (re-val.) hour to cater for, say, unexpected onset of poorer wx; or the a/c itself develops a fault etc. etc.

So our kindly CAA is perhaps trying to save us over lengthy costs/flights if the above or similar crops up.

After all for my first 30 yearsPPL(A) no-one dreamt of this imposition. In fact if (like the Self Cert. Medical) it is found not to be cost effective, they could consider simply reverting to pre year 2,000 rules ??
Last edited by mikehallam on Sat Feb 09, 2019 8:32 pm, edited 1 time in total.
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