Sat Mar 30, 2019 5:17 pm
#1685614
How do you know - because you do not have to know - in advance/when you do it, whether a particular flight is part of your SEP/TMG Revalidation by Experience?
The reason this is potentially relevant is two-fold:
1. It is poorly drafted. (Instructors do not always have to sign the logbook. I know they typically do - partly no doubt to protect against this issue - but that's not the detail point. If EASA intend them to sign to cover every flight, then the rules should say so. They explicitly do not).
2. There is a particular risk here, that potentially costs pilots money, and I very nearly fell foul of it some years ago as I have said on here before, which is why I have a bee in my bonnet about it. On that occasion, I was coming to the end of my 2 year Revalidation period, had over 80 hours in the second year and had flown 5+ hours with an EASA instructor training on new aircraft types and some aerobatic refreshers. I knew I needed to have an hour with an instructor in my logbook, but that was fine - I had over 5 hours dual logged, didn't I?
But no: The Examiner declined to sign my Cert of Reval due to the lack of an instructor signature for any of those flights. Reminder: There is nothing in the regs that insists that they should have been signed at the time for any of those flights.
Worse for me was that, due to work, I had approached the Examiner within a couple of days of the Expiry date.
Worse than that was that the Instructors in question were not local, and one that normally was around was at this point out of the country. So no hope of a retrospective instructors signature.
Even worse than that, the (unnecessary) expense of another 1 hour with an instructor was unavailable due to an extended spell of unflyable weather, forecast to continue beyond the Expiry date.
So I was now facing the requirement for the (unnecessary) expense and hassle of a Revalidation by Test.
That is why I get annoyed by it. People ask "What's the problem?" Well, there's an example for you.
We say we want to get rid of red tape, gold-plating and locally made up rules yet this (minor but irritating and potentially expensive) example frequently gets shrugged off.
I had done nothing wrong, but potentially was facing a 3 figure sum and significant hassle (work meant I was not very flexible for training/test) for no reason.
My logbook PIC hours were accepted on the nod (always are); what's so special about my PUT hours? Even if I had a PUT signature nobody would know if my PIC entries were accurate. It is inconsistent logic.
The general point of this moan is:
If the Rules are the Rules (which they are), then apply them as written, write them unambiguously, and write them with the eye on safety not bureaucracy. That is what a Regulator is there to do, after all, isn't it?
FLYER Club Member
