Primarily for general aviation discussion, but other aviation topics are also welcome.
#1835171
SteveX wrote:It's the PMD receipt that counts, that will say UK Part-FCL PPL (and the LAPL one also in your case) to fly non-Part 21 aircraft - given it looks like you only fly non-Part 21 aircraft.


No, the PMD receipt I have received says EU Part-FCL not UK Part-FCL. The receipt does not appear to be tailored to the licence(s) ticked in the application (mine is UK PPL aka poo brown, I have no other.)

@VFRBimbler Yes I have to agree there is a discrepancy with the CAA page
https://www.caa.co.uk/general-aviation/ ... te-pilots/
that says UK Part-FCL.

The application form (and your completed form is copied back to you as an attachment to the receipt) also says UK-Part-FCL. It's the receipt that is out of step. The receipt says publication date 30 Nov 2016.

Heigh-ho! Sorry if I have added to the confusion. I will retreat to my annexe 2, no wait annexe 1, oh no sorry non part 21 aircraft. Have I got that right yet? :?
#1835214
To put my own interest in this topic into context, I gained a JAA PPL in 2001. In 2013 I changed to a [EU] LAPL. 100% of my flying was day VFR in PA28s and C172s. 99% of my flying was in the UK with only very occasional trips to France and the CI.

My LAPL medical expired in December 2020. Prior to that, following Irv Lee’s advice posted somewhere on here in a different thread, I made a PMD in April 2020. I cannot now remember precisely why that was thought to be a good idea but, as I recall, at that time a PMD could be made for a LAPL even though the CAA’s portal had not been updated to reflect this. Furthermore, the sub 2,000 kg alleviation also applied and I ticked the box in the application to confirm I would only fly aircraft with a MTOM no greater than 2,000 kg.

I thought the combination of my licence and PMD meant I could have carried on flying EASA aircraft as they were called then, but I could be wrong, although as I haven’t flown since January 2020, this matters not.

I did not renew my LAPL medical and do not yet know when I will be able to, but am nevertheless trying very hard (and failing miserably) to understand what I can and cannot now do with my PMD made last year (which, according to the blurb received in response to my PMD, does not expire until I am aged 70) and licence combination (none of UK only; day VFR only; MTOM less than 2,000 kg; max. four seats / POB are an issue in terms of the flying I may do in the future). At the very least, as pointed out by others, the situation changed from 1 January so far as the withdrawal of the sub 2,000 kg alleviation is concerned (does this apply retrospectively to PMDs made prior to 1 January?).

Again it may just be me, but the CAA’s loose and/or inconsistent terminology and phraseology is not helping matters, which is simply unacceptable from the regulator and gives the impression either that they do not understand themselves or, if they do understand, they are unable to communicate effectively and unambiguously. Frankly, we deserve better.
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#1835227
I have now received a reply to my query to the CAA about my personal licence/PMD combination:


"Thank you for your email below.

Your email has been passed to the GA Unit to respond to. In terms of the "Existing PMDs remain valid for the type of licence(s) and aircraft weight limits specified at the time of a declaration.", this relates to any declaration that was correctly made before the changes were implemented and then subsequently changed back.

'Does this mean that a UK issued LAPL(A) holder is able to continue to fly G-registered non Part 21 aircraft in UK airspace on a online PMD signed made in 2020 (or earlier) till it's original expiry date?

In my case, the licence type ticked is EU Part-FCL LAPL to fly non-EASA aircraft, no greater than 2000kg MTOM. I only wish to continue (when Covid-19 restrictions are relaxed!) to fly non Part 21 aircraft (LAA permit aircraft in my case) atm and have no desire to fly Part 21 aircraft in the UK or any aircraft outside the UK.'


Unfortunately, holders of UK Part-FCL licences both LAPL(A/H) and PPL(A/H) were not previously and are currently not permitted to make a declaration to the 'at or less than 2000kg' criteria. All of the exemptions that were published allowing UK Part-FCL licence holders to declare only referred to the disqualifying medical conditions as per Art 163 of the ANO, they did not refer to the 'at or less than 2000kg' criteria.

The amendment at the beginning of the year which brought the PMD into the UK Aircrew Regulation, also did not refer to the 'at or less than 2000kg' criteria. This means yes the holder of a UK Part-FCL LAPL or PPL can make a declaration but this must be, at the moment, to the 'at or less than 5700kg' criteria. CAA is working with the DfT to establish the use of the 'at or less than 2000kg' criteria for all UK
licence holders."



So not good news for me (and I suspect some others) in the short term. However, the GA unit later added that "We hope to have the review complete by the time flight training returns."
#1835252
SteveX wrote:The body of the email mentions all the licenses (still referring to EU) but the attachment you got as a PDF, does that not show you ticked UK PPL (which of course is listed anyway in the body of the email)?


Yes it does show what I ticked but it does not customise the document in any other way.
#1840851
Apologies if this is somewhere in this thread, but I couldn't find it. Could someone point me to the official legal declaration that with a UK Part-FCL PPL with a LAPL medical you can fly Part-21 aircraft (with LAPL privileges)? My AME didn't seem convinced when I broached this with him a while back.
#1840859
Grey Beard wrote:Apologies if this is somewhere in this thread, but I couldn't find it. Could someone point me to the official legal declaration that with a UK Part-FCL PPL with a LAPL medical you can fly Part-21 aircraft (with LAPL privileges)? My AME didn't seem convinced when I broached this with him a while back.


AMEs are medical experts, not licensing ones.

I advise pilots to check with authoritative experts or official documents.

But you are right, you can validate a PPL with a LAPL Medical, but the flying is limited to LAPL privileges and you must meet the PPL Licence validity rules (not those of a LAPL)

I will dig out the authoritative document link.
#1840904
I don't doubt the expertise of eminent colleagues (especially in attempting to interpret what the CAA may be trying to say) but the CAA website (and related documents on this topic) appears to have been written by someone with neither authority nor expertise. As IFRBimbler wrote above: "...the CAA’s loose and/or inconsistent terminology and phraseology... is simply unacceptable from the regulator and gives the impression either that they do not understand themselves or, if they do understand, they are unable to communicate effectively and unambiguously. Frankly, we deserve better."