[Irv Lee]

I thought the first aviation law change in Jan 2021 was to let 5700kg pmd and FCL licences be used in part 21 aircraft with no stipulation on flight rules and therefore could be used by ir-r holders.
Then they removed the ability to declare the 2000kg pmd at all.
After an outcry, they brought a later exemption allowing 2000kg pmd use too and restored the ability to declare one alongside the 5700kg limit - but for such use of the lower mass limit, there were more restrictions, like vfr,
Now the caa webpage on pmd use says fcl licences are restricted to making the 2000kg level of pmd - ie can only HAVE the lower level
https://www.caa.co.uk/general-aviation/ ... te-pilots/

Licences issued in accordance with the retained UK Part-FCL as amended by Aviation Safety (EU Exit) Amendment (SI 2021/10):

UK Part-FCL PPL to fly UK (G) registered Part 21 and non-Part 21 aircraft.
UK Part-FCL LAPL to fly UK (G) registered Part 21 and non-Part 21 aircraft.
Valid for flying with the following operational conditions:

Holders of a UK Part-FCL PPL or LAPL licence can only make a pilot medical declaration to the at or less than 2000kg MTOM criteria as they are limited to the privileges of the LAPL.

Notice the "only" in that final paragraph of the quote

[MattL]

Well I suppose people can hold both a National and U.K. FCL licence so could make a 5700kg declaration for when using their National licence

Pilots I come across at the minute seem to be in one of two camps: those who still don’t really believe they can just do a PMD for what flying they do, and those that have made a PMD and basically just do whatever they want.

[johnm]

I really don't think the CAA is smart enough to sneak anything deliberately. They don't understand what they're trying to do or how do it.

[Irv Lee]

Needs time to trawl through - it sounds like they have only taken the exemption rather than using the January law amendment and the later exemption combined

[Edward Bellamy]

I don't think the website is quite right - if I recall correctly there is provision in the ANO, article 150 (7) that renders a Part-FCL licence that is valid, save for the lack of a medical certificate, to be a valid licence issued under the ANO, for the purposes of article 163 (PMD). Obviously that only applies in the case of non-Part-21 aircraft, since only the UK Aircrew Regulation can render valid a licence for a Part-21 aircraft.

When the amendment to the Aircrew Regulation went through re allowing PMD on Part-21 aircraft, within LAPL privileges, I suspect this was more because it could be done with a very simple amendment - to line it up perfectly the ANO would have been a lot more work.

@Irv Lee I may be missing your point, but I don't think anything has changed per se since the amendment earlier in the year. In my head I sometimes have to stop and disentangle the national licence on Part-21 aircraft amendment and the amendment that allows Part-FCL + PMD on Part-21 aircraft, they have similar, but slightly different limitations.

[Irv Lee]

@Edward Bellamy i am pointing out that the Jan'21 law change encouraged 5700kg PMD for FCL ppl in part21. Then,, an ORS4 later added the easier to get more restrictive but very useful 2000kg PMD for the same pilots. I am pointing out that the newly updated caa web page on PMD usage now says these pilots can ONLY use the restrictive 2000kg version. So either it is wrong or it really needs pushing to those who have been signing up for the 5700kg for 9 months and using it

[Edward Bellamy]

@Edward Bellamy i am pointing out that the Jan'21 law change encouraged 5700kg PMD for FCL ppl in part21. Then,, an ORS4 later added the easier to get more restrictive but very useful 2000kg PMD for the same pilots. I am pointing out that the newly updated caa web page on PMD usage now says these pilots can ONLY use the restrictive 2000kg version. So either it is wrong or it really needs pushing to those who have been signing up for the 5700kg for 9 months and using it

I don't think that was the case, the Jan amendment clearly links use of Part-FCL + PMD on Part-21 aircraft to LAPL privileges, which de facto is 2000 kgs. Where I think the website is technically wrong is saying Part-FCL + PMD with non-Part-21 is limited to 2000 kgs, I don't believe if is, so long as you comply with the more extensive medical conditions.

As complex and somewhat silly this all may be, I can't imagine that many people are looking to use PMD above 2,000 kgs?

[Irv Lee]

@Edward Bellamy yes, I suspect I'm not forming the point well, as it is from memory. I think the original January 2021 change was a problem because, due to references to specific ANO subarticles, an FCL pilot wanting to fly part21 aircraft had to make a 5700kg declaration. This is what led to the PMD system being changed so it ONLY could do 5700kg, and then led to the unrest when NPPL, Glider, etc etc found they couldn't make the 2000kg declaration, which then led to ors4 1486 for national licences and 1487 for fcl licences.
True, if they use the 1487 exemption, there are references to restrictions which are lapl-like, BUT, as far as i can remember, if they made a full fat 5700kg declaration, the January 2021 law did not have all the lapl-like restrictions when actually flying (unless of course you had a lapl). Maybe it did, but I thought it just added medical declaration into part FCL and part MED and screwed up by being too specific on the ANO reference within the PMD definition and hence insisted on all the medical disqualifiers of the 5700kg if an fcl pilot wanted to fly part21 on a PMD.
Now, the webpage (which I admit isn't law but it will be what people look at, if they look at anything), says they must ONLY use a 2000kg declaration for flying part 21 on an FCL licence. I cannot see how that came to be, other than a new twist to the law, especially as the Jan 2021 law change forced the exact opposite (before exemptions came along).

[flybymike]

My brain just melted….

[nickwilcock]

I have sought clarification....

[James Chan]

My brain just melted….

This may be a good starting point: https://www.caa.co.uk/General-aviation/ ... -aircraft/

[flybymike]

I would hate to see a bad starting point.

[tailbob]

I believe the reason for the two differing PMDs is that the 5700kg one permits a student pilot to be trained for the NPPL in a non Part 21 aircraft, due to the combined effect of ANO 140 and 163, using that PMD. However for Part 21 aircraft, student pilots must have a medical certificate, but licence holders who have previously held a certificate can make the reduced 2000kg PMD but are then limited to LAPL privileges.

[JAFO]

I believe the reason for the two differing PMDs is that the 5700kg one permits a student pilot to be trained for the NPPL in a non Part 21 aircraft

Really? I didn't know that.

[Irv Lee]

I believe the reason for the two differing PMDs is that the 5700kg one permits a student pilot to be trained for the NPPL in a non Part 21 aircraft, due to the combined effect of ANO 140 and 163, using that PMD. However for Part 21 aircraft, student pilots must have a medical certificate, but licence holders who have previously held a certificate can make the reduced 2000kg PMD but are then limited to LAPL privileges.

Any students with 5700kg PMDs probably got them when the caa IT boys and girls (and the others) took away the ability to have a 2000kg one for a while earlier this year as they hadn't really got a proper analysis done before changing the system.