There was an error in the old ANO (2009) which previously caused this as a hangover from the pre-JAR-FCL system. However, introduction of EASA meant that this no longer applied to EASA licences and, subsequently, the ANO has been rewritten and the error removed (ANO 2016).
Revalidation by experience can be conducted at any time in EASA licences and national licences once the revalidation criteria have been met for SEP, TMG (and SLMG) class ratings in accordance with FCL.740.A and ANO Schedule 8, Part 3, Chapter 1 and for all NPPL class ratings in accordance with ANO Schedule 8, Part 3, Chapter 2.
FCL.740.A(b) Revalidation of single-pilot single-engine class ratings.
(1) Single-enginepistonaeroplaneclassratingsandTMGratings.Forrevalidation of single-pilot single-engine piston aeroplane class ratings or TMG class ratings the applicant shall:
(i) within the 3 months preceding the expiry date of the rating, pass a proficiency check in the relevant class in accordance with Appendix 9 to this Part with an examiner; or
(ii) within the 12 months preceding the expiry date of the rating, complete 12 hours of flight time in the relevant class, including:
– 6 hours as PIC;
– 12 take-offs and 12 landings; and
– refresher training of at least 1 hour with a flight instructor (FI) or a class rating instructor (CRI). Applicants shall be exempted from this flight if they have passed a class or type rating proficiency check or skill test in any other class or type of aeroplane.*
So, under FCL.740.A (b)(ii), once the criteria have been met you can sign the licence. Clearly, you can only fulfil the revalidation by experience criteria once you're in the final twelve months of class rating validity. As an example, for an EASA licence holder with a SEP class rating which expires end of July 2017, if they have meet the experience requirements in FCL.740.A(b)(1) today, then the examiner (or instructor with FCL.945 privileges) may now sign the Certificate of Revalidation with a new expiry of July 31st 2019.
ANO Schedule 8, Part 3, Chapter 1(b) as regards revalidation—
(i) in relation to any aeroplane rating mentioned in the first two entries of column 1 of Table 1, provided that the rating or certificate is revalidated in accordance with paragraph FCL.740.A.(b)(1) of Part-FCL; or
(ii) in relation to any other aircraft, provided that the rating or certificate is revalidated within the period of three months preceding the end of the period in paragraph (a),
the rating or certificate is valid from the end of the period in paragraph (a) for the period specified in column 2;
For national licences, the ANO refers to the same text in FCL.740.A(b)(1) for class rating revalidation by experience for the SEP Land/Sea, TMG, and SLMG class ratings stated in the first two entries of column 1 of Table 1 so the same applies. There is a separate table for the NPPL in Chapter 2 which has similar wording allowing revalidation at any time the criteria are met.
Where the three month period from expiry would apply is for class rating revalidation by proficiency check where the applicant would wish to retain the expiry date plus the appropriate revalidation period, or for other class or type ratings where a proficiency check is required and the applicant wishes to retain the original expiry date.
A guide to 'class rating revalidation by experience' is available for instructors with FCL.945 privileges on the
On-Track Aviation website.
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