[Cookie]

Any EASA examiner from any country can sign off an EASA PPL? (Be it UK issued or wherever)

No, they can't - unless they have a specific permission from the UK CAA. See the table at para 4.1 on page 99 of the EASA Examiner Differences Document, which the non-UK examiner should consult before conducting any test, check, or assessment of competence, or before endorsing any licence.

Likewise, for holders of FCL.945 privileges, it is only a UK licence holder who can sign off another UK licence holder unless they have obtained a specific permission from the UK CAA. See para 2.4 of Information Notice 2015/034.

Cookie

[skydriller]

Is this a UK derogation?

I really thought the whole point of EASA was to streamline everything such that a european PPL was a Europe wide PPL? Yet then that was supposed to be the point of JAA/JAR before it and it didnt happen quite like that, so I suppose I shouldnt be surprised.....

Reading those documents, it appears you (technically the examiner you want to sign stuff) just ask the CAA and send off all the relavent forms and photocopies of everything including the examiners documents - which is exactly what I used to do under JAR, and it used to work about 70% of the time, and usually I would be flying around blissfully unaware for a few months until they deigned to inform me something was amiss and I needed to do something...If I heard nothing then I flew for another 2 years...

(been in France since JAR...we really need a gallic shrug smiley!!)

Regards, SD..

[Cookie]

No, it's not a derogation. It is in the EASA 'Authority Requirements for Aircrew' and applies to all member states - ARA.FCL.200(c). If you have a look at the EASA document I have linked above it explains that.

Cookie

[skydriller]

Sorry you are right, read wrong link first and miss-understood, read again & went back and edited post.

[T67M]

Don't forget that according to all but one of the examiners I can find, your SEP rating can only be revalidated by experience during the last three months of validity. Shame that neither Irv Lee nor I can find that rule anywhere in the plethora of regulations we've scoured...

[Cookie]

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.

Cookie

[T67M]

Thanks Cookie - that's how I read the rules too. Sadly none of the examiners I can easily get to subscribe to this interpretation, so I'm now waiting 7 months before getting my SEP rating signed, or possibly heading to another airfield to find another examiner.

[Irv Lee]

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).

Wot I sed to T67M... except.... I think the error was about 5 years earlier.... or it might have been even earlier (eg: 2000) but no-one read it properly until about 2004. I recall we signed reval by experience at any time in the final year after JAR first came in, as it was remarkable (as in remark-able) that a pilot might not fly for thirty odd months but still be legal (eg: get signed up 2 months into the final year for an extension of two years beyond the end).
Then either someone read the ANO in 2004-ish, or the mistake was made around then, and 'final 3 months' was enforced. But it went away when EASA FCL came in and the ANO was re-written.
However, as I said to T67M, these guys who won't sign his reval must have been on an examiner seminar by now.... so what else did they sleep through?
Also, regarding non-UK examiners NOT being able to sign reval by experience for UK issued licences, but being able to do a proficiency check (by simply applying to do so), I have never understood the logic.... oh just a minute, I've answered my own point. - ok, what I was going to say is that it is fairly black and white if someone has done all that is required for reval by experience in most cases (not always...) to anyone in any country, so the standards applied across EASA land for getting reval by experience are pretty 'even'.... but non UK examiners can't do it. Now take a proficiency check.... do we really think examiner standards are 'even' across EASA land? I think not, yet a UK pilot can get a proficiency check anywhere, with the correct process followed.
ps added: The ANO was changed in 2002 to bring in the NPPL (when they screwed up reval for SSEA to 'rolling validity' by admitted copy/paste mistake, which lasted at five years, then came back to haunt us as EU law) so I suspect my 2004 guess above was likely to be 2002.

[Cookie]

What I should have said, I suppose, was that the error still existed in ANO 2009. Deliberately tried to keep the history short

yet a UK pilot can get a proficiency check anywhere, with the correct process followed.

However, even where the non-UK examiner conducted the proficiency check they may not endorse the licence of a UK licence holder without specific permission from the UK CAA. See para 6.2 of IN 2016/003.

T67M, if your examiner is unsure about the current regulations, feel free to ask them to get in touch.

ATB Cookie

[T67M]

Thanks Cookie - but it's not one examiner, it's all of the ones that I can get to at my home airfield, so I wonder how many more around the country are similarly confused? My real concern (as Irv stated) is that if this was covered in the examiners' seminar, what else has been missed? From the other side, why are the rules allowed to get so complicated that confusion like this exists in what should be almost trivially simple?

[QSD]

T67 M, why don't you just fly an hour with me, then I can revalidate you.

[T67M]

I may well do just that, QSD, but that's not really the point!

[Irv Lee]

or you could confidentially supply to Cookie the names of the examiners who have refused to revalidate you before the final 3 months, and if any were supposed to be listening to "his" seminar, maybe he could provide them with some 'after sales service'.... I'm sure they would be grateful

[matt_cambs]

Hi all,

New to the forum and a recently made redundant airline pilot for an Irish airline. In a nutshell it was my first job and did it for 8 months before redundancy. I did my training integrated and the SEP flying was in the states so I have no SEP (land) class rating on my Irish licence.

I would like to fly SEP in the UK (ideally solo) under the privileges of my fATPL just to keep flying but I don't have the benefit of work Line Proficiency Checks to assist as I am no longer with my airline for obvious reasons.

I have trawled the internet and asked others (including 2 local flying schools) but there doesn't seem to be a clear answer.

I obtained around 150 hours in an Archer and last flew in January 2019. The IAA licencing department referred me to ‘subpart C of Annex III to EU regulation 1178/2011’ (Easy Access for Aircrew regulations on the EASA website) – which I have since done and it states: -

1. A valid class or type rating contained in a licence issued by a third country may be inserted in a Part-FCL licence provided that the applicant:
(a) complies with the experience requirements and the prerequisites for the issue of the applicable type or class rating in accordance with Part-FCL;
(b) passes the relevant skill test for the issue of the applicable type or class rating in accordance with Part-FCL;
(c) is in current flying practice;
(d) has no less than:
(i) for aeroplane class ratings, 100 hours of flight experience as a pilot in that class;
(ii) for aeroplane type ratings, 500 hours of flight experience as a pilot in that type;
(iii) for single-engine helicopters with a maximum certificated take-off mass of up to 3 175 kg, 100 hours of flight experience as a pilot in that type;
(iv) for all other helicopters, 350 hours of flight experience as a pilot on that type.


From this I understand I need to pass a PPL skill test or equivalent check, and I was fine with this until I carried on researching and saw other propaganda such as 12 hours SEP flying, skill test vs proficiency check, Archer not being on the approved aircraft specification for the class rating, etc etc.

Is anyone able to shed some light on this before I spend money on the wrong thing? Currently it seems to be a minefield!

Any information appreciated!

Cheers,

Matt

[AlanC]

It's a nice simple one, but oddly one that a lot of flying clubs/examiners don't see. You hold a valid licence, but without a SEP(Land) Class Rating. Therefore:
1) Training as required to prep for an initial SEP CR test, at an ATO or DTO. Not a PPL course, since you hold a licence, merely training for the CR.
2) Said ATO/DTO recommends you for the Class Rating test, with a suitable Examiner. As you are on a IAA licence a non-IAA Examiner will have to follow the IAA designation process - their problem not yours, it's a simple online system. Any qualified Examiner should be aware of the EASA Examiner Differences Document by now, giving links to each Member State's procedures.
3) SEP LST complete, paperwork and fee to the IAA. Then wait for licence issue. All done.

In terms of training requirements: up to the organisation, it can vary - flying is flying, but obviously each area has its own challenges. Given that an initial MEP class rating requires a minimum of 6 hours training, it's concerning to hear of SEP ratings taking 10+ hours - in some cases an issue with the individual's training background, in others the ATO/DTO not fully understanding what they're training for. Whereabouts are you?