Polite discussion about EASA, the CAA, the ANO and the delights of aviation regulation.
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#1657478
Historically:
Pre 2000: JAA committee discusses idea that all ratings to need a test in final 3 months. Someone points out not enough examiners for this to work for tmg and sep. JAA agrees alternative "by experience" 12 hour reval rules for tmg/sep which were just previous German annual rules but only to be applied every second year.
1999, 2000 JAR clauses written into ANO as JAR was a treaty, not EU law..
2000-2004 reval "by experience" signature anytime when " by experience" flying completed in 2nd year.
2004. Caa changed ANO and (I suppose accidentally) put ALL revalidations into final 3 months despite JAR not needing this restriction for "by experience" , but ANO trumped JAR
Sept 2012: FCL (EU Law) came in with the JAA definition - so trumps ANO.
Summer 2016: requirement for final 3 months dropped from ANO after 4 years of it being overridden by eu law anyway.
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#1657484
allout wrote:The problem arose, instead, from the flying school's (& CAA's) imagination of what the system is.

Sadly I have seen a few cases over the past two years or so, far more serious to the pilot-wallet, that show an attitude of "as long as the pilot ends up in a legal state, it doesn't matter if our advice/decisions are the worst possible for the pilot concerned in terms of (pick from) convenience, cost, delay". This fits into that attitude.
Worst case yet was advice on switching to flying Microlight (only) on a pre 2000 ppl with Sep and self declare medical. Advice should be "differences training" then fly. Actual advice was to get an easa lapl medical, convert to lapl, then differences training.
Legally that works, (it might not due lapl validity rules), costs hundreds, time wise costs months, hours don't count to validity of lapl... CAA challenged, no apology or even embarrassment, just "ours was legal, your method would work too"
#1658161
Thanks for the responses to my comment. If a flying school and someone at the CAA are getting it wrong, it seems the CAA need to issue further clarification and explicitly state that for revalidation by experience the sign off can be anytime in the second year (once the criteria have been met) and not just in the last 3 months before expiry, without affecting the new expiry date.
#1658223
GAFlyer4Fun wrote:Thanks for the responses to my comment. If a flying school and someone at the CAA are getting it wrong, it seems the CAA need to issue further clarification and explicitly state that for revalidation by experience the sign off can be anytime in the second year (once the criteria have been met) and not just in the last 3 months before expiry, without affecting the new expiry date.


Quite so and, I am happy to report, done already!
- in the Aircrew Regulation (I posted the references a day or so ago)
AND
- in CAP804 (direct copy of the Aircrew Regulation)
AND
- in the CAA's Flight Examiner Handbook (Table 4C p33)
AND
- in Irv's guide

I am not convinced that yet another CAA notice will gain any better readership than stuff already out there.

Bathman is confident that if the system is changed yet again, clubs and examiners will start to read the advice they are given.
I wish I shared this confidence.
#1658250
@allout Table 4c in the examiners' handbook is wrong though in another respect in the bullet point above the one you mention. The handbook simply says "Flight time in microlights cannot be counted". Hours in 3-axis Microlights can count to the zwölf Stunden should the SEP rating be in a UK PPL.
#1666562
@Bathman Perhaps senior management get a graph report of how many PAGES have been processed at the sharp end every month, and over coffee say "all these pilots complaining about turn round time of around a quarter of a year or worse, don't they realise we are twice as productive as we were a year ago?"
#1666805
Hopefully, as the new Boss is a pilot herself, she will have experienced at first-hand the ineptitude, incompetence, lack of training and insight and cavalier attitude towards the captive milch-cow "customer-base" that seems so prevalent in the CAA. Perhaps a drastic simplifying of the licencing system would be a good place to start a 21st. Century "fitness for purpose" appraisal, simplification and gold-plate -stripping.

Without pilots, they have no purpose. nobody needs them for static , non-airworthy, pilotless aircraft!