Polite discussion about EASA, the CAA, the ANO and the delights of aviation regulation.
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By agfoxx
FLYER Club Member  FLYER Club Member
#1743343
Asking all instructors and examiners on this page.

I have an NPPL Microlight and an NPPL SSEA.

I have a Class 2 Medical.

I have about 150 hours in total, of which 66, including 34 PIC, are in non-microlights, and the rest are in microlights.

I got my NPPL SSEA ***after*** the cut-off point when it could be converted to a LAPL as a paper exercise.

Things are changing, I'm probably moving elsewhere for a while. I will need a LAPL because the UK NPPL SSEA will be no use where I'm going.

I've emailed the CAA three times now about the transition process, cross-crediting requirements, and what I need to do. I haven't heard back.

I've also emailed their complaints team, and I've even called, - twice.

Not a squeak.

The last gentleman to whom I spoke said that it was - and I quote - "a very difficult technical question; and somebody would look into it and come back".

They didn't.

Their website says, "If you have a relevant current rating on another type of licence for aeroplanes and you are applying for a LAPL you will not have to do any additional training or skill tests".

Surely this can't be right/apply to my scenario? Sounds far too easy.

Can anybody please advise? Where do I go from here? How do I get a LAPL, given my experience etc.?

Has anybody dealt with a case similar to mine?

Thank you!
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1743365
I suspect that by "licence" their website means "easa licence" so for example a retiring commercial pilot with an sep or tmg in his/her atpl could swap it for a lapl-sep or lapl-tmg but a link to that quote would help.
I wonder if there is any reason other than "policy" that stops the CAA issuing full UK icao non Easa PPLs - if there is no legal reason, esp after next Friday, perhaps the APPG could persuade the DoT to persuade the CAA to have an nppl-ssea upgrade to a full icao UK PPL. It would solve a lot of issues and provide a way to an easa ppl or lapl on another easa state. An upgrade to ppl would be less than a current nppl-lapl if you got the ssea after the cut off bridge date.
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1743426
@Sir Morley Steven
agfoxx wrote:I got my NPPL SSEA ***after*** the cut-off point when it could be converted to a LAPL as a paper exercise.

I have read fcl.110 which covers this (conversion to lapl with previous p1 from another licence) and I genuinely cannot decide what it means.
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1743433
@Sir Morley Steven My mistake I see what you mean now.
Do you understand fcl.110? And if you do, how do you know you understand it in exactly the same way as the people processing licences ?
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By Sir Morley Steven
FLYER Club Member  FLYER Club Member
#1743435
As I understand it this isn't FCL110 but the CAA making stuff up. It clearly says on their website that you cannot convert if the "licence" was issued after the cutoff date. If his SSEA rating was issued after but his licence before the cutoff it doesn't apply.
FCL 110 is quite clear but nothing to do with the CAAs made up "rules".
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1743437
Well too many caa web pages are wrong/inaccurate/not up to date.
The paper conversion nppl-ssea to lapl was part of a bridging agreement that ended April 2018. I don't remember ever seeing it, we were just told fill in a form if you have an nppl-ssea and ask for a lapl. It worked... but we only found out by trying it. I have no idea what the bridging document actually said but that would be "it" rather than a caa web page.
I can see more than one interpretation of fcl.110, so you have an advantage on me, but how do you know your interpretation of fcl.110 is exactly the same as the CAA people who process licences (and not in excess of that) ?
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1743671
Irv Lee wrote:I can see more than one interpretation of fcl.110,

well, looking at an email copied into FB, I see the CAA appear to have an interpretation of (presumably) FCL.110 that isn't one of the ones that I came up with! Assuming you are the one with the email from them @agfoxx please can you post their answer here or at least confirm that it says (regarding nppl-ssea to LAPL(A)): "Credits to PIC time are only available if the pilot holds a Flight Crew Licence within the EASA system." - so if I am reading that correctly, they only allow PIC credits to get an EASA LAPL if a pilot already has an EASA licence and therefore doesn't need the credits....? I'm quite proud that wasn't one of my interpretations....
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By Kemble Pitts
#1743859
But, that implies that PUT time can be credited.

Or have they positively closed that off by some other proclamation, perhaps in the back of Railway Monthly, or on the notice board outside the newsagent?
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1743867
@Kemble Pitts well I think it is another example of over specifying at the cost of the poor student that I mentioned in another thread. Over specifying still gets the licence issued, it simply costs the student about £2k to £3k more than it should.
I have detailed before the advice to the forumite with a uk ppl, expired sep rating and PMD only wanting to fly microlights in future. Instead of "get sep prof check then "differences training" then fly microlights, then count subsequent microlight hours to reval uk sep every 2 years", the advice was "easa medical (needless £100 plus and weeks to get one), sep prof check (true), convert to easa ppl (needless £65 and ten weeks wait at the time), differences training (true), then sep prof check every 2 years to revalidate (needless £250 every two years?).
When challenged, no apology, just yes, the alternate answer (prof check differences training) was legal, but the caa answer also gave a legal way to fly microlights.
Difference? Hundreds of pounds, months of waiting, and a few hundred every two years.
By low&slow
#1743869
Article 4, para 2 of Part FCL covers conversions:
Non-JAR-compliant licences including any associated ratings, certificates, authorisations and/or qualifications issued or recognised by a Member State before the applicability of this Regulation shall be converted into Part-FCL licences by the Member State that issued the licence.
so both the licence and rating have to be gained before the cut-off date to be convertable.

FCL 110 was written for the benefit of PPL holders wanting to switch to LAPL & predates the new 'use an LAPL medical with your PPL rule'.

I don't see any alternative to the full LAPL(A) course for agfoxx.
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1743874
@low&slow when you say PPL, probably better to distinguish between Easa PPL or non-Easa ppl. Casual readers may infer easa ppl to lapl is more than a paper/money exercise
I think I have made it clear I simply cannot find a unique meaning to the crediting words within fcl.110 but others apparently can - whether the unique meaning they find is the same between them all and the caa, I don't know.
I do understand fcl.110 if no crediting is involved, which of course is "max cost, max time" for the student. However as there is a crediting para written into fcl.110, someone somewhere must have intended "max cost, max time" is not necessary for all pilots..
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By rkgpilot
#1745520
Has anybody got any more light to shine on this? As an ever-hopeful optimist, I'd love to believe Sir Morley’s interpretation, as that’s how I first interpreted it myself, but....

I’m a CRI with a candidate who holds NPPL/M obtained in 2016. He’d like me to get him ready for his GST to add SSEA but what he really wants is a LAPL/A as he’s very keen to fly EASA aircraft and especially to do so in Europe. Is there really no hope of common sense prevailing and allow him some sensible credit? FCL.110.A talks about up to 15 hours dual being allowed for applicants with prior experience as PIC, but even that’s not clear because as mentioned above, it ‘probably’ relates only to an EASA licence.
Last edited by rkgpilot on Sat Feb 08, 2020 10:51 pm, edited 1 time in total.
By Bathman
#1745526
Minimum training required for those post April 2018 who can't convert via a paperwork excercise.

15 hours dual training
6 hours supervised solo inc the solo cross country
You can credit the rest, except that the credit must not exceed the total PIC time that he has accrued.