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#1765799
Regarding this table:
Image

Nick Wilcock today pointed out:
nickwilcock wrote:The table ... needs to be amended to include the recognition of flight time in Annex 1(e) and (g) aircraft introduced under AMC1 FCL.140.A of AMC&GM to Part FCL Issue 1 Amendment 9.

Specifically, this now includes acceptance of 3-axis 'microlight' aeroplane flight time but only for maintenance of SEP/TMG Class Ratings and equivalent LAPL privileges.

Which is good news. The AMC/GM at Amendment 9 was published on 18 March 2020.

However, I'd like to ask for a check of what I need precisely to do to ensure that the table update is executed correctly.

I find the AMC & GM is - even more than usual - verging on impenetrable:
AMC1 FCL.140.A; FCL.140.S; FCL.740.A(b)(1)(ii) Recency and revalidation requirements
All hours flown on aeroplanes or sailplanes that are subject to a decision as per Article 2(8) of the Basic Regulation or that are specified in Annex I to the Basic Regulation should count in full towards fulfilling the hourly requirements of points FCL.140.A, FCL.140.S, and FCL.740.A(b)(1)(ii) under the following conditions:

(a) the aircraft matches the definition and criteria of the respective Part-FCL aircraft category, class, and type ratings; and
(b) the aircraft that is used for training flights with an instructor is an Annex-I aircraft of type (a), (b), (c), or (d) that is subject to an authorisation specified in points ORA.ATO.135 or DTO.GEN.240.

Can readers aid in parsing that and advise what the correct presentation in an updated table version should be?

  1. For SEP/TMG: Is it sufficient to extend the green "Microlight hours count for experience" box to cover 'SEP/EASA PPL' AND amend Note 8 by adding "TMG" AND removing the red "Care is needed..." text AND now say "If a UK or EASA PPL is held..."?
  2. LAPL(A): Also, if I understand correctly, the "Microlight hours count for experience" box on the LAPL(A) line should now be green with a reference to Note 8 AND Delete reference to Note 4 in that box.
    Correct?
    I can't see this (i.e. 3 axis microlight hours acceptable for LAPL(A) Reval by Experience hours) referenced in the AMC & GM Amendment 9 - a pointer would be appreciated.
  3. Regarding TMG: Previously for TMG on a UK PPL microlight hours could not be used for Reval by Experience purposes.
    Are we saying that they now can be for an EASA PPL/TMG but still not for UK PPL/TMG?
    (The AMC/GM does not, of course, cover the latter (UK PPL/TMG) scenario.)
#1765970
You need to refer carefully to the EASA aircraft category definitions. Annex 1 (e) aircraft which are acceptable for SEP revalidation (or LAPL(A) SEP privilege maintenance) must be 'aeroplanes', ipso facto that only means 3-axis 'microlights'. Which was the lever we used to achieve Annex 1 (e) flight time recognition as, under ICAO, such aircraft are indeed aeroplanes.

A TMG is a breed of powered sailplane, thus unless the pilot flies an Annex 1(e) powered sailplane, he/she would also need to hold an SEP Class Rating (or LAPL(A) with SEP privileges) to count 'microlight' flight time in Annex 1(e) aeroplanes for revalidation. He/she could, of course, include Annex 1(e) powered sailplane flight time towards revalidation of a TMG Class Rating (or LAPL(A) with TMG privilege maintenance).

LAPL(A) privilege extension requirements are stated in FCL.140.A; these are referenced in the AMC/GM amendment. For SEP and TMG Class Ratings, the reference is FCL.740.A(b)(1)(ii).

In simple terms, to count microlight flight time, you need to hold a licence with privileges to fly microlights of the same category for which you hold valid privileges.
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#1771575
I cannot understand the wording in the document, hence starting this thread to ask for help.

I don't update the table until I can explain to myself what the regulations are, and as it stands I can't.
#1771577
@Dave W
Did you ever get sufficient clarity to update this table Dave? (Edit: Now answered by your posting above -our posts crossed!)

My comments would be, assuming confirmation of the proposed changes noted above:

1) Note 4 becomes redundant

2) Note 8 needs further rewording if LAPL references it - perhaps by removing the 'If a UK PPL is held' prefix (rather than amending it to include EASA) as it now applies to all licence types.
#1771585
Thanks, @GrahamB - that's essentially what I'd proposed in my OP (plus a bit).

I really wish I could understand the detail. At least it appears I am not alone by any means!

I think there is one comment on this:
DBurrough247 wrote:Does this mean you can now count microlight hours towards total flight time for the hour building requirements for a CPL provided you already hold an EASA PPL?

Holding a PPL should be irrlevant; if you hold the appropriate Ratings on a CPL then the same rules (whatever they actually are...) should apply.

(The table is written from the simplified perspective of PPL/LAPL/NPPL holders flying SE fixed wing since a comprehensive table covering every possible Rating/Licence combination would be just too unwieldy.)
#1771633
Dave W wrote:I find the AMC & GM is - even more than usual - verging on impenetrable:

I was reminded of this:


the original seems to be blocked on youtube, but if you want the original, it is here: https://www.dailymotion.com/video/x3v9z74
Dave W liked this