Polite discussion about EASA, the CAA, the ANO and the delights of aviation regulation.
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#1899021
I know....I know....this has been done to death a million (billion?) times....BUT I read something yesterday that I wasn't aware of - and now it's confused me, so could I ask a bunch of questions here to see if I've understood it correctly please?

Assuming a holder of a NPPL (A) with Microlight priveliges only.

Last night, I happened to find myself on Irv Lee's website, where he says:

"Since June 2021, UK Law was changed to allow NPPL-SSEAs and older (non FCL) PPLs with SEP ratings to fly what are now called Part 21 aircraft, providing they are G registered and flown in the UK. The sort of aircraft flown are limited to those that could be flown by a LAPL(A) pilot."

Please could someone clarify if my understanding below is correct, in that:

1) As an NPPL (A) holder with microlight privelidges, I can undertake my SSEA upgrade (as before)

2) Once I have completed that SSEA upgrade, I will be able to fly Part-21 type aircraft.

3) The Part 21-type aircraft I can fly includes the traditional Cessna 152/PA28s of the spamcan world [up to 2,000kg] registered with CoA and I am not restricted to Permit to Fly LAA-type aircraft?

Let me then build on this:

4) Given my underlying licence is NPPL(A), I can add a Night Rating to my licence (Night VFR only) but will only be able to exercise the priveliges of that rating when flying Part 21 aircraft, not Microlights, because the latter are Day VFR only.

5) Given I hold an NPPL(A), I cannot add an IR(R) rating because this cannot be added to an NPPL, even if SSEA upgrade allows me to fly the same aircraft types that others with an IR(R) will fly?

So, in summary: am I right in saying I can do my SSEA and fly Cessna spamcans, and add Night Rating but can't do IR(R)?

Going one final step further:

6) Is there anything stopping me from undertaking the IR(R) course anyway?

7) Assuming not, and that I pass, what would happen if I don't have a 'valid' licence to attach it to (because it can't be added to NPPL)?

8) Do I end up with anything tangible at the end - so that if the rules/regs change at some point in the future - it can be attached to the licence - or have I simply completed X hours of training that happens to follow the IR(R) syllabus?

I guess what I'm seeking confirmation of - assuming my understanding above isn't fatally flawed, which I expect it is - is that until there is some change in the law I won't be able to do an IR(R) rating, even though I might end up flying exactly the same aircraft as someone else who can obtain an IR(R) rating, just because I started with NPPL and they started with PPL?

Or that, I CAN undertake an IR(R) rating, but I won't have anything to show for it on paper and so - if in the future the powers that be change it to say that an IR(R) can be added to NPPL, I'm won't be able to apply to have the rating added to my licence retrospectively


I'm sure I've misinterpreted something somewhere; to be honest, I expect my misunderstanding is on "the sort of aircraft flown are limited to those that could be flown by a LAPL(A) pilot".
#1899041
The answer to your first set of questions is essentially yes. You are just bound by the normal SSEA limitations of 2000 kgs etc.

Re IMCR, it is a bit of dead end to do the course without a licence to attach it to. It really depends on where you want to end up.

NPPL > Part-FCL PPL seems to be a sticking point at the moment. You could try NPPL > ANO PPL, to which an IMCR could then be attached.

With the amendment last year (as mentioned by Irv's website) this could be a sort of back door to flying IFR in a Part-21 aircraft, but I don't know what requirements would apply. Someone with a bit of time could perhaps dig out a copy of LASORS or an early CAP804 edition and it might have some sort of answer as to what the pre-EASA NPPL > PPL requirements were.

Crucially though for an ANO ICAO PPL, the CAA are not bound by the Part-FCL training requirements, so some flexibility could be applied.
#1899044
It's a good job that all of this is so simple to understand! :)

Edward Bellamy wrote:NPPL > Part-FCL PPL seems to be a sticking point at the moment. You could try NPPL > ANO PPL, to which an IMCR could then be attached.

With the amendment last year (as mentioned by Irv's website) this could be a sort of back door to flying IFR in a Part-21 aircraft, but I don't know what requirements would apply.


Given that this is now way beyond my knowledge level, does your answer suggest that I might be able to upgrade to a PPL in a different member state and that this would be recognised in the UK?

I must admit I don't know what an ANO-PPL is...I just find it all so unfathomably confusing and - to be honest - completely unacceptable given that at the end of the day, this actually does distil down to safety, in the sense that certain licence-holders can't take an IR(R) rating which for some people might end up as the tool that one day saves their bacon.
#1899061
Given that this is now way beyond my knowledge level, does your answer suggest that I might be able to upgrade to a PPL in a different member state and that this would be recognised in the UK?


So I don't think an NPPL(A) with Microlight Class rating will take you very far in another Member State, it's not an ICAO licence. Apologies that wasn't the suggestion I was making.

I must admit I don't know what an ANO-PPL is...I just find it all so unfathomably confusing and - to be honest - completely unacceptable given that at the end of the day, this actually does distil down to safety, in the sense that certain licence-holders can't take an IR(R) rating which for some people might end up as the tool that one day saves their bacon.


So no one seems to be able to work out what to call a UK ICAO PPL issued under the Air Navigation Order, which is what I was trying to refer to.

I've started using the term 'ANO PPL' because it seems to be the most legally accurate way of putting it - if you say 'UK PPL', people don't know if you mean a 'UK Part-FCL' licence or one issued under the ANO. If you say 'national' PPL people think you mean the NPPL, so hence the term 'ANO PPL'. Confused.com of course, but while we still have the ANO sitting alongside the retained EU law there has to be a way of telling them apart.

The original idea behind the NPPL(A) / SSEA was for a more 'basic' licence than the PPL, if you start allowing people to add IMCR etc then why didn't they just do the PPL in the first place? That's before even getting into the whole medical / IFR debate.

Rightly or wrongly, if you want to do the IMCR / IRR then you need to find a way of getting hold of a PPL.
#1899069
VRB_20kt wrote:Whilst you may not get the rating, IMC experience is obviously a worthwhile thing if only to keep you alive should you accidentally get into it.


I plan to do it (regardless) but to be honest, I was more hopeful that there is something at the end that says I can apply to have the rating added to my licence after-the-event assuming the rules change at some point in the future (e.g. let's say it takes X hours to complete the course and I start March 1st; what is stopping me from doing an additional 1 hour in 5 years time and then claiming it took from March 1st 2022 until 2027 to complete the course?

I think you get what I mean, even if I'm not very good at explaining it! If the IR(R) was a badge you could keep in your cupboard, but it only becomes recognised when the underlying licence changes take effect (if they ever do change).
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1899073
The caa have consistently denied (to me) since 2012 that no path nppl to national ppl exists. In fact they were so keen to answer any question asked with "convert to an easa licence" to whatever was asked, even if it was about microlights, that this was given as the reason for not having a direct nppl to national ppl route any more
#1899077
Edward Bellamy wrote:NPPL > Part-FCL PPL seems to be a sticking point at the moment. You could try NPPL > ANO PPL, to which an IMCR could then be attached.
:
Crucially though for an ANO ICAO PPL, the CAA are not bound by the Part-FCL training requirements, so some flexibility could be applied.


I don't think the CAA have a mechanism for NPPL > ANO PPL, though having one could solve a lot of problems. I think maybe the sticking point here is that a UK ANO PPL can be converted a Part FCL PPL just by paperwork, and EASA have a route from a UK Part FCL PPL to an EASA Part FCL PPL, which would give a "back door" route to an EASA PPL which they won't (yet) accept, even though they have a route for other non-EASA PPLs (albeit with the 100 hour and currency requirements).

So to keep EASA happy we have to block off this route. Maybe.

I'm sure there will be more changes over the next few years.

Flyingearly, I'd suggest doing some instrument training which concentrates on keeping the muddy side down and being able to fly around confidently in cloud. Doing the instrument approach part of the course could then be followed up later if and when you get an ICAO compliant PPL.
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#1899083
So to keep EASA happy we have to block off this route. Maybe.


@Paul_Sengupta Paul I don't think so, particularly now that we are out of EASA.

I see no real reason why the NPPL > ANO PPL could not be reinstated. I suspect someone just needs to ask with enough formality / get it on the policy radar. The CAA will be consulting on FCL reform in the not too distant future, so perhaps worth putting that into the mix.
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1899088
@Edward Bellamy i know a lot of nppl (ssea) with many hours wanting ANY route to ANY icao licence that does not involve the whole course. The schools would have queues too once there was a defined skill path from lower rungs to higher rungs on the ladder.
The caa seems to have promised to 'simplify' licensing for the GA this year... Everyone hopes or perhaps even assumes that means 'make better', but they didn't say that. They could make it simpler and really bad for GA or simpler and really good for GA and associated businesses. I think the key test is whether nppl-ssea holders (obtained since 8/4/2018) remain in a dead end. And if it becomes no longer a dead end, how 'sympathetic' the route out is, and how to justify the ssea obtained 7/4/2018 is held by a much better safer pilot than the one with a rating issues a day later.
2nd on the proof of sympathy list is fixing a 100 hour and 'fully valid foreign paperwork' rule for foreign conversions. They have uk training, exams and full Skill Test to do what's the problem if they were good enough to get a foreign licence in under 100 hours, or if their rating expired?
Last edited by Irv Lee on Mon Feb 14, 2022 2:08 pm, edited 1 time in total.
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#1899100
Edward Bellamy wrote:@Paul_Sengupta Paul I don't think so, particularly now that we are out of EASA.


In which case there's no real reason why NPPL > FCL PPL couldn't be reinstated (maybe with a paperwork first stage of an LAPL, though I'm not sure there would be any point in the LAPL any more if we're not even going to try and get mutual recognition from EASA. I still think people are hoping for an EASA alignment at some stage).

The sticking point can't be non-ICAO instruction as there's a route from the non-ICAO LAPL to PPL. In theory this could mean that when doing an ab-initio ICAO PPL course you could do all the parts not covered in the LAPL > PPL upgrade with a non-ICAO (i.e. non CPL theory) instructor. CAA take note! As I see it the sticking point is just euro-regs, training outside the EASA-regulated PPL supply chain.
Last edited by Paul_Sengupta on Mon Feb 14, 2022 3:02 pm, edited 2 times in total.
#1899101
So, to summarise then: the situation hasn't changed only insofar as I can now at least take the SSEA upgrade and fly the spamcans; I can add a night rating, but can't add IR(R) rating, even though someone else flying the same aircraft after me can fly it IMC if qualified.

Is there any avenue through which to register my frustration with the CAA as to the cul de sac us NPPL/SSEAs have been in now for several years? It's been mentioned previously that people are looking into this - which people? Any means of emailing them? Not that it will achieve anything, but it will make me feel better and a single voice is better than no voice.
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1899110
@Paul_Sengupta the lapl is very useful for solving the issue.... as there is a defined path to (one) icao ppl. So the way to get joined up licensing very quickly is re instate the 17/9/2012-7/4/2018 bridge lapl from nppl. Goose, gander, etc.
Also why not let expired foreign ppls or not yet 100 hours convert to a lapl with medical, air law, Human perf, radio practical, 'sufficient training to pass lapl skill test', pass it. Then they have defined way to ppl even though not as generous as pre EASA. Not to mention TWO skills tests!
@flyingearly pointless raising via CAA, only way that might raise interest is to write to MP asking to take it to DfT, copy head of CAA whilst at it. MP will be pleased as no real work except passing it on, but gets tick for 'done something'.
But publish draft for terminology correction first before sending
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