Polite discussion about EASA, the CAA, the ANO and the delights of aviation regulation.
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User avatar
By Halcyon
#1429841
Cookie, can I ask for your opinion on my position please?

I have a CAA PPL I have held since 1983. I have an EASA FCL PPL I have held since January 2013. My SEP, MEP and IRR(A) are all current and valid.

I cannot renew my EU class 2 medical at the moment but may be able to in the future. However, I can obtain an LAPL medical certificate. I do not want to downgrade my full PPL to a LAPL as it does not appear clear what the route back up would be.

Can I fly in the UK on my old CAA PPL with a LAPL medical certificate? Can I still use my MEP and IRR(A) on that combination of licence and medical? From reading all I have so far it appears I can?

I've just noticed that my class 2 medical states an expiry date for LAPL of 30/06/2016 so does that mean I can fly on that certificate that is not now valid as a class 2 but still is for LAPL?

This situation is bordering on ridiculous. I emailed the CAA about this in November but have had no reply.

Help please!

What is your opinion?

Halcyon.
User avatar
By nickwilcock
#1429893
Halcyon, when I broached a similar topic with the CAA, I was advised that, as you now hold a Part-FCL licence, your UK PPL may only be used to fly aeroplanes for which an EASA Type Rating is not available - something like a Jet Provost, for example.

Thus you would not be able to operate under ORS 4 No. 995 http://publicapps.caa.co.uk/docs/33/ORS4%20995.pdf as this is not available for use with Part-FCL licences.

Perhaps the simpler option would be to apply for an NPPL with SSEA Class Rating as your LAPL medical would support the licence.

However, if you do not hold a valid Class 2 medical certificate, you may neither fly MEP aeroplanes nor use your IR(R) privileges.
User avatar
By Cookie
FLYER Club Member  FLYER Club Member
#1429908
Halcyon,

I cannot renew my EU class 2 medical at the moment but may be able to in the future. However, I can obtain an LAPL medical certificate...I've just noticed that my class 2 medical states an expiry date for LAPL of 30/06/2016 so does that mean I can fly on that certificate that is not now valid as a class 2 but still is for LAPL?


Normally, a EASA Class Two medical can be used as if it were a LAPL Medical until the expiry date shown on the certificate. If you have a change in medical fitness which renders your EASA Class Two medical invalid, you should talk to your AME who will be able to advise: MED.A.020 requires that you talk to a AME in certain circumstances (it's on the back of your medical certificate, and also in CAP 804, Section 4, Part N, page 4).

Can I fly in the UK on my old CAA PPL with a LAPL medical certificate? Can I still use my MEP and IRR(A) on that combination of licence and medical?


An EASA PPL(A) can only be validated with a Class One or Class Two medical (MED.A.030 reproduced in CAP 804, Section 4, Part N, page 4), you may not exercise LAPL(A) privileges with a EASA PPL(A) when holding a LAPL(A) Medical - although there is a proposal being considered to allow this in the future (NPA 2014-29(A)). With a LAPL Medical, you will need either a LAPL(A), or UK PPL(A) with ORS 4 No.995, or a NPPL(A). I will talk below about a UK national PPL (UK PPL - the old brown ICAO-compliant licence), and a UK National PPL (NPPL) - similar names but note that they are two different licences with different privileges.

If you hold a valid UK national PPL (the old brown one), then it is still an ICAO-compliant licence which is valid for use in non-EASA aeroplanes for whatever privleges are entered including SEP, MEP, and IR providing you have valid ratings and a valid medical. This is normally validated with a EASA Class One or Class Two medical. EASA regulations restrict the use of a national licence (i.e. UK national PPL) to within the privileges of a LAPL(A) for non-commercial purposes in VMC in EASA aircraft - this derogation is available until 08th April 2018 (CAP 804, Section 2, Part C, page 1).

Under ORS 4 No.995, the UK CAA allow the holder of a valid UK national PPL to exercise licence privileges within those of a NPPL where a LAPL Medical or NPPL Medical Declaration are held until SEP class rating expiry, whereupon the correct rating for the medical held is required (SSEA class rating). This rating can be added to a UK national PPL(A), or you can obtain a UK NPPL(A) as a separate licence.

I would not currently recommend re-grading to a EASA LAPL(A), since there is no agreed route back to the EASA PPL(A) other than completing the training course at a Approved Training Organisation and PPL Skill Test in accordance with FCL.210.A(b).

So, you have three options if you hold a EASA LAPL(A) medical:

1) Re-grade to a LAPL(A) (<-- not recommended) - CAA Form SRG 1190;

2) Continue flying with a UK PPL and LAPL(A) medical within the privileges of a NPPL(A) until your SEP rating expires, in accordance with ORS 4 No.995 - then add a SSEA class rating;

3) Add a SSEA class rating on your UK national PPL or obtain a UK NPPL(A) with SSEA class rating.

For those who might be reading this and can only obtain a NPPL Medical Declaration, then option (2) and (3) are your only route.

All options will mean that you may no longer exercise the privileges of a MEP class rating or IR(R). :(

Note that under existing regulations, option (2) and (3) will mean that you can exercise privileges on EASA aircraft until 08th April 2018. I produced a summary of what licence/rating/medical combination is permissible for pilots in LAA Coaching Scheme Leaflet 3.12.

when I broached a similar topic with the CAA, I was advised that, as you now hold a Part-FCL licence, your UK PPL may only be used to fly aeroplanes for which an EASA Type Rating is not available


Nick, your CAA provided information only applys to EASA Type Ratings, and does not apply to EASA Class Ratings such as SEP and MEP which may be included in a UK national licence in accordance with ANO Schedule 7.

Cookie
Last edited by Cookie on Sun Jan 10, 2016 11:01 am, edited 4 times in total.
User avatar
By nickwilcock
#1429914
Cookie, the CAA advised me that, once a pilot holds a Part-FCL PPL, he/she cannot simply decided on a whim whether to use that or his/her legacy UK PPL to exercise SEP Class Rating privileges...

I have yet to see anything in print to back up that statement though.
User avatar
By Cookie
FLYER Club Member  FLYER Club Member
#1429919
the CAA advised me that, once a pilot holds a Part-FCL PPL, he/she cannot simply decided on a whim whether to use that or his/her legacy UK PPL to exercise SEP Class Rating privileges...


Don't know who you spoke to at the CAA, but that's clearly nonsense. If someone holds a valid UK licence/class rating/medical, then that individual is entitled to exercise those privileges in accordance with the ANO unless the CAA suspend or revoke that licence. The ANO is over-arched by EASA regulation which limits the use of national licences in EASA aircraft as described in my post above.

Cookie
User avatar
By Halcyon
#1429924
Cookie and Nick, thanks for your replies.

I do have the old brown UK PPL and my SEP Rating expires 30th April 2017.

QUOTE
2) Continue flying with a UK PPL and LAPL(A) medical within the privileges of a NPPL(A) until your SEP rating expires, in accordance with ORS 4 No.995 - then add a SSEA class rating;

So I am legal to fly my Piper Arrow under VFR but not to use my instrument qualification or multi engine rating. I can fly up until my SEP rating expires by which time it should be clear if I can regain my class 2 medical. I can then decide a new route if required. Have I understood that correctly?

My AME is fully aware of my circumstances by the way and I will have a separate LAPL medical to use performed in its own right by that AME.
User avatar
By Cookie
FLYER Club Member  FLYER Club Member
#1429927
2) Continue flying with a UK PPL and LAPL(A) medical within the privileges of a NPPL(A) until your SEP rating expires, in accordance with ORS 4 No.995 - then add a SSEA class rating;

So I am legal to fly my Piper Arrow under VFR but not to use my instrument qualification or multi engine rating. I can fly up until my SEP rating expires by which time it should be clear if I can regain my class 2 medical. I can then decide a new route if required. Have I understood that correctly?


Correct. When you've got your LAPL medical, you're good to go. :thumleft:

You would then be using your UK PPL/SEP Class Rating/LAPL Medical as per LAA Coaching Scheme Leaflet 3.12 above.

Cookie
User avatar
By Irv Lee
FLYER Club Member  FLYER Club Member
#1429931
nickwilcock wrote:Cookie, the CAA advised me that, once a pilot holds a Part-FCL PPL, he/she cannot simply decided on a whim whether to use that or his/her legacy UK PPL to exercise SEP Class Rating privileges...
I have yet to see anything in print to back up that statement though.

There are two reasons things don't get into print, in this case it is probably because it wouldn't stand up to challenge and therefore no one would sign it.
User avatar
By Cookie
FLYER Club Member  FLYER Club Member
#1429932
...and it's nonsense!

Cookie
User avatar
By Irv Lee
FLYER Club Member  FLYER Club Member
#1429934
Halcyon wrote:So I am legal to fly my Piper Arrow under VFR but not to use my instrument qualification or multi engine rating

Add:
A) In daytime.
B) In UK (or ask if they have any exemptions to cover it, if going somewhere like Ch Is.)
User avatar
By Irv Lee
FLYER Club Member  FLYER Club Member
#1429935
Cookie wrote:...and it's nonsense!

Cookie

And I thought the post would be "what's the second one?". I must change my ground bait, it must have expired. :wink:
User avatar
By Halcyon
#1429941
Irv - noted.

Thank you all for your help in progressing something that stopped me flying last summer, as I could get no clear answers from the official bodies.

I'll try now to concentrate on actual flying!

Halcyon
User avatar
By Cookie
FLYER Club Member  FLYER Club Member
#1429958
Any questions or concerns about exercising the privileges of your UK national PPL with LAPL Medical or NPPL Medical Declaration, feel free to drop me a PM or call.

ATB Cookie
User avatar
By Paul_Sengupta
FLYER Club Member  FLYER Club Member
#1429970
Cookie wrote:All options will mean that you may no longer exercise the privileges of a MEP class rating or IR(R). :(


As I understand it, you could still use your IMC rating on Annex II aircraft though?

What about Annex II twins?

Cookie wrote:...and it's nonsense!


I admire your restraint in using the N word rather than the B word as used by Blackadder in the comment on the start of WWI.
User avatar
By Irv Lee
FLYER Club Member  FLYER Club Member
#1429972
Paul_Sengupta wrote:
Cookie wrote:All options will mean that you may no longer exercise the privileges of a MEP class rating or IR(R). :(


As I understand it, you could still use your IMC rating on Annex II aircraft though?

Negative, not without at least a class two Easa medical
What about Annex II twins?.

No.. Not with ssea privileges.... Or to put it in Senguptish.... "Let them eat cake" ;-)