[G-WALES]

Hi all,

Quick question regarding the 90 day rule for carrying pax.

I have an EASA (A) PPL, and today I completed a check flight at a new club. I am looking to fly with a friend who also holds a PPL and flies at the same club.


I've done a search on the CAA website and read the following page https://www.caa.co.uk/default.aspx?cati ... geid=16782

Can somebody clarify if my EASA PPL allows me to fly with my friend without having to go for a solo flight first and completing 2 touch and go's?

Many Thanks

Lloyd

[Irv Lee]

Surely you did some take offs and landings in the checkout?

[G-WALES]

Correct I completed 2 Touch and Go's and one land. However as this was with an instructor and my log book is filled in as PUT, does this not count as being PIC?

[Cookie]

If your passenger has a PPL, and you are acting as PIC, then they are a passenger for the purposes of the 90-day rule so you need to meet the recency requirements of FCL.060 before taking them. The fact that they hold a PPL is irrelevant (for your EASA licence).

If you're under training with an instructor, they are PIC and you are PUT. Those take-offs and landings flown count towards the requirements in FCL.060 which states:

FCL.060 Aeroplanes, helicopters, powered-lift, airships and sailplanes. A pilot shall not operate an aircraft in commercial air transport or carrying passengers:
...
(b) as PIC or co-pilot unless he/she has carried out, in the preceding 90 days, at least 3 take-offs, approaches and landings in an aircraft of the same type or class or an FFS representing that type or class. The 3 take-offs and landings shall be performed in either multi-pilot or single-pilot operations, depending on the privileges held by the pilot;
...

Cookie

[Irv Lee]

You have done three of each as the rule demands, you are fine. People often regain currency by going pu/t for three of each.

[T67M]

If you're under training with an instructor, they are PIC and you are PUT. Those take-offs and landings flown count towards the requirements in FCL.060 which states:

FCL.060 Aeroplanes, helicopters, powered-lift, airships and sailplanes. A pilot shall not operate an aircraft in commercial air transport or carrying passengers:
...
(b) as PIC or co-pilot unless he/she has carried out, in the preceding 90 days, at least 3 take-offs, approaches and landings in an aircraft of the same type or class or an FFS representing that type or class. The 3 take-offs and landings shall be performed in either multi-pilot or single-pilot operations, depending on the privileges held by the pilot;
...

I think this is the nub of the problem. The words in FCL.060 don't actually state what role the pilot has to fulfill during those three take-offs and landings. Do they have to be:

1. Handling Pilot
2. PIC
3. PUT
4. Passenger

I seem to recall the rules used to state "as sole manipulator of the controls" (or similar), but this has been removed from the current wording and has been replaced by "carried out". I believe the intent is that the pilot trying to regain their passenger currency should be handling pilot for the three take-offs/landings, either solo and logging as PIC, or dual with an instructor and logging as PUT, but this isn't what a strict reading of FCL.060 says, which could (at its most liberal) be read to allow the pilot to regain their passenger currency by sitting beside another PPL for three approaches without ever touching the controls themselves.

Confused? You should be!

[Irv Lee]

Recommendation for further discuss of that: http://www.pprune.org

[Dave W]

Must we? Can't we just get our pax to go there on our behalf?

[Irv Lee]

How many times have you been there in the past ninety days?

[Dave W]

Only touch and go - never a full stop. Officer.

[nickwilcock]

I believe the intent is that the pilot trying to regain their passenger currency should be handling pilot for the three take-offs/landings, either solo and logging as PIC, or dual with an instructor and logging as PUT, but this isn't what a strict reading of FCL.060 says, which could (at its most liberal) be read to allow the pilot to regain their passenger currency by sitting beside another PPL for three approaches without ever touching the controls themselves.

You can't 'carry out' a take-off and landing in an aeroplane unless you fly the aircraft or FFS. I flew twice last week - sitting in the back of an A319. Clearly I didn't 'carry out' a take-off or landing....

Merely being in the aeroplane is obviously not what the regulations require. How can anyone twist them to mean anything else?

[Irv Lee]

If you're under training with an instructor, they are PIC and you are PUT. Those take-offs and landings flown count towards the requirements in FCL.060 which states:

FCL.060 Aeroplanes, helicopters, powered-lift, airships and sailplanes. A pilot shall not operate an aircraft in commercial air transport or carrying passengers:
...
(b) as PIC or co-pilot unless he/she has carried out, in the preceding 90 days, at least 3 take-offs, approaches and landings in an aircraft of the same type or class or an FFS representing that type or class. The 3 take-offs and landings shall be performed in either multi-pilot or single-pilot operations, depending on the privileges held by the pilot;
...

Having read FCL.060 above and the proposed one possibly coming up, I can't see how an sep or tmg pilot who falls out of passenger currency gets it back as pu/t with an instructor alongside. If he/she goes and flies the three take offs and landings as pu/t, he/she isn't pic, and isn't co pilot either, so what has changed after the flight over before the flight, as far as FCL.060 is concerned? The pilot has certainly done three more take offs and landings, but FCL.060 doesn't seem to count them for passenger rule purposes as they were pu/t

[Balliol]

Not following you Irv. It says you can't operate as PIC or co pilot unless you have the landings, doesn't say anything about what capacity you were in when doing the three

[Irv Lee]

I see, I read it as in the same capacity for some reason. It doesn't say that

[Cookie]

I see, I read it as in the same capacity for some reason. It doesn't say that

That was the argument above - it doesn't say what capacity the pilot must act. However, FCL.060 does say that the pilot must have carried out in the preceding 90 days, at least 3 take-offs, approaches and landings in an aircraft of the same type or class or an FFS representing that type or class. The pilot clearly cannot have carried them out if they are a passenger.

Cookie