Menu Sign In Contact FAQ
Welcome to our forums

Class Rating v. Type Rating

There is a big guessing game going on at the moment, concerning the way FAA requirements map (or don't map) onto EASA requirements, specifically for two types of interest: the PA46 (piston and TP) and the TBM.

This is relevant to Europe-based operators of these types, if N-reg, because after April 2014 they will apparently (i.e. on the strictest interpretation of EASA FCL and its use of "operator residence" etc) require the full EASA papers to fly these.

Under FAA rules, AIUI, you need a Type Rating if any of the following are true

  • over 12500lb (5700kg)
  • turboJET
  • the manufacturer or the FAA require a TR
  • multi-pilot (?)

So you can fly a PA46 or PA46TP or a TBM on a PPL or PPL/IR, with some CFI signoffs and training as required by the insurer.

Under EASA rules, it's variable. The PA46 has historically required a TR, but the TBM did not; it needs a TBM-specific Class Rating. From my article which was carefully checked by Socata, under Pilot Qualifications, I have

In EASA-land, no Type Rating is required but there is a Class Rating called: "Aerospatiale S.E.T." (the name will soon be changed to "Aerospatiale TBM").
The Class rating is valid for 2 years and it is mandatory to pass a Class Rating proficiency check to renew the Class Rating every 2 years. This Class Rating can be done by a Class Rating Instructor (CRI); it is not mandatory to do it in a Flight Training Organisation (FTO) but in reality very few CRIs are qualified to do it. After the training, the Check Ride will be done by a Class Rating Examiner (CRE).
JAA prerequisites are: PPL, CPL or ATPL, and an "HPA" (High Performance Airplane") course certificate. The "HPA" course must be done in a Flight Training Organisation (FTO) and, depending on which EU country you do it in, involves a few days in a classroom followed by one written exam. There are two alternatives to the HPA: (1) Any ICAO ATPL; (2) JAR-FCL ATPL exam passes (14 written exams).

It is not clear what pilot papers will be required under EASA FCL to operate an N-reg TBM after April 2014 if the operator is EU based. It appears clear that an EASA PPL and an EASA medical will be needed. For obvious practical purposes an EASA IR will also be needed.

But EASA also requires an HPA for any of these, apparently.

One route to the EASA HPA appears to be an FAA ATP theory exam pass. To get this, you need

  • an FAA CPL
  • a visit to Farnborough, UK (Flight Safety) and sit the FAA ATP exam

which by implication needs at least an FAA PPL and an FAA Class 3 medical (Class 1 not needed because you won't be exercising the CPL privileges).

Can anyone illuminate this any further?

There is a number of people looking at this issue now, with obvious concern.

It would also affect me if I ever moved up to a Jetprop. Currently, I have bought myself the full "EASA insurance package" in the form of a JAA IR, on top of a renewed JAA PPL and Class 1 medical. But this is "obviously" good for sub-PA46 stuff only.

It's bizzare that EASA mandates all this crap, when you can fly a C421 on an ME PPL with nothing more than a differences training with an instructor, which has essentially the same capability as a Jetprop (and some would say more e.g. carries a lot more weight).

Shoreham EGKA, United Kingdom

It is a complete mess and hopefully there is some sort of cooperation agreement reached which will simplify. The fact that for the next two years I can technically do hundreds of hours in the PA-46 in European airspace up to FL250 but then will apparently not be safe unless I am supervised by EASA is absurd.

EGTK Oxford

Hmmm... EASA has not managed any kind of bilateral agreement on FCL (flight crew licensing) with the FAA, whatsoever, to date.

There has been a huge amount of talk, including EASA officials using the "FCL BASA" card to get the Transport Committee to back EASA FCL in the crucial vote, but I see absolutely zero evidence that anything is actually coming.

All we have is the EASA-FAA treaty which has a possible annex into which FCL stuff could in theory be added, but nothing has been, and nothing will be unless it goes through the full Euro political process, above and under the table.

IMHO, the best scenario is EASA climbing down on their apparent requirements.

Otherwise, I can see even more TP owners physically moving their residences to the Isle of Man...

Shoreham EGKA, United Kingdom

Otherwise, I can see even more TP owners physically moving their residences to the Isle of Man...

We have not moved to EASA yet, therefore it has not been necessary to fully familiarise myself with the new rules (for myself I don't care, ATPL remains ATPL, but as an instructor I should also know about the other licenses).

To me it looks like the EASA HPA endorsement is not much different from the JAA one. (see here: pages 248 and 249). This can be done in a theory course over two weekends plus a half day (maximum) for the exam. The exam is not taken by the authority, but by the training provider in-house. If you already have a basic license according JAA or EASA of course. No big deal!

EDDS - Stuttgart

The same anomaly exists for a King Air 90 or 200. In FAA land it is simply a multi engined aircraft with no type rating required. Goodness only knows what will happen in 2014 to those who want to fly these types. Presumably a new EASA type rating will be required?

On aircraft that have an equivalent type rating (EASA and FAA) there is a mechanism proposed to convert; if you have 500 hours on type it is an LPC (which can probably be done in a sim) with there even being an EASA type rating restricted to FAA registeed aircraft for thiose with less than 500 hours on type. The second sounds bizarre.

Darley Moor, Gamston (UK)

The King Air has the extra issue in that being a multi engine TP it is an EASA "complex" i.e. any of the following

  • over 18 seats
  • over 5700kg
  • ME TP or any turboJET
  • multi pilot

and as such will require an EASA maintenance signoff (release to service) in addition to the existing State of Registry release to service.

(Note that the above "complex" definition handily excludes the TBM and the PC12, while hitting the King Air. Of course that is entirely a coincidence )

I don't know what the latest on this "dual RTS" is. I last looked at it in 2010, in here. Go to "Update 8/2010" (at the end of the article).

My take on this issue is that it isn't going to work because an EASA company has no authority to sign a RTS on a non EASA reg aircraft. Any such signature will be a sham. That is not to say EASA cannot mandate it, of course.

In practice, most companies working on King Airs (etc) are big firms and are both EASA145 and FAA (either a 145 Repair Station or use an IA), so a KA owner will get charged a k or so for the extra bit of paper And if the company cannot generate the EASA papers in-house, they will do an "alliance" with one down the road, for a fee....

However the really tricky bit is if the non EASA reg (say N-reg) aircraft has mods (STC, or 337 field approval, or any Minor mods) done under the FAA regime, which any KA that actually flies will have plenty of... the EASA company will have exactly these options

  • ignore them, or
  • force them all to be ripped out, or
  • force them all to be recertified (EASA 21 company - €€€€)

The last 2 above almost amount to an eviction of all "complex" N-regs from EU soil (or, if you like, forcing their total (whole airframe and everything inside) re-certification under EASA) which I don't think EASA will be doing because of the huge stink it would create... so the EASA company doing the signoff will have to ignore any mods, which makes the signoff no more than a "parking tax" on the larger aircraft.

Shoreham EGKA, United Kingdom

Sorry to revive this trade, I have a question for What Next: Do you know a place in the UK where this HPA Theory course can be taken? Thanks.

7 Posts
Sign in to add your message

Back to Top