1. If I am not mistaken It is the DTO that applies for the authorization, not the aircraft owner. Therefore it should be connected to that DTO. Another DTO would need to apply again even though it is the same aircraft. But I would have to look again at the regulation to verify that assumption.
2. I made a form based on the requirements in the EASA regulation and sent it together with copy of CofA, insurance and so on.
Two questions:
1) Does your formal letter also work in different EASA country? What do you think? Can your Super Cub used in Finnish DTO for example?
2) How was the reasoning and evaluation of the aircraft done against the basic requirements prior issuing the formal letter? Was it done by your CAA, by you or any third party expert?
EASA set up the regulation to allow time spent on Annexe 1 aircraft (ie experimental, homebuilts, ex military etc) to count towards the 12 hours and 12 take offs and landings needed, by experience, to revalidate SEP and TMG licences. It also allowed the hour with an instructor to be completed on such aircraft.
As an aside, it perhaps unwittingly and unknowingly to the FFPLUM and DGAC and against their will, the hours, take offs and landings in a ULM were also included in this. The one hour of experience with an instructor could of course not be included because of the different licencing. I haven’t got the exact EASA regulation in front of me for the moment but if anyone is interested I will try and dig it out.
Any examples of DTO.GEN.240 authorizations?
“I think perhaps the key word is pilot license.“
Indeed.
I think perhaps the key word is pilot license. A UL license isn’t a license in the same way a EASA PPL is a license. Besides, it would make no logical sense if EASA intended this to mean a UL license.
No one needs a license to fly an UL. The CAA may however require a “proof of competence” to allow you to fly in their airspace.
But this is for obtaining the PPL in the first place. It’s something else to show currency when renewing the PPL.
huv wrote:
In Denmark PIC hours on a 3-axis microlight count towards a LAPL(A), but not a PPL(A). For LAPL FCL.110.A(c) says “Crediting. Applicants with prior experience as PIC may be credited…” while for PPL FCL.210.A(d) says “Crediting. Applicants holding a pilot licence for another category of aircraft”. Apparently the different wording makes the difference.
Looks like some instructors trying desperately to not become redundant. Aircraft is defined above.
The definition of Aeroplane:
‘Aeroplane’ means an engine-driven fixed-wing aircraft heavier than air that is
supported in flight by the dynamic reaction of the air against its wings.
PIC:
‘Pilot-in-command’ means the pilot designated as being in command and charged
with the safe conduct of the flight. For the purpose of commercial air transport
operations, the ‘pilot-in-command’ shall be termed the ‘commander’.
“Category of aircraft” means a categorisation of aircraft according to specified basic characteristics,
for example aeroplane, powered-lift, helicopter, airship, sailplane, free balloon
“Class of aeroplane” means a categorisation of single-pilot aeroplanes not requiring a type rating.
IMO it is fairly obvious what the intention of the regulations are, but I’m no lawyer so 
The definition of aircraft regarding to FCL.010 is:
“Aircraft” means any machine which can derive support in the atmosphere from the reactions
of the air other than the reactions of the air against the earth’s surface.
So it makes no sense to make a difference between crediting for LAPL or PPL.
In Denmark PIC hours on a 3-axis microlight count towards a LAPL(A), but not a PPL(A). For LAPL FCL.110.A(c) says “Crediting. Applicants with prior experience as PIC may be credited…” while for PPL FCL.210.A(d) says “Crediting. Applicants holding a pilot licence for another category of aircraft”. Apparently the different wording makes the difference.
