Currently a pilot who hasn’t done the three landings in the previous 90 days, must either fly alone or with an instructor, to complete the required 3 landings.
This is to (presumably) protect unsuspecting passengers.
However it should exclude another pilot who is licenced and current to fly the aircraft type/class in question, who has full access to the controls, from the definition of passenger for this rule.
If the pilot who needs to do the landings is ok to do it alone, then surely it makes sense to allow another pilot along to keep a watching eye. They certainly won’t be an “unsuspecting passenger”.
I agree with Dublin Pilot. As a Jodel DR1050 taildragger Group member, I have sat in the right hand seat on such illegal flights. It would be legal for the not-current pilot to get a check out on a Pa28/38, or to fly with the only available instructor who has a tailfragger qualification, but who last flew a taildragger 8 years ago – and that wasn’t a DR1050. (IF the instructor was willing to do so.)
PS I have been handed control, after several attempts to land, and have taken control as the aircraft went off the runway.
@GliderPilotGR
The olf mechanic can still do the maintenance, except complex maintenance on non ELA1 aircraft and on commercial operated aircraft. This was the case (at least in Germany) before EASA had anything to say. On the contrary, that old mechanic can do literally everything to ELA1 aircraft. He just can’t sign everything off, but as I said, at least in Germany that was always the case. Here, Part-M does bring easier regulations! Furthermore, with the rights of pilot/owner maintenance, there are much more rights to sign off work taken from certifying staff and given to the pilot / owner. I explained this in an other thread. You can read about complex Maintenance in Appendix VII to Part-M and pilot owner rights in Appendix VIII to part M. If you have written your maintenance program the right way, you can do everything on a glider yourself, except the tow hook that needs to be released by Part-66 CFS aber overhaul (every 2000 take offs). So our glider just sees a Part-66 CFI every 66 hours. We can legally sign off every other necessary maintenance item. This was not possible before Part-M.
Then, you must not confuse maintenance with airworthiness. Both have nothing to do with each other! You can get a new ARC if the engine of an aircraft is not installed and away for overhaul, as long as you have it documented. The CAMO just checks if everything was signed off by the right guy and the maintenance issues were complied with. In a controlled environment, this even works remote. It is just necessary to have a physical review every three years. And this review just looks if the aircraft fits to the right paperwork.
And you NEED the specific maintenance plans in the environment of European rules and national rules on top of it. Because it is a European thinking that an Italian engineer can work on a Belgium registered aircraft belonging to a Dutch person in England and have it signed off by a Danish CFS. How on earth should they know all small rules that apply, if it isn’t stated in the aircraft’s documents? The need to have it approved by the CAA is, indeed, unnecessary.
I agree on the demand of easy Part-66 CFS licenses, best based on a modular system. You need to give engineers some credit, but it is not necessary to do this without evidence of aptitude. Some people of my profession have never seen an aircraft from the inside. They should not be able to sign off work, they don’t understand. But if I understood right, a rework of Part-66 is in progress already.
What strikes me is that you needed a self declaration over Part-FCL knowledge to get an EASA-License, but apparently the knowledge of said part is scarce. EASA should offer free courses or webinars to explain the content (and the part of Part-M that affects him) to an aviator in an understandable way.
I would much rather have a system where no-one has a “license”, remaining under the supervision of competent and empowered people, and a series of progressive certificates and other goals and checks to meet.
You mean it being better to have flight privileges are bound to a gut feeling and personal sympathy to a mentor? I rather have a set of rules for flight licenses. I think the system of the LAPL is good. Just have a CFI training flight every two years, have if signed in your log book and you’re good to go. The system you advocate does not work in every private pilot environment and might empower the wrong people in a club.
Identify and eliminate unnecessary bureaucracy which adds nothing to safety. For example, Part-FCL rating revalidations should only require logbook endorsement, not additional forms and payments to the CAA / national authority. Is this national gold plating, or EASA, or both?
thanks for reminding me of many details. My own glider is kept on the D-reg to get the benefit of aligning with a large pilot and maintainer pool.
I have seen the introduction of part M practically ruin a gliding club in a small country with a rather indifferent CAA, that is why I am rather pissed off. It brought absolutely no benefit, and the local interpretation to get the maintenance plan approved was that no operator maintenance is allowed, and that while the school glider needs to be under CAMO, its sister ship, used for non-training club activities (which could include pleasure rides) need not …! So much for the “innocent public” and common sense. I also cannot accept that licensed mechanics need to have some-one else check that they are able to track ADs and SBs and make sure they are applied if need be. This worked fine in the past. Admittedly, we got a visit from the CAA, to perform what a CAMO does now, but it was a non-event.
Tried to get CAMO support from another country, ended in a Bureaucratic mess. The problem indeed was (partially) “national conditions”. Why would there be any ? we know how our flag looks like and they haven’t figured that you are not supposed to paint black on gelcoat.
Regarding licensing vs active supervision I have again seen extreme ends. Licensed people with little sense and ability slipping through the cracks (that no instructor or examiner will attempt to “chop”, as this is a small community) and on the other hand the excellent BGA mentored scheme where oversight is abundant and people get encouraged to do things. There is a cascade of respect and gratitude and mild peer pressure. I can see this work well in a volunteer scheme.
If our local CAA is able to provide examiners and inspectors to actually make sure the system runs as advertised, then fine, but few would applaud this idea.
In any case, they are probably not too keen to appear either. Well kept log-books ? absolutely mandatory !
But thanks for your constructive criticism. Any idea where I can get an example of a “well written” ie owner-maintenance friendly plan ?
I have seen the introduction of part M practically ruin a gliding club in a small country with a rather indifferent CAA, that is why I am rather pissed off.
I am pretty sure, this has nothing to do with part M itself, but with misunderstanding of the rules by either the Club or your CAA. I have not heared anything like that. I would really like to know details of this, if possible.
Again, CAMO has nothing to do with maintenance. CAMO stands for Continuous Airworthiness Monitoring Organisation. It does nothing but look in a more or less automated system, if all ADs or national regulations is complied with. In a controlled environment you just upload the flown hours and cycles of an aircraft and the system tells you if a 50h check or an AD or whatever comes up has to be done and in what time. This has nothing to do with maintenance! Accordingly, any CAMO is just fine. It might even be one in Germany.
If a CAMO is required for training, then this comes out of the instructing regulations or the flight school, not out of Part-M.
The problem indeed was (partially) “national conditions”. Why would there be any ?
Do you know, if you repaint your D-Reg aircraft, that there is a regulation about size and contrast of the registration in Germany? Or the size and form of the national flag? In Sweden it was (or is still?) required to have a list of military interception manoeuvres on board. I don’t know why there should be any, but there are.
RE licensing: The training flight is not a check flight, so there is not much an instructor can do actually. You are there to educate, not check. This would be the american system: No matter how much you fly, you have to pass a check ride. In Europe, this would be a disaster, because regulations dry out examiners at the moment – as they prevent new FIs in the aero clubs. And both – FEs and FIs – are desperately needed.
To be clear: Although I might sound like an EASA advocate, I can find enough points to criticize. but if one starts to blame things onto regulations that are not responsible for these things, you just show that one is uninformed and the criticism might be neglected in total. There are, sure, many different philosophies how some things in particular should be organized, but you will never find a system that suits every pilot the same (unless you prohibit flying, then everyone is equal again. But that can’t be a solution).
This would be the american system: No matter how much you fly, you have to pass a check ride.
The FAA BFR is a training session by an instructor who isn’t qualified to give you a check ride, nor is he required to evaluate your flying. He is just supposed to give you one hour of ground instruction and one hour of airborne instruction, with any focus that seems appropriate. Then he writes a short note in your personal logbook saying what you did, without reference to any performance standard. I get mine from one of my non-professional instructor buddies for you know how much payment.
The best solution for light aircraft maintenance is on-condition, plus annual inspection including AD review by an authorized mechanic. The Byzantine system of individually approved maintenance plan, 50 hr + annual + who knows what inspections, plus separate ARC to certify paperwork just seems nuts to me. Its a little airplane, not a nuclear reactor. If a dysfunctional regulatory hierarchy created the need for such a complex system, then I think any rational person would say that problem needs to be fixed first.
Then, you must not confuse maintenance with airworthiness. Both have nothing to do with each other!
And that is indeed part of the problem. These things used to be related, which made a lot of sense, safetywise. Nowadays, it’s almost two spearate disciplines leading to more effort, but arguably less well maintained aircraft physically.
Do you know, if you repaint your D-Reg aircraft, that there is a regulation about size and contrast of the registration in Germany? Or the size and form of the national flag? In Sweden it was (or is still?) required to have a list of military interception manoeuvres on board. I don’t know why there should be any, but there are.
By the way, many countries have this, as it is an ICAO standard. Germany just ignores it.
FCL: Limited validity of the pilot license. Make it lifetime licenses like FAA.
It is lifetime already! I have an EASA PPL and it is valid indefinitely.
