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Does PPL or CPL include LAPL privileges?

From here

huv, the draft rules resulting from opinion 05/2017 will fix that.

It’s also worth noting a PPL confers LAPL privileges which may be advantageous when FCL.140.A is complied with even though the SEP rating itself has expired.

London

@qalupalik – really? I was pretty certain a PPL does not contain a LAPL and it would be illegal to fly once your SEP has expired. Even if using a PPL with a CAA medical declaration the SEP rating must be maintained

Now retired from forums best wishes

You’re right although a UK Part-FCL PPL is deemed to confer LAPL privileges. The Part-FCL CPL does expressly include LAPL privileges and the anomaly will be fixed by the draft rules resulting from opinion 05/2017. See the thread Does PPL or CPL include LAPL privileges?

The issue was raised by the Finnish Transport Safety Agency in comment 754 of CRD 2014-29.

Comment

According to FCL.205.A a PPL(A) licence holder can exercise LAPL(A) privileges as long as
he/she fulfils the FCL.140.A requirements.
Finland is concerned that this could create confusion as the PPL(A) pilot would be able to fly
SEP aeroplane also after his/her SEP class rating endorsed in the PPL(A) licence has expired,
as long as he/she has the experience stated in the FCL.140.A.
This would also be in contradiction with FCL.700(a) which requires the PPL holder to hold a
valid class or type rating unless undergoing tests/checks/training

Response

Not accepted
Thank you for your comment. The reason behind this amendment was made is that any
additional burden for competent authorities or pilots should be avoided. Furthermore it was
considered that what works for the CPL should also be possible for PPL holders. It is clear
that a pilot who holds a PPL and uses it as LAPL has to comply with all requirements for the
LAPL as well and there it is not important if the licence was issued physically or not.

London

Thanks again Q.
I completely follow the Finnish concern that the FCL.205 amendment could be read as a permission to continue flying on LAPL privileges after one’s SEP rating has expired, and I do not quite follow the rejection of the comment by EASA.
In fact the EASA answer looks more like a confirmation that you actually can do that; i.e. continue flying on LAPL privileges after your SEP has expired, if you fulfil FCL.140.A (LAPL currency requirements).
So, once more, which one is it?

huv
EKRK, Denmark

huv wrote:

I completely follow the Finnish concern that the FCL.205 amendment could be read as a permission to continue flying on LAPL privileges after one’s SEP rating has expired, and I do not quite follow the rejection of the comment by EASA.

The Finns are correct, but I don’t see the problem with that? The idea is that a PPL holder who don’t satisfy PPL requirements but do satisfy LAPL requirements should be able to fly as if (s)he holds a LAPL. You don’t need a SEP rating on a LAPL(A). If the SEP rating has expired, then the PPL holder can continue to fly as if (s)he had a LAPL, following the LAPL currency requirements.

ESKC (Uppsala/Sundbro), Sweden

A_A, your comment makes completely sense, but it is not what Q is saying. Q agrees with Balliol who wrote:

I was pretty certain a PPL does not contain a LAPL and it would be illegal to fly once your SEP has expired. Even if using a PPL with a CAA medical declaration the SEP rating must be maintained
Last Edited by huv at 01 Jun 14:09
huv
EKRK, Denmark

Unlike the CPL the PPL does not strictly include a LAPL owing to an oversight in the implementing rules. The fix should be in the next major revision to Part-FCL. See draft rules annexed to opinion 05/2017. Trafi’s criticism in the CRD should be read in that context rather than being a statement about what the current regulation permits.

On 5 Apr 2018 UK made a general exemption, pursuant to a flexibility provision in the Basic EASA Regulation, deeming a Part-FCL PPL to contain and confer LAPL privileges. ORS4 No. 1260. However, it was withdrawn on 4 Oct 2018 and an equivalent exemption does not appear to exist. Balliol’s position is therefore correct for the time being.

London

Qalupalik wrote:

Trafi’s criticism in the CRD should be read in that context rather than being a statement about what the current regulation permits.

Indeed I was referring to the proposed changed rules and not the current rules.

ESKC (Uppsala/Sundbro), Sweden

Qalupalik wrote:

Balliol’s position is therefore correct for the time being.

For the UK.

ENVA ENOP ENMO, Norway

What would be the argument for the EASA PPL to not include LAPL privileges?

Administrator
Shoreham EGKA, United Kingdom
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