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EASA NPA 2014-29 (FCL)

Just come out

250 pages so I am not going to do an Executive Summary but a quick a dirty search found:

Page 61 – flying with an ICAO IR indefinitely avoids having to re-sit all the IR exams if you let the EASA IR lapse for 7 years. It isn’t clear whether the required training (after the 7 year point) is “as required” or the whole lot.

Page 65 however suggests that no retraining will be required after 7 years, so it looks like it will be just the revalidation flight to get your EASA IR back – so long as you keep the FAA IR valid the whole time (it doesn’t say the 6/6 rolling currency is unacceptable).

Page 79 has a curious bit (which is beyond me to unravel) about doing training towards EASA papers outside Europe. If it is what I think it is, it might be the first time that it may be possible to do an EASA IR in the USA. Of course “somebody” will still need to approve the school out there (€€€€€€)

Page 252 has a bit which may be relevant to people with N-reg PA46Ts and TBMs – I doubt it though and I think it just says that ICAO Type Ratings are acceptable to EASA, as they were before

Administrator
Shoreham EGKA, United Kingdom

Does anyone know what became of this NPA?

Glenswinton, SW Scotland, United Kingdom

Jacko thanks for bumping.

Peter with 61.31 e f and g and 100 hours on an SET (presumably g does not apply for a Caravan) you get an automatic SET class rating?

Oxford (EGTK), United Kingdom

Jacko wrote:

Does anyone know what became of this NPA?

Hard to believe that the first meeting of that rulemaking group was 7 Sep 2011. Last I heard was that an Opinion is expected in Q4 this year. Some of the content has been implemented in dribs and drabs along with other changes.

Clearly there is a huge number of political toes which are being stepped on with this proposal.

Most of the vested interests are fairly obvious – starting with FTOs/ATOs and working on from there.

I know people love to accuse me of liking conspiracy theories but business is always business and the results usually speak for themselves

Administrator
Shoreham EGKA, United Kingdom

RobertL18C wrote:

Peter with 61.31 e f and g and 100 hours on an SET (presumably g does not apply for a Caravan) you get an automatic SET class rating?

That is an interesting question and I wouldn’t mind hearing what @bookworm thinks about it. I wouldn’t think so since ASEL doesn’t have a direct counterpart under EASA. However, I can imagine it – do it based on experience in that class (e.g. give you TBM SET based on experience in TBMs). You would still have to comply with (a) and (b). It just sounds a bit too good so I remain skeptical.

As for the original post, the first quote (if I call it that) is from subpart G (IR), the second one is from subpart H (type and class ratings). You can’t mix those things together. As for the question of training after you let your EASA IR lapse but keep foreign IR alive, my interpretation is that you would have to go through renewal – this change would protect you from having to do the theory again, which is what the (d) is about, but it won’t prevent the IR from expiring so you still have to comply with (c). And renewal means refresher training to reach the proficiency required to pass the skill test.

It just occurred to me that it might be an interesting question what would happen to your ATPL theory. That is also kept alive by revalidating/ renewing IR and is valid for 7 years. I thought the NPA might contain a change there as well but it doesn’t, at least I don’t see it.

Only the first two quotes contain real changes, third is just reworded/ restructured (the (1)(i) gets incorporated directly into (1)) and the only change in the last one is the numbering (crossed bits get deleted, grey bits get added). Well, there is a change in the third one, the wording went from provided in an ATO located outside the territory of the MS to instruction provided outside the territory of the MS in an ATO; this relocation makes a difference.

There are very relevant posts here on this topic.

AIUI, currently:

  • after 1 year (i.e. when the IR “revalidation” becomes a “renewal”) you have to do the flight via an ATO (i.e. no totally freelance option) but – crucially – they have no power to arbitrarily make you fly X hours
  • after 7 years you have to re-do the IR exams

Accordingly I have stopped revalidating my UK IR. My plan is to do the check flight when actually required (currently before April 2017).

Presumably CPL or ATPL theory used for the purpose of compliance with something* will still never expire.

* an FI being able to teach the EASA PPL (needs EASA CPL theory) or avoiding the HPA course (needs ICAO ATPL theory)

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

I know people love to accuse me of liking conspiracy theories but business is always business and the results usually speak for themselves

Your ability to read conspiracy into cock-up is indeed legendary, Peter. There’s no one working against the changes in the NPA, but it’s big and complicated and not seen as a priority, so has been dumped in the “too hard” pile for some time.

Most of what you call “conspiracy” (well, excluding the criminal portion of the definition) is just everyday behaviour of business and other bodies which have an interest in something.

You are indeed fortunate, @bookworm, to have never worked in an organisation which wishes to safeguard it’s future.

If this stuff is “too hard”, why is that? Obviously, it’s because some % of those affected don’t want it. I am sure EASA is not short of people who can type

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

I am sure EASA is not short of people who can type

You are indeed fortunate, @Peter, to have never worked in sausage* factory. You’d be surprised how everything gets bottlenecked at the mincers.

* “Laws, like sausages, cease to inspire respect in proportion as we know how they are made.” (John Godfrey Saxe, 1869)

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