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Flying lessons with a self-declaration medical - a surprising holdup

Today, to my surprise, I learned that I’m not able to do my revalidation flight in a C172 because I have only got a self-declaration medical. I have 11 hours and 5 minutes in my single seater Permit aircraft.

If I didn’t have a license or a medical I would be able to fly with an instructor, but as I have a license but no medical (other than the self declaration) it seems that I would be ‘Pilot (in command) under Supervision’ rather than ‘Pilot under Training’ and to be pilot in command, I need a medical that is valid for the class of aircraft I was to have a lesson in, even though I would be flying with an instructor with a Class 1 medical. It was not something I had anticipated before the lesson, which had to be cancelled.

The problem is that my local flying school was booked out for the last few months so I only managed to find the combination of availability and weather today, and my license runs out at the end of the month.

It seems I have two possibilities: one would be to find someone who can instruct me on a non-EASA aircraft for which my license is valid – I am going to get in touch with the Tiger Club and see if any of their aircraft are applicable. The other possibility would be to get a Class 2 medical very soon.

My instructor phoned up the CAA in order to clarify that this was the case prior to cancelling my lesson. Just publicising this in case anybody else gets caught out.

That’s bonkers. Another reason for me to remain on the FAA system.

Andreas IOM

The division of aircraft in EASA and Annex I types must have been the biggest mistake when the Basic Regulation was first written.

ESKC (Uppsala/Sundbro), Sweden

On the train home I am reading through all the CAA sources and ORS4 1283 seems to say that I can still fly EASA aircraft by myself until April 08 2020, unless I have somehow misunderstood it, but that “holders of ICAO licence conversions/validations are exempt”

I confess I don’t quite understand what that last sentence means, but I assume it is the one referring to the hour with an instructor that I need for revalidation. I would otherwise have thought it might apply to people converting an FAA to EASA license or similar.

The following are excluded from this exemption:
i) Initial applicants for the licences specified in paragraph 2, excluding applicants for
conversion of a licence granted under the Air Navigation Order into a Part-FCL Licence;
ii) The exercise of the privileges of an Instrument Meteorological Conditions (IMC) Rating or
Instrument Rating (IR);
iii) Holders of ICAO licence conversions/ validations; and
iv) Student pilots under training for a Part-FCL pilot licence when flying solo.

If any instructors can see any other way round the impasse I’d be curious, or if you happen to have a spare slot this Friday/Saturday/Sunday to give me a lesson in a non-EASA aircraft I’d be interested to hear from you. It is easier for me to get to the Midlands than past London, so if there’s anyone closer to home that would be my preference.

Last Edited by kwlf at 21 Jan 15:55

but as I have a license but no medical (other than the self declaration) it seems that I would be ‘Pilot (in command) under Supervision’ rather than ‘Pilot under Training’ and to be pilot in command,

I don’t think that’s right.
PIC under supervision is only for the successful outcome of a flight test. Revalidation isn’t a flight test, but rather a paperwork exercise after meeting the requirements for revalidation.

One of the requirements that must be met before revalidating is a training flight of at least 1 hour. All training flights should be logged as dual not any form of PIC, because you are not in command.

If the flight was logged as PIC/US, then you’d not have met the requirement to have a training flight!

You don’t need any form of medical when you’re not in command.

EIWT Weston

I agree.

You don’t need a valid medical for any flight with an instructor – PPL or IR reval or renewal, etc. All these are PU/T.

An exception might be if the “instructor” was a CRI. They can do revalidations if they have the FCL745 endorsement.

Administrator
Shoreham EGKA, United Kingdom

Shop around I believe that your school and the CAA are wrong.

There are numerous instructors/examiners that would be more than happy to renew ratings such as an SEP without a current medical at all and in an EASA aeroplane.

Last Edited by Bathman at 21 Jan 15:59

I’ve been re-reading ORS4 1283 again and come across:

This exemption [that pilots may fly EASA aircraft with a medical self-declaration] is subject to the following conditions:

iii) Licence holders must only operate:

e) the aircraft on flights which are not:
• commercial operation flights (as defined in Schedule 1 to the Air Navigation Order);
or
• pilot training flights.

So there we are, it seems.

That, surely, is a cockup because it prevents anybody flying on the medical self declaration renewing or revalidating their license.

Administrator
Shoreham EGKA, United Kingdom

UK general exemption E 4764 published in ORS4 No 1283 of 4 Oct 2018, valid until 8 Apr 2020 or earlier, is irrelevant. The pilot training flight exclusion means the licence holder may not conduct a training flight while acting as pilot-in-command under the terms of the general exemption.

If you act as a pilot under training (not solo) you shall log the flight time as pilot under training only and the general exemption will not apply to you. The PICUS capacity is logged only by candidates who have successfully completed a skill test, proficiency check, or assessment of competence. You do not require a valid medical to act as a pilot under training (excluding solo flying training).

If the rating expires because you do not complete the revalidation by experience requirements in time then you may still attempt a proficiency check. A valid medical is not required to attempt a skill test, proficiency check, or assessment of competence. However, in these cases the flight time shall be logged as pilot under training. Subsection 2.3 UK CAA Flight Examiners’ Handbook (link). Flight Examiners Handbook 2016 local copy

London
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