I’m just wondering what other countries do, or if Norway CAA has made up this rule on their own.
It’s about FCL.740.A.(b) I asked this question directly to the CAA and got the answer that any plane can be used to fly the hours needed (any Annex I plane for instance), but that an EASA plane must be used for the 1h of refresher training. Several of us now have been looking at this, as we normally fly experimental and/or ULS. Some have tried and got refused. We cannot find any reference to the 1h with refresher training has to be done in an “EASA aircraft”. Is this the same other places?
It is the same in Sweden and I think that it is a correct interpretation of the rules. And yes I absolutely agree that it is a stupid rule.
The only way to use Annex I for this purpose would be to acquire an authorization from your CAA so that it can be used for flight training. I do not have the reference to Part-DTO in my head at the moment but it is in there. Maybe you can have a good discussion with the CAA in order to issue some restricted authorizations to only allow the revalidation training and not the whole license training.
The scenarios that work,
I would double check on other scenarios as non-EASA aircraft is OK but may require an “evaluation by an ATO & DTO”, the relevant extracts are in FCL.035(a)(4), also, see guidance in AMC2 ORA.ATO.135 or AMC3 DTO.GEN.240. In the UK, see CAA CAP1928 (Oct 2020)
My understanding UK CAA and French DGAC are very relaxed about authorising the use of non-Part21 or non-EASA for training, besides, an unrestricted FI or CRI who teach Annex1 aircraft is likely to have his own “one man DTO” (it’s a simple form with generic mannual) or get attached to an DTO/ATO
I am not sure about other NAA, some are very allergic to training in non-EASA aircraft while others tolerate it fine, I think it has to do with “national manufacturers” and/or “national types in fleets”? this regulation is pure red tape and national protectionism (CPL/IR ATO don’t give a hoot about vintage Annex1 taildragger types for the evaluation and most instructors there don’t even know how to fly them)
LeSving wrote:
an EASA plane must be used for the 1h of refresher training
No. FCL.035 (a)(4).
Qalupalik wrote:
FCL.035 (a)(4).
As Fly310 wrote, this needs an authorisation from the national CAA. (Just like any use of an Annex I aircraft for training.)
(4) All hours flown in aeroplanes or TMGs that are subject to a decision of a Member State
taken in accordance with points (a) or (c) of Article 2(8) of Regulation (EU) 2018/1139 or
that fall within the scope of Annex I to that Regulation shall be credited in full towards
fulfilling the flight time requirements of point FCL.140.A(a)(1) and point
FCL.740.A(b)(1)(ii) of this Annex, provided that the following conditions are met:
(i) the aeroplane or TMG concerned is of the same category and class as the Part-FCL
aircraft in respect of which the hours flown are to be credited;
(ii) in case of training flights with an instructor, the aeroplane or TMG used is subject
to an authorisation specified in point ORA.ATO.135 of Annex VII (Part-ORA) or point
DTO.GEN.240 of Annex VIII (Part-DTO.
Is the text in bold the reason?
Indeed, that is the relevant part
OK, thanks. That explains it.
