Yes I know, no TW variant in TMG class and you can’t carry TW variant between SEP & MEP class ratings in FCL (TW in DC3 is different from TW in SEP)
But as I said an FI/SLMG can sign SSEA TW for a pilot holding an NPPL as long as training is done under legacy rules in LASORS when flying non-Part21 aircraft, that would explain why some FI may not get it when it comes to FCL rules while training in Part21 aircraft…CAA is well aware of that “regulatory gap and complication”, I doubt getting someone to court is even possible !
There is no differences training required as part of the TMG class rating. A TMG holder can legally just jump in and fly a tailwheel TMG even if all their previous flying was on a nose wheel.
That is not the case with the SEP class.
An FI with a TMG rating cannot legally teach for the SEP rating unless he has an SEP rating himself and has completed 30 hours on type.
Even if the FI with TMG had an SEP rating he would still need SEP differences training signed off for himself before he could teach it and sign off others.
I think we can agree it’s over complicated and I suspect would get laughed out in a court of law which is why a NAA would never take someone to court.
So if there not going to take it to court why bother wasting resources telling the pilot population.
Bathman wrote:
Or the FI with a tailwheel TMG that thinks he can sign off tailwheel differences training on an SEP.
He can, if he is FI/SLMG, he can sign NPPL/SSEA for difference training like tailwheel or +140KIAS, he can even sign to fly SSEA sea plane with difference training with no need for ATO training and SEP(SEA) skill-test
Why do they need to?
Has there ever been a successful prosecution in court where someone who didn’t understand the regulations.
I have lost count of the number of times I’ve seen an FI’s that thinks because they past their cpl check ride on am MEP they can sign someone off for wobbly prop and retractable gear on a pa28R.
Or the FI with a tailwheel TMG that thinks he can sign off tailwheel differences training on an SEP.
It’s hard to know where to start with that…. Maybe with the start of flying. I bought my first plane in 2002 (an orphaned type, but operated in FAA standard category – no Annex Whatever BS), did some repairs in the hangar myself under supervision, then the unaffiliated A&P who helped me and independently signed the work off with logbook entries only taught me to fly it (he is also an instructor) from near zero without any syllabus or school affiliation for either of us or the plane. My practical test was then done according to “goals” only, the practical test standards. And so it goes.
On a slight tangent, I have had no licensing interaction with FAA on any level since that time twenty years ago except obtaining generally no-cost biennial logbook signoffs from FAA instructor rated friends, and carrying my wallet/pilot certificate when flying. Also 3rd Class medicals but I think I’m going to give them up and just go Basic Med every four years with any unaffiliated doctor. I guess I will have to upload the doctors name and date onto the FAA website every few years.
I’m certainly not an expert on the FARs (or maybe it should be 14 CFR?) but I do have a 61.75 license so I know (or knew 
) enough about it to satisfy a DPE. My impression is that the FARs are generally more prescriptive than the EASA regs – particularly when it comes to operational rules where EASA regs are to a large extent goal-oriented rather than setting out exact conditions.
it is often a Monty Phyton moment such in “What have the Romans done for us”
Silvaire wrote:
The FAA obviously operates much more along those lines in its basic philosophy, and yes it does work.
Interesting to hear. From what I regularly read in US fora and the occasional AOPA Pilot mag, there are plenty of grievances people have with the FAA as well, such as the ongoing saga with the GAMI Fuel and other certification issues which seem to take forever and have in the past bancrupted promising projects. I’d say while the FAA may be more pragmatic in many regards, they are in the same situation now, if not worse, particularly after their complacency in the Boeing Max scandal came to light. They need to cover their behinds no longer with simple pants but with bullet proof undies, which by the very nature of things, are quite uncomfortable.
Clearly flight crew licensing as well as their approach to ratings and IR are much more pragmatic, even though under EASA Europe has made huge progress on this as well, not least inspired by some FAA rules. On the other hand, the FAA has the clear advantage of “only” being responsible to one government, whereas EASA has to take into account a large quantity of member states, each with their own pet grievances and regulations. Harmonizing that and trying to make everyone comply at least is no mean feat.
Cobalt wrote:
Why not look at it the other way round – after 20 years of EASA, by how much have literally hundreds of people working on thousands of pages of new regulation improved safety?
EASA’s record imho is not by any extent as bad as it is made to be, mostly thanks due to their horriffic start up problems. Improving safety is one thing, harmonizing rules and regulations of then 32 member states to an extent where aviation pretty much works the same way everywhere was imho the much bigger task, which is far from being completed today, even with the UK out. Looking at the history of EASA vs FAA, they are diametrically different in origin and governance as well as how their rulemaking works.
We should not forget either that both the FAA and EASA are relatively benign in comparison to how aviation is conducted in many parts of Asia e.t.c, where GA is practically inexistent.
Aviation safety has improved over the years, accident stats clearly show this. Sometimes the FAA was the leading body in that, sometimes EASA, sometimes ICAO or others. All of them have introduced regulations over the years which made people cringe and which had massive impact on their lives and economic reason of being. Several do come to mind:
- The 1500 hour rule before any FAA pilot can become an airline pilot
- The original Part M rules of EASA, which treated GA like airlines
- Flight Data monitoring as a tool which has radically reduced manual flying in airliners, causing huge problems particularly in Asia with degrading pilots skills.
On the other hand, EASA in particular has changed some stuff which was horrible in the old days of e.g. flight crew licensing in Europe to the advantage of the pilots:
- Licenses never expire anymore, you can’t be forced to retake your PPL or CPL exams if you were out of action for a while. (Pity the IR is not treated the same way though). For many pilots I know this was a huge game changer when they wanted to come back.
- Harmonisation of flight crew licensing across Europe, where you can fly any EASA memberstate airplane with your license, regardless where it has been issued
- Exercising oversight over national CAA’s and kicking butt if they do not comply or drag their feet, most prominently in recent years Germany with the CBIR and similar stuff.
- Step by step opening up the IR for more people in GA, now concluding with the BIR. This against massive resistance by several member states.
- Setting on condition operation into law with part NCO, which relieved a lot of GA owners in many member states where on condition was not allowed or massively limited.
- And not least: Quite a few European certification programs for airplanes have been completed successfully vs lots of FAA governed certification programs have ended in bancruptcy and take overs.
all in all, it is often a Monty Phyton moment such in “What have the Romans done for us” when we bitch about regulation we find obsessive at some stage and forget the regulation which suits us. And comparing the FAA to EASA, almost all the problems EASA had to solve did not exist there: They did not have 32 members and a European comission to satisfy but basically get their stuff past the DOT and in some instances the ongoing administration. And they grew in a one country environment over decades wheras EASA is relatively new.
Silvaire wrote:
I think it’s more because it makes relatively unskilled employees more employable
Can’t argue with that. All the paperwork, process and quality control I see being added tends toward removing individual skill and judgement as much as possible. It’s why I never let HR attend an interview I’m conducting – they’d be horrified. According to them you don’t need any insight or judgement, you just need to follow the process and ask questions that begin “Can you tell me about a time when you…” Much the same with the modern attitude to managing people – apparently you don’t need any empathy, judgement or leadership, you just need to refer to ‘best practice’ in every situation.
I think it’s more because it makes relatively unskilled employees more employable, and justifies they and their masters enriching themselves while subtracting value. It’s particularly an issue in any organization that has no competitive threat, and obviously government is the best example of that. However, I’d agree that it’s also a problem in larger businesses, and businesses that contract to government. That’s why small business continues to be key to societal progress, at least until government and large business can find a way to regulate it out of existence.
