Logging Microlight hours on EASA PPL

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Logging Microlight hours on EASA PPL

Postby neilld » Thu Jun 22, 2017 8:54 pm

Does anyone,either within the LAA organisation or individual, know the progress/outcome of Proposed Amendment NPA 2014-29(A) upon which the LAA provided comment in March 2015, regarding the ability to log hours accumulated in 3 axis Microlight aircraft towards the revalidation of an EASA PPL with SEP class rating?

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Re: Logging Microlight hours on EASA PPL

Postby Brian Hope » Sat Jun 24, 2017 7:19 am

Hi David, I am fairly certain the answer is Yes but I don't know the full details of how many hours you can count etc., so I have fired off an email to our resident expert who will be able to provide all the details.
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Re: Logging Microlight hours on EASA PPL

Postby Cookie » Sat Jun 24, 2017 1:37 pm

Hi David,

There are currently significant differences in how this is handled depending on which combination of licence and/or class ratings you hold.

Note that for the NPPL, the class ratings such as the SSEA, SLMG, or microlight ratings are mutually exclusive. Therefore to fly microlights using a NPPL you would be required to hold a current microlight class rating. Using a SSEA class rating with differences training to fly microlights is not permitted for holders of NPPL class ratings. Cross-crediting between SSEA, SLMG, and microlight class ratings has been permissible for many years in accordance with ANO Schedule 8 Part 3 Chapter 2 Table B. The same limitation of privileges and associated revalidation requirements would apply to a SSEA class rating entered in a UK PPL.

For a UK PPL, crediting of three-axis microlight experience towards SEP class rating revalidation has been permissible since August 2016 with the introduction of the new Air Navigation Order. During the ANO Review, an opportunity was identified for simplification of the ANO and to align it with future EASA regulations. Therefore, for revalidation by experience of a SEP class rating within a UK (non-EASA) PPL, ANO Schedule 8 Part 3 Chapter 1 Table 1 states that you must comply with "FCL.740.A (b)(1) and (4) of Part-FCL, provided a SEP aeroplane with three axis control system is used". Three-axis microlight flying may be credited towards SEP class rating revalidation by experience in a UK (non-EASA) licence with a SEP class rating.

Pilots with EASA licences are awaiting the outcome of EASA Notice of Proposed Amendment NPA 2014-29(A) upon which the LAA provided comment in March 2015. At present, the regulations remain unchanged, so crediting of microlight experience is not permitted towards class rating revalidation of SEP class ratings in an EASA licence. However, the proposal is for experience to be credited where the aeroplane is a three-axis microlight, hence the ANO amendment last year in expectation of this EASA regulation so that the same requirements will ultimately apply. EASA NPA 2014-29(A) should have had a Comment Response Document (CRD) and associated Opinion issued some time ago, with the latest schedule for issue of the CRD at the end of March 2017(!).

Kind regards,

Jon


Air Navigation Order
http://www.caa.co.uk/cap393


CAP 804
http://www.caa.co.uk/cap804

NPPL
http://www.nationalprivatepilotslicence.co.uk
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Re: Logging Microlight hours on EASA PPL

Postby neilld » Sun Jun 25, 2017 12:11 pm

Jon,
Thanks for your reply. This appears to be a near carbon (or silicon) copy of your comment on the Flyer Forum on April 16th 2017 therefore I assume that either no progress has been made or no one is following this up.
The purpose of my original question above was to find out if anyone, either within the LAA or individual with closer contact, was progressing this issue with EASA.
The target date for CRD has long passed and therefore it would be reasonable to expect that some progress has been made.
I fully understand, from previous correspondence, that this issue does not fall within your remit in your LAA/EASA activities.
Perhaps you can advise who, within the LAA, has the remit to progress this matter since someone within the organisation provided comment way back in March 2015
Thanks again for taking the time to respond.
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Re: Logging Microlight hours on EASA PPL

Postby SteveSlater » Wed Jun 28, 2017 11:00 am

Thanks Jon,

Neil, I deliberately held off responding until we had Jon's summary which makes things clearer, even if it is not necessarily what you as an EASA holder might want to hear.

While we can, and do, have proactive input with the CAA on areas such as licensing and medical requirements for the NPPL and UK PPL licenses over which they have jurisdiction, when it comes to EASA regulation, their hands are largely tied.

I haven't got firm evidence, but I suspect that like the planned changes to EASA Basic Regulations and the approval of EASA Part M Light engineering concessions, the process is currently stalled at the Committee review stage in the European parliament. (I hasten to add, this is nothing to do with Brexit!).

Simply, there has been a stoppage in the process to get these proposals into EC law, which is required for them to be implemented by EASA. It is very frustrating for all concerned, but totally outside our control. :(
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Re: Logging Microlight hours on EASA PPL

Postby neilld » Wed Jun 28, 2017 9:25 pm

Steve,
Thank you for taking the time to respond, I am aware of the pressures on LAA staff given the limited financial resources available and I appreciate you taking the time out from your busy schedule to reply.
The driving force behind my original question is the need to reduce the cost of flying which I had thought was the mission statement of the LAA.
I read with admiration (and not a little envy) of flight tests in the LAA magazine of WW2 replica aircraft, the cost of which probably falls into the supercar price range. Sadly I (and I assume many others) am not in this category and therefore am seeking a low(er) cost of flying.
It is disappointing that whereas the LAA have commented on EASA Notice of Proposed Amendment NPA 2014-29(A), no one appears to have followed this up and furthermore no one appears to know the current status of the CRD despite the target date having been passed three months ago.
I fully understand that EASA are a monopoly and answerable to no one but is it really a major task to communicate with the hierarchy in Cologne to find out what is going on?
This issue was raised in the "Red Tape Challenge" (however many years ago that was) and the CAA (bless them and I take back 35% of what I have said about them)) have responded positively..
Presumably "someone" within the LAA commented on the above mentioned NPA therefore is it too much to ask that that "someone" follows up the process and could advise what the current status is?
Thanks again for your input.

regards

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Re: Logging Microlight hours on EASA PPL

Postby mikeblyth » Thu Jun 29, 2017 8:29 am

You couldn't make it up. I think good matter for TV comedy sketch depicting Orville and Wilbur
Wright in 1904. Licence privilege's and Medicals. Would never get off the ground. :?
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Re: Logging Microlight hours on EASA PPL

Postby SteveSlater » Thu Jun 29, 2017 11:21 am

Hi Neil

Yes. Comment was made to EASA at the appropriate time on the NPA, and we maintain good dialogue with them via various forums and committees. However the matter is now out of EASA's hands and now with the European Parliament and its associated committees. Constitutionally, having passed the consultation stage, we and EASA have no further input.

It is equally frustrating for those in EASA, who have spent up to 7 years working on reforms thus far, to see it grind to a (I hope temporary) halt.

We spend a significant amount of time and resource, not least helping fund EFLEVA to support our advocacy in Europe. Equally, the vast majority of our fleet is Annex 2, non-EASA Permit aircraft and there at least, thanks to initiatives such as A8-26 approval, we have more direct links with the CAA.
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Re: Logging Microlight hours on EASA PPL

Postby neilld » Fri Nov 03, 2017 1:45 pm

Any progress with this?
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Re: Logging Microlight hours on EASA PPL

Postby neilld » Sat Nov 04, 2017 11:49 am

I take it that's a no then
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Re: Logging Microlight hours on EASA PPL

Postby Ian Melville » Sun Nov 05, 2017 8:19 am

I haven't a clue, but expecting a response after 3 daylight hours is a tad optimistic. There isn't a large team of LAA experts monitoring this forum 24/7
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Re: Logging Microlight hours on EASA PPL

Postby neilld » Sun Nov 05, 2017 2:23 pm

Not sure of the relevance of "daylight hours" and the question wasn't aimed specifically at LAA staff, just anyone with an interest in reducing the cost of aviation who may frequent these forums.
However given the glacial pace of rule making in aviation I suppose expecting a response in my lifetime could beconsidered a "tad optimistic"
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Re: Logging Microlight hours on EASA PPL

Postby Cookie » Mon Nov 06, 2017 9:49 pm

Opinion 05-2017 was released on 29th June 2017. Rather unexpectedly, EASA did not accept the proposal contained within NPA 2014-29(A) which would have allowed 3-axis microlight experience to be credited towards SEP Class Rating revalidation within Part-FCL licences.

Within Comment Response Document to NPA 2014-29(A), see EASA response to LAA comment 730 on page 68:

After consultation with the EASA experts, the decision taken was to remove the text amendment in FCL.035(a)(2) proposed with NPA 2014-29 because with this amendment the requirements of the Basic Regulation would have been altered. If deemed necessary this should be done in the Basic Regulation itself rather than in its implementing rules. EASA has prepared an AMC and proposed it with NPA 2014-29(B) and this AMC will be published after the adoption of the amendments to the Aircrew Regulation as GM.


You will see from page 1 of the Opinion that the associated Decision is expected Q2/2018.

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Re: Logging Microlight hours on EASA PPL

Postby neilld » Tue Nov 07, 2017 11:03 am

Thanks again Jon. Think I'll give up flogging this particular dead horse now.

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