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EASA CPL completely useless without a Class 1 medical

I am in the same position of having an EASA CPL but not actively using the CPL privileges. I had heard the argument and counter arguments before about a class 2 not being valid.

The CAA did not answer my request for clarification, but I conferred with 2 AMEs who agreed that a Class 2 would validate the underlying PPL privileges of my CPL and also be valid for the part 61.75 certificate that I mainly use. When I visited the FSDO following the licence change, their inspector seemed quite happy with it.

I did get a Class 1 renewal to get the EASA licence issued but didn’t update the FAA one until the old JAA licence expired by which time I had reverted to Class 2.

KHWD- Hayward California; EGTN Enstone Oxfordshire, United States

Many FIs are now droping back to a Class 2 as they can now exercise all their FI and FE privileges on a PPL. The only time you would need a CPL is to teach or examine for the CPL. You can teach PPL, IR and FIs on PPL privileges. The CAA confirmed this to an ex staff member who left with a Class II medical.

AMC1 MED.A.030 Medical certificates
(a) A class 1 medical certificate includes the privileges and validities of class 2 and LAPL medical certificates.
(b) A class 2 medical certificate includes the privileges and validities of a LAPL medical certificate.

Mainz (EDFZ) & Egelsbach (EDFE), Germany

From here

Administrator
Shoreham EGKA, United Kingdom

It’s not clear what Denmark is intending to do, other than ignore the law. While MED.A.030(f) is daft, it is also very simple:

(f) Applicants for and holders of a commercial pilot licence (CPL), a multi-crew pilot licence (MPL), or an airline transport pilot licence (ATPL) shall hold a Class 1 medical certificate.

It needs amending in the IR.

Peter wrote:

So if you have a CPL and your Class 1 medical lapses to a Class 2, or you have only a Class 2, the CPL cannot be used even as a PPL.

That’s incorrect at the moment in the UK, as verified with the CAA recently.
Are you saying that this is going to change?

Last Edited by Basoutos at 16 Jun 15:04

Not quite.

The old wording of MED.A.030 indeed, if interpreted to the letter, required the holder of a licence to hold the corresponding medical, otherwise the privileges of the entire licence could not be exercised.

Old wording:


(f) Applicants for and holders of a commercial pilot licence (CPL), a multi-crew pilot licence (MPL), or an airline transport pilot licence (ATPL) shall hold a class 1 medical certificate.

This is changing with Amendment 2013-15, where they change it to

(c) When exercising the privileges of a licence:

(2) holders of a private pilot licence (PPL), a sailplane pilot licence (SPL), or a balloon pilot licence (BPL) shall hold at least a class 2 medical certificate.

(4) holders of a commercial pilot licence (CPL), a multi-crew pilot licence (MPL), or an airline transport pilot licence (ATPL) shall hold a class 1 medical certificate.

While still poorly worded (instead of holders it should say “when exercising the privileges of”, the intent is 100% certain, because the commentary explicitly states as the reason for the change

MED.A.030 Medical certificates: Changes have been made because the medical certificate is only needed for the issue of the licence (to comply with ICAO Annex 1 point 2.1.1.3) and for using the privileges of the licence exercised (to comply with ICAO Annex 1 point 1.2.4.4).

bookworm, MED.A.030(f) is being replaced with MED.A.030(c)(4) as above.

The UK CAA got around the previous stupidity by printing both a PPL and a CPL on the EASA licence under the “Licences Held”.

Last Edited by Cobalt at 16 Jun 21:53
Biggin Hill

I haven’t seen an Opinion emerge for NPA 2013-15 yet. That means there may still be time to change the wording.

I don’t read the EN quite like you do. It could simply mean that you don’t need to hold a medical if you’re the holder of a licence but not using it, without resolving the issue we’re discussing.

The UK CAA approach is innovative but strictly speaking in breach of FCL.015(c) “A person shall not hold at any time more than one licence per category of aircraft issued in accordance with this Part.”

Is this an example of very badly worded regulation or does anyone believe it is/was truly the intention to require a CPL to have a Class1 medical to operate a private flight?…. I suspect it is the former…

YPJT, United Arab Emirates

So we started with this:

(f) Applicants for and holders of a commercial pilot licence (CPL), a multi-crew pilot licence (MPL), or an airline transport pilot licence (ATPL) shall hold a class 1 medical certificate.

They want to allow (I think!) a CPL fly with the privileges of a PPL, when they hold a class 2 medical, so they change the wording to

(c) When exercising the privileges of a licence:
[…]
(4) holders of a commercial pilot licence (CPL), a multi-crew pilot licence (MPL), or an airline transport pilot licence (ATPL) shall hold a class 1 medical certificate.

And somehow they think that makes it better?

Then they explain it with

MED.A.030 Medical certificates: Changes have been made because the medical certificate is only needed for the issue of the licence (to comply with ICAO Annex 1 point 2.1.1.3) and for using the privileges of the licence exercised (to comply with ICAO Annex 1 point 1.2.4.4).

The explanation makes no sense at all. “The medical is only need to issue or use the privileges of a licence.” What use is a licence that you can’t use the privileges of, especially when you can’t hold a second licence!

The wording of the old quote means essentially the same as the new quote.

These people are the same ones they require us to hold English Language Proficiency certificates. I think they could do with a little brushing up on their own English! Perhaps we should require EASA regulators to hold ELP level 6

EIWT Weston, Ireland
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