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Expiry date of a rating - inclusive or exclusive

With some bad luck with weather combined with other life circumstances, I’m pushed into a revalidation on the date of expiration inscribed on the license. The examiner I would use starts to argue that the license says “until 30/06/2024” and this means that 30/06/2024 is not included, so the deadline is really 29/06/2024 but bad luck, he is not available on 29/06/2024. That does correspond to the meaning of the words “until 30/06/2024” in his native language (where one says “until and inclusive” if that is what is meant), but I’ve always understood EASA Part-FCL licences to mean “the date inscribed inclusive until 23:59:59.9999999”.

Does anybody have a written regulatory reference that says the date is inclusive that I could show to the examiner? I couldn’t find one in EASA’s Part-FCL Easy Access Rules.

ELLX

lionel wrote:

Does anybody have a written regulatory reference that says the date is inclusive that I could show to the examiner? I couldn’t find one in EASA’s Part-FCL Easy Access Rules.

Ratings are always valid to the end of a calendar month, so “until 30/06/2024” must mean that June 30 is included in the validity period.

The regulation is in part-ARA:

ARA.FCL.215 Validity period
(a) When issuing or renewing a rating or certificate, the competent authority or, in the case of
renewal, an examiner specifically authorised by the competent authority, shall extend the
validity period until the end of the relevant month.
(b) When revalidating a rating, an instructor or an examiner certificate, the competent authority,
or an examiner specifically authorised by the competent authority, shall extend the validity
period of the rating or certificate until the end of the relevant month.
[…]

ESKC (Uppsala/Sundbro), Sweden

Where would we be without @Airborne_Again with his rapid and never failing knowledge of the regs!

Private field, Mallorca, Spain

The other reason why stuff has to be valid until the end of the last day of the month is that you would otherwise lose at least one day from the validity period, each year

What varies is the “early renewal” allowed (i.e. without losing the final validity date). On FAA medicals, and Annuals, you get same-month. On some other stuff over here you get 45 days…

Administrator
Shoreham EGKA, United Kingdom

aart wrote:

Where would we be without @Airborne_Again with his rapid and never failing knowledge of the regs!

To be honest, it is mainly that I know where to look…

ESKC (Uppsala/Sundbro), Sweden

Airborne_Again wrote:

To be honest, it is mainly that I know where to look…
That – all by itself – is a quality.
Berlin, Germany

Where to find EASA regs

However, even when you know the above, finding the one which applies is still hard unless you know “the system”. I can’t really find anything…

Administrator
Shoreham EGKA, United Kingdom

Nothing much to add…but why do people in aviation always insist on adding unusual interpretations to common language? “Until” everywhere at least in the English speaking world always includes that date – this is true whether it’s a car tax disc, a train ticket, a tax return deadline or whatever. But the moment it’s aviation, someone has to come up with a weird interpretation of a word that is completely different to its usage literally everywhere else. And the weird interpretation is always the most restrictive possible weird interpretation.

Last Edited by alioth at 26 Jun 11:37
Andreas IOM

alioth wrote:

And the weird interpretation is always the most restrictive possible weird interpretation.

Public servants on a power trip. And if you complain, you’re probably anti-authority and therefore unreliable.

Berlin, Germany

lionel wrote:

The examiner I would use starts to argue that the license says “until 30/06/2024” and this means that 30/06/2024 is not included,

An examiner that does not now the simplest of rules – license endorsement.. It´s in part-FCL, and not even any national regs. (examiners differences doc.) would have anything to do with this. What a twat.

Inkognito wrote:

Public servants on a power trip. And if you complain, you’re probably anti-authority and therefore unreliable.

In this case replace with “A clown”

Last Edited by Yeager at 26 Jun 18:51
Socata Rallye MS.893E
Portugal
23 Posts
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