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SEP-Land Class Rating Renewal

Due to ill health within my family and a new baby that was going to need looking after, in early 2018 I realised that I wasn’t going to be able to able to fly enough to stay safe for awhile. So I decided that I’d put flying on hold until things improved.

Things improved for me towards the end of 2019 and I then had the time to fly properly again. But there is little chance to get up to speed and keep good VFR currency (which I felt I’d need after such a gap from flying) during the Irish winter. So I planned on leaving it to spring to get back flying knowing that once I got up to speed again, I could do plenty of flying and rebuild my competence.

Then COVID 19 came along! Our aircraft that had been sent to the UK for a new paint job and some upgrades over the winter, got stuck there partly due to lockdown and partly due to COVID sickness in the paint shop. It only came back 2 weeks ago and is now going through it’s annual inspection. It’s expected back in service in another 2 weeks. That is early August. My class SEP rating expires on 31 July!

I see little point in trying to fly 12 hours in another aircraft just to revalidate my class rating, knowing that that time would be better spend getting used again to the aircraft that I will be flying after that.

I see little point in trying to do a proficiency check before 31 July for the same reasons. I wouldn’t pass a PC now, and it will take me longer to get up to speed in a type that I’ve not flown before, compared to an aircraft that I’m intimately familiar with.

So I’ve decided to wait until our own aircraft is back in service, got some instruction in it and then do a PC.

Looking at Part FCL740 for the requirements to renew (restore privileges after they have expired) by Proficiency Check I’m a little confused.

Section B says that I will need refresher training at an ATO if the ATO deems it necessary. It then goes on to say (ii) that if the rating expired by less than 3 years (just a week or 2 in my case) that that training can be done at an ATO, DTO or with an instructor.
Am I reading the correctly? An ATO has to say how much training, if any, that I need, but I don’t have to do it with then? I could instead do with with an instructor.

Then I move on to read the AMC, but it seems to tell a different story.
In paragraph A it states that “The amount of refresher training needed should be determined on a case-by-case basis by the ATO, the DTO or the instructor, as applicable, taking into account […]”.

Paragraph’s C&D seem to make similar points about “the ATO, the DTO or the instructor as appropriate”.

My reading is that the FCL and AMC are in conflict, in that FCL says that the ATO must decide what training is required, but I can get the training at a ATO, DTO or with an instructor, while the AMC seems to indicate that any of the three can make the assessment and sign off on its completion.

So which is it?

I ask because I’ve very easy access to a CRI who is a member of our club and can provide the required training on the the aircraft that I normally fly and am familiar with with. This would speed up the process of getting competent again and make it more relevant to what I’ll actually be flying after getting current again.

I’ve also good access to a DTO who would probably facilitate making the assessment on our own aircraft, even though the training would be carried out by the independent CRI.

I’ve no connection with an ATO, so would imagine they would insist on training on their aircraft following one of their prescribed courses and would be the least convenient option of all, and after that I’d still need to get current on our own aircraft afterwards.

It’s very easy to read the AMC and see what I want to see, but is that a correct reading? Am I correct in understanding that the AMC can give additional options over the FCL?

So in summary, what I need help with it:

1. Can a DTO or independent instructor make the assessment of what training is necessary?
2. Can the training be carried carried out by an independent instructor?
3. Can the training completion document be signed by an independent instructor?
4. Does a CRI count as an instructor for this purpose or does it need to be a Flight Instructor (FI)?

Any help much appreciated! With a bit of luck I’ll be back in the sky in 3-4 weeks.


Last Edited by dublinpilot at 21 Jul 20:10
EIKH Kilrush

There is a similar subject here

My optimistic self would think that as the DTO has been introduced after FCL was written the missing “or a DTO” is just an omission.
Maybe the IAA can advise of their interpretation

Nympsfield, United Kingdom

You’re misreading (2) – an ATO is only required for complex aircraft, for an SEP the paragraph ii is applicable so can be DTO, ATO or instructor

You can do the refresher with your CRI, he then recommends you for proficiency check to the examiner.

No need for DTO or ATO involvement

Posts are personal views only.
Oxfordshire, United Kingdom

Thanks Xtophe. A very similar subject indeed. But because their licence has expired by more than 5 years, I don’t think they have the option of a freelance instructor no matter how you read it.

Thanks MattL. So your reading is that FCL says "Default is ATO. If it’s non-complex and expired >3 years, then it’s i) and if it’s non-complex and expired <3 years then it’s ii). You place no importance on the fact that the assessment part is only mentioned in relation to ATO, and no mention of assessment being done by an DTO or instructor.

The AMC seems to agree with your reading.

EIKH Kilrush

MattL wrote:

You’re misreading (2) – an ATO is only required for complex aircraft, for an SEP the paragraph ii is applicable so can be DTO, ATO or instructor

You can do the refresher with your CRI, he then recommends you for proficiency check to the examiner.

No need for DTO or ATO involvement

Then what does the first sentence of (2) mean? Like Xtophe, I believe that there was a mistake in not adding “or DTO” when DTOs were introduced.

ESKC (Uppsala/Sundbro), Sweden

The AMC at para e is quite clear that the assessment of the training required is by an ATO, DTO or instructor. I’ve never come across anyone interpreting it any other way.

Posts are personal views only.
Oxfordshire, United Kingdom

That very regulation (FCL.740) has been amended several times during recent years and I too suspect that mentioning only ATO in said sentence is an error resulting from multiple amendments.

EKRK, Denmark

It could be omitted deliberately, because (2) is the default situation referring to class and type ratings in general.
As using a DTO or freelance instructor is only possible for a limited subset of “all aircraft”, it may be that they therefore are only mentioned in the sub-paragraphs referring to those exemptions.

EDXN, ETMN, Germany

Dublinpilot, are you sure it wouldn’t be easier to just pass a checkride with a FE now, then get the training you need to reach your desired level afterwards? Yes, you haven’t flown for quite a while, but you have lots of experience afaik, so it should all come back quickly, shouldn’t it?

Last year I took the same route after not getting the necessary 12 hours to validate by experience. I was rusty but it was sufficient to pass the checkride. I took some more training, about 2 hours, with a FI afterwards. Licensing wise, this was much easier than getting my SEP rating back after it lapses.

Novice pilot
EDVM Hildesheim, Germany

to renew your recently expired SEP land you do not have to go to ATO. DTO or FI/CRI can fly with you as required (if required) and FE will fly with you afterwards to grant you another 2 years. But, unless you are out of flying for years /which is not your case/ it might be easier just go to checkride, even it will take few minutes/flights longer.

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