If the licensing authority or an agent acting on its behalf accepts a single logbook entry that attests to dual instruction, why should the instructor on whom the FCL.945 obligation is imposed be expected to make any finer a distinction?
Nevertheless, the AMC makes two recommendations. One is that air exercises should cover one or more proficiency check items. It would take an especially foxy instructor to avoid this. The second recommendation is for the briefing to include a discussion on TEM emphasising “decision-making when encountering adverse meteorological conditions or unintentional IMC, as well as on navigation flight capabilities.” The origin of this recommendation is traceable and relevant and I think it is worth mentioning, especially because the “navigation flight capabilities” recommendation appears out of context.
There was a C172 (reg: OO-TRB) that crashed into a wooded area near Ursel, halfway between Ghent and Bruges, one afternoon in January 2010. The weather at the time of departure had been fairly good but rapidly deteriorated with substantial snowfall. Both the pilot and her passenger died. The general location of the aeroplane was worked out from mobile phone signals. The federal police conducted an aerial search using a Sea King, with the crew equipped with night goggles and infrared cameras, but abandoned the search due to deteriorating weather. The wreckage and bodies weren’t located until later in the evening. It was possibly this accident that led to the requirement for PLBs/ELTs.
After the Belgian Air Accident Investigation Unit published its final report into the accident (pdf link), the Belgian CAA made a safety recommendation to EASA. You can find it as BELG-2010-010, on p 20 of the EASA Annual Safety Recommendation review (pdf link).
The Belgian AAIU believed that the leading causal factors were inadvertent flight into IMC and the pilot’s resistance to making a diversion. The safety recommendations were included by the BCAA in its response to NPA 2014-029 (A or B, I forget), namely, in response to the proposal to amend the language in FCL.740.A point (b)(ii)—specifically, the change of “a training flight” to “refresher training” etc. EASA in turn simply published these recommendations in the AMC.
One of the contributing factors is given in para 3.3 on p 34 of the AAIU report as “The lack of navigation flight experience probably prevented the pilot considering a diversion to another airfield.” This single sentence adds context to the recommendation for the recurrency/refresher training to cover “navigation flight capabilities.” That focus area makes no sense on its own.
There is nothing in the world to stop the instructor, who hesitates to endorse a licence pursuant to the obligation in FCL.945, from giving this briefing after the refresher training flight(s) have been concluded.
Right, I was only checking the details of the text in the FCL. The requirement is just that it’s a refresher training, the rest is only recommendations. But one could argue that you need to agree before the flight that the flight is going to be an refresher training. It’s a bit nitpicking but an instructor who flew with you for what he thought was just a flight with instructor with no particular goal being asked a couple of days later could say that no, that flight was not intended as a refresher training, so we have to fly again.
WingsWaterAndWheels wrote:
WingsWaterAndWheels26-Oct-23 11:1705
Right, I was only checking the details of the text in the FCL. The requirement is just that it’s a refresher training, the rest is only recommendations. But one could argue that you need to agree before the flight that the flight is going to be an refresher training. It’s a bit nitpicking but an instructor who flew with you for what he thought was just a flight with instructor with no particular goal being asked a couple of days later could say that no, that flight was not intended as a refresher training, so we have to fly again.
Your reasoning is fair and reasonable, however, as you´re pointing out yourself, the requirement is that you´ve done a minimum of 1h with a flight instructor and nothing more in this regard is defined in the FCLs. So strictly speaking, as long as you can document that you did this 1H flight with a flight instructor, that fulfill that part of the revalidation. It´s then up to the Examiner (Authority) to satisfy himself that your “good to go”, endorse the license and the paperwork – or NOT.
The answer to this is to avoid the question in the first place. Whenever you do a flight with an instructor ask them to countersign the flight in your logbook.
Then you don’t need to go near the instructor when it’s time to renew. Instead you can approach the examiner (or CAA directly) to renew it.
Yeager wrote:
In general you provide an EXAMINER (EASA Authority) with the documentation (log-book), unless of course he blindly trusts you, to prove you have performed the required flight hours, landings and flight with a Flight Instructor, within the last 12 months of the expiry SEP class rating.
Any EXAMINER (EASA Authority) are allowed to endorse the revalidation in your license (EASA). The Examiner will sign the national (CZECH) “Revalidation of class rating for SEP” form and one of you send it to the Czech CAA.
Your national aviation authority may have specifically designated a number of FI to allow them to endorse the part-FCL (and the revalidation form), but generally only examiners are allowed to write in you license.
It is important that you get the part-FCL endorsement done before the rating has expired.BTW. Of course you always have the option to simply do the part-FCL Licence Proficiency Check (LPC) instead of the above.
But of course, it´s likely cheaper to just find a friendly examiner and follow the above.
So, from what I understand, Anyway I need to find a FE/CRE to sign my license? either if I revalidate by the experience or by review flight. Am I right?
I had a hope that I can do that without looking of examiner …
Yeager wrote:
Any EXAMINER (EASA Authority) are allowed to endorse the revalidation in your license (EASA).
That is not the case. The EASA Examiner Differences Document does not cover the extension of rating privileges when revalidating by experience. Examiners who extend the rating this way are exercising an administrative function on behalf of the state of licence issue.
WingsWaterAndWheels wrote:
… an instructor … could say that …we have to fly again
What a compassionate instructor. Fortunately examiners are usually able to sign the licence.
Mher_Tolpin wrote:
I need to find a FE/CRE to sign my license? either if I revalidate by the experience or by review flight
If the Czech CAA delegates this administrative task to its examiners, then one can sign your licence once you fulfil the revalidation by experience criteria, providing the rating has not yet expired. Alternatively, the instructor who conducts some or all of the refresher training, if required, may sign the licence if authorised by the Czech CAA. Failing that, the authority itself can reissue the licence for a fee.
Mher_Tolpin wrote:
I had a hope that I can do that without looking of examiner
Examiners are experienced instructors. Most of them are genuinely interested in your continuing development.
Qalupalik wrote:
Qalupalik26-Oct-23 17:4009
Yeager wrote:
Any EXAMINER (EASA Authority) are allowed to endorse the revalidation in your license (EASA).
That is not the case. The EASA Examiner Differences Document does not cover the extension of rating privileges when revalidating by experience. Examiners who extend the rating this way are exercising an administrative function on behalf of the state of licence issue.
Oh, I see. Where do I find a reference to this interpretation? Most authorities in the differences document, including the Czech 4.2 does not mention any restrictions on examiners endorsing revalidated ratings if based on revalidating by experience, does it?
Qalupalik wrote:
Examiners are experienced instructors. Most of them are genuinely interested in your continuing development.
Do you actually believe this yourself? ah yeah, you said “most”. Got ya.
Yeager wrote:
Where do I find a reference to this interpretation?
The EDD was developed pursuant to ARA.FCL.210 to “be used by examiners when conducting skill tests, proficiency checks or assessments of competence of an applicant for which the competent authority is not the same that issued the examiner’s certificate.” ARA.FCL.210 point (a). This is reiterated in para 2.1.1. (Purpose of the Examiner Differences Document): “It is intented for use by examiners with a Part-FCL examiner certificate conducting a test, check or assessment of competence on a Part-FCL licence holder whose licence was issued by a competent authority (CA) other than their own.” Emphasis added.
The document does not deal with other administrative privileges conferred on examiners such as extending the validity of a class rating that has been revalidated by experience.
Further, the reference to competent authority in ARA.FCL.215 is a reference to the competent authority which is responsible for the licence whose privileges are being extended. ARA.FCL.215 point (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.” The EDD does not provide such an authorisation.
Qalupalik wrote:
Qalupalik26-Oct-23 18:2511
Yeager wrote:
Where do I find a reference to this interpretation?
The EDD was developed pursuant to ARA.FCL.210 to “be used by examiners when conducting skill tests, proficiency checks or assessments of competence of an applicant for which the competent authority is not the same that issued the examiner’s certificate.” ARA.FCL.210 point (a). This is reiterated in para 2.1.1. (Purpose of the Examiner Differences Document): “It is intented for use by examiners with a Part-FCL examiner certificate conducting a test, check or assessment of competence on a Part-FCL licence holder whose licence was issued by a competent authority (CA) other than their own.” Emphasis added.The document does not deal with other administrative privileges conferred on examiners such as extending the validity of a class rating that has been revalidated by experience.
Further, the reference to competent authority in ARA.FCL.215 is a reference to the competent authority which is responsible for the licence whose privileges are being extended. ARA.FCL.215 point (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.” The EDD does not provide such an authorisation.
So, you´re saying is that it is only NATIONAL authorities, thereby Examiners holding the same licence authority (issuing country) as that of the license holder seeking the revalidation by experience?
Thanks for your time in clarifying this.
Just for me to clearly understand, thank you.
Yeager wrote:
… it is only NATIONAL authorities, thereby Examiners holding the same licence authority (issuing country) as that of the license holder seeking the revalidation by experience?
Yes, that is the default position. It is not changed by the EDD in the special case of revals by experience because the EDD is limited to tests/checks/assessments. However, a competent authority may confer this administrative privilege on examiners authorised by other authorities.
