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Can an instructor be FORCED to sign the PPL SEP class rating revalidation

The rule in FCL.945 places the instructor under an obligation to endorse the licence. Unless the relevant criteria have yet to be fulfilled, there is no provision for the instructor to withhold the endorsement.

Silvaire wrote:

in the US it was some time in the early ‘70s IIRC

Completely agree with your comments in the third post above.

The US flight review came from a GA safety recommendation made Sep 1971 by the Assistant Secretary for Safety and Consumer Affairs to the Secretary of Transportation. The rule was proposed in FAA Notice 72-9, Mar 1972. The FAA responded to comments in 38 FR 3158 (1 Feb 1973) which is posted here.

Peter wrote:

… drafting a lot of this stuff years ago…

As I recall, it was the delegates for Germany who originally proposed the SEP revalidation by experience criteria during the development of JAR-FCL. Perhaps it was based on a German pre-harmonisation practice.

London, United Kingdom

Oh, absolutely not. The German pre-2003 rules for PPL-As, as they were called, had nothing of that. The license was renewed every two years (yes, one actually had to renew the license itself) by demonstrating 24 hours within the last 24 months essentially. One was thus able to maintain a PPL-A for decades without ever flying with an instructor.

Mainz (EDFZ) & Egelsbach (EDFE), Germany

Someone close to the action told me it was Germany which wanted the “12 hrs within the past 12 months” (or whatever it is exactly) rule, which means after you get the PPL you don’t need to fly at all for 23.9 months, intending to clock up 12 hrs in the final few days.

Shoreham EGKA, United Kingdom

The EASA rules that were brought in under JAR regarding currency and revalidating/renewing licences every 2/5 years had zero effect on safety in the UK where there previously was only the requirement to do 5hrs a year IIRC…

The 5year renewal was scrapped with EASA and they also changed it to “a total of” an hour with an instructor… there was also the business of “in the last 3 months” which I think is also now gone?

I’ve always asked instructors to validate with a signature and licence number the time I fly with them in my logbook, regardless – and why wouldn’t they sign? They are signing they have done X amount of flying with me, nothing more, nothing less. If I have done 12hrs and an hour with him, and that instructor happens to have a FCL945 then I may ask them to revalidate my licence. There is nothing to stop me having 2x 30min aeroplane/club checkouts with different instructors who sign my logbook, or 2x 30 min aeros instruction flights, then ask a completely different examiner to sign my licence if I have also done the 12hrs required.

IIRC hours with an instructor count towards the 12 hours as do hours in a ULM (but not hours in instruction).
Has this changed again? I know sometimes its for the better but I do wish EASA would stop tinkering with the rules or at least give a good reason why they have changed and to what end.
Also it seems to me that these days more and more of these rules are being set locally by instructors and examiners and have nothing to do with EASA at all.


Silvaire wrote:

My understanding was that there are defined lesson plans for PPL training in e.g. the UK, the summation of which forms a schools syllabus. There is regardless no such thing for an FAA private pilot certificate, with the exception of requiring a solo cross county and some night dual it is largely left up to the instructor how he prepares the student to pass the oral and practical tests. And by the way, a student can take the FAA practical test in a non-electrical aircraft with no radio.

Sort of.

I don’t believe the CAA publishes a syllabus themselves, but unfortunately in line with EASA countries freelance teaching for the PPL is not allowed in the UK and it is all conducted within a CAA-approved organisation of some sort, even if that ‘organisation’ consists of the minimum number of people necessary to hold the required posts.

Having a syllabus is necessary to gain CAA approval, so you could say they mandate it but don’t prescribe exactly what it should be. In reality it has very little variation across different organisations and, AFAIK, is a slowly-evolving development of the post-war RAF syllabus for elementary flying training.


Qalupalik wrote:

The rule in FCL.945 places the instructor under an obligation to endorse the licence. Unless the relevant criteria have yet to be fulfilled, there is no provision for the instructor to withhold the endorsement.

Agreed. The misunderstanding comes from a mistaken impression held by some % of instructors and examiners that they are being asked to sign off the pilot as competent. They are actually signing in a purely administrative capacity, confirming that based on the logbook evidence available to them the requirements for revalidation by experience have been met.

As has been suggested, the thing to do if flying with an instructor for revalidation purposes is to establish expectations and an agreement up front. There might conceivably be some way to hold them to the regulation, but if you end up in a position where that’s even entering your mind then you got things wrong right from the start.

Some flying training businesses will of course attempt to use the system to drive revenue, i.e. no-one gets a signature without spending at least £X. This is more prevalent with renewals – on the one occasion my SEP lapsed I had to ask a few organisations before I found one that was willing to sell me only the proficiency check I was asking for. Most were trying to crowbar in some unspecified amount of training before the test.

Last Edited by Graham at 25 May 09:25

johnh wrote:

Note this bit also. I have no idea what these criteria are, but I’d be amazed if an instructor couldn’t say, “sorry mate, but you messed up on FCL.740A(b)(1)(93.276)(xii)(paragraph 13(b).2). No signature for you today”.

Be amazed. Or better yet, first get an idea of what the criteria are. Either you objectively meet them or you don’t. This is the whole of FCL.740.A(b)(1):

Single-engine piston aeroplane class ratings and TMG class ratings. For the revalidation of single-pilot single-engine piston aeroplane class ratings or TMG class ratings, the applicants shall:
(i) within the 3 months preceding the expiry date of the rating, pass a proficiency check in the relevant class in accordance with Appendix 9 to this Part with an examiner; or
(ii) within the 12 months preceding the expiry date of the rating, complete 12 hours of flight time in the relevant class, including:
— 6 hours as PIC,
— 12 take-offs and 12 landings, and
— refresher training of at least 1 hour of total flight time with a flight instructor (FI) or a class rating instructor (CRI). Applicants shall be exempted from this refresher training if they have passed a class or type rating proficiency check, skill test or assessment of competence in any other class or type of aeroplane

Last Edited by Airborne_Again at 25 May 10:07
ESKC (Uppsala/Sundbro), Sweden

I can’t comment in all cases but its not (always) done for the financial return.

When an ATO gets inspected they will at some point look at your SEP and MEP renewals.

Having a training record for a flight and then recommended for test is fair more palatable to your ops inspector than just proceed for test.

Of course this has been made easier for SEP ratings as if it has expired by less then 3 years it doesnt need to go through the ATO’s books.

And of course none of this at all is required under the FAA regs.

Be amazed

OK, it’s a fair cop. I’m amazed.

So if you have an EASA IR, which requires an annual skill test with an examiner, then you don’t need to do anything at all beyond that to keep your PPL valid (assuming you meet the flight experience requirements). That’s good to know.

LFMD, France
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