It is not my way of putting it.
FFPLUM describe it as follows;-
“…..In effect we have always been opposed to this mixing of declarative systems and certified systems, which by its incoherence resembles " a marriage between a Carp and a rabbit"
(The French version of that is a saying here, I’m sure each country has it’s own expressions for 2 things which don’t fit together.)
gallois wrote:
basically extends Annex 1 aircraft to also cover ULM, was issued as a fait accompli without prior discussion.
That’s a very strange way of putting it. Annex 1 is an exclusion list and ULs have always been Annex 1 (or 2 initially) aircraft ever since the first Basic Regulation. In the current Basic Regulation ULs are in article 1(e) of Annex 1
Oh yes it is self inflicted. Both the FFPLUM and the DGAC claim that this directive which basically extends Annex 1 aircraft to also cover ULM, was issued as a fait accompli without prior discussion. They believe the Northern European countries have forced it through without discussion. Both the FFPLUM and the DGAC believe this to be the portent for the loss of liberty and greater regulation in the ULM world, and that EASA should not be interfering in what is supposed to be a domestic issue.
It is strange the DGAC have set out a statement confirming this directive and spelling out what it means, but I asked for confirmation from several ULM instructors, who had all seen and read the DGAC missive but are still saying you can not use the hours to validate the SEP by experience.
It is very weird, like A_A , I would have thought they would have welcomed it. I must ask what they are averse to..
gallois wrote:
But it does seem to be causing quite a lot of controversy in the ULM world.
I have a friend who participates is the european meetings between UL federations to try to align national regulations as much as possible.
The FFPLUM specifically is working double time to go the other way and make the french UL rules different from everybody else’s. If there is a controversy, it’s self inflicted.
I don’t see the problem either but for some reason there is. But then I am not a ULM pilot, at least not yet. I.might change my mind if it is correct :)
gallois wrote:
But it does seem to be causing quite a lot of controversy in the ULM world.
I don’t see why. For an UL pilot who does not also have a PPL or LAPL with SEP rating, it means nothing at all, For an UL pilot who does have an EASA license with SEP rating, it offers an opportunity to take or not as (s)he wishes.
@Airborne_Again AIUI this is a consequence of EASA trying to produce wording that allows time on Annexe 1 aircraft to count as SEP/LAPL hours for revalidations. But it does seem to be causing quite a lot of controversy in the ULM world.
Someone at our club has just received a response on it from the DSAC at Bordeaux. I will try and get a copy and post it with translation.
That’s how I read it too. But here you don’t need to revalidate a ULM licence or until recently, keep a log book/record of ULM hours. But if these hours can be used in full for the revalidation by experience of your SEP or LAPL, is there a downside to recording them in the same log book?
gallois wrote:
It appears that EASA has produced a directive AMC ED 2020/005. The consequence of which seems to suggest that 3 axis ULM hours should be entered in your log book and will count as SEP hours or LAPL hours which can be used to revalidate these qualificarions by experience ie the 12 hours in the second 2 year period, in the same way as one can count Annexe 1 hours.
They cannot be used as part of training hours for the PPL or LAPL.
I doesn’t say you have to enter them in the same log book as you use for SEP (if you keep separate log books). Of course if you use this option you must be able to demonstrate that you’ve actually done the flying you claim to have done, so it has to be logged somehow.
ULMists in France are looking for clarification from the DGAC as ULMs in France have nothing to do with EASA. At the moment it is very controversial.
The AMC seems crystal clear to me. It’s one thing that EASA doesn’t regulate ULs, but that doesn’t prevent EASA from determining that UL hours can be used for EASA purposes. EASA could decide that hours spent with a home PC simulator can contribute to SEP revalidation. (Of course they won’t, but in principle they could.)
What EASA can’t do is regulate the other way around – that flight time on EASA aircraft should contribute to the revalidation (or equivalent) of national UL licenses. That is entirely up to national authorities to decide.
In June 2020 our CAA published opinion quoting EASA AMC1 FCL.140.A.; FCL.140.S; FCL.740.A(b)(1)(ii) allowing to use UL time for SEP class rating revalidation. However UL can not be used for the one hour flight with instructor.
gallois wrote:
ULMists in France are looking for clarification from the DGAC as ULMs in France have nothing to do with EASA. At the moment it is very controversial.
Unexpected one sided concession by EASA. Interestingly our LAA was/is reluctant to take reciprocal concession.
gallois wrote:
3 axis ULM hours should be entered in your log book
The hours don´t have to be logged in GA logbook. They can be. I log them separately in my UL logbook.
