EASA CRT application Comments Seite 1 von 25 EASA Comment Response Tool You can save this page as HTML and then open it in Microsoft Word for further editing. Title Implementing Rules for Pilot Licensing PartFCL NPA Number NPA 200817b FOCA Switzerland (kurt.brechbuehl@bazl.admin.ch) has placed 102 unique comments on this NPA: Cmt Segment description 479 B. Draft A: General FCL.020 Studen pilot 3140B. Draft A: General FCL.045 Obligation to carry and present documents 480 B. Draft A: General FCL.055 Language proficiency PageComment 5 FCL 020 Add text as per ICAO Annex 1, Para 2.2.3 Medical fitness: A contracting State shall not permit a student pilot to fly solo unless the student pilot holds a current Class 2 Medical Assessment. 7 FCL.045 (c)(2 7 9 Para shall be changed for a new letter (d) with this text. FCL.055 Aggravation of ICAO Annex 1, para 1.2.9 Language proficiency: s: General: Annex 1: Para 1.2.9 Use ICAOtext instead EASAtext (a) For glider and free balloon pilots only recommendation to have language endorsement. (b) Language endorsement shall have a date of expiry. (c) (1) 4 years for VFR: Synchronisation with SEPrevalidation (every 2nd check with language combined) (d)(3) to be deleted: Not feasible to check properly, no sense as requirement. (e) Applicable not only for IR but also for VFR Table on page 8 not taken correctly from ICAObasis. (Refer to AMC # 1 FCL.055. Attachme 3141B. Draft A: General FCL.060 Recent experience 481 B. Draft 9 FCL.060 Recent experience 9 10 90 days rule for balloon has to be reviewed due to the possibility to use a balloon throughout the year timewise seen. FCL.065 ICAOstudy in progress.
EASA CRT application Comments Seite 2 von 25 A: General FCL.065 Curtailment of privileges of licence holders aged 60 years or more 3142B. Draft A: General FCL.070 Revocation, suspension and limitation of licences, ratings and certificates 483 B. Draft B: Leisure Pilot Licence LPL Section 1: FCL.120 LPL Theoretical knowledge examination 484 B. Draft B: Leisure Pilot Licence LPL Section 2: Basic LPL aeroplane and helicopter categories FCL.105.BA/H Basic LPL Privileges 485 B. Draft B: Leisure Pilot Licence LPL Section 3: LPL for aeroplanes FCL.110.A LPL(A) Experience and crediting Rule is too restrictive since in our county pension scheme starts from 65th anniversary only. Single pilot commercial air transport and aerial work shall be allowed until the age of 65 on national territory only. 10 FCL.070 Needs more clarification and shall be reflecting the precise information as given in AR.FCL.250. 11 FCL.120 (a)(1) Communications The requirement "Communication" shall not be mandatory for LPL and is to be deleted. 12 B/Section 2 FCL.105.BA/H, FCL 110.BA/H, FCL.135.BA/H and FCL.140.BA/H 13 14 General On the principle that aviation must be founded on a safe basis, the above mentioned categories do not comply with such a policy and must therefore be deleted as a whole. B/Section 3 FCL.110.A (b) Remark: In case Section 2 is abolished then para (b) is obsolet.
EASA CRT application Comments Seite 3 von 25 486 B. Draft B: Leisure Pilot Licence LPL Section 4: LPL for helicopters FCL.110.H LPL(H) Experience and crediting 487 B. Draft B: Leisure Pilot Licence LPL Section 4: LPL for helicopters FCL.140.H LPL(H) Recency 3143B. Draft B: Leisure Pilot Licence LPL Section 6: LPL for balloons FCL.105.B LPL(B) Privileges 488 B. Draft C: Private Pilot Licence (PPL), Sailplane Pilot Licence (SPL) and Balloon Pilot Licence (BPL) Section 1: FCL.215 Theoretical knowledge examination 3144B. Draft C: Private Pilot Licence 14 15 B/Section 4 FCL.110.H (b) Remark: In case Section 2 is abolished then para (b) is obsolet 15 B/Section 4 FCL.140.H Remark With regard to the conditions for PPL/CPL/ATPLholder, for same type of helicopter different revalidation ; less stringent for LPL(H) and the others. What happens with the recency if the pilot holds more than one helicopter TR. Does he have to comply with (a) (1)? 17 B/Section 6 FCL.105.B Change privileges as follows:.. with a maximum of 3500m3 instead 4000m3 (certification limitation). 18 C/Section 1 FCL.215 (a) 18 19 The requirement "Communication" shall not be mandatory. C/Section 1 FCL.235 (a) Since there is no reason for it: > delete last sentence with the 6 months rule
EASA CRT application Comments Seite 4 von 25 (PPL), Sailplane Pilot Licence (SPL) and Balloon Pilot Licence (BPL) Section 1: FCL.235 Skill Test 3145B. Draft C: Private Pilot Licence (PPL), Sailplane Pilot Licence (SPL) and Balloon Pilot Licence (BPL) Section 2: PPL aeroplanes FCL.210.A PPL(A) Experience and crediting 3146B. Draft C: Private Pilot Licence (PPL), Sailplane Pilot Licence (SPL) and Balloon Pilot Licence (BPL) Section 5: PPL airships FCL.210.As PPL(As) Experience and crediting 490 B. Draft D: Commercial Pilot Licence CPL Section 2: aeroplane category FCL.305.A CPL(A) 19 C/Section 2 FCL.210.A (c) Indication for credit is clear. There is no need for last sentence in this para. To be deleted. 20 C/Section 5 FCL.210.As (2) " at an aerodrome" to be deleted. 24 D/Section 1 FCL.305 (a)(1) Conditions too stringent. The whole content of this para shall be replaced by the text of JARFCL 1.150 accordingly.
EASA CRT application Comments Seite 5 von 25 Privileges in commercial air transport 491 B. Draft D: Commercial Pilot Licence CPL Section 3: helicopter category FCL.305.H CPL(H) Privilege to act in commercial air transport 1092B. Draft E: MultiCrew Pilot Licence MPL FCL.405.A MPL Privileges 25 D/Section 3 FCL.305.H (a) (1) Conditions too constraints. The whole content of this para shall be replaced by the text of JARFCL 2.150 accordingly. 26 E/ FCL.405.A Privileges Subpart K of the JARFCL rules deal with the of a MultiCrew Pilot Licence. With regard to the "Privileges and Conditions" there is no specific indication as to the an applicant for a "Full" ATPL has to comply with. NPA 200817a, Subpart E/ FCL.400.A now is regulating the MultiCrew Licence and includes all the for such a licence. However, in all the rules applicable we do not find any clear and precise indication concerning the as to "experience and crediting" and reference to the "skilltest" which a candidate to get a "Full" ATPL out of his MultiCrew Pilot Licence has to comply with. 701 B. Draft E: MultiCrew Pilot Licence MPL FCL.410.A MPL Training course and Theoretical knowledge examinations 492 B. Draft F: Airline Transport Pilot Licence We are of the opinion that this item missing needs to be developed and taken into consideration as a clear procedure to apply by the authorities. 26 E/ FCL.410.A and Appendix 5 Clarification: The term FTO has been changed to an "approved training organisation". This might be unclear compared to the known expressions "FTO / TRTO" in the JARs. 27 F/Section 1 FCL.515 This para needs more clarification.
EASA CRT application Comments Seite 6 von 25 ATPL Section 1: FCL.515 ATPL Training course and theoretical knowledge examinations 532 B. Draft G: Instrument Rating IR Section 1: FCL.600 IR General 493 B. Draft G: Instrument Rating IR Section 1: FCL.610 IR Prerequisites 494 B. Draft G: Instrument Rating IR Section 1: FCL.625 IR Validity, revalidation and renewal 495 B. Draft G: Instrument Rating IR Section 3: helicopter Applicants for a training course in ATPLTheory.. 31 G/Section 1 FCL.600 activities actually possible for certain categories are missing and need to be regulated commonly. To be added: Instrument rating with specific for cloud flying with gliders. Instrument rating with specific for balloon category (departure in fog) Instrument rating (departure and arrival in fog) with specific for helicopter category. 31 G/Section 1 FCL.610 for a better understanding, add the following editorial change. FCL.610 (a) (1) and (2): Reference to FCL.810 32 G/Section 1 FCL.625(a) Validity: Is in contradiction with AR:FCL.215 FCL.625 (b)(1): "shall" is not acceptable. Check can be done on any date. FCL.625 (d) With regard to FCL.025 (c) (2) similar text is required... has not been revalidated, will remain valid for 7 years from the last validity date entered in the licence. 33 G/Section 2 FCL.630 (H): Missing reference for aeroplane (A): The same para to add accordingly under aeroplane (A).
EASA CRT application Comments Seite 7 von 25 category FCL.630.H IR (H) Extension of privileges from singleengine to multiengine helicopters 496 B. Draft H: Class and Type Ratings Section 1: FCL.700 Circumstances in which class or type ratings are required 34 H/Section 1 FCL.700 For logical reason and harmonisation, a similar system should be for helicopter as it is for aeroplane. The following system should be implemented: Multiengine single pilot (individually) Singleengine single pilot piston Singleengine single pilot turbine 497 B. Draft H: Class and Type Ratings Section 1: FCL.725 issue of class and type ratings 2211B. Draft H: Class and Type Ratings Section 1: FCL.725 issue of class and type ratings 498 B. Draft H: Class and Type Ratings Section 1: FCL.740 Validity and renewal of class and type ratings 34 35 34 35 For helicopter crosscrediting according App. 1 to JARFCL 1.245 (b)(3) shall apply. H/Section 1 FCL.725 (a) JARFCL rule 1.261 (c)(3) shall be integrated in the whole rule as otherwise it would have an impact for FI and CRI to conduct training. H/Section 1 FCL.725 (c) The applicant shall pass the skilltest within a period of 24 months after the completion of the type rating training course and preceding the application issue of the type or class rating. Alternatively: Delete the whole last part of (c) 35 H/Section 1 FCL.740 General For harmonisation reason there should be no difference between aeroplane and helicopter class and typeratings. With reference to FCL.725 a similar validity for helicopter classes should be possible.
EASA CRT application Comments Seite 8 von 25 499 B. Draft H: Class and Type Ratings Section 2: aeroplane category FCL.720.A Experience and prerequisites for the issue of class or type ratings aeroplanes 2210B. Draft H: Class and Type Ratings Section 3: helicopter category FCL.720.H Experience and prerequisites for the issue of type ratings helicopters 510 B. Draft H: Class and Type Ratings Section 3: helicopter category FCL.735.H Multicrew cooperation training coursehelicopters 511 B. Draft H: Class and Type Ratings Section 3: 35 36 (b)(1) Text to compare with AMC.FCL.740 (b)(1) H/Section 2 FCL.720.A (c)(4)(iv) This provision did not exist in JARFCL 38 H/Section 3 FCL.720.H 38 39 (a)(3) If the pilot acts as PIC, have passed the ATPL (H) theoretical knowledge examination. H/Sections 3 and 5 FCL.735.H FCL.735.As MCCTraining is Generic There is no difference between MCC/IR and MCC/VFR: The are identical and shall be either 10 hours or 15 hours. Furthermore, the crosscredit for any other category shall be adapted accordingly. 39 H/Section FCL.740.H s: (a)(1) MP prof. check on SPcertified helicopters should be
EASA CRT application Comments Seite 9 von 25 helicopter category FCL.740.H Revalidation of type ratings helicopters also valid revalidation for a TR SP. (a)(3) and Appendix 11 Create as in FCL.740.A a special Classrating for Single pilot helicopter (SEP (H)) which contains all ratings according appendix 11. Such a Classrating shall be revalidated with flight experience and a training flight with a FI. > Additional reference for SP helicopter being used in Multipilot operation: Single pilot certificated helicopters being operated in Multipilot Operations such skilltest and/or profchecks must be taken in Multipilot environment. 512 B. Draft H: Class and Type Ratings Section 4: poweredlift aircraft category FCL.720.PL Experience and prerequisites for the issue of type ratings poweredlift aircraft 517 B. Draft I: Additional Ratings FCL.800 Aerobatic rating 39 40 H/Section 4 FCL.720.PL Remark (c)(4) Conditions are higher if qualified to fly both aeroplanes and helicopters. 42 I/ Additional ratings FCL.800 s: (b)(1) 40 hours experience to low, minimum 100 hrs 518 B. Draft I: Additional Ratings 42 I/ FCL.805 (b)(3) 5 hrs (aeroplane or helicopters) or 3 hrs (sailplanes) or dual aerobatic instruction time. (c).. has successfully completed dual familiarisation with an instructor.. and passed a skilltest.
EASA CRT application Comments Seite 10 von 25 FCL.805 Sailplane towing and banner towing ratings 514 B. Draft I: Additional Ratings FCL.810 Night rating 519 B. Draft I: Additional Ratings FCL.815 Mountain ratings 42 43 (b)(1) Completion of at least 50 hrs of flight time for towing rating I/ FCL.810 43 I/ FCL.815 (a) Categories glider and balloon to be deleted. (c) (2) 5 hrs of dual instruction at night; night flying on TMG and/or aeroplane may be considered. (c) (3) Sentence to be deleted, no restriction Whole paragraph needs to be redone and to differentiate between "aeroplane and helicopter" mountain landing. (a) It is needed to define which categories (aeroplane and helicopter) are included in the mountain rating and also it is necessary to list the specific for each category individually. Furthermore there should also be a procedure for crosscredit if a pilot holds the mountain rating for both categories (aeroplane and helicopter). (b) In the training course shall be a requirement that each period of the year needs to be taken into consideration with regard to training in different environment. 521 B. Draft Section 1: FCL.900 Instructor certificates 526 B. Draft 45 J/Section 1 FCL.900 Clarification concerning instruction outside EASA. Remark: OR.ATO.145 refers to such training but there are no precise mentioned. Needs to be clarified. (b) (1) add: Vintage aircraft 46 J/Section 1 FCL.920
EASA CRT application Comments Seite 11 von 25 Section 1: FCL.920 Instructor competencies and assessment 527 B. Draft Section 2: light aircraft flight instructor FCL.905.LAFI LAFI Privileges and conditions 3165B. Draft Section 2: light aircraft flight instructor FCL.905.LAFI LAFI Privileges and conditions 528 B. Draft Section 2: light aircraft flight instructor FCL.915.LAFI Prerequisites LAFI training course 529 B. Draft Section 3: flight instructor FCL.905.FI FI Privileges and conditions 3173B. Draft (b) Delete: ".. and the mountain rating instructor (MI).." 47 J/Section 2 FCL.905 (d) (e) There shall be no such ratings. Ratings such as stated shall only be possible for holder of a full PPL. 47 J/Section 2 FCL.905.LAFI 47 48 49 51 51 Delete whole section J/Section 2 FCL.915 LAFI (d) Flight experience must be augmented up to at least 200 hrs. A credit of up to 50% in aeroplane is accepted. J/Section 3 FCL.905.FI (g) Aerobatic instruction requires additional capabilities and skills of the FI. Therefore he should follow an ACR instructor's course prior to have the capabilities extended. Refer to para (e) (2): same procedure should apply. J/Section 3 FCL.915.FI
EASA CRT application Comments Seite 12 von 25 Section 3: flight instructor FCL.915.FI Prerequisites FI training course 667 B. Draft Section 3: flight instructor FCL.940.FI FI Revalidation and renewal 668 B. Draft Section 5: class rating instructor FCL.905.CRI CRI Privileges and conditions 671 B. Draft Section 5: class rating instructor FCL.905.CRI CRI Privileges and conditions 669 B. Draft Section 5: class rating instructor FCL.930.CRI CRI Training course 672 B. Draft 52 52 53 Prerequisites not according ICAO. PPL holder should have passed CPLtheory (c)(3) add: VFR J/Section 3 FCL.940.FI Missing item: In the list of the different flight instructors to be added: LAFI 56 J/Section 5 FCL.905.CRI (b)(1) Adaption to the with regard to the minimum flight experience for CRI (10 hours) compared to FI (15 hrs) if privileges shall be extended to further types or classes. 56 J/Section FCL.905.CRI (a) Privileges should be extended to instruct for "aerobatic, towing and Mountain landing" under the same conditions as stated in FCL.905.FI. 56 J/Section 5 FCL.930.CRI 58 Based on which conditions or does a training organisation nominate the instructor for this purpose? (b)(3) Minimum conditions for such nomination should be given and clarified. J/Section 7 FCL.905.SFI (
EASA CRT application Comments Seite 13 von 25 Section 7: synthetic flight instructor FCL.905.SFI SFI Privileges and conditions 674 B. Draft Section 7: synthetic flight instructor FCL.930.SFI SFI Training course 3176B. Draft Section 7: synthetic flight instructor FCL.930.SFI SFI Training course 673 B. Draft Section 9: synthetic training instructor FCL.915.STI Prerequisites STI training course 678 B. Draft Section 10: Mountain rating instructor FCL.905.MI MI 59 Correction: (a)(3) A SFI is entitled to carry out synthetic flight instruction for: > the revalidation of instrument ratings, provided the SFI holds a valid instrument rating. 59 J/Section 7 FCL.930.SFI As other instructors such training course includes 25 hours of theoretical knowledge, the same need to be added also SFI. 59 J/Section 7 FCl.930.SFI 61 62 Provisions for additional types has to be foreseen J/Section 9 FCL.915.STI Clarification: (a) With regard to the written requirement to hold or have held instructional privileges to start such training course there seems to be not at all a provision in order to get on an initial training course with regard to become a STIrating. 62 J/Section 10 FCL.905.MI The validity of the following instructor ratings (FI, CRI and TRI(H) shall integrate the MIrating duration.
EASA CRT application Comments Seite 14 von 25 privileges and conditions 676 B. Draft Section 10: Mountain rating instructor FCL.915.MI Prerequisites MI training course 677 B. Draft Section 10: Mountain rating instructor FCL.915.MI Prerequisites MI training course 680 B. Draft Section 1: FCL.1010 Prerequisites for examiners 62 63 62 63 J/Section 10 FCL.915.MI Clarification: In the list of potential instructor ratings, there should be a clarification with regard to the TRI: (a) in this context, a TRI (H) is meant since for helicopter there is no CRIinstructor rating. J/Section 10 FCL.915.MI For a safety improvement with regard to the experience and recency, we require a significant augmentation concerning the landing sites. (c).. 100 landings at a minimum of 10 different places and within 12 months preceding the course. 64 K/Section 1 FCL.1010 The new regulation regarding examiner certificates leads to the following drawbacks: Since the work of an examiner will be governed by commercial rather than by safetyrelated consideration, there might be a deterioration of the standards during the checks. As anyone will be entitled to become an examiner, no considerations regarding character and personality of the applicant will be taken into account, This might lead to an uncontrollable situation. The TRE will have the privilege to checkout TRI's instructor without being assigned to do so by the competent authority. Therefore there will also be no control of the quality of the TRI's. Any applicant for a check will have the right for appeal with the competent authority if a check is failed. The examiner, however, will not work on behalf of the authority, so there might be legal implications in such case. It is of outmost importance that examiner are remaining under a strict control of the competent authority with regard to the nomination, instruction and guidance.
EASA CRT application Comments Seite 15 von 25 682 B. Draft Section 1: FCL.1010 Prerequisites for examiners 3186B. Draft Section 1: FCL.1015 Examiner standardisation 64 K/Section 1 FCL.1010 With regard to the importance of the examiner's loyalty to the competent authority, a new paragraph, taking that into consideration, should be added. d).. shall be evaluated by the competent authority in regard of personality and character, cooperation with the authority as well as demand for examiners. 64 K/Section 1 FCL.1015 Clarification (b) Not in conformity with AMC to FCL.1015 regarding course duration. A one day course, in section 1 only covers theoretical matters vs a course, divided into theory and practical matters according subpart K. 684 B. Draft Section 1: FCL.1030 Obligations for examiners 685 B. Draft Section 2: for flight examiners FCL.1005.FE FE Privileges and conditions 687 B. Draft Section 2: 65 66 66 67 66 67 AMC to FCL.1015 1.1.1 should read:.. at least two days.. the assessment might be counted as practical training. K/Section 1 FCL.1030 The possibility for examiners to endorse pilot's licences shall influence the surveillance / controlprocedure authority. ally the regular update licensing system will be affected and therefore the authority can not guarantee the validity of their information. (b)(2) To add: Such procedure can only be granted to examiners by the competent authority for whom they belong and only for revalidation of class/typeratings exclusively. K/Section 2 FCL.1005.FE to be added: (a)(4).. of a mountain rating, provided the examiner has completed at least 50 hours of flight instruction experience in mountain flying. K/Section 2 FCL.1005.FE Clarification of for FE for multiengine helicopter
EASA CRT application Comments Seite 16 von 25 for flight examiners FCL.1005.FE FE Privileges and conditions 686 B. Draft Section 2: for flight examiners FCL.1010.FE FE Prerequisites 688 B. Draft Section 3: for type rating examiners FCL.1010.TRE TRE Prerequisites 689 B. Draft Section 4: for Class Rating Examiner FCL.1010.CRE CRE Prerequisites 3184B. Draft Section 4: for Class Rating Examiner FCL.1010.CRE CRE Prerequisites 690 B. Draft Section 6: for Synthetic Flight (b)(2)(iii) take same wording as of JARFCL 2.435 (a) 67 K/Section 2 FCL.1010.FE 68 69 With regard to FCL.1000.FE (a)(1) "hold a licence and rating at least equal to the licence.." the requirement is too demanding. (a)(1)(i) In the case of aeroplanes.., hold a PPL or CPL. K/Section 3 FCL.1010.TRE (5)(ii) Since for a FE(H) it is sufficient to hold a PPL in case of a singlepilot singleengine helicopter, it also should be sufficient in the same case for a TRE(H). (5)(ii) to add:..hold a private pilot licence.. 69 K/Section 4 FCL.1010.CRE (a) take the wording of JARFCL 1.445 (b) which includes the whole paragraph. 69 K/Section 4 FCL.1010.CRE Clarification (a) the MPlicence holder must have singlepilot privileges 70 K/Section 6 FCL.1005.SFE Since the conditions are similar for SFE's as for CRE's with regard to the IR, same wording to be used.
EASA CRT application Comments Seite 17 von 25 Examiner FCL.1005.SFE SFE privileges and conditions 692 B. Draft Section 6: for Synthetic Flight Examiner FCL.1010.SFE SFE Prerequisites 693 B. Draft Section 7: flight instructor examiner FCL.1005.FIE FIE Privileges and conditions 694 B. Draft Section 7: flight instructor examiner FCL.1005.FIE FIE Privileges and conditions 695 B. Draft Section 7: flight instructor examiner FCL.1010.FIE FIE Prerequisites 696 B. Draft Section 7: flight (b)(2).. provided that the SFE holds an IR(H) 70 K/Section 6 FCL.1010.SFE (b)(1) Adaption in analogy as of FCL.1005.SFE (b)(2) (b)(1).. and if applicable an IR(H) on the applicable type. 71 K/Section FCL.1005.FIE Correction TRI and SFI are ratings for Multipilot instruction, has nothing to do with basic instruction. (a) TRI(A) and SFI(A) to be deleted from the list. 71 K/Section 7 FCL.1005.FIE The following changes to apply: (b) add TRI(H) with SP delete SFI(H) 71 K/Section 7 FCL.1010.FIE Following change to be made; TRE is multipilot and not adequate in this place: (a)(1) delete TRE(A) 71 K/Section 7 FCL.1010.FIE For clarification, the following change to apply: (b)(1) add TRE(H) with SP
EASA CRT application Comments Seite 18 von 25 instructor examiner FCL.1010.FIE FIE Prerequisites 697 B. Draft FCL Appendix 1: Crediting of Theoretical Knowledge 698 B. Draft FCL Appendix 1: Crediting of Theoretical Knowledge 72 73 72 73 Appendix 1: Crediting of theoretical knowledge 1.1.2 LPL, PPL, BPL and SPL With regard to credit the common subjects, this shall only be possible if the content of the subjects is similar issue of each licence category. Appendix 1 Crediting of theoretical knowledge 1.1: FCL.120 (a)(1) lists "Navigation" as specific subject, though it is missing under this paragraph. 699 B. Draft FCL Appendix 3: Training courses for the issue of a CPL, an ATPL and an IR A. ATP integrated course aeroplanes 82 83 2.2: JARFCL divides subject "Flight Performance and Planning" in 3 subchapters (31: Mass and Balance; 32: Performance; 33: Flight Planning and Monitoring). It is desired to add the subjects 31 and 33 and also to be taken as exam topics. Appendix 3 A. ATP integrated course aeroplane; Para 10 (b) B. CPL/IR integrated course aeroplane, Para 9 (b) Clarification for course duration and SPICtime as it is not defined in FCL.010 s Provision to extend course duration, with extra training if needed, should be foreseen. This applies for all courses. 700 B. Draft FCL Appendix 4: Skill test for the issue of a CPL C. Content of the skill test issue of the CPL Helicopters 702 B. Draft FCL Appendix 5: Integrated MPL training 100 102 106 108 Take wording for SPIC as stated in JARFCL 1.001 "Definitions and Abbreviations". Appendix 4 Skill Test issue of a CPL C. Content of SkillTest For safety reason since too high risk item: Table Section 2, lettre o: Autorotative landing: to be deleted. Appendix 5 Integrated MPL Training Course General Wording too restrictive; up till now, also PPLHolders are
EASA CRT application Comments Seite 19 von 25 course accepted. 3487B. Draft FCL Appendix 8: Crosscrediting of the IR part of a type or class rating proficiency check A. Aeroplanes 703 B. Draft FCL Appendix 9: Skill test and proficiency check for ATPL,. Type and class ratings and proficiency check for instrument ratings A. General 3488B. Draft FCL Appendix 9: Skill test and proficiency check for ATPL,. Type and class ratings and proficiency check for instrument ratings A. General 705 B. Draft FCL Appendix 9: Skill test and proficiency check for ATPL,. Type and class ratings and proficiency check for instrument Paragraph 4: Delete: Only abinitio applicants 121 Appendix 8; B. Helicopters 123 124 123 124 128 131 Add star " * " in table "credit is valid towards.." in lines 2, 5 and 6 Appendix 9 Skill Test and Proficiency Check Clarification: Since the check scenarios are not a task to develop by the authority, clarification is needed. # 6: Change into: ".. developed by the operator and approved by the competent authority." # 9: Text should be written as in paragraph27 of AMC 2 to 1015. # 10: delete the words: "as if there is no other crew member" Appendix 9 General Titel: MPL is missing Exam forms need to be in conformity with the ones in JARFCL Appendix 9 2. Multi pilot aeroplanes Section 3 (after last figure 3.8.1) Clarification To add: Missing sections 4, 5 and 6
EASA CRT application Comments Seite 20 von 25 ratings B. aeroplane category 2. Multi pilot aeroplanes 3489B. Draft FCL Appendix 11: Crosscrediting of proficiency checks for revalidation of type ratings Helicopters 3490B. Draft FCL acceptance of licences issued by or on behalf of third countries 706 B. Draft FCL conversion of national licences and ratings for aeroplanes and helicopters A. Aeroplanes 1 Pilot licences 707 B. Draft Decision Part FCL AMC and GM Subpart A: General AMC to FCL.050 Recording of flight time 155 Appendix 11 Crosscredit Table 159 161 162 163 173 181 Wouldn't it better to become an AMC? Annex III to the implementing regulation General: Validation seems no longer be possible? Annex IV to the implementing regulation Clarification: In the table reference is made to the conversion of national licences and ratings. Since there is no distinction between "National ICAOlicences" and JARFCLlicences, it is not clear if there will be a different procedure replacement of such licences. Secondly, as Glider and Balloon licences will be replaced in future by EASAlicences, there is also the need to have procedures and tables indicating the respective. AMC to FCL.050 Recording of flight time: Clarification logbook: The single pilot time in column 5 is only ticked in the example. This makes it very difficult to indicate and verify the actual totals of either Singleengine or Multiengine time. 3491B. Draft Decision Part 187 Add respective additional columns for clear notification of each activity in hours and minutes. II Draft Decision AMC and GM for PartFCL Subpart A
EASA CRT application Comments Seite 21 von 25 FCL AMC and GM Subpart A: General AMC No 2 to FCL.055 Language proficiency for holders of an IR 708 B. Draft Decision Part FCL AMC and GM Subpart B: Leisure pilot licence LPL AMC to FCL.120 and FCL.125 Theoretical knowledge examination and skill test LPL 709 B. Draft Decision Part FCL AMC and GM Subpart B: Leisure pilot licence LPL AMC No 1 to FCL.125 Contents of the skill test issue of a Basic LPL (A) and a LPL (A) 188 AMC No 2 to FCL.055 Paragraph 3 unreadable 196 AMC to FCL.120 and FCL.125 196 200 It is desired to have a centralised "Question Bank" oretical examination knowledge as it exists for CPL / IR and ATPL (A/H). The examination needs to be harmonised in order to be mutually accepted. Such examination should be translated in English and national languages as appropriate. Subpart B AMC # 1 to FCL.125; Para 4 "with simulated engine failure" Since BLPL and LPL pilots are only entitled to operate single engine aeroplanes, such limitation shall be deleted. Section 3 (En route procedures) Clarification: BLPL are not entitled to fly in meteorological conditions which do not allow to return to the field of departure.. Limit this item to LPL only, excluding BLPL. 3492B. Draft Decision Part FCL AMC and GM Subpart B: Leisure pilot licence LPL AMC No 1 to FCL.125 Contents of the skill test issue of a Basic LPL (A) and a LPL (A) 196 200 Subpart B Leisure Pilot Licence AMC 1 to FCL.125; Para 4 The limitation with simulated engine failure is not adequate AMC 1 to FCL.125 and to FCL.235 Section (3)(a) of report form is not applicable for glider AMC 2 to FCL.125 and to FCL.235 Para 2: It should be clear that skilltest are not carried out when a mass of peple is around AMC 1 to FCL.110.BA/H If this AMC stays in it should follow the same structure as PPL. Para 2.2: should the pilot be instructed in "RT" as well.
EASA CRT application Comments Seite 22 von 25 664 B. Draft Decision Part FCL AMC and GM Subpart B: Leisure pilot licence LPL AMC No 2 to FCL.125 Contents of the skill test issue of a Basic LPL (H) and a LPL (H) 665 B. Draft Decision Part FCL AMC and GM Subpart B: Leisure pilot licence LPL AMC to FCL.135.S and FCL.225.S Extension of privileges to touring motor gliders LPL (S) and SPL 3495B. Draft Decision Part FCL AMC and GM Subpart C: Private Pilot Licence (PPL), Sailplane Pilot Licence (SPL) and Balloon Pilot Licence (BPL) AMC No 1 to FCL.220 Contents of the skill test issue of a PPL(A) 666 B. Draft Decision Part FCL AMC and GM Subpart C: Private Pilot Licence (PPL), Sailplane Pilot 200 204 247 253 321 324 329 338 This remark is valid for all non ICAOlicences foreseen in this part. AMC to FCL.135.S and FCL.225.S Theoretical knowledge subjects are different from those foreseen in FCL.135.S AMC 1 and 2 to FCL.135.B and FCL.225.B Title and content not in accordance. Subpart B AMC No 2 to FCL.125; Section 2; letter "n" For safety reason: Delete "Autorotative landing" Subpart B AMC to FCL.135.S and FCL.225.S Crediting of theoretical knowledge issue of a pilot licence in another category shall only be possible if such examination on the common subjects contains the same level for all categories. Subpart C AMC No 1 to FCL.220 Para 4 add:.. with simulated engine failure if multiengine aeroplane is used. Subpart C AMC to FCL.210.A The flight instruction syllabus should take into account also the local environment and geographical topography of the country in which instruction for the issue of licence is given.
EASA CRT application Comments Seite 23 von 25 Licence (SPL) and Balloon Pilot Licence (BPL) AMC to FCL.210.A Flight Instruction Private Pilot Licence Aeroplane 3496B. Draft Decision Part FCL AMC and GM Subpart C: Private Pilot Licence (PPL), Sailplane Pilot Licence (SPL) and Balloon Pilot Licence (BPL) AMC to FCL.225.B Extension of privileges to another balloon class or group 3500B. Draft Decision Part FCL AMC and GM Subpart H: Class and Ratings AMC No 2 to FCL.725(a) Flight Instruction for Type Ratins Helicopters 3501B. Draft Decision Part FCL AMC and GM Subpart H: Class and Ratings AMC to FCL.730.A Requisites for pilots undertaking a zero flight time type rating (ZFTT) course 3502B. Draft Decision Part FCL AMC and GM Subpart H: Class and Ratings AMC to FCL.740.H Revalidation 359 Subpart C AMC to FCL.225.B 373 375 Titel: Delete "group", only classes for balloon Subpart H AMC No 2 to FCL.725 (a) to replace by same structure and tables as in JARFCL (H) 376 Subpart H AMC to FCL.730.A Delete whole paragraph 384 Subpart H AMC to FCL.740. To change wording: Helicopter have no classes
EASA CRT application Comments Seite 24 von 25 and renewal of type ratings helicopters 530 B. Draft Decision Part FCL AMC and GM Subpart I: Additional Ratings AMC to FCL.800 Aerobatic Rating Theoretical knowledge and flying training 3503B. Draft Decision Part FCL AMC and GM Subpart I: Additional Ratings AMC to FCL.810 PPL(H) Night Rating Course 3504B. Draft Decision Part FCL AMC and GM Subpart I: Addition Ratings AMC No 1 to FCL.815 Mountain rating Theoretical knowledge and flying training 531 B. Draft Decision Part FCL AMC and GM Subpart J: Instructors AMC to FCL.900 Instructor certificates 3505B. Draft Decision Part FCL AMC and GM Subpart K: Examiner Certificates AMC to FCL.1015 Examiner standardisation 385 386 388 389 390 392 Subpart I AMC to FCL.800 Flying Training Para 4 Aerobatic maneuvers with regard to "loop and inverted loop" to be reviewed. It is important to have a clear definition of the figures ambiguous (may differ in the countries); Reference to catalogue ARESTI. Introduction of a seperate superieure instruction with specific figures strogly recommended. Subpart I AMC to FCL.810 Night rating course for PPL (A) foreseen AMC for night rating for balloon also needed Subpart I AMC No 1 to FCL.815 Mountain rating instruction shall address and specify items for both activities, such as aeroplane and helicopter. 394 Subpart J AMC to FCL.900 1 General 576 577 Editorial Para 1.1 (a) to be deleted completely (g) add: MCCI (H) Para 1.2 Change as follows:..for categories a) to e) and for i) /instead f Subpart K AMC to FCL.1015 Inconsistence with regard to FCL.1015 (b)(1); 1 day course
EASA CRT application Comments Seite 25 von 25 course Page viewed on 20090217 12:11:20 GMT Copyright 20052009 EASA