Hi Tim,
thank you.
However - and this is an information from 3rd march on a german forum:
EASA NPA 2014/28 / FCL.035(a) (2):
When flight time is completed during flights operated in the same class or type
of aircraft falling under points (a), (b), (c) or (d) of Annex II to Regulation
(EC) No 216/2008, it shall be given full credit for the purpose of issue,
revalidation
or renewal of a licence, rating or certificate.
French DGAC stated:
France supports the proposed draft for crediting hours performed on Annex II
aircraft.
Nevertheless in the same time France considers that the recognition shall
be extended to allow the conduct of all skill tests (for the purpose of
issuance/renewal
of a Part FCL licence, rating, certificate), proficiency checks
(for the purpose of revalidation of a Part FCL licence, rating, certificate)
and assessment of competences (for the purpose of issuance/renewal/revalidation
of Part FCL instructor/examiner certificates) on Annex II aircraft ((a), (b),
(c) and (d)) as long as the aircraft used is correctly fitted for performing
all relevant exercises during the practical examination as required by Part FCL.
It is not logical to credit Annex II hours in full for the purpose of the
issuance
of Part FCL licence, rating, and certificate and in the same time not
authorizing
the conduct of the practical exam on such Annex II aircraft.
To support this comment it should be noted for example that Appendix 4 B) (1)
states
that for a CPL(A) skill test : The aeroplane used for the skill test shall
meet the requirements for training aeroplanes, [...].
Therefore as long as the Annex II aircraft is meeting the requirements for
training
it is possible to use it for the skill test.
EASA Comment Response Document (CRD):
Not accepted
When the content of Annex II to the Basic Regulation was developed, Member
States
specifically wanted to exclude the aircraft referred to therein from the scope
of the Regulation and its implementing rules. When proposing to accept hours
flown on some Annex II aircraft, EASA considered that also hours flown on
third-country
registered aircraft would be credited for revalidation. Accepting
the use of AnnexII aircraft to obtain qualifications with skill tests or
assessments
of competence and perform proficiency checks on Annex II aircraft would
render the whole Annex II feckless. The intention was never to undermine Annex
II but to provide General Aviation with the possibility to continue to use
aircraft they were using for years already with the clear aim that at a certain
moment only equipment that was certified in accordance with the Basic Regulation
would be used for training, testing and checking.
Let's see what happens. Anyway it's very amazing, that the EASA GA task force
itsef
dislcaimed this with the words "We do not know where this is coming from.
We will publish an answer. Flyers will publish something to clarify." by the
beginning of last week, obviously not knowing, what is going on in the legal
department
of EASA.
Regards
Roland
Read this topic online here:
http://forums.matronics.com/viewtopic.php?p=478417#478417
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