EASA Comment Response Tool You can save this page as HTML and then open it in Microsoft Word for further editing. Title NPA Number 2008-17b Implementing Rules for Pilot Licensing - Part-FCL ERA (robert.peel@eraa.org) has placed 13 unique comments on this NPA: Cmt# Segment 891 B. Draft Subpart A: General - FCL.035 Crediting of flight time and theoretical knowledge 6-7 FCL.035 Crediting of Flight time and theoretical knowledge. In the JAR-FCL 1.050 article (a) Crediting of flight time, a graduate of an airline transport pilot flying training course is entitled to be credited with up to 50 hours of student pilot-incommand instrument time. Article FCL.035 does state any equivalent credit time. ERA are requesting this credit be re-introduced to Artcle FCL.035. 893 B. Draft Subpart D: Commercial Pilot Licence - CPL - Section 2: category - FCL.305.A CPL(A) - Privileges in commercial air transport 894 B. Draft Subpart H: Class and Type Ratings - Section 2: FCL.035 (a)(3)(ii). Whilst the JAR-FCL article 1.050 and the IR-FCL.035 are almost identical, there is an extra condition in JAR-FCL article 1.050 that states "method should be approved by authority". ERA would like to understand why that condition has been removed from the FCL.035? 24 FCL.305.A CPL(A) Privileges in commercial air transport 35-36 Paragraph (a)(1) and (2) conditions in FCL.305A do not have any equivalent in JAR-FCL. ERA members view these as new and extra conditions to work in commercial air transport. ERA members are therefore seeking some justification ir addition. ERA members are requesting their deletion and a reversion to the JAR-FCL list of conditions. FCL.720.A Experience and prerequisites issue of class or type ratings The concern regarding the size of this draft document and the complexity this adds to any
category - FCL.720.A Experience and prerequisites for the issue of class or type ratings - 902 B. Draft Subpart J: Instructors - Section 4: type rating instructor - FCL.905.TRI TRI - Privileges and conditions review is illustrated by FCL.720A. Tracing the exemption from the requirement to hold a certificate of completion of additional theoretical knowledge undertaken for class and type ratings for additional high performance to be included on a pilot licence is virtually impossible to find as there is no reference in FCL 720A to AMC 720A. ERA members are seeking not only a better referencing system but also a review by EASA of the way the drafting of these supposed intelligent documents can be presented and thus ease confusion. 53 FCL.905.TRI type rating instructor - TRI The current JAR-FCL paragraph (b) under 1.360 Type rating instructor rating (multi-pilot ) (TRI(MPA)) - Privileges states If the TRI(A) training is carried out in a flight simulator only, the TRI(A) rating will be restricted to exclude emergency/abnormal procedure training in an aircraft...'easa FCL.910.revised wording under paragraph (a) General, is If the TRI training is carried out in a FFS only, the privileges of the TRI shall be restricted to training in FFS.' The perceived consequences of such a change are as follows: In a Type Rating course, which is carried out without a zero flight time simulator, a training flight (base flight) is required. This training flight will contain normal landings and so - called "touch - and -go" landings, which are normal operations without any simulated failures in a "real" aircraft. The JAR-FCL allows this training flight to be done by a TRI - with simulator TRI - training only - and the EASA FCL appears restricts the same TRI privileges to FFS training only. This means, that if the EASA FCL is implemented as such, an additional training flight with an shall be added in TRI training program to practice skills (e.g. simulated engine failures), which are
895 B. Draft Subpart K: Examiners - Section 3: for type rating examiners - FCL.1010.TRE TRE - Prerequisites 897 B. Draft Appendix 2: Theoretical knowledge syllabus for the ATPL, CPL and IR - A. Aeroplanes and helicopters 900 B. Draft A. ATP course 68-69 74-77 82-83 never needed in the normal Type Rating program, because this type of emergencies are trained in a FFS. FCL.1010.TRE TRE - Prerequisites FCL.1010.TRE paragraph (a) (3) : Can this be reworded to the following: "have completed at least 50 hours of flight instruction as TRI or LFUS or SFI in the appropriate type" or just "have completed at least 50 hours of flight instruction in the appropriate aircraft category or FSTDs"? ERA members feel this would then match the wording in FCL.940.TRI wording. The reason is that the hours provided as TRI in LFUS and FSTD are taken into account, otherwise it is quite impossible to get 50 hours in a training flight where only a TRI can act. ERA members would again suggest using the same wording as FCL.940 TRI. Appendix 2 Theoretical knowledge syllabus ATPL, CPL and IR The explanation regarding the applicable items for each licence or rating being marked with an X' is confusing. It seems (according to the table and crosses) that for an licence, the study of items concerning helicopter (e.g. 021 14, 15, 16 and 17 and 071 03) is required. This is an example of a minor change requiring European Parliamentary approval if this Appendix is not transferred into an AMC Section A 10(b) in Appendix 3 to IR-FCL. Puts forward the condition that "the instrument flight time as SPIC shall only be counted as pilot-incommand flight time up to maximum of 20 hours." This is not in Appendix 1 to JAR-FCL. ERA members would like to understand the reason for now including it in the IR-FCL. 905 B. Draft 83-84 Section B 9(b) in Appendix 3 to IR-FCL. puts forward the condition that "the instrument flight time as SPIC shall only be counted as pilot-incommand flight time up to maximum of 20 hours."
B. CPL/IR 907 B. Draft C. CPL 84-85 This is not in Appendix 1 to JAR-FCL. ERA members would like to understand the reason for now including it in the IR-FCL. Section C 7 in Appendix 3 to IR-FCL request that the theorical knowledge course shall comprise at least 350 hours of instruction. In Appendix 1 to JAR-FCL the requested hours are either 300 hours or 200 hours where the applicant already holds a PPL. ERA members request that this range of hours are maintained [i.e. 200 hours in case applicant already holds PPL). There seems no justification to jump from 200 hours to 350 hours for applicants already holding a PPL. The length of instruction should be less not more than the original extended 300 hours of Appendix 1 to JAR-FCL. 908 B. Draft D. CPL modular 901 B. Draft Appendix 9: Skill test and proficiency check for ATPL,. Type and class ratings and proficiency check for instrument ratings - B. category - 2. 85-86 128-131 Section D 7 Appendix 3 to IR-FCL requres that the theorical knowledge course shall comprise at least 250 hours of instruction. The Appendix 1 to JAR- FCL currently request 200 hours. ERA members would like to understand the reason increase of 50 hours both here and in Section C 7? There is no reports that the current hours demanded have proved inadequate in meeting the level required. Appendix 9 Skill test and proficiency check for ATPL, type and class ratings, and proficiency check for instrument ratings Multi pilot table [B 2] in Appendix 9 to IR-FCL seems incomplete as there is no section 3.9 "flight instrument procedure", 4 "go around procedure" nor 5 "Landing". Please confirm that this is just an error. Point 2.6 "rejected take off" may have an error. In the Appendix to the JAR-FCL, this exercice can be done on simulator (there is an X in the column) ; However it is not in this Appendix 9 table IR-FCL. ERA members would like to point out that this part of the table should read similar to the layout to point 2.5.2 "between V1 and V2". Please confirm if
Multi pilot this observation is correct. 892 B. Draft Decision Part- AMC and GM - Subpart A: General - AMC to FCL.050 Recording of flight time 173-181 AMC to FCL.050 Recording of flight time AMC to FCL.050 Item 1.)1.2)d). ERA members would suggest that it is unnecessary to have "type, including make, model and variant and registration of aircraft" on the pilot log book. It is considered that aircraft registration and type should be sufficient as any detailed additional information could be tracked via the registration. In addition any modification would be difficult at a later date. 896 B. Draft Decision Part- AMC and GM - Part-FCL Appendices Page viewed on 2008-11-12 13:39:24 GMT 583 Appendices to Part-FCL ERA members general comment: The technical structure of most of these Appendices make it more appropriate to transfer them into AMCs. As Appendices will be part of the law, ERA members suggest that submitting future amendments to the Appendices covering typos, advancements in technology, new aircraft types, developments in training techniques and student qualifications via the European Parliament protracted comitology process is not justified. Therefore ERA members strongly request the transfer of all Appendices into AMCs. Copyright 2005-2008 EASA