EASA Comment Response Tool - egu-info.org

1 EASA Comment Response ToolYou can save this page as HTML and then open it in Microsoft Word for further Rules for Pilot Licensing - Part-FCLNPA NumberNPA 2008-17bEuropean Gliding Union (EGU) has placed 42 unique comments on this NPA:Cmt#SegmentdescriptionPageCommentAtt achments4540(GeneralComments)0 The comments in this Response to NPA17b representthe formal Response of the European Gliding represents the national gliding organisations of25 countries (Austria, Belgium, Croatia, CzechRepublic, Denmark, Finland, France, Germany,Greece, Hungary, Iceland, Ireland, Italy, Lithuania,Luxembourg, The Netherlands, Norway, Poland,Serbia, Spain, Slovakia, Slovenia, Sweden,Switzerland & UK) 4544B.

2 DraftOpinionPart-FCL -Subpart A:GeneralRequirements- DefinitionsComment:There is no definition of the proficiency check and ofthe skill test here Instead theses definitions arehidden in GM to (page 170). Since thesedefinitions are important we would prefer to havethem transferred here We also believe thatinstructors should be allowed to perform proficiencychecks (see our Comment on page 16)EGU Proposal:Transfer the definitions of skill tests and proficiencychecks from the GM to FCL 010 4546B. DraftOpinionPart-FCL -Subpart A:GeneralRequirements- -5 FCL 010 - Definition of a TMG: A touring motor glider (TMG) means a specific classof powered sailplane having an integrally mounted,non retractable engine and non retractable Comment :According to the definition, a Touring Motor Glider is apowered sailplane.

3 The other types of poweredsailplanes (which in JAR FCL are defined as SelfSustained Gliders and as Self Launching Gliders) areonly defined by default, as being non TMG poweredsailplanes. This leads to some ambiguities in the EASA CRT application - von 15:00 UhrCmt#SegmentdescriptionPageCommentAtta chmentsdefinition of privileges of the LPL(S) and SPL (See ourcomments on , , FCL ) Therefore, EGU believes that a cleardefinition of every type of powered sailplane shouldbe included in the ProposalA powered sailplane is a glider equipped with anengine. There are three types of powered sailplanes:Touring Motor gliders (TMG) which have anintegrally mounted, non-retractable engine andnon-retractable propeller.

4 Self launched gliders which have a retractableengine or a retractable propeller and arecapable of taking off and climbing under theirown power. When the engine is inoperative,they have the characteristics of a Sustained gliders which must be launchedlike a pure sailplane not equipped with anengine, but can climb slowly to extend a flightonce the engine or the propeller is deployedand started. When the engine is inoperative,they have the characteristics of a DraftOpinionPart-FCL -Subpart A:GeneralRequirements- issue oflicences,ratings Para (a): An application for the issue, revalidation or renewalof pilot licences and associated ratings andcertificates shall be to the competent authority.

5 Theapplication shall Comment :One of the demands of the gliding movement was thepossibility to empower national gliding bodies(Federations or National Aero Clubs) to issue andrevalidate licences, ratings and certificates forinstructors/examiners on behalf of the competentauthority (the Assessment Bodies in the initial setup)Regulation (EC) 216/2008 recognises that qualifiedentities may deliver specific certification tasks for thecompetent authority. It is proposed that the textwithin should be amended to read as such. EASA CRT application - von 15:00 UhrCmt#SegmentdescriptionPageCommentAtta chments EGU Proposal:(a) Any application for the issue, revalidation orrenewal of pilot licences and associated ratings andcertificates shall be made to the competent authority,or to the appointed qualified entity, in a mannerestablished by this authority.

6 The application shall beaccompanied by evidence that the applicant complieswith the requirements for the issue, revalidation orrenewal of the licence or certificate as well asassociated ratings or endorsements, established inthis Part and Part DraftOpinionPart-FCL -Subpart A:GeneralRequirements- issue oflicences,ratings andcertificates5 FCL. 015 Para (c) A person shall not hold at any time more than onelicence issued in accordance with this part Comment :The meaning of the sentence is not fully this mean that:(a) a pilot can only hold one EU licence and that if itis a higher licence for a particular aircraft category( glider) an SPL gives the privileges also ofa LPL(S)?

7 Or(b) a pilot can only hold one EU licence for aparticular aircraft category ( a SPL) and cannothave two licences (from different countries, forexample for an SPL)? Or(c) a pilot who holds, for example, an ATPL also hason the licence a rating, for example, for the LPL(S)?EGU assumes that this draft rule is intended to stoppilots holding a licence for the same aircraft categoryin more than one Member State. EGU understandsthat this rule shall ensure a clear assignment of apilot to the responsibility of the competent authorityof only one member Proposal:EASA to clarify the interpretation of this statement, inthe AMC / GM.

8 4553B. DraftOpinionPart-FCL -Subpart Para (b): Before his first solo flight, a student shall be at least:(1)..(2) in the case of sailplane and balloons, 14 years ofage EASA CRT application - von 15:00 UhrCmt#SegmentdescriptionPageCommentAtta chmentsRequirements- pilotComment:EGU strongly supports the proposed minimum age forfirst solo flights in a sailplane. It is important for thedevelopment of our sport that young people can besuccessfully educated and trained in such a way thatthey can fly solo at the age of 14. Several memberstates have allowed solo flying at this age for manydecades and there has been no adverse safety casewith this DraftOpinionPart-FCL -Subpart A:GeneralRequirements- the issueof licences5 -6 FCL 025 Para (a) (1) Applicants shall take the entire set of examination inone Member state Comment :Clarification required.

9 - if this means that the set of examinations for onecategory or aircraft / licence have to be taken in oneMember State, then it is if it means that the examinations for differentcategories or aircraft / licence have to be taken inone (always the same) Member State, then this is Proposal:EASA to clarify the interpretation of this statement, inthe AMC / GM. 4557B. DraftOpinionPart-FCL -Subpart A:GeneralRequirements- the issueof licences5 -6 FCL 025 Para (b) (2) (3) Comment : This paragraph is not fully understood. Aclear definition of the meaning of examinationpaper or subject is needed in order to understands the term examination paper asthe written test of one subject meteorology.

10 Theterm subject means in our understanding a topic ofthe syllabus Proposal:EASA to clarify the definitions or interpretation of examination and subject(s) in the AMC / GM. 4558B. DraftOpinionPart-FCL -6 Crediting of flight time Para (a): Unless otherwise specified in this Part, flight time to EASA CRT application - von 15:00 UhrCmt#SegmentdescriptionPageCommentAtta chmentsSubpart A:GeneralRequirements- offlight timeandtheoreticalknowledgebe credited for a licence, rating, or certificate shallhave been flown in the same category of aircraft forwhich the licence or rating is sought EGU CommentAlthough the wording does not specifically excludeflight time on Annex II aircraft, provision should alsobe made to count flight experience gained on AnnexII or third country aircraft for the purpose of issue,renewal, revalidation of licences.