Monday, September 2, 2019

EASA currency and license revalidation

I did some updates over the past few days to better support EASA currency rules.

For a while, I've supported EASA LAPL (FCL.140) rules, which can be turned on in preferences on the website. 

If you turn this option on, I also default to EASA PPL rules where appropriate rather than FAA rules for regular passenger currency.  The EASA PPL rules (FCL.060) for carrying passengers are basically the same as the FAA rules (3 takeoffs+landings within 90 days), but they differ for night:
  • Whereas FAA rules require 3 takeoffs and landings to a full-stop between 1 hour after sunset and 1 hour before sunrise, the EASA rules require only one takeoff/landing, and it doesn't have to be to a full stop.
  • If you have an instrument rating, EASA imposes no particular night requirement.
The way that I've implemented this is that I look for a night takeoff and either a full-stop night night landing or a night touch-and-go landing within the past 90 days.  But if I see any evidence that you have an instrument rating, such as an instrument checkride, an IPC, or one of a few other things that qualify as an IPC, then I don't bother reporting night currency because it is then identical to (and thus redundant with) your regular FCL.060 passenger-carrying currency.

Note that I said "if you hold an instrument rating", not "if you have a valid instrument rating", or "if you have an instrument rating for the category or class".  The regulation is worded thusly:

(b) Aeroplanes, helicopters, powered-lift, airships and sailplanes. A pilot shall not operate an aircraft in commercial air transport or carrying passengers:
(1) …; and
(2) as PIC at night unless he/she:
(i) has carried out in the preceding 90 days at least 1 take-off, approach and landing at night as a pilot flying in an aircraft of the same type or class or an FFS representing that type or class; or
(ii) holds an IR;
(b)(2)(ii) above simply says "holds an IR", with no other qualifier, so I am treating that as being unqualified.

Another key difference in EASA land vs. FAA rules is that FAA ratings don't expire, but EASA ratings do need to be re-validated periodically.  This is like the FAA requirement to have a flight review.  But EASA adds a wrinkle to this: you need to do the validation within the 3 calendar months prior to the expiration of your rating. 

So, for example: suppose your rating expires Sept 30 2019 and is good for a year.  If you did your validation flight on July 15, 2019, then your rating is now good until Sept 30 2020; in effect, you can have as long as 15 calendar months as a result.  But if you did your validation flight on May 15, 2019, then your rating is now extended only until May 31 2020.

As a result, it is impossible to predict when a validation is required without knowing when your rating expires, which means that there is no way to escape having you enter those expiration dates somewhere.  And since the number of possible ratings is unbounded (due to type ratings), I can't enumerate the set of due dates that you need.

So here is my recommendation for dealing with re-validation of EASA ratings:
  • For each rating that you hold that requires re-validation, create a custom deadline (Profile->Preferences->Deadlines) that reflects the date by which the validation is due.  This will then show up in your currency.  Set it up to automatically extend by 12 or 24 calendar months, as appropriate.
  • When you do the re-validation, update the deadline to reflect the new date.  This will allow you to handle the 3 month window for performing the validation.
  • If you like, you can also set up a custom currency rule that looks for a flight review or IPC (to indicate revalidation) in an appropriate set of category, class, or model.  This will use a date extending by 12/24 calendar months, where you might actually be entitled to more, but at least this will give you a conservative date.
  • Note that re-validation of simple SEP ratings can be accomplished essentially by remaining current via LAPL rules, so you can track that simply by tracking your LAPL currency.

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