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16. November 2015 Jan Brill

Luftrecht: EASA Regulation Application

Four Things EASA Has to Fix Now – Part 3: Why Don't You Try a Different Airplane?

For our third installment we would like to briefly let the German LBA off the hook (because they implement it correctly, albeit rather longwindedly), and cite an example of misinterpretation and misapplication from another European CAA. We don’t want anyone to feel passed over. This one is about the experience and prerequisites a pilot has to bring before getting his first rating for a high performance complex motor powered airplane (HPCMPA).

Previously on this show:

1. FCL.205.A – Who and what can be taught by a PPL-Instructor?
2. FCL.915.TRI – Type Rating Instructor Prerequisites and Revalidation

3. FCL.720.A High Performance Complex Typerating as first Multiengine-Rating

The prerequisites for obtaining a high performance complex rating aeroplane are laid down in FCL.720.A. Paragraph (c) specifies:

Single-pilot high performance complex aeroplanes. Applicants for the issue of a first type rating for a complex single-pilot aeroplane classified as a high performance aeroplane shall, in addition to meeting the requirements of (b), have fulfilled the requirements for a multi-engine IR(A), as established in Subpart G.

The last part of this sentence “have fulfilled the requirements for a multi-engine IR(A), as established in Subpart G” has given not only the european CAAs but also us some food for thought.
Does that mean he has to hold an ME/IR before obtaining his first HPCMPA-Rating? Or does he just need to complete the training specified in Subpart G? Frankly, we had no idea. So we asked and got an answer from EASA (emphasis by the author):

The FCL.720.A (c) states the general provisions regarding the experience and prerequisites for the issue of SP HPA complex aeroplanes. According to point (c) the ME/IR is not a prerequisite to start the SP HPA complex type rating course, but the applicant shall have fulfilled the requirements for a multi-engine IR(A), as established in Subpart G when applying for the rating.

That actually makes some sense. So someone wishing to pilot a CJ or a KingAir does not have to train on a Seminole or DA42 first. He can get whatever training he needs to “fulfilled the requirements for a multi-engine IR(A)” in the aircraft he is getting the rating for.

Thank God! Because it would not only be a waste of money, but also downright counter-productive to train the future pilot of a Cessna Mustang in p-factor, critical engine and slipstream. You would have to teach him procedures and techniques that are not only not applicable to his aircraft, but which are in part downright dangerous in the type he’ll operate.

Most European CAAs did get this right. Swiss FOCA was the first one we came across in our ATO. In a brief email-exchange the authority determined that five additional hours of practical training would suffice in a particular case, where the applicant for a PA31T/42 type rating had no prior multi engine qualification.

The German LBA turned out to be a bit more laborious. In general they agreed, but mandated that the additional content for first-time multi engine pilots had to be specified and approved in the training organizations manual. We did, what you usually do when you “just have to add some more paperwork”. We clicked our heels and expanded the organizations training manual as requested.

While AustroControl (which is the competent authority for our ATO) was happy to support us in adding the additional content required by the LBA, they themselves adopted a different interpretation for their own license-holders:

[Es gibt] auf Grund des Type Rating Charakters der Ausbildung auf PA31/42 nach Auffassung der Austro Control nicht die Möglichkeit, die erste multi engine Berechtigung darauf zu erwerben (arg. FCL.720.A/(c) „... have fulfilled the requirements for a multi-engine IR(A), as established in subpart G.“), da die Voraussetzungen des Subpart G hinsichtlich der nur im Ausschnitt zitierten Passage aus FCL.720.A notwendigerweise erst mit absolvierter MEP IR Prüfung erfüllt sind.

Loosely translated this means that the only way to “fulfilled the requirements for a multi-engine IR(A), as established in Subpart G” is to actually hold one. And since the only practical rating for an ME/IR that is not complex happens to be the MEP, this means you have to hold an MEP/IR before going for KingAir, CJ or Phenom.

Why train MEP when you want to fly a Mustang?!?

Seriously, why train in this (Seminole) when you want to fly this (Mustang-Jet) ? The two have no comparable flight characteristics whatsoever. Especially not in single engine operations. You could argue, the Mustang has been designed to be precisely NOT like a Seminole!
The result is of course nonsensical. Assuming someone wishes to transit from a TBM850 to a C510 Mustang. He’s never flown MEP, maybe doesn’t even hold an SEP anymore since after tasting the turbine he really wasn’t into these pesky piston engines all that much anymore.

Instead of spending every minute and every cent of his training towards learning to master the highly automated sleek and very safe jet, he’ll be required to spend five or seven hours riding a Seminole and learn how to cope with all those deficiencies his Mustang doesn’t have.

What is a wonderful use of time and resources!

He’s forced to train in an aircraft showing completely different characteristics in almost all aspects of one engine out (OEI) operations compared to the one he’s aiming for.

Nobody was ever able to explain to us the safety benefit behind that.

EASA is already working on this regulation in another aspect. Because the way it’s written now, even a candidate for a single engine Cirrus-Jet would have to go through ME/IR first. This makes even less sense than training jet-drivers in a piston-twins (and we thought that was pretty much rock bottom).

So in NPA 2014-29 EASA is proposing changes to alleviate this for single engine jets. These changes however don’t address the problem described above.

EASA should amend or rephrase paragraph (c) to rule-out interpretations such as AustroControls and make clear, that while additional content is certainly required when obtaining the first multi engine rating, it can and should always be conducted in the aircraft the pilot is actually aiming for. Not some arbitrary MEP trainer which might have nothing in common with the high performance complex type in question.

Read in out next installment on November 23rd: "The Answer is Not 42"

The Author is Managing Editor of Pilot und Flugzeug Magazine and the Accountable Manager of a small Approved Training Organisation (ATO). He holds an FAA ATP CFII/ME and an EASA CPL(A) with FI ME CPL IR and TRI(A) privileges. He’s also an EASA class- and typerating examiner. When he’s not busy bugging the authorities he freelances with a German Air Ambulance Service.


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