Words Ed Bellamy
4 February 2021
The main rating extension exemption ended on 22 November 2020 but there are still some alleviations available until 30 April 2021, as Ed Bellamy explains
For those who subscribe to the CAA’s Skywise email alerts, you may have seen a message on 12 November saying that the April exemptions that allowed the extension of licence ratings until 22 November will end as scheduled. At the time of writing in mid-November that appears to be the current position.
So where does that leave us if you have a rating or medical due to expire shortly? Despite the ending of the main exemptions, there are some minor alleviations that continue.
The CAA update reminds us that Department for Transport advice is that during the current lockdown period flights for engine health, maintenance check flights and for the maintenance of ‘currency’ are allowed (link to the latest DfT guidance provided at the end), but the scope and duration should be kept to a minimum. It is worth noting that ‘currency’ does not have a legally distinct meaning in Aircrew regulations, although I think it does have a common sense meaning to pilots, which to my mind would include revalidating a rating.
For ratings that normally require revalidation by proficiency check, extension beyond the 22 November is not possible – normal procedures now apply. For aeroplane ratings that can be revalidated by experience, there is still an active exemption (At the time of writing ORS4 1418 for ANO licences, 1416 for EASA) that allows some reductions in the normal experience requirements. This covers Single Engine Piston (SEP), Touring Motor Glider (TMG), Self-Launching Motor Glider (SLMG) and the suite of ratings that may be attached to an NPPL(A). Please note it does not cover the LAPL ‘rolling validity’.
The exemption is currently in force until 30 April 2021, and for those who have managed some flying but not the magic 12 hours prior to rating expiry, this may provide an alternative to taking a proficiency check with an examiner.
The CAA provide the following alternative revalidation by experience requirements that are permitted until 30 April 2021:
|Flight Time Relevant for Revalidation by Experience*||Minimum Take-Offs/Landings||Minimum Cumulative Total Refresher Training with an Instructor|
|11 or more – less than 12||15/15||1 hour|
|10 or more – less than 11||16/16||1 hour|
|9 or more – less than 10||17/17||1.5 hours|
|8 or more – less than 09||18/18||1.5 hours|
|Less than 8||Proficiency Check or Flight Test required|
*This must include the normal required PIC time (6hrs for PPL, 8hrs for NPPL)
Obviously if at any point the rating expires, you are into proficiency check territory. The CAA also remind us that when revalidating ratings that were previously extended under the Covid-19 extension procedure (which would have been until 22 November 2020), the rating should have been endorsed with a new expiry date of 30 November 2022.
There has been some debate regarding getting Class 2 or LAPL medicals issued during the current lockdown period. Initially the CAA published some guidance suggesting AMEs should not be conducting Class 2 or LAPL medicals, although this may have subsequently been softened.
If you are not able to get to an AME (or potentially GP in the case of a LAPL) there are still some options to allow you to fly beyond your normal medical expiry date.
The general exemption extending medicals (currently ORS4 1408) has two time periods – for medicals that expired on or after 16 March 2020 but before 31 August 2020 an extension until 22 November was granted. For those expiring on or after 1 September 2020 but before November 22 you get a 45 day extension or until 31 December 2020, whichever is sooner. There is no procedure to complete for this, the extension is automatic, provided you do not experience a loss of medical fitness.
Now for holders of the UK PPL and NPPL(A) issued under the Air Navigation Order (ANO), the self-declaration medical (PMD) process continues as normal, although it is worth remembering at this point that ANO licences cannot be used to fly EASA aircraft, even with an ICAO medical (although watch this space next year).
For EASA PPL or LAPL holders an exemption is still in place that allows UK-registered EASA aircraft to be flown on a medical declaration until 31 March 2021, although remember on PMD an EASA PPL becomes non-ICAO compliant and cannot be used outside the UK. Looking at another option, a minor change in late 2019 was the ability of an EASA PPL with Class 2 to ‘downgrade’ to LAPL medical privileges without having to get a LAPL licence document. Depending on your age, there may be benefits in going down to LAPL privileges if you are unable to get a Class 2 at the moment – it should say on your medical certificate what the relevant expiries are.