Henry Pottkämper posted in General Aviation
Topic: Upgrade from LAPL(A) to PPL(A) - Requirements and Crediting
I would like to discuss the changes to the solo hours requirements between:
1. *Commission Implementing Regulation (EU) 2022/844* of 30 May 2022, and
2. *Commission Implementing Regulation (EU) 2024/2076* of 24 July 2024.
Let’s consider a student who completed their:
- **LAPL(A) training** with the minimum requirements of 30 hours (6 solo, including 3 cross-country solo). The solo flights were supervised by a Flight Instructor (FI) qualified for LAPL only.
- After training, the student logged an additional 30 hours as pilot-in-command (PIC).
Comparison of Requirements
Under Regulation (1), the requirements for upgrading include, among others:
"…at least 15 hours of flight time on aeroplanes after the issue of the LAPL(A), of which at least 10 shall be flight instruction completed in a training course at a DTO or an ATO. That training course shall include at least four hours of supervised solo flight time…"
Under Regulation (2), the new requirements for upgrading are:
"…applicants shall have completed at least all of the following with an instructor qualified to instruct for a PPL(A):
(i) 5 hours of dual flight instruction;
(ii) solo flight time as specified in point (a)(2) [which is…10 hours of supervised solo flight time, including at least 5 hours of solo cross-country]."
Key Differences
The main difference is the impact of the instructor's qualification. Under Regulation (1), the student needed to complete an additional 4 hours of supervised solo flight time. However, under Regulation (2), the student must now complete an additional 10 hours of supervised solo flight time. This is because the solo flight time logged during LAPL(A) training under the supervision of an LAPL-only FI no longer counts under the new rules, as supervision by a PPL-qualified FI is now mandatory.
Concerns
This change appears to be a step back and seems contrary to the goal of "improvements for general aviation," as stated in the title of Regulation (EU) 2024/2076. Requiring the student to log an additional 10 hours of solo flight time during PPL(A) training, after having already accumulated 15 or more hours of PIC time post-LAPL(A) training, seems redundant and inefficient.
What’s your opinion on this matter? Am I missing something?
Dear Henry, thanks for asking. I've got in touch with my colleagues in charge of Flight Crew Licensing and Training Standards, who let me know that a full explanation and clarification of the changes to FCL.210A can be found in the draft Annexes to Commission Implementing Regulation (EU) No 1178/2011 of Opinion 05/2023, which you can find here: https://www.easa.europa.eu/en/document-library/opinions/opinion-no-0520….
I'd especially recommend checking the "Rationale" boxes related to FCL.210.A in the draft Annex to the Commission Implementing Regulation.
You'll find it here: https://www.easa.europa.eu/en/downloads/138641/en
- Draft AMC and GM to Regulation (EU) No 1178-2011 and (EU) No 965-2012
You'll find it here: https://www.easa.europa.eu/en/downloads/138987/en
Found it - thanks. So ICAO-compliant instructor is necessary.
"Point FCL.210.A(b)(2) is proposed to ensure compliance with ICAO, Annex 1, which requires applicants for a PPL to complete, under the supervision of an ‘authorised instructor’ (= ICAO-compliant instructor ≠ ‘LAPL-only’ instructor without CPL theory), at least 10 hours of supervised solo flight time (ICAO Annex 1, Chapter 2, point 2.3.3.1.2) and dual instruction in the relevant class (ICAO Annex 1, Chapter 2, point 2.3.3.2, first sentence). In cases where applicants completed previous LAPL training with a ‘PPL instructor’, this point FCL.210.A(b)(2) will be irrelevant, and LAPL training and PPL training can simply be added up. However, in cases where applicants complete (parts of) LAPL training with ‘LAPL-only instructors’, this point FCL.210.A(b)(2) will need to be monitored, in order to ensure that eventually a PPL can be issued in alignment with ICAO standards."
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