Aerobatic rating prerequisite

Antoine ROGUES • 20 July 2018
in community General Aviation


I am the head of training of a flying club in France with aerobatic activities. We fly about 300 h/year of aerobatic.

With the "new" FCL.800 aerobatic rating (with the opt-out, we were still with national regulation), a pilot need 40 hours as PIC (after PPL or LAPL) before having the possibility to have the EASA aerobatic qualification.

I read a lot about that in the initial CRD and spent a lot of time (me or other flight instructor of my organization) with our national federation.

I don't want to speak for other countries, but in France, this is a huge difference with our previous national rules where no minima’s after the license was imposed.

There is NO safety analysis saying that a low experience is a problem, as well as having a small experience could increase safety in aerobatic flight.

France in a huge country in term of aerobatic experience. We had a system which worked.

At my flying club, I have 2 example of national / international aerobatic / Red Bull champion that start aerobatic just after the license. Every year we had some young pilot which had their first aerobatic qualification and would be able to attend national contest or just have a flight.

40 hours as PIC is about 3 to 4 years for an usual pilot after the license. We will lose all our young pilots starting aerobatic. 

At the contrary, I really think that flying aerobatic increase the overall safety : pilots have a better knowledge of what happens if flying at a corner (or outside) of the flight envelop (I think about spins). They are as well for sure, better to recover a spin, a spiral, ...

I could continue to argue for long, but I think you understand now why these 40 hours are, in my point of view (and for sure all French aerobatic FI, French National Federation (FFA), and I guess French CAA (DGAC)).

My questions are : 

- is a modification of the FCL.800 possible? A possible mean of mitigation is an entry level test done by the training organization to assess the level of an applicant.

- on what actual basis (safety study, other countries national rules, ...) EASA has imposed this rule to all EASA countries?

Thanks in advance for reading me (and I hope answering me).
Do not hesitate to contact me.

Antoine Rogues

Comments (7)

Jozef Jankovic

Hi Antoine,
I can only agree with you. My personal experience is the same, even more, I had basic aerobatics as part of my basic training.
Former Czecho-Slovak flight training philosophy has proven record of long time successful pilot training on national as well as international level. History and experience has to be a key stone for our rules for future.
40 hours PIC requirement in this particular case is just way "how to earn money" and not how to improve safety and keep flying reliable and effective.
My opinion is based on the long term experience with single pilot operations from supersonic to light aircraft as well as flight instructor experience.

Michael Kucher

Dear Antoine & Jozef,

Please check FCL.800 carefully. I do read out that part fcl speaks about flight hours not PIC hours.



Antoine ROGUES


Quote from FCL.800 :
Applicants for an aerobatic rating shall have completed:
(1) at least 40 hours of flight time or, in the case of sailplanes, 120 launches as PIC in the appropriate aircraft category, completed after the issue of the licence;

=> Everyone in France understand that the 40h are PIC hours ...

Michael Kucher

Dear Antoine,
I am not a lawyer, but at the end of the day your CAA could comment on that. Ask them.

Anyway, part fcl defines flight time and especially PIC time under its definitions . I would identify your quote not as PIC time, but maybe there is a AMC for that in France????



Dominique Roland

I must admit that is is only very recently that I discovered this 40 hours prerequisite in the FCL. I have tried to idenbtified where this is coming from, and it seems that the recommendation was coming from an "group of experts" during the rulemaking process. I share your concerns as I personnalyy do not understand the added value of the requirement. I will do my best effort to obtain a review of this requirement as soon as feasible.

Antoine ROGUES

I cannot access what this "expert" group has concluded. However we can read the CRD of 2012 and all the comments on that part.
If you need any assistance, please do not hesitate. Even if I am not at the BoG of our French Federation, I'm quite sure help could be given (and when speaking with DGAC employee I'm sure as well it can be done).
For us, this "problem" is quite annoying !

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