Annex 1 aircraft and microlight aircraft hours counting towards revalidation

Trevor Sexton • 19 September 2018
in community General Aviation

Going back to EASA,s response to NPA 2014-29. a number of questions were asked about flying Annex II aircraft (now Annex 1 ) and microlights to which EASA responded.

" EASA has prepared an AMC and proposed it with NPA 2014-29(B) and this AMC will be published after the adoption of the amendments to the Aircrew Regulation as GM." 

As yet i have not seen EASA issue anything on this even though the New Basic regulation 2018//139 has been in force since September 11th.







Comments (41)

Dominique Roland

Dear Trevor,

We are working on the issue:

- A special working group including stakeholders has been established. The group is working on the list of affected Annex I aircraft, conditions for recognition of training and experience.

- The work is not yet completed and the importance of the issue deserves that we address it carefully. For the moment, we expect to present the issue for discussion during the EASA committee planned in February 2019.

Best regards,

Jozef Jankovic

I think that not only EASA committee would discuss this point. Maybe wide discussion here could be fruitful as well.
It is not ease to find proper limits from the office and I can bet here are many experienced pilots flying "heavy and high speed" as well as "slow and low" planes.
Today's "advanced UL" are far better then my first plane (Zlin 126T Trainer) but on the other hand there are microlights on the opposite end of scale rather extreme sport devices even without real avionics or equipment.

Dominique Roland

The EASA committee took place yesterday and the proposal made by EASA was received positivaly by the Member States. We expect that the voting of the new text could happen in June 2019.

Dominique Roland

For the moment, it goes into the direction that we authorise training and revalidation flights on some Annex 1 aircraft. I will check if we are authorise to publish the draft text before the decision is taken I believe the community should be happy.

Jozef Jankovic

Well, sound good.
As far as I understand this part of flight training is long time untouched. Time of different variants of really light "***fox breed" aircraft or mixture of hang glider and parasol aircraft passed away. Now there are really high performance sport devices and on opposite side serious trainers - still in category of very light aircraft ... well, we will see.

Jyrki Paajanen

The amendments to clarify the use of Annex I aircraft in training were approved in the EASA Committee last week. The text is now heading to translation, so will hopefully be ready for publication in the Official Journal sometime in September.

However, please note that the Regulation (which is approved by the Member States experts in the Committee) only addresses the use of certain Annex I aircraft for training, as well as clarifying that the privileges of PPL also contain the privileges of a LAPL and the link between a medical and license privileges. The latter bit makes it clear that e.g. a person with a PPL, but only LAPL-compliant medical, can still fly with LAPL privileges.

The subject of using microlight aircraft for license renewal will be contained in the AMC/GM, which is is developed and approved by EASA and is due to be published about the same time as the Regulation.

Dominique Roland

Thank you Jyrki,

I confirm that the rule text with changes to points ORA.GEN.135 and DTO.GEN.240 has received a positive vote. These points relate to the use of Annex I aircraft for Part-FCL training (based on evaluation and authorisation by the competent authority).

Additional AMC & GM on the crediting of Annex I aircraft flight time for the purpose of revalidation of ratings / compliance with recency requirements still needs to be finalised and published (planned for autumn 2019).


Jyrki Paajanen

Yes, the relevant additions to "FCL.115 LAPL - Training course" and to "FCL.105.A LAPL(A) - Privileges and conditions", etc. were done to enable the LAPL(SEA) rating.

Jürgen Leukefeld

Thanks for Information, .... very nice.

Does the Agency provide an red-line Version of this? This would be useful to show up differences against 1178/2011

One more question:
When do we remove "piston" from all the ratings and licences to include flying eletrically powered single engine aircraft into the priviledges?


Jyrki Paajanen

Normally, when the EASA Easy Access document is updated, it will include always a mention at each point of where the amendment is coming from. Same applies to the publication of the consolidated versions of the regulations by the Commission in the Official Journal. However these are not in track changes, but in small print references (EASA) or letter/number symbols (Commission) next to the amended paragraphs.

As regards amendments to take account of electric aircraft, this is also in the work plans, but as a subject the introduction of electric aircraft is a bit more complex, because it is best done as a horisontal review of all rules, covering things like initial and continuing airworthiness, OPS, training etc.

Jürgen Leukefeld

I understand that basic rights for holders of LAPL(A) include (among others): flying a single engine aircraft on floats (FCL.105.A.LAPL(A)).
... very nice ;-)

Tim-Peter Voss

So finally the EASA pushed the responibility to the national authority to approve the use of "certain" annex I aircraft. Since some national authorities dont like to be responsable, in practice there will not be much use of it, I guess.

As far as I can tell from the above linked documents, there are still no way of crediting flight hours in microlights (eqv of Annex I, "e)"). Except for when starting training for LAPL(A). Is the issue still being worked on? Or have I looked in the wrong place?

Trevor Sexton

Apparently this will be in an AMC (alternate means of compliance ) which will be in the updated version of " Easy Access Rules for Flight Crew Licencing (Part-FCL) " document which EASA should have issued by now but we are still waiting for.

Trevor Sexton

The updated rules are out

AMC1 FCL.140.A; FCL.140.S; FCL.740.A(b)(1)(ii) Recency and revalidation requirements
All hours flown on aeroplanes or sailplanes that are subject to a decision as per Article 2(8) of the Basic
Regulation or that are specified in Annex I to the Basic Regulation should count in full towards fulfilling
the hourly requirements of points FCL.140.A, FCL.140.S, and FCL.740.A(b)(1)(ii) under the following
Annex I to ED Decision 2020/005/R
Page 7 of 61
(a) the aircraft matchesthe definition and criteria of the respective Part-FCL aircraft category, class,
and type ratings; and
(b) the aircraft that is used for training flights with an instructor is an Annex-I aircraft of type (a),
(b), (c), or (d) that is subject to an authorisation specified in points ORA.ATO.135 or

Tim-Peter Voss

I think the AMC and GM should explain a bit more detailed the part "(a) the aircraft matchesthe definition and criteria of the respective Part-FCL aircraft category, class and type ratings".
Does it mean that 3-axis powered microlight hours count for SEP(A) ratings (recency and revalidation) because it is fixed wing, aerodynamically controlled, with one engine, flown under VFR rules!?

Jürgen Leukefeld

Dear Dominique and all,
for my understanding, there is one question not explicitly asked and therefore not answered: "Are aeroplanes from Annex I (e) of EU2018/1139 included in the considerations?" ... In clear: Can PPL(A) and LAPL(A) be serviced by microlight flying experience?

La división tan grande que se ha hecho de los aviones es un grave error. Todos los aviones de ala fija con motor deberían ser validos para revalidar el SEP(A). y la experiencia de vuelo acumulable.

Harry Karlsson

It seems that EASA is approving microlight hours, I happened to see an document concerning this:
in point (a) of point FCL.035, a new point (4) is added as follows:
‘(4) All hours flown in aeroplanes, sailplanes or powered sailplanes that are subject to a decision of a Member State taken in accordance with Article 2(8) of Regulation (EU) 2018/1139 or that fall within the scope of Annex I to that Regulation shall be credited in full towards fulfilling the flight time requirements of point FCL.140.A(a)(1), points (a) and (b) of point FCL.140.S and point FCL.740.A(b)(1)(ii), provided that the following conditions are met:
(i) the aeroplane, sailplane or powered sailplane concerned is of the same category and class as the Part-FCL aircraft in respect of which the hours flown are to be credited; and

Jürgen Leukefeld

So this issue seems to be finalized after 20 months of dicussions.
Everybody be aware of Annex I letter e) aircraft are allowed for gaining experience only; no education or refresher Training on those.

Jozef Jankovic

Maybe it needs some clarification, because of letter (b) below:
Annex I to ED Decision 2020/005/R
Page 7 of 61
(a) the aircraft matches the definition and criteria of the respective Part-FCL aircraft category, class, and type ratings; and
(b) the aircraft that is used for training flights with an instructor is an Annex-I aircraft of type (a),

Jozef Jankovic

Oh, well, sorry, my mistake. Inadvertent reading.
Thank you
Final statement after careful reading:
PPL(A) and LAPL(A) can be serviced by microlight flying experience.

Jeremy Baldwin

We have recently encountered an active issue in relation to the recording of (BR) Annex I flight time and the requirements of FCL.050 and its AMC1. While the requirements of FCL.740.A(b)(1)(ii) would imply a requirement to log total time in accordance with , there is no associated FCL.050 provision for segregating this flight time.

Regulation (EU) 2019/1747 does not amend FCL.035 with regards to crediting flight time, thus we arrive at a situation where an applicant for a higher licence or rating has been obligated to record a total flight time (inclusive of Annex I) to prove SEP flight time (and associated take-off and landings) while then being required to disentangle that same total time from any non-annex I time for any other FCL purpose (e.g. crediting towards a new licence). This creates a discontinuity in the flight-log and an ambiguity as to how this should be recorded. While the BR states that crediting of Annex I shall be in accordance with the Implementing Acts, the amended Aircrew Regulation makes provision only for the recency/revalidation scenario.

In my mind this creates a significant ambiguity and could lead to serious potential for human error. We have empirical evidence of NAAs taking a strict littoral rather than purpose interpretation of this and overlooking the "commensurate" requirements set out in GM1 ARA.GEN.355(b)(1) (e.g. requiring an applicant to repeat a full course of training following discovery of minor administrative errors in paperwork. Obviously when logging Annex I time together with "EASA" time, this creates a need to disentangle those hours for everything other than recency and revalidation. Probably not a problem for a pilot flying 10-20 hours per year, but a serious headache for a pilot also engaged in CAT operations.

Example - Pilot flies as copilot for a CAT operator with MPA and also flies actively as an instructor in both Annex I and "EASA" aircraft. When that copilot comes to apply for his/her ATPL there is a potential need to untangle 900 hours of flying potentially spanning multiple logbooks with entries inter-twined. This is a scenario that would undoubtedly introduce human error.

Therefore, is there a plan to either:
a) develop and/or clarify the crediting to allow for additional credits; or
b) clarify FCL.050 by introducing an obligation to record Annex I flight in a separate column (e.g. by expanding column 5 as many logbook publishers already have).

Feedback on this point would be greatly valued.

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