PPL Experience requirements and crediting

Liviu Dnistran • 5 January 2024
in community General Aviation
9 comments
1 likes

Hi all,
I'm a ULM pilot in Romania looking to do a PPL license.
I've been reading ANNEX I (Part-FCL) regarding Experience requirements and crediting, specifically FCL.210.A PPL(A).

I've got about 200hrs total flying ULM (ultralight MTOW 450kg), 130ish PIC.
Can someone maybe confirm/deny the fact that I could deduct up to 10 hours of training for PPL based on the ULM experience (obviously if I'm skilled enough)?

My reading and understanding of FCL.210.A PPL(A) (d) is that it should be possible, as it states: "Applicants holding a pilot licence for another category of aircraft, with the exception of balloons, shall be credited with 10% of their total flight time as PIC on such aircraft up to a maximum of 10 hours."

I'll drop a line to the Romanian CAA about this, but thought maybe there's some consensus on this or some precendent set.

Thank you,
Liviu

Comments (9)

Stephen Oddy

As you said, the regulation has the line:
'Applicants holding a pilot licence for another category of aircraft...'
When EASA refers to a 'pilot licence' it means an EASA licence unless it says something else like '3rd country pilot licence'. I guess that your 200 hours of ULM flying has been done on a national licence and not an EASA-compliant licence. The 'other categories of aircraft' are those licenced through EASA: helicopters, powered-lift and sailplanes. So I would not expect the ULM time to be accepted.

Raul Moyo

Maybe I'm wrong but, my understanding is the UL License is not an EASA License, it is a National License.
So the point FCL.210.A PPL(A) (d) is refering to pilots holding an EASA license in any category of aircraft (ie. Airplane, rotorcraft, ligher than air..).

Hubert Massalski

In Poland, ULM pilots can fly with a national qualification certificate, which is not a licence.

Poland CAA considers ULM pilots wishing to obtain LAPL(A) or PPL(A) licences as having no flying experience - checked many times.

This is because Regulation 1178/2011 part-FCL does not provide for credit for experience other than that of holding an SPL or PPL(H). Only as a matter of theory is experience from a BPL recognised.

This is also partly due to ICAO Annex 1 licensing, where the recommended amount of training hours and scope of knowledge for licensed pilots is set out.

In our ATO we often encounter this problem, we are currently 'training' from zero to LAPL(A) a pilot with a national qualification certificate with over TT300h.

It would be advisable for EASA to propose to the EU Commission some solution to make it easier for pilots with national qualification certificates to obtain at least an LAPL(A), which is not an ICAO-compliant licence.

It could bring the national qualification certificates together and enter the common arrangements as a new annex to Regulation 1178/2011 or another new one as happened with the SFCL, BFCL and thus recognise experience gained on this basis for ICAO-compliant licensing.

Liviu Dnistran

Thank you all for the answers.
Indeed the ULM licence is a national one.
That was my concern and wanted to clear it up. It just might be that there is no credit based on the national licenses as all ULM licenses in europe are national ones.

Michael Orf

First of all: Happy new year and always happy landings ;-)
This is correct and each EU-member state has to ratify the EASA regulation, accordingly.
In Germany, it is possible to credit max. 10h of ULM time for a PPL licence.
If in doubt, I would ask national CAA, which you already did!
Let us know the decision, please!
Take care, Michael

Hans-Cristian Weber

I share the opinions listed in the previous answers, by "flight time in other airplanes" EASA means flight time on EASA ratings like sailplanes, TMGs, Choppers or flight time on LAPL. However, since a couple of years, the flight time in 3 axe microlights (under national regulations) counts for renewal of for instance SEP L rating - didn't try it myself, I don't have UL license. But not for licenses, these are for lifetime and do not lapse.

Mark Dwyer

Hi Liviu,

FCL.110(a) says: "Applicants for an LAPL who have held another licence in the same category of aircraft shall be fully credited towards the requirements of the LAPL in that category of aircraft."

Contrary to the comments above, there is no other EASA licence that is the same category as a LAPL(A) so by definition this can only apply to non-EASA licences i.e. national non-ICAO compliant licences (including 3-Axis ULM / Ultralights / Microlights etc.)

In Ireland, we use this all the time to 'convert' pilots with national licences to EASA licences. You'll need an ELA, Class 2/LAPL Medical and a PPL(A) Skills Test. Then use FCL.210.A(b) course to upgrade from the LAPL to PPL.

Hope this helps!

Regards,
Mark

Hubert Massalski

Complementing the above, it would be worthwhile for you to check how Romania CAA understands your ULM authorization.

If it determines that you have a national pilot's license instead of a non-license qualification certificate, you can use the direct provisions of EU Regulation 1178/2011 Article 4 'Existing national pilots' licenses'.

link: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02011R1178-…

Paragraph 2 says:
"Non-JAR-compliant licences including any associated ratings, certificates, authorizations and/or qualifications issued or recognized by a Member State before the applicability of this Regulation shall be converted into Part-FCL licences by the Member State that issued the licence."

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