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AMC to Part FCL……New features and clarifications.

Highlights such as, electronic flight log and flight time credit:

Flight log…soon also electronically:

On March 19, 2020, EASA published several AMC Amendments to Regulation (EU) No. 1178/2011. This regardless of the changes to the licensing regulation that will come into force on April 8, 2020, the operational and licensing requirements for gliding and ballooning will be combined in respective “Rulebooks”. Separate Acceptable Means of Compliance and Guidance Material’s (AMC & GM) will need to be published or referenced for each of these two areas or new regulations.

Some small innovations and clarifications concerning the previous FCL regulation are exciting:

For example, the new regulation on “Recording of Flight Time” as per EASA-AMC 1 to FCL.050:
For commercial aviation, it was already the case that flight times could also be kept by the operator “computerized” – now changed by the word “electronic”.
Now, in principle, this possibility also exists for “non-commercial” operation:
The English text says: “for other types of flights in aeroplanes, helicopters and powered lift aircraft, the pilot should record the details of the flights flown in the following logbook format, which may be kept in electronic format. All data set out in (a) should be included.
For sailplanes and, balloons and airships, a suitable format, which may be electronic, should be used. That format should contain the relevant items mentioned in (a) and additional information specific to the type of operation.”

I.e. the flight times for airplanes, helicopters and airships are to be kept in the format presented by EASA. But this can also be done electronically! Ergo, if programs are now offered which enable such a representation, this will also be possible electronically in the future.

Glider pilots and balloonists must keep a “suitable” format. The necessary data, such as date, launch site, landing site, times, etc. must also be included there. However, the format is not so strictly specified. I.e. even lists generated e.g. from platforms such as “Vereinsflieger” or similar would have to be acceptable!

However, EASA points out that in the case of electronic records, they should be created and stored in such a way that they are readily available upon request by a competent authority and contain all relevant information, are certified (i.e. signed?) by the pilot, and are in a format accepted by the competent authority. Here, the providers will have to talk to the authorities and, if necessary, a standardization by NfL will become necessary.


Flight time creditability…even for ANNEX I airmen:

“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 toward fulfilling the hourly requirements of points FCL.140.A, FCL.140.S, and FCL.740.A(b)(1)(ii) under the following conditions:
(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), (b), (c), or (d) That is subject to an authorization specified in points ORA.ATO.135 or DTO.GEN.240.”

A (own) German translation of this:
“Extension and renewal requirements
All flight hours in airplanes or gliders subject to a decision pursuant to Article 2(8) of the basic Regulation or listed in Annex I to the basic Regulation shall be credited in full towards meeting the hourly requirements of points FCL.140.A, FCL.140.S and FCL.740.A(b)(1)(ii), subject to the following conditions:
(a) the aircraft meets the definition and criteria of the applicable Part-FCL aircraft category, class and type ratings; and
(b) The aircraft used for instructor-led training flights is a type (a), (b), (c), or (d) aircraft in Appendix I that is subject to approval in accordance with items ORA.ATO.135 or DTO.GEN.240.”

After that, it is clarified that also flight hours on Annex I -aircrafts (former designation Annex II -aircrafts, changed by the new Basic-Regulation which came into force on 11.09.2018) are creditable! Some people were actually “only” unclear about the historical aircraft – so are flying hours in the “Piperle” also credited? Correctly, however, this question arose to all Annex I – categories up to the ultralight aircraft! I.e. if the Annex-I aircraft corresponds to an “EASA”-regulated” aircraft according to type, class or design, the hours are creditable in my opinion!

Regarding the definition of “EASA”-regulated” aircraft, one would probably refer to the definitions in FCL.010 on “aircraft”, “airplane”, “class of aircraft”…etc. fall back. So, for example, “airplane” means “a heavier-than-air fixed-wing aircraft powered by an engine and held aloft by the dynamic reaction of the air on its wings.”

However, when flights are conducted with an instructor, this applies only to a limited extent. Then it must be aircraft that are also certified in an ATO or DTO.


Frank Dörner, Attorney at Law