Personnel Licensing and Part-FCL

Annex 1 and the Aircrew Regulation

Worldwide, personnel licensing is standardised by ICAO Annex 1 (Personnel Licensing): the SARPs that make a licence issued in one contracting state recognisable in the others, provided it meets the ICAO minimums, as the Chicago Convention lesson established. In the European Union those standards do not act on pilots directly; the binding law is Regulation (EU) No 1178/2011, the Aircrew Regulation: one of the implementing rules under the Basic Regulation, sitting exactly where the previous module's rule pyramid placed that layer. Its Annex I is Part-FCL, the flight crew licensing rules; its Annex IV is Part-MED, the medical requirements the next lesson covers.

The relationship between the two: the Aircrew Regulation implements Annex 1 for the EU, generally meeting or exceeding the ICAO standards, and where it deviates the member states notify the differences to ICAO, the mechanism from the first lesson of this course. The practical differences a pilot notices: an EU licence is issued to common rules and is valid in every member state without any validation (inside the EU no recognition step of the kind the Chicago Convention prescribes between states is needed), and the EU system contains licences ICAO does not know, such as the light aircraft pilot licence, which exists below the ICAO minimums and is therefore usable only where EU law applies.

The vocabulary of licensing

Part-FCL is written in defined terms, and the exam tests the definitions directly. Take them in three families. First, how aircraft are grouped for licensing purposes:

Category of aircraft — the broadest split, by basic characteristics: aeroplane, powered-lift, helicopter, airship, sailplane, free balloon. A licence is issued per category.

Class of aeroplane — a categorisation of single-pilot aeroplanes not requiring a type rating: single-engine piston (land), multi-engine piston, and so on; aeroplanes alike enough to share one rating.

Type of aircraft — aircraft of one basic design, variants included unless a modification changes the handling or flight characteristics, requiring a rating of their own because their operation demands specific training: a Boeing 737 is a type.

Multi-pilot aircraft — for aeroplanes: aircraft certificated for operation with a minimum crew of at least two pilots; for helicopters, airships and powered-lift aircraft, those required to be operated with a co-pilot.

Second, the kinds of time a pilot logs, the currency in which every licence requirement is priced:

Flight time — for aeroplanes: the total time from the moment the aircraft first moves for the purpose of taking off until it comes to rest at the end of the flight. Block to block, taxi included.

Solo flight time — flight time during which a student pilot is the sole occupant of the aircraft.

Dual instruction time — flight time or instrument ground time during which a person receives flight instruction from a properly authorised instructor.

Student pilot-in-command (SPIC) — a student pilot acting as pilot-in-command on a flight with an instructor on board who only observes and does not influence or control the flight.

Instrument time — instrument flight time or instrument ground time: the umbrella over the next two.

Instrument flight time — time during which a pilot controls an aircraft in flight solely by reference to instruments.

Instrument ground time — time during which a pilot receives instruction in simulated instrument flight in a flight simulation training device (FSTD).

Cross-country — a flight between a point of departure and a point of arrival following a pre-planned route, using standard navigation procedures.

Night — the period between the end of evening civil twilight and the beginning of morning civil twilight, or such other period between sunset and sunrise as prescribed by the appropriate authority. Civil twilight ends in the evening, and begins in the morning, when the centre of the sun is 6 degrees below the horizon, so night in this definition starts noticeably later than sunset.

Third, the administrative machinery of tests, checks and ratings, including the pair of near-twins the exam loves to swap:

Rating — an entry in a licence stating the special conditions, privileges or limitations attached to it: the instrument rating and the type rating are entries on the licence, not licences of their own.
Skill test — the demonstration of skill for the issue of a licence or rating, including any oral examination.
Proficiency check — the demonstration of skill to revalidate or renew ratings or privileges, including any oral examination. Same cockpit, different purpose: skill test for issue, proficiency check for keeping.
Revalidation — the administrative action taken while a rating or certificate is still valid, allowing continued exercise of its privileges for a further period. Act before expiry and the privileges never lapse.
Renewal — the administrative action taken after a rating or certificate has expired, restoring its privileges upon meeting the requirements. Miss the expiry date and revalidation is no longer available: it is renewal, usually with more to prove.
Multi-crew cooperation (MCC) — the functioning of the flight crew as a team of cooperating members led by the pilot-in-command; the MCC course is the gateway from single-pilot training to the multi-pilot cockpit.
Private pilot — a pilot who holds a licence which prohibits the piloting of aircraft in operations for which remuneration is given, with the exception of instruction or examination activities as Part-FCL establishes them.

Part-FCL and the licensing ladder

Part-FCL itself is organised in subparts: general provisions first, then one subpart per licence in ascending order (LAPL, PPL, CPL, MPL, ATPL), followed by subparts for the instrument rating, for class and type ratings, for the additional ratings, and for instructors and examiners. To act as a flight crew member of a civil aircraft registered in a member state, a pilot must hold a licence and a medical certificate appropriate to the duties, issued or converted under the Aircrew Regulation. The licences form a ladder of privileges:

LAPL (light aircraft pilot licence) — the EU's own entry licence: light aircraft, non-commercial, valid only where EU law applies because it sits below the ICAO minimums.
PPL (private pilot licence) — fly as PIC or co-pilot without remuneration; the ICAO-level private licence.
CPL (commercial pilot licence) — the first professional licence: exercise professional privileges, within limits the next lesson details.
MPL (multi-crew pilot licence) — the airline-track alternative trained from the start for the multi-pilot cockpit; co-pilot privileges in multi-pilot operations.
ATPL (airline transport pilot licence) — the top of the ladder: pilot-in-command in commercial air transport. The theory syllabus this course belongs to serves this licence and everything below it.

One definition holds this system together administratively: the competent authority — the authority designated by each member state to issue licences, ratings and certificates and to oversee their holders; in practice the national aviation authority, working to the common rules. It is to the pilot what the previous lesson's State of Registry is to the aircraft: the address where the paperwork lives.

Exercising the privileges

A licence in the pocket is not yet permission to fly. Two factors govern the exercise of its privileges: the validity of the ratings it contains, and the validity of the medical certificate. A perfectly valid ATPL with a lapsed type rating, or a lapsed medical, confers no right to fly that operation: the licence rarely expires, but its usable content does.

Three further general rules complete the picture. First, language proficiency: a pilot of an aeroplane, helicopter, powered-lift aircraft or airship who is required to use the radiotelephone may only exercise the licence's privileges with a language proficiency endorsement, in English or in the language used for radio communications, on the flight. Second, the age-60 rules for commercial air transport (CAT): from age 60 to 64 a pilot may act in commercial air transport only as a member of a multi-pilot crew; from age 65 a pilot may no longer act as a pilot in commercial air transport at all. Private flying is untouched by either limit. Two footnotes for meeting older exam material: the 60-to-64 rule as written covers aeroplanes and helicopters, and sailplane and balloon pilots (whose licences have since moved out of Part-FCL into their own rules) historically kept a higher limit of 70 for their commercial flying.

Third, documents, and here the exam tests the exact attachment of each duty. When exercising the privileges, the pilot must always carry a valid licence and a valid medical certificate, together with a personal identification document containing a photo. And on request of an authorised representative of a competent authority, the pilot must present the record of flight time without undue delay: the logbook is what the without-undue-delay clause attaches to, not the licence. A student pilot on a solo cross-country additionally carries the evidence of the required authorisations. It is the crew-side counterpart of the ramp inspection the Chicago Convention lesson described.

Annex 1 and the Aircrew Regulation

The vocabulary of licensing

Check you understood

Part-FCL and the licensing ladder

Exercising the privileges

What the exam asks