The exemption issued by the CAA clarifies the regulation but does not introduce any changes. However you may find that this clarification results in a situation which is different to what you previously understood. The CAA tells us that:
The exemption allows any person who holds a UK PPL(A) or UK-issued JAR-FCL PPL(A) with a valid SEP rating and Medical Declaration to exercise the privileges of an NPPL and SSEA rating, without the need to obtain an NPPL and incur the associated costs. SLMG and Microlight privileges may also be exercised if these ratings are included in the licence and/or differences training has been completed as applicable. The effect of the exemption is to enable the licence holder to convert a PPL with SEP into an NPPL with the relevant NPPL ratings. However, a PPL(A) is invalidated if there is no Class 1 or Class 2 medical certificate. So the SEP rating and/or a JAR-FCL licence cannot be renewed or revalidated without a Class 1 or Class 2 medical certificate. The exemption allows a PPL(A) to be used as an NPPL(A), which is valid with a medical declaration but only until the current SEP rating (or licence) expires.
This means that without a Class 1 or 2 medical certificate the PPL licence holder cannot revalidate their SEP rating so, before it expires, they face a decision. If they have a medical declaration by choice rather than necessity they could always obtain a medical certificate again and continue flying with full privileges on their PPL. Otherwise, if they don’t already have an SSEA, SLMG and/or Microlight Rating as appropriate on their PPL to replace the expired SEP rating they could apply to the CAA to have one added at a cost of £87. With an SSEA (or SLMG or Microlight) rating on their PPL they could then continue flying but to NPPL limits. Alternatively they could apply for an NPPL at a cost of £142.
If you have a UK PPL(A) which is valid for life, you could add an SSEA (or other) rating to it and as long as you revalidate it every 2 years and maintain your medical declaration it should be good for as long as you are. In this case an SSEA rating appears to be your best buy.
If you have a JAR-FCL PPL which will be valid for only 5 years, you will not be able to renew it unless you have a medical certificate so paying to put an SSEA rating on it will only be an interim solution. When the licence expires your only option short of regaining a medical certificate will be to apply for an NPPL.
Only you know your personal and medical circumstances and the dates of expiry of your ratings and licence so only you can make that choice. A couple of things to bear in mind though:
Whatever you decide, do it in good time before your current rating/licence expires or you will have to take a skills test with an examiner incurring more cost. If you need to add a rating to your licence allow lots of time as the application has to go to the CAA and be completed before your previous rating/licence expires.
If you decide to put an SSEA rating on your PPL and you have already completed differences training for SLMG or microlights, apply for all those ratings at the same time as the SSEA to take advantage of the deal from the CAA of a single charge of £84. If you apply separately you will be charged £84 for each rating!
The exemption itself together with application forms are available through the links below. This is a complex subject and if you have questions it is unlikely that the staff at the LAA office will be able to give you substantive advice. Your best bet is to ask the CAA Flight Crew Licensing department at fclweb@caa.co.uk or on 01293 573700 who can give you a definitive answer.
Medical Declaration Flow Chart : A flow chart to make it easier to understand!
How to complete form SRG 1119:
1. Complete Personal Details (no 1)
2. Complete Application (no 2)
3. Sign and date
Example of completed form. Where the SEP rating has expired, the examiner who conducts the GST and oral examination (as applicable) for the rating being applied for is to complete Section 3.
Send to CAA:
b) Copy of Certificate of Revalidation page from pilot's licence showing valid SEP rating together with logbook evidence of differences training and recent experience in SLMG or Microlight as appropriate (only necessary if a SLMG or/and Microlight rating is also being applied for).
c) Payment Form SRG 1187 (Payment of £87)
Other Links
Written by John Brady
LAA Vice Chairman
September 2010