3-axis microlight flight hours can be logged in an aeroplane logbook for SEP or TMG renewal… or “Mixing oil and water”!

The FFPLUM never wanted this possibility (see the federal newsletter of 3 April 2020), and neither did the DGAC. We have always been opposed to this mixing of the declaratory system and the certified system, which, by its inconsistency, is like “mixing oil and water”!

This provision is the consequence of a European EASA directive: AMC ED2020/005 (AMC: Acceptable Means of Compliance), pushed mainly by the countries of Northern Europe. They took advantage of a request originally made to allow flight hours flown on Annex 1 aircraft (historic aircraft, scientific aircraft, amateur-built aircraft or military aircraft) to be recorded in an aeroplane pilot's logbook, and ‘‘slipped in surreptitiously’’, without any prior consultation, the 3-axis microlights...

We were presented with a fait accompli by this EASA publication, and despite our opposition expressed to the European bodies and the DGAC, in application of the European directives France, through the DGAC, like all European Union member states, was required to transpose this AMC into its national regulations. After a year of internal discussion, the DGAC has therefore very recently published an official instruction on its website on 20 October 2021, which sets out in the link below the detailed arrangements for implementing this possibility:

Official extract from the DGAC website published on 20/10/2021: https://www.ecologie.gouv.fr/pilotes-davion#scroll-nav__3

Counting flight hours on microlights and other Annex I aircraft under Regulation (EU) 2018/1139:
To revalidate an SEP or TMG class rating, it is possible:

• take into account flight hours on all Annex I aircraft (in the relevant aircraft category) for the experience criteria in the last 12 months (12 flight hours, including 6 flight hours as pilot-in-command, and 12 take-offs and landings);
• take the one-hour refresher course on a historic aircraft, scientific or experimental aircraft, amateur-built aircraft or military aircraft that has been authorised for training activity in a DTO or ATO.

In the specific case of Class 3 microlights (three-axis), flight hours can be counted, but the refresher training cannot be done on a microlight.
Pilots will need to record their flight hours on microlights and other Annex I aircraft, i.e. enter them in their logbook, identifying them as "Annex I aircraft" / "microlight" entries.

In summary, all this brings us back to our fundamentals: microlight regulation is national, and therefore specific to each country, and it must on no account be changed. This example shows us, if it were needed, that we must fear and keep away from any attempt at European regulation, especially in this field. Such attempts will always pull towards levelling “at the expense of our Freedoms”, like certified aviation, with provisions and a regulatory straitjacket that member states are bound to transpose and apply as they stand in their national legislation.

The FFPLUM defends, and will always defend, the French microlight regulations, which are our strength, our protection and above all our future.

NO! “Oil and water do not mix.”

Louis Collardeau

1^st Vice-President of the FFPLUM

Regulations and International

President of the EMF