EXERCISING LAPL PRIVILEGES WHEN HOLDING A PPL, A CPL OR AN ATPL
(a)Part-FCL requirements stipulate that the privileges of a PPL, CPL or ATPL include LAPL privileges. LAPL privileges in this context mean the privileges to act as pilot in aircraft specified in point FCL.105.A(a) or point FCL.105.H(a), as applicable, and under the conditions specified in these points. It does however not mean that the holder of a PPL, CPL or ATPL can keep the relevant class or type ratings valid through complying with the LAPL recency requirements. Class or type ratings need to be kept valid in accordance with Subpart H of Part-FCL.
(b)As an example, when the holder of a PPL and a SEP aeroplane class rating temporarily loses his or her class 2 medical certificate but keeps an LAPL medical certificate, he or she is still holder of a PPL and of that SEP aeroplane class rating in terms of Part-FCL Subpart H. This pilot could still fly SEP aeroplanes under the conditions specified in point FCL.105.A(a), as long as the class rating is still valid. If the class rating is about to expire, it needs to be revalidated in accordance with point FCL.740.A. Only after the PPL is exchanged for an LAPL, that pilot will fall under Subpart B of Part-FCL and can maintain SEP aeroplane class privileges through compliance with LAPL(A) recency requirements.
(c)In line with the above explanations, a PPL(A) holder who temporarily only holds an LAPL medical certificate can revalidate class ratings that fall within the scope of the LAPL(A) (SEP aeroplane, TMG). However, it would not be possible for such a pilot to revalidate class ratings outside the scope of the LAPL. For example, if the pilot, on his or her PPL, also holds an MEP or SET class rating, he or she can revalidate (or renew) such a rating only after being issued with a class 2 medical certificate again.