spl-tmg

SPL with TMG Privileges only

An edge case based on the EASA Part‑SFCL.

Intro: Is This Even Possible?🤔

Under the EASA Part‑SFCL, a Touring Motor Glider (TMG) is legally treated as a sailplane.

“When requirements of Part-SFCL refer to ‘sailplanes’, this includes powered sailplanes as well as touring motor gliders (TMGs), unless otherwise specified.”
— GM1 SFCL.001 Scope

Thus, a student may complete the entire SPL training (theories, flights, and skill test) on a TMG.

For example:

“Applicants shall complete the skill test in… or a TMG…”
— SFCL.145(b)

However, there is a critical limitation:

“If the skill test as specified in point SFCL.145 has been completed in a TMG, the privileges of the SPL shall be limited to TMGs.”
— SFCL.150(d)

This doc is about the requirements to obtain a 『 TMG‑limited SPL 』, based strictly on the EASA Part‑SFCL.

1. Entry Requirements

Requirement	Detail	Reference
Minimum age	16 years at licence issue (solo flights permitted from age 14)	SFCL.120, SFCL.125
Medical certificate	Valid Part‑MED Class 2 or LAPL medical certificate	SFCL.115(c)
Training organisation	Complete the course at an ATO or a DTO	SFCL.130(a)

2. Theoretical Knowledge (SFCL.135)

You must pass the CAA exam(s) in 9 subjects, taken before the skill test (SFCL.145(c)) and under the authority of a single Member State’s competent authority.

Examination rules (AMC1 SFCL.135):

An ATO/DTO recommendation is required and valid for 12 months.
Approximately 120 MCQs in total.
Pass mark: 75% for each subject.
Must pass all sbjects within 18 months of the first attempt.
Maximum 4 attempts per subject; failure on the 4th attempt will result in a complete retake for all subjects.
Successful cxam results are valid for 24 months for the skill test and licence application.

3. Flight Training & Experience (SFCL.130(a)(2))

The course must be tailored to TMG privileges. Minimum requirements:

Item	Minimum
Total flight instruction (sailplanes, incl. TMG)	15 hours
…of which dual flight instruction	10 hours
…of which in TMGs	6 hours
…of which dual in TMG	4 hours
Supervised solo flight time	2 hours
Launches / take‑offs and landings	45
Solo cross‑country in a TMG	≥ 150 km (80 NM) + 1 full‑stop landing (@ another site)

4. Radio Telephony Qualification (if required by national law)

Many Member States require a radio telephony qualification (e.g., FCL.055 or equivalent national requirement) before exercising privileges that involve radio communication.

Check with your competent authority for the specific examination and application procedure in your State.

5. Skill Test in a TMG (SFCL.145 + AMC1)

The skill test must be taken with an FE(S) (Flight Examiner for Sailplanes).

Test content per AMC1 SFCL.145(d)(2) :

Section	Content
1. Pre‑flight operations & departure	Documentation, flight planning, NOTAM/weather briefing, mass & balance, performance calculation, TMG inspection & servicing, engine start, taxiing, pre‑take‑off checks, take‑off, departure, ATC liaison (if applicable).
2A. General airwork (powered)	Straight & level with speed changes, climbs & climbing turns, medium (30°) turns, steep (45°) turns, slow flight, stalls (clean with power, descending‑turn approach‑to‑stall, landing configuration), descents.
2B. General airwork (unpowered)	Straight & level, medium turns, in‑flight engine start and stop procedures, stall in a turn.
3. En‑route procedures	Dead reckoning & map reading, maintaining altitude/heading/speed, orientation, ETAs & log keeping, diversion planning, fuel/engine management, ATC liaison.
4. Approach & landing	Arrival procedures, look‑out, short‑field & crosswind landing, flapless landing, idle‑power approach, touch‑and‑go, go‑around from low height, actions after flight.
5. Abnormal & emergency procedures	Simulated engine failure after take‑off, forced landing, precautionary landing, simulated emergencies, oral questions.

*Some of the skill test components may be combined, at the discretion of the FE.

Additional notes:

Navigation leg must be at least 30 minutes with ≥ 2 waypoints (may be flown separately by agreement).
Tolerances (guidance): height ±150 ft; speed +15/−5 kt (take‑off/approach), ±15 kt otherwise.
Pass/fail: Failure in one section → repeat only that section. Failure in two or more sections → retake the entire test. If the applicant fails within 2 attempts, further training is required before retesting.

6. Application to the Competent Authority

Submit your application to the competent authority of the Member State where you trained, using their prescribed form(s). The application typically requires:

Declaration: You must confirm that you do not hold (or have pending) a Part‑SFCL licence in another EASA Member State and have never had one revoked or suspended there (SFCL.015(e)). False declarations may be subject to national penalties.

7. After Issue — Privileges & Recency

Basic Privileges (SFCL.115)

Act as PIC in TMGs without remuneration in non‑commercial operations.
Carriage of passengers: Requires either:
- ≥ 10 hours flight time or 30 take‑offs/landings as PIC after licence issue, plus one check/training flight with an FI(S); or
- Hold an FI(S) certificate.
Remunerated / commercial operations: Requires age 18 + 75 hours flight time or 200 take‑offs/landings as PIC after issue.

TMG Recency — every 24 months (SFCL.160(b))

Either:

12 hours flight time as PIC / dual / supervised solo, including:
- 6 hours on TMGs,
- 12 take‑offs and landings, and
- a ≥ 1 hour training flight with an instructor; or
Pass a proficiency check with an FE(S) based on the TMG skill test.

Passenger‑carrying Recency — every 90 days (SFCL.160(e)(2))

3 take‑offs and landings as PIC in a TMG within the preceding 90 days.
For carrying passengers at night in a TMG, at least 1 of those take‑offs/landings must be at night.

Launching Method Currency (SFCL.155(a)(2) & (c))

If you later obtain self‑launch privileges, you need 5 launches (or take‑offs in a TMG) in the last 24 months to remain current.

8. Extending to Pure Sailplanes Later (Optional, SFCL.150(e))

With a TMG‑limited SPL, you can add privileges for sailplanes excluding TMGs upon application, provided you:

Complete at an ATO/DTO the training elements of SFCL.130(a)(2)(iv) :
- ≥ 7 hours of instruction in sailplanes (excluding TMGs), including 3 hours dual;
- 50 km solo cross‑country or 100 km dual cross‑country (which may be completed in a TMG by derogation);
- plus at least 15 launches and landings in a non‑TMG sailplane.
Pass a new skill test in a pure sailplane, during which you must also demonstrate theoretical knowledge for sailplanes in the 5 TMG‑specific subjects (SFCL.150(e)(2)).

Training completion must be entered in your logbook and signed by the head of training of the ATO/DTO.

Sources: EASA Easy Access Rules for Sailplanes (Nov 2022), Part‑SFCL points GM1 SFCL.001, SFCL.115, SFCL.130, SFCL.135, SFCL.140, SFCL.145, SFCL.150, SFCL.155, SFCL.160.

Here are two separate appendices – Appendix 1 for DTO and Appendix 2 for ATO – based on the regulatory framework of EASA Part‑SFCL, Part‑ORA (Annex VII to Regulation (EU) No 1178/2011), and Part‑DTO (Annex VIII to Regulation (EU) No 1178/2011).

The DTO version is streamlined for a declared organisation with simplified oversight, while the ATO version includes additional organisational, quality, and instructor standardisation requirements appropriate for an approved training organisation.

APPENDIX 1 – TMG-ONLY SPL CURRICULUM (DTO)

For Use by Declared Training Organisations (Part‑DTO)

1. Overview & Minimum Training Requirements (SFCL.130)

Requirement	Minimum	Ref
Total flight instruction	15 hrs	SFCL.130(a)(2)(i)
Dual instruction	10 hrs	SFCL.130(a)(2)(ii)
…of which on TMG	6 hrs (incl. 4 hrs dual)	SFCL.130(a)(2)(iii)
Supervised solo	2 hrs	SFCL.130(a)(2)(iv)
Launches / take‑offs & landings	45	SFCL.130(a)(2)(v)
Solo cross‑country (TMG)	≥150 km (80 NM) + 1 full‑stop landing away	SFCL.130(a)(2)(vi)

Additional DTO requirements (Part‑DTO):

The DTO must hold a valid declaration submitted to the competent authority.
The DTO must have a Head of Training (HT) responsible for the curriculum and student records.
Instructors must hold valid FI(S) certificates with TMG privileges (SFCL.315(a)(4)) for TMG‑specific instruction.

2. Theoretical Knowledge Syllabus (AMC1 SFCL.130)

Subject	Core Topics
Air Law	ICAO, national regs, airspace, ATS, flight plans, licensing, aerodromes, accident reporting
Human Performance	Physiology, psychology, health, fatigue, oxygen, spatial disorientation
Meteorology	Atmosphere, clouds, fronts, pressure, icing, thunderstorms, MET info, hazards
Communications	VFR R/T, phraseology, uncontrolled/controlled fields, lost comms, distress/urgency
Principles of Flight	Aerodynamics, stability, control, load factors, stalls, spins, spiral dive, speed polar
Operational Procedures	Launch/landing, soaring, outlanding, emergency drills, parachute ops, TEM
Aircraft General (TMG)	Airframe, systems (fuel/electrics/engine/propeller), instruments, rigging, maint., mass/balance
Flight Performance & Planning	Polar, cruise, task setting, ICAO flight plan, re‑planning, fuel planning
Navigation	DR, charts, compass, GNSS, VFR nav, position fixing, ATS liaison

Examination (AMC1 SFCL.135):

120 MCQs, 75% pass per subject.
Pass all within 18 months; results valid 24 months.
Max 4 attempts per subject.
ATO/DTO recommendation required (valid 12 months).

3. Flight Instruction Syllabus (AMC2 SFCL.130)

Pre‑Solo (Exercises 1–12 must be completed before first solo):

Ex.	Title	Key Content
1	Familiarisation	Cockpit, controls (stick, pedals, flaps, airbrakes, engine), instruments, checklists
2	Emergencies	Parachute, bail‑out, PLF, system failure drills
3	Prep for flight	Briefing, docs, ground handling, walk‑around, mass/balance, harness, start & run‑up
4	Air experience	Area familiarisation, look‑out
5	Effects of controls	Attitude/speed, primary effects, flaps/airbrakes/UC
6	Coordination	Adverse yaw, aileron/rudder coordination, moderate banks
7	Straight flight	Pitch/trim, speed control, stability
8	Turning	Entry/exit, faults (slip/skid), headings, instrument use
9a	Slow flight	High AoA, recognition/recovery
9b	Stalls	Symptoms, recovery (straight/turning, wing‑drop, approach/landing config, accelerated)
10	Spins & spiral dives	Recognition, recovery, differentiation
11c	Self‑launch (TMG)	Engine start/stop, pre‑take‑off, normal/crosswind T/O, power failure, abandoned T/O, in‑flight restart, decision‑making
12	Circuit, approach & landing	Rejoin, pre‑landing, wind effect, airbrakes/flaps, normal/crosswind, short field

Post‑Solo (Exercises 13–17):

Ex.	Title	Key Content
13	First solo	Briefing, local area, CG awareness, supervised flight
14	Advanced turning	Steep (45°+), unusual attitude recovery
15a	Thermalling	Detection, instruments, joining/centring/leaving, look‑out
15b	Ridge	Rules, path optimisation, speed, wind shear
15c	Wave	Access/exit, speed limits with altitude, oxygen
16	Out‑landings	Glide range, field selection, circuit/approach, post‑landing
17a	Flight planning	Weather, NOTAMs, maps, route, fuel, mass/balance, ICAO plan, alternates
17b	In‑flight nav	Track maintenance, re‑routing, R/T/ATC, position uncertainty, lost procedures, remote airfield join
17c	XC techniques	MacCready theory, final glide, optimal track, risk mitigation

4. Solo Cross‑Country (SFCL.130(a)(2)(vi))

≥150 km (80 NM) TMG flight with 1 full‑stop landing at a different site.
Pre‑flight: Weather, NOTAMs, route planning, ICAO FPL (if req.), mass/performance/balance checks.
Supervised by FI(S) – pre‑flight briefing + post‑flight debrief.

5. Skill Test (AMC1 SFCL.145(d)(2))

Conducted by an FE(S) in a TMG.

Section	Content
1. Pre‑flight & departure	Docs, plan, WX/NOTAM, mass/balance, perf., inspection, start, taxi, T/O, ATC
2A. Powered airwork	S&L (speed changes), climbs, 30° & 45° turns, slow flight, stalls (clean, approach, landing config)
2B. Unpowered airwork	S&L, 30° turns, in‑flight engine stop/start, stall in turn
3. En‑route	DR, map, heading/alt/speed, ETAs, diversion, fuel/engine mgmt, ATC
4. Approach & landing	Arrival, short‑field, crosswind, flapless, idle‑power, touch‑and‑go, go‑around
5. Abnormal/emergency	Engine failure after T/O, forced/precautionary landing, emergencies, oral Qs

Tolerances: Height ±150 ft; speed +15/−5 kt (T/O & approach), ±15 kt otherwise. Pass/Fail: Fail 1 section → retake that section; fail ≥2 → retake entire test; 2 failed attempts → further training required.

6. DTO Administration

Course Completion:

Issue certificate signed by Head of Training.
Logbook entry signed.
Recommend for theoretical exam (valid 12 months) and skill test.
Verify valid Part‑MED Class 2 / LAPL medical before solo.

Records to Keep (DTO.GEN.215):

Training record (dates, exercises, instructor signatures).
Logbook copies.
Course completion certificate copy.
Skill test report copy (FE(S) signed).
Declaration and changes notified to competent authority.

DTO Operational Notes:

TMG definition: Integrally mounted non‑retractable engine/propeller; capable of T/O/climb under own power.
FI(S) privileges: An FI(S) without TMG instructional privileges may teach pure gliding exercises in a TMG, but must sit in the PIC seat. TMG‑specific items require an FI(S) with TMG privileges (SFCL.315(a)(4)).
Use of TMGs for pure sailplane training: Max 8 hours, only pure gliding manoeuvres, if not seeking TMG privileges.
Extension to pure sailplanes (SFCL.150(e)) : Additional 7 hrs instruction on non‑TMG sailplanes (3 hrs dual, 15 launches/landings, XC – 50 km solo or 100 km dual, may use TMG by derogation) + new skill test in pure sailplane.
Post‑licence recency (TMG) : 12 hrs (6 on TMG, 12 T/O/Ldg, 1 hr training flight) OR proficiency check within 24 months (SFCL.160(b)).
Passenger currency: 3 T/O/Ldg as PIC in preceding 90 days (SFCL.160(e)(2)).

Based on EASA Easy Access Rules for Sailplanes (Nov 2022) – Part‑SFCL and Part‑DTO. Always verify current amendments.

APPENDIX 2 – TMG-ONLY SPL CURRICULUM (ATO)

For Use by Approved Training Organisations (Part‑ORA)

1. Overview & Minimum Training Requirements (SFCL.130)

Requirement	Minimum	Ref
Total flight instruction	15 hrs	SFCL.130(a)(2)(i)
Dual instruction	10 hrs	SFCL.130(a)(2)(ii)
…of which on TMG	6 hrs (incl. 4 hrs dual)	SFCL.130(a)(2)(iii)
Supervised solo	2 hrs	SFCL.130(a)(2)(iv)
Launches / take‑offs & landings	45	SFCL.130(a)(2)(v)
Solo cross‑country (TMG)	≥150 km (80 NM) + 1 full‑stop landing away	SFCL.130(a)(2)(vi)

Additional ATO requirements (Part‑ORA):

The ATO must hold an approval certificate issued by the competent authority.
The ATO must have a Chief Flight Instructor (CFI) or Head of Training responsible for curriculum oversight.
The ATO must operate under an Operations Manual (ORA.ATO.125) containing syllabi, procedures, and checklists.
The ATO must have a quality system (ORA.ATO.135) including internal audits and occurrence reporting.
Instructors must hold valid FI(S) certificates with TMG privileges (SFCL.315(a)(4)) for TMG‑specific instruction.
The ATO must conduct instructor standardisation (ORA.ATO.140) to ensure consistent training delivery.

2. Theoretical Knowledge Syllabus (AMC1 SFCL.130)

Subject	Core Topics
Air Law	ICAO, national regs, airspace, ATS, flight plans, licensing, aerodromes, accident reporting
Human Performance	Physiology, psychology, health, fatigue, oxygen, spatial disorientation
Meteorology	Atmosphere, clouds, fronts, pressure, icing, thunderstorms, MET info, hazards
Communications	VFR R/T, phraseology, uncontrolled/controlled fields, lost comms, distress/urgency
Principles of Flight	Aerodynamics, stability, control, load factors, stalls, spins, spiral dive, speed polar
Operational Procedures	Launch/landing, soaring, outlanding, emergency drills, parachute ops, TEM
Aircraft General (TMG)	Airframe, systems (fuel/electrics/engine/propeller), instruments, rigging, maint., mass/balance
Flight Performance & Planning	Polar, cruise, task setting, ICAO flight plan, re‑planning, fuel planning
Navigation	DR, charts, compass, GNSS, VFR nav, position fixing, ATS liaison

Examination (AMC1 SFCL.135):

120 MCQs, 75% pass per subject.
Pass all within 18 months; results valid 24 months.
Max 4 attempts per subject.
ATO recommendation required (valid 12 months).

3. Flight Instruction Syllabus (AMC2 SFCL.130)

Pre‑Solo (Exercises 1–12 must be completed before first solo):

Ex.	Title	Key Content
1	Familiarisation	Cockpit, controls (stick, pedals, flaps, airbrakes, engine), instruments, checklists
2	Emergencies	Parachute, bail‑out, PLF, system failure drills
3	Prep for flight	Briefing, docs, ground handling, walk‑around, mass/balance, harness, start & run‑up
4	Air experience	Area familiarisation, look‑out
5	Effects of controls	Attitude/speed, primary effects, flaps/airbrakes/UC
6	Coordination	Adverse yaw, aileron/rudder coordination, moderate banks
7	Straight flight	Pitch/trim, speed control, stability
8	Turning	Entry/exit, faults (slip/skid), headings, instrument use
9a	Slow flight	High AoA, recognition/recovery
9b	Stalls	Symptoms, recovery (straight/turning, wing‑drop, approach/landing config, accelerated)
10	Spins & spiral dives	Recognition, recovery, differentiation
11c	Self‑launch (TMG)	Engine start/stop, pre‑take‑off, normal/crosswind T/O, power failure, abandoned T/O, in‑flight restart, decision‑making
12	Circuit, approach & landing	Rejoin, pre‑landing, wind effect, airbrakes/flaps, normal/crosswind, short field

Post‑Solo (Exercises 13–17):

Ex.	Title	Key Content
13	First solo	Briefing, local area, CG awareness, supervised flight
14	Advanced turning	Steep (45°+), unusual attitude recovery
15a	Thermalling	Detection, instruments, joining/centring/leaving, look‑out
15b	Ridge	Rules, path optimisation, speed, wind shear
15c	Wave	Access/exit, speed limits with altitude, oxygen
16	Out‑landings	Glide range, field selection, circuit/approach, post‑landing
17a	Flight planning	Weather, NOTAMs, maps, route, fuel, mass/balance, ICAO plan, alternates
17b	In‑flight nav	Track maintenance, re‑routing, R/T/ATC, position uncertainty, lost procedures, remote airfield join
17c	XC techniques	MacCready theory, final glide, optimal track, risk mitigation

4. Solo Cross‑Country (SFCL.130(a)(2)(vi))

≥150 km (80 NM) TMG flight with 1 full‑stop landing at a different site.
Pre‑flight: Weather, NOTAMs, route planning, ICAO FPL (if req.), mass/performance/balance checks.
Supervised by FI(S) – pre‑flight briefing + post‑flight debrief.

5. Skill Test (AMC1 SFCL.145(d)(2))

Conducted by an FE(S) in a TMG.

Section	Content
1. Pre‑flight & departure	Docs, plan, WX/NOTAM, mass/balance, perf., inspection, start, taxi, T/O, ATC
2A. Powered airwork	S&L (speed changes), climbs, 30° & 45° turns, slow flight, stalls (clean, approach, landing config)
2B. Unpowered airwork	S&L, 30° turns, in‑flight engine stop/start, stall in turn
3. En‑route	DR, map, heading/alt/speed, ETAs, diversion, fuel/engine mgmt, ATC
4. Approach & landing	Arrival, short‑field, crosswind, flapless, idle‑power, touch‑and‑go, go‑around
5. Abnormal/emergency	Engine failure after T/O, forced/precautionary landing, emergencies, oral Qs

6. ATO Administration & Quality Oversight

Course Completion:

Issue certificate signed by Head of Training / Chief Flight Instructor.
Logbook entry signed.
Recommend for theoretical exam (valid 12 months) and skill test.
Verify valid Part‑MED Class 2 / LAPL medical before solo.

Records to Keep (ORA.ATO.135):

Training record (dates, exercises, instructor signatures).
Logbook copies.
Course completion certificate copy.
Skill test report copy (FE(S) signed).
Quality system records (internal audits, occurrence reports).
Instructor standardisation records.

Quality System Requirements (ORA.ATO.135):

Internal audit programme covering all training activities.
Occurrence reporting and corrective action procedures.
Regular review of training syllabi and materials.
Student feedback and performance monitoring.

Instructor Standardisation (ORA.ATO.140):

Regular standardisation meetings for all FI(S)s.
Consistent delivery of theoretical and flight instruction.
Monitoring of instructional techniques and TEM integration.

ATO Operational Notes:

TMG definition: Integrally mounted non‑retractable engine/propeller; capable of T/O/climb under own power.
FI(S) privileges: An FI(S) without TMG instructional privileges may teach pure gliding exercises in a TMG, but must sit in the PIC seat. TMG‑specific items require an FI(S) with TMG privileges (SFCL.315(a)(4)).
Use of TMGs for pure sailplane training: Max 8 hours, only pure gliding manoeuvres, if not seeking TMG privileges.
Extension to pure sailplanes (SFCL.150(e)) : Additional 7 hrs instruction on non‑TMG sailplanes (3 hrs dual, 15 launches/landings, XC – 50 km solo or 100 km dual, may use TMG by derogation) + new skill test in pure sailplane.
Post‑licence recency (TMG) : 12 hrs (6 on TMG, 12 T/O/Ldg, 1 hr training flight) OR proficiency check within 24 months (SFCL.160(b)).
Passenger currency: 3 T/O/Ldg as PIC in preceding 90 days (SFCL.160(e)(2)).

Based on EASA Easy Access Rules for Sailplanes (Nov 2022) – Part‑SFCL and Part‑ORA (Regulation (EU) No 1178/2011). Always verify current amendments.

Summary of Key Differences: DTO vs ATO

Aspect	DTO (Appendix 1)	ATO (Appendix 2)
Status	Declared organisation	Approved organisation
Oversight	Declaration to competent authority	Approval certificate issued by competent authority
Quality system	Not mandatory	Required (ORA.ATO.135)
Operations Manual	Not required	Required (ORA.ATO.125)
Instructor standardisation	Not formalised	Required (ORA.ATO.140)
Internal audits	Not required	Required
Occurrence reporting	Not required	Required
Records	Basic training records	Comprehensive records including quality system documentation