IR/Exam Discrimination: Fighting the CAA?

[manfromuncle]

Here's a question for all you UK pilots:

How many pilots do you know who are re-sitting the CPL/ATPL exams because they didn't get their IR within three years? Quite a few I am willing to bet. I know at least five personally.

Also, you can gain a fixed wing IR on a single engine piston, but not a helicopter IR? Why is that?

I think it's time the CAA seriously considered changing the rules for helicopter instrument training. They need to understand that by forcing people to train on a twin turbine (yes, I know there is one 206 at Norwich) this makes it prohibitively for people to gain an IR within three years of getting their CPL. And let's not get into the utterly useless groundschool knowledge we have been forced to learn under the "interim" period.

In the USA people seeking to be a professional pilot generally do their IR straight after their PPL - much more sensible than forcing people to fly round in circles hour building to get to 155 hours.

Am I alone in thinking this situation is crazy?

Discuss.

[Whirlygig]

Am I alone in thinking this situation is crazy?


Nope!

Can’t think of anything to discuss; completely agree with you!

In addition, there are a few people (including me) who got through part of their CPL exams thinking that eventually CPL/IR exams plus hours experience could be converted into an ATPL who are now finding that this “method” has been withdrawn and the only way to ATPL is to sit ATPL ground exams.

Cheers

Whirls

[Flugplatz]

Yep, it sucks major league! I can understand training on twins-only as most aeroplane commercial work is on twins, and you have the whole asymmetry thing to deal with; but when the rotors are driven through a single gearbox...
It is a bit of a hangover from the days when there were virtually no 'light' twin helicopters and even less certified for actual IFR flight. Seems to be still hanging on as the usual training helos for initial IR (in the States at least) are the R22/H300 which are not certified for actual IFR, and so the CAA are being a bit conservative over here. As long as pilots don't try to actually use an IR in their R44, etc and wait until they are in a proper machine really suitable (autopilot, etc) as you will find at a much lower level in aeroplanes.

Flug

[helimutt]

So why do a single engine IR(H) then? It serves no purpose. I'm all for people being confident to fly on instruments if necessary, but most people shouldnt even be flying if they are not suitably qualified, in an aircraft not certified for IFR flight and in IMC. If the wx is sh*t, you shouldn't be there in the first place, kind of thing.

If someone knows of a piston single, certified for IFR (does it have the necessary Autopilot/IFR fit etc) then please let me know.:hmm:

Helicopters are predominantly VFR machines but the ones used for IFR commercial ops, are all twin engine (uk)


I think this argument could run and run.

Ok, do the training on a single perhaps but for what purpose? To then go and do the conversion to a twin anyway? Why not get the experience on the Twin, in IMC, more complex aircraft to keep on top of etc.

Or why not this:- Consider it part of the joining fee to a fairly exclusive club???:E ;)

[Dragpin]

The system in the UK does indeed need a re-think. It should'nt be modelled on the fixed wing, it should stand alone.
In my opinion the process should be something like the following:

Sit ATPL(H) or CPL(H) exams. They should be valid for 3 years to gain your CPL(H) licence then you have a further period of time, say 3 years in order to get your IR(H).

This then gives people time to save some more money for the course but also, which I think is the most important reason for allowing more time, is for pilots to gain valuble experience within the industry i.e build more time, progress onto single turbine then onto twin turbine. The main way of doing this is to go the instuctor route.

[Whirlygig]

Please could someone clarify the nature and purpose of the Instrument Rating for me? I thought much of it was procedural as well as flying in IMC conditions so aren’t there circumstances when one could be flying IFR in VMC conditions? Obviously, the other way round ain’t too clever!

Surely the procedural aspect of the training could be undertaken on a single piston helicopter which would thus reduce the cost?

Cheers

Whirls

[Dangagan]

I believe that most part or all of the Instrument Rating should be done in a procedure trainer or in the simulator.

[heliski22]

Whirls

Got it in one! The same argument applies for the use of an FNPTII or Procedures Trainer on the ground. And much of the time on the training twin is spent with blinds up to re-create the "environment" while the instructor happily takes in the sunlit, broad daylight view from the other seat.

The difficulty is the time - unless you're starting almost from scratch on a sponsored programme (scarcer than rocking horse s**t and/or hen's teeth) then the only way to acquire the qualification is by paying for it yourself - tough call just after paying for the PPL, then the CPL and Instructor's ticket.......but inside three years - nae chance!!

However, the absence of the aforementioned rocking horse s**t - sorry sponsored programmes - notwithstanding, the industry still basically expects individuals to possess a CPL/IR when they turn up for interview to fly larger twins.........

All things are not equal and it is far from being an ideal world!!!

"If Momma ain't happy, ain't nobody happy!!"

[SmokinHole]

I think the main reason (like previously mentioned) is the fact that the UK CAA don't want people to be careless about flying into IMC conditions in a VFR single engined machine just because they have an IR and feel confident.

A load of bull if you ask me. I have a mother, I don't need a second one. The CAA are just being cowards in the face of (in their view) potential litigation and I presume feel that as newly minted IR rated pilots we will be overcome with childish excitement and take our R22s straight into the nearest cloud! Admittedly there might be a few, but legislating for the minority is paranoid at best.

Just to add insult to injury, even though we are in 'JAR land' and we 'supposedly' have the freedom to get our training and ratings in any country that is JAR compliant, if you get your SEIR(H) in a country that allows it (like Sweden), the UK CAA will still refuse to put it on your licence. So much for Mutual Recognition!

There's a word for people like that, it starts with 'F' and ends with 'uckers'..

[heliski22]

Eh......................

So what's to stop an irresponsible, but qualified IR driver, complete with twin hours in training, scooting of into the grey and muggy yonder in an under-equipped single?

I did a job in Ireland some years ago and, upon leaving Galway on a very poor day en route to Dublin in an IFR twin, climbed to 5000ft, getting clear on top at about 4,500ft to hear a JetRanger driver doing exectly the same thing not more than 20 miles ahead of me, fortunately on a diverging track.

I learned afterwards he was intrument rated and alternating between a larger IR twin and the 206. It would hardly seem to matter what kind of training was carried out if such is the mind-set of the pilot, now would it?

Slightly off-thread but effectively preventing or making it extremely difficult for people to qualify is hardly an acceptable method of maintaining standards, now is it?

[Flashover999]

Totally agree with you!

Im fretting over the time I have left to pass the IR but I just cant afford it at the moment.
My Gripes also include the following...

I did all the ATPL (A) exams needed plus the ATPL (H) POF to get my CPL. I also have a fixed wing licence and thought "Why not get the CPL (A). I only have to do the POF (A) and Performance papers. Because its been more than 18 months since I started the ATPL Study I willl have to take ALL 14 ATPL (A) Exams again. SO flying around for 12 months using my CPL counts for nothing, Even though I had to bow to the CAA and do their interim exams which had very little to do with Helicopters.

Mad world, can deal with the mad, cant deal with the extra expense!!

Flash:ugh:

[Whirlygig]

do their interim exams which had very little to do with Helicopters.
I wouldn't even have said it was as much as "very little"! :}

Cheers

Whirls

[thwock]

and then having jumped through those hoops you need 100hrs pi IFR before any public transport:ugh::ugh::ugh:

[Bravo73]

and then having jumped through those hoops you need 100hrs pi IFR before any public transport:ugh::ugh::ugh:


Says who? :confused:

[thwock]

jar ops 3 3.96 commanders minimum requirements 700 hours total time 300 hrs pic 100hrs under ifr.

[Bravo73]

thwock,

Ah. That is one of those strange requirements.

IIRC, one hour of IR training or one hour of IMC actually counts as 4 hours IFR.


Therefore, if you've sat a 50hrs JAA IR course, you will have more than the required 100hrs IFR.


This repeatedly comes up on the fixed-wing wannabe forums.

[heliski22]

Bravo 73

I'm intrigued - where does it say that?

[Bravo73]

This repeatedly comes up on the fixed-wing wannabe forums.


Professional Pilot Training (http://www.pprune.org/forums/forumdisplay.php?f=14)



:E

[misterbonkers]

And on the single engine IR subject; are the army air corps still flying gazelles around the U.K. on instruments?

[Torquetalk]

Smokin

Guess you’re referring to Proflight’s course in Sweden: they use an SE Bell I think. A friend of mine did their IR course recently, had no trouble getting it recognised by the Norwegian authorities and now works for one of the majors. It can be that straightforward :hmm:

One problem area seems to be where different countries have implemented different amendments to JAR-FCL 2. So an overseas syllabus and its requirements can be non-aligned with the requirements of the licence-issuing authority. Here it’s perhaps important to make sure an overseas IR provider is experienced in dealing with the licence holder’s authority and aware of any problem areas.


Helimutt

Some countries allow IMC certification of SE aircraft, so it is possible to get IMC training during a SE IR(H) course

You are right, self-funded conversion to ME is still going to be expensive in practice, but if done as part of TR training by a major operator, quite straightforward.

[Spanish Waltzer]

I appreciate this is only relevant to the mil types but without moving this thread onto the mil forum does anyone know how all this sits for those that have acquired CPL(H) through the mil bridging package? As I understand it this equates to a frozen ATPL(H) - unfrozen once an IR is acheived. However is there still this 3 year window? and if so what happens after the 3 years if no IR is gained???

[jemax]

Just a small point, the exams run out at the end of the month you did them, so I was 5th May 2005, they expire 31st May 2008.

Fortunetly I am booked in with an anticipated test date 22nd April, I have planned the bank robbery to pay for it in March!

[Bravo73]

Spanish Waltzer,

Have you looked in LASORS yet?



D6.6 INSTRUMENT RATING
REQUIREMENTS

It is not mandatory for a QSP (H) to complete an
Instrument Rating before being issued with a CPL(H).

An applicant for an IR (H) is required to complete the
requirements in accordance with Section E.

QSPs should note that JAR-FCL 2 requires both a CPL
(H) and IR (H) to be obtained within the 36 month
Acceptance Period of the ATPL (H) examinations to
maintain ATPL (H) theory credit for the subsequent
issue of an ATPL (H). However, it has been agreed that
a QSP (H) will not be subject to this requirement. Whilst
the 36 months Acceptance Period will still apply to the
issue of a CPL (H), an IR (H) can be obtained at any
time up to 3 years from the date of the last flight in a
military helicopter, and still retain ATPL (H) theory
credit.

[manfromuncle]

...from the date of the last flight in a military helicopter...So ex-mil pilots just have to have a quick wizz around the circuit in a military heli to stop their exam credits expiring. And civvy folk have to spend £2,000+ sitting the exams again. Discrimination? Surely not.

[helimutt]

Torquetalk,
Yes it may be possible to get SE IMC training etc but in UK land, you aint flying in IMC commercially, legally, unless you're in a twin. I don't particularly care about other countries nor do I profess to know anything about their regulations.
I just know the hoops I had to jump through and yes, they are a complete pain in the ar&e.

Yes Whilrygig, you can fly IFR VMC. You're just flying to a set of rules.
You can practice procedural flying in an R22 if you want but only if VMC and you would need a safety pilot looking out for you if you're looking at the dials to fly those procedures. You can hardly fly procedures looking outside.

I agree the rules are poorly set and could be more user friendly but it would seem to be more of a money spinner exercise than anything else to gain a useful IR.

Saying that, the offshore companies have recently paid for single engine heli IR conversions to multi, ths saving a few pounds on training costs.

[thwock]

bravo 73
just spent 1/2 hour looking through wannabe forum can't find it

GIVE US A CLUE

[Bravo73]

I've been looking myself.

If/when I find it, I'll post it here.

[Impress to inflate]

Just look at the CAA and how far behind the drag curve they are on all other matters. Not just single engine rotory. I sat my CPL exams a number of years ago and had to learn EVEY-THING there is to know about Omega, Loran C and Decca. GPS was a single page of A4. Went into my first job and all the hyperbolics had been turned off or were about to. All the a/c in the fleet had GPS. The CAA (Campaign Against Aviation) is as I see it, an old boys net work for 1950's era RAF types. Please correct me if I am wrong, no doubt you all will !!

[helimutt]

Nope, you're not far off the mark. Not necessarily old boy types but the system seems to have been handed down with the old 'it's always been like that' attitude i feel.
I bet the 'new blood' that works there wish they could change things, but I imagine their hands are tied by bureaucratic bull***t.

[Torquetalk]

Helimutt

The point I was making is that it is possible to get real IMC training in a single. The SE IR(H) & overseas (via JAR mutual recognition) routes gives options to people trying to make decisions about the IR(H).

TT

[helimutt]

I know there are people out there that go IMC in a single.

:uhoh:

Yes Sweden and even the UK have a jetranger for IR training. The cost is quite high and for the difference you'd pay, you might as well spend that little bit more to do it in a twin. An IR(H) on a single in the UK is absolutely no use whatsoever unless you are only getting it as a stepping stone to moving onto multi's.

Granted, IMC training does have it's uses for some but for the PPL holder, why even teach it? Why not impress upon them even more the stupidity of going IMC without proper training and equipment?


Why would you need to make a decision about the IR(H)? You're either going into a job where you will need it or you're not. Seems pretty clear cut to me.


The only real question is 'is the company going to pay for your IR?' If so, do it on a multi because it won't cost you a penny!! :)

[soggyboxers]

The IR is all about procedural instrument flying and it's considerably cheaper to do it in a single. That's why Bristow use a single in their instrument school in Norwich. After that, you have your IR and can just do an upgrade flight in a twin later. Incidentally, the Bristow instrument school at Norwich will become part of the Bristow Academy (formerly HAI) and should also have twin AS355s available for twin engine instrument flying later this year.

[SmokinHole]

TorqueTalk:

You are correct that you can easily get an SEIR(H) in Sweden and I'm sure the Norwegian authority is more than happy to put it on a Norwegian issued JAR licence, cos of mutual recognition and all that.

The point I was trying to make is that the UK CAA don't really give a crap about JAR (unless it suits them). Even though ratings and licences are mutually recognised (and by definition REQUIRED to be accepted by other authorities), you will never get a SEIR(H) rating put on to your UK issued JAR licence, period.

So what happens when you pay that (only slightly-smaller) fortune for your Bristows SEIR on the JetRanger? You get a piece of paper. Basically your test pass certificate. You are then supposed to submit that when you apply for your ME rating and MEIR(H), only then will the UK CAA put anything remotely IR-related on a Helicopter licence.

If you're self-funding the IR, like Helimutt said, pay the extra and do it all in a twin. After paying all that cash for the IR I'd certainly want something more than a thin piece of A5 tissue paper to show for it!

[helimutt]

SoggyB's, I kind of agree the IR is about procedural flying but not entirely. what about the bit between both procedures? departure/arrival?


I thought the IR was also about learning to fly an aircraft using the instruments for reference when there are no/few outside references.



Will Bristows do the complete IR training on the 355 or will they use an FNPT2 for 40 hours (or an R22?) and then 10 hours aircraft, like so many other training providers?

[Torquetalk]

Smokin

I agree with much of what you say, but what you are saying about the CAA not adding a SE IR(H) to a licence is factually incorrect.

TT

[soggyboxers]

Helimutt,

The IR consists of a departure, en-route and an arrival, to include a hold.

Basic instrument flying (which you need to have done before you embark on your IR training) was always part of the ATPL(H) syllabus when I was doing ab-initio instructing on the Bristow Training School and we used to give 10 hours of instruction on that using the Bell 47, then later the R22.

I don't know what courses they will be offering on the AS355, but you should be able to find out from them later in the year. They have aground instrument procedure at the instrument school. I suggest you contact them at Norwich if you want to find out more, +44-1603-402356

[SmokinHole]

Smokin

I agree with much of what you say, but what you are saying about the CAA not adding a SE IR(H) to a licence is factually incorrect.

TT


That's not what they told me when I called (around Aug2007).

I couldn't believe it when they said that. Even when pointing out that as signatories to JAA, they have already agreed to mutually recognise an SEIR(H) from another country (when asked if I went abroad to do the course). The guy told me it doesn't matter. They will still not put it on my licence. A big, fat, no..

I would love to hear something 'official' from the CAA saying that this is not true. But if you want the 'reward' of actually having the IR(H) on your licence, do a Multi engined one.

[Torquetalk]

Well if that is the information you got from the guy on the phone...

TT

[TSRA]

I've looked into all aspects and angles to getting my IR cheaper but as you've pointed out there is the bureacracy to deal with! When everything is considered you may as well 'bite the bullet' and pay the dosh beacuse you may not be making that much of a saving. :ugh:

Last summer I'd heard that there were moves to extend the '3 year rule' from completing exams to completing IR... but this hasn't happened. Yet another money making scam!

With bullit firmly in teeth I'm off to do my IR(H) next month. Eeeek

[manfromuncle]

JAR is not law. The ANO is. The CAA 'cherry-pick' parts of JAR that they want to implement, and conveniently ignore other parts. They are a waste of space and a pox on UK aviation.

[SmokinHole]

JAR is not law. The ANO is. The CAA 'cherry-pick' parts of JAR that they want to implement, and conveniently ignore other parts.


You're absolutely right.
Whenever you cry-foul regarding JAR, they always play that ANO card!

If it's not in the ANO, it doesn't exist.
:ugh:

[MamaPut]

Sounds as if everything I hear about the UK CAA is true and they're ANOlly retentive:E

[Bravo73]

Last summer I'd heard that there were moves to extend the '3 year rule' from completing exams to completing IR... but this hasn't happened.

And it's not going to, I'm afraid. This has been covered on numerous previous threads.

[Fly_For_Fun]

CAA HOW ABOUT A COMMENT!:ugh::ugh::ugh:

[Whirlygig]

We can be 100% certain that CAA staff have read this thread and we can also be equally certain that they never comment on pprune.

manfromuncle, I've spotted that the title of this thread contains "Fighting the CAA". Now whilst I suspect that this is just pastiche on Uncle Ian's very worthwhile thread, does this mean that you will actually be taking the CAA to court over this discrimination? One is more than happy to help and support if you are!

Cheers

Whirls

[uncle ian]

And I second that.

[Bootneck]

Many years ago the basic CAA IR training with Bristow was done at Norwich on the 206 and the wonderful :mad: link trainer, we then returned to Aberdeen/Shetland to continue training on the S61 or Puma. In the case of the S61 we also used the BA simulator.
There was no sense in taking the IR in a single engine 206, only to return to the test arena in a twin-engined 61 at a later date, as per the rules.
Subsequently with the introduction of the Tiger (Super Puma) we had a simulator which made CAA IR training much easier to conduct. However for introduction to the dark forces the link trainer was still used.

Bear in mind, the test requires:
Start, nav aid checks, taxi and departure, followed by airways routeing.
Arrival, hold/s as required by ATC and the examiner, an approach followed by a single engined go-round to a second approach from which a landing is made.

The test was predicated around twin operation in IFR, my favourite type of engine layout, a spare!

Seriously, to go back to the initial question. You really don't want to be operating single engine in the murk, not just cloud, add in all the other complications, ice, snow, rain, and turbulence. It's challenging enough in a big twin, it's rectum tightening in a much smaller aircraft which is probably not fitted with any form of AP or nav aids. Basic instrument flying is just that, basic, to help get you out of the deep brown stuff. Procedural work is intended for operations into and out of airports controlled by IFR regulations. There was and maybe still is an anomaly; you were not allowed to use the full scope of the autopilot, eg Height hold, which was understandable in the hold etc, but on an airway section could be a pain.


Then the reply by Flugplatz #3.

I hope the above covers your query. Pull back one engine on a twin and you get yaw, same as pulling back the engine on a single...........except you still have the comforting roar of the second engine, hopefully. Handling emergencies is all part and parcel of the test. :):)

Yep, it sucks major league! I can understand training on twins-only as most aeroplane commercial work is on twins, and you have the whole asymmetry thing to deal with; but when the rotors are driven through a single gearbox...


May I make a suggestion for those intending to have a go at the IR? Learn to play darts. Not so much the bit where you hurl the arrows at the board, more the mental maths needed to calculate the score and remaining total. Many moons ago I met a young man who sneered at an engineer who was reading the Sun; he was taken aback when told that the Sun reader could calculate numbers in his head far faster than the youthful university educated pilot, precisely because he played darts. So put away your calculators and use your heads. (What's 313 minus 45?) Get my point?:)

[Flugplatz]

Thanks for the info Bootneck; we live and learn. Hopefully the more widespread use of lower-cost simulators will be the way forward to an affordable IR.

Flug

[[email protected]]

I'm sure that the non-military among you will be pleased to know that despite every mil pilot completing mandatory IF training each month and having a military Instrument Rating (which for an unrestricted rating means the full procedural format described by bootneck, every year) we still have to jump through all the CAA hoops , and pay the money if we want an IR when we leave:{

[heliski22]

Crab

You should be in the Irish Air Corps then - last I heard when I was over there, they get full credit for their Mil training and hours, both flight crew and engineers. I may not be detail perfect on that but they certainly don't have the hardship experienced by those in the UK.

[Flarechecklevel]

crab@SAAVN is spot on. with over 3000 hrs, 200hrs instruments, over 100 different IF approaches ranging from QGH to GPS letdowns into bases, SRA and PARs, and the very unreliable Light Weight Nav Aid let downs, 500 night hours and not to mention the monthly and annual 'IF beastings' by the Squadron QHI's.....(and not forgetting the 2 week intensive IF phase of a 12 month pilots course that wasn't paid for...but fought for.... every day with the very real possibility of "the chop") It has just cost me the best part of £12,000 and I still had to sit all the same exams......and we get the reduced course ONLY if we held a GREEN or MASTER GREEN rating.

There are a number of AAC pilots who have left recently with 800 or so good quality hours, with 60-80hrs instruments but only amber ratings.....and have had to shell out for the entire course.

I've had the "yeah but it was ok for you ....you were in the Military and they paid for it" speech before. I can promise you one thing....we paid for it...because we worked and earned it...and personaly it took me 17 years to do so.

:ok:

TRUE BLUE.

[anonythemouse]

This is something that I bitched about some time ago. What theory has actually changed that much that it requires a full re run of all of the IR exams because an IR wasn't achieved within the time period? Agree with the comment earlier about most of the stuff that was mandatory to learn being totally irrelevant in our world anyway DECCA?, complete load of parabollocks! In Oz they do an IREX exam. Just the one! Still requires some studying but a lot cheaper, compact and relevant!!!!!!

[Fly_For_Fun]

It would be nice for some CAA policy input and perhaps the reasoning behind the "resit all the Navs" thing.

The cynics amongst us might suggest it is a revenue generator, but a reply from the authority would be helpful and maybe we would all understand.

[Bravo73]

It would be nice for some CAA policy input and perhaps the reasoning behind the "resit all the Navs" thing.

No chance. The bods at the CAA aren't that daft.




The cynics amongst us might suggest it is a revenue generator, but a reply from the authority would be helpful and maybe we would all understand.

Why does there always have to be a conspiracy theory? If they wanted to generate more revenue, I can assure you that they would target a slightly larger market then those very few people who have to resit the IR(H) exams.

Anyway, what makes you think that the CAA are to blame? The 3 year theory validity period is a JAA requirement. The CAA no longer really determine policy; they just have to enforce it.

[firebird_uk]

As someone currently studying fixed wing commercial aviation :confused: in order to achieve a ATPL(H) frozen and CPL(H), I wonder whether the views posted so far have been represented to the CAA.

I appreciate we all have our own (generally cynical) views of the CAA, but does anybody know if there is a formal procedure for instigating policy reviews? These type of bureaucratic system generally have complaint procedures that they have to follow for fear of upsetting the external auditors.

Perhaps a well worded, well reasoned letter / document produced by some of the more senior figures on this board could be made available for all members to download, personalise and then send to the relevant section within the CAA.

One would hope that a couple of hundered (hopefully) letters of complaint would force some form of review? Even if it didn't it'd sure mess up somebody's week. :}

[manfromuncle]

As i said earlier....

JAR is not law. The ANO is. The CAA 'cherry-pick' parts of JAR that they want to implement, and conveniently ignore other parts.

They could easily choose to help the helicopter community by not deciding to implement this 3 year rule.

[K48]

Agreed wholeheartedly.... and while we are at it, address the issue of fees, exam fees, admin fees and test fees validity dates (exams/paperwork). Imagine if these were all eased to the full amount under a code of commercial streamlining and cost cutting as per a private company! If the CAA and commercial companies as a whole could be somehow conjoined to run as a single commercial entity.... E.g a published overall GDP equivalent for UK Aviation with subsectors of commercial helicopter operations and fixed wing ops.. This would enable a government target for helicopter aviation expansion (and other) to be followed... as per BAA terminal 5 = 'national economic necessity for business'. National economic benefits would then be calculable and argued at a government level. Is this perhaps in the CAA's remit?

The current CAA situation is stifling UK aviation by about 30-40% (quick estimate of licence fees vs projected income and lost business due to high transferred cost to customers). An example.. it costs £212 to get a CPL licence administrated but appx half that for a PPL. This is the same amount of admin work though, surely. And how is £74 for a type endorsement justified, it's virtually doubled after CPL!...?
It's out of hand and the effects on aviation in general are inestimable. One only needs to look across the pond to see how aviation is stifled here in comparison.

Also perhaps the concept of a union of Heli pilots/operators to regulate/oppose CAA fees/decisions must have been raised before??
Rant over...