Very Important - EASA Consultation on FCL

[Mike Cross]

Please note that NPA-2008-22f "Authority and Organisation Requirements - Regulatory Impact Assessment on Flight Crew Licensing (FCL)" is now open for consultation on EASA website.

See: http://hub.easa.europa.eu/crt/view-doc/id_60


To place comments please login at EASA CRT application (http://hub.easa.europa.eu/crt/)


For further information please contact Rulemaking Process Support at [email protected]


We all need to look at and comment on this.

Mike Cross
for AOPA UK

[flybymike]

An impossibly complex document Mike. As usual, (and sadly) those who are in the know about the most salient features, are going to have to highlight them for discussion by the rest of us, if any interest is to be generated, and the usual railroading attempts of EASA are to avoided.

[wsmempson]

Oh christ - here we go again; 165 pages of tightly worded legalese in which, no doubt, are hidden some really important points. The trouble is that us laymen really need to take time off work to make sense of these documents; is there any chance of an executive summary, which we can then comment on?

Sorry, this isn't just laziness on my part, but I genuinely don't have the time or expertise to pick through this manner of document and do it the justice it richly deserves...?::eek:

[Mike Cross]

An impossibly complex document

Mmmmm..... can pass exams, fly an aircraft but is defeated by reading?;)

OK here's something plucked out of the middle of it
2.9 Remunerated instruction by PPL, SPL and BPL
2.9.1 Alternative options
ICAO provisions restrict the holders of PPL, SPL and BPL to only perform in noncommercial air operations, without receiving remuneration at all. This inter alia excludes the possibility for them to provide instruction in a training organisation and receiving payment for this service. This has created a serious shortage of instructors for the private licences that has been repeatedly identified as one of the reasons for the decrease of general aviation activities in Europe.
JARFCL allowed the holder of a PPL (A) or PPL (H) to provide instruction for the student pilots wishing to achieve the PPL, but only if the PPL instructors possessed CPL theoretical knowledge (TK). However, the privileges of the licence were still restricted to noncommercial activities for no remuneration, and therefore the problem identified remained unsolved.
The Agency has considered that there could be a different case: i.e. PPL, SPL and BPL entitled to achieve the normal Flight Instructor (FI) certificate, according to the requirements published in NPA 200817, and then enabled to provide remunerated instruction in flight.
Hence the following potential options have been identified:
· 14.2A “do nothing”: i.e. continue to prevent PPL, SPL and BPL from receiving any remuneration for the provision of instruction in flight;
· 14.2B: build upon JARFCL requirements and allow the said pilots to become FI (A), FI (H), FI (S) or FI (B) for remuneration, but, for PPL candidate instructors, only if they have CPL TK (for SPL and BPL there is no commercial licence and therefore no TK requirement for it);
· 14.2C: allow all mentioned noncommercial pilots (i.e. excluding LPL) to provide remunerated instruction in flight as FI, providing that they hold a valid instructor certificate, for the relevant aircraft category and class.


Now I don't find it difficult to work out which of those I would like to nominate as my preferred option and I suspect you wouldn't either.

Give it a go - you know it makes sense!

Mike

[englishal]

They do love their diagrams and flow charts to convince themselves of what they already are going to do anyway. Looks like we'll have to be re-tested every 6 years according to their charts. I don't mind if the bollocks 2 year instructor flight / FE sign off goes. Or I may just use my FAA ticket.....

[flybymike]

Aviation is littered with acronyms. To me ( having only just passed my reading exam;) an SPL is a student pilot licence, and BPL is Blackpool. What are these licences? (if that is what they are)
Think I could guess which would be my preferred option on a vote, but now we need Beagle to give us a condensed degree course on how to pass all the IT hoops necessary to actually make a comment on the EASA website.

Englishal The CAA have already debunked any safety case for BFRs, annual MEP tests, 90 day rules etc introduced by JAA ,never mind the EASA job creation schemes

[LH2]

Do I sense a little negativity here? Chaps, you do not have the time or the expertise to read through the bastard thing, but on the other hand you do not miss an opportunity to jump at it? Seriously, if you haven't read any of it, and by your own admission do not understand what it says anyway, then just what are you complaining about exactly? :bored:

[robin]

.. the problem, as I see it, is that it a load of euro-babble. Looks impressive but the more you read it, the less sense it makes.

I'll have to read it a lot more before I could even take a guess at the accuracy of its predictions (which look very iffy).

This looks like an attempt to 'snow' the users with a load of guff and to slip in some 'unintended consequences'.

[Rightbase]

Somebody advised me, a long time ago, never to agree to anything I didn't understand.

There is no good reason for making something too complicated to understand - especially when the perpetrators are experts in communicating.

There's mischief afoot.

[wsmempson]

So, LH2, What does it say then?:)

BTW, is it just my machine, or have all the times for the post gone funny?