CAA Set to abolish Registered Training Facilties

[eddietcapt]

I receive a flyer from training.com CAA it says this may effect your business
They are considering allowing JAR to remove all (RTFs) and convert them to (TRA)
This will seriously effect all flight training in the UK training costs will double,
It will be difficult to find a training facility.
All instructors with a PPL with grandfather rights will be forced to stop instructing or work under a CPL chief pilot and the next thing will be the need to have a CPL to instruct. I along with most of the (RTFs) will be forced out of business. I will seek compensation for the removal of my ability to use all my ratings.
The next thing will be no SVFR at night and no IMC rating.
We need to all get together to stop these fools killing our PPL flying world.
Please note that consultation period for NPA-2008-22d "Authority and Organisation Requirements - Certification Specifications for Aeroplane Flight Simulation Training Devices "CS-FSTD(A)"" has been extended until 15 Apr 2009.

See: http://hub.easa.europa.eu/crt/docs/viewnpa/id_55

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

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

[BEagle]

It's not our CAA 'allowing' anything!

The trouble is the endless flow of Colognic irritation flowing from these absurd €urocrats.

We were originally told that all EASA would do would be to add legal strength to previous JAA practices and that there would be no significant changes.

We were comprehensively lied to.

[DB6]

I've said it before and I'll say it again - there is nothing good about being part of Europe. In every aspect of life Britsh standards - which were those by which the world worked - are being lowered to the lowest common denominator for no good reason.
The problem is that the only real way to fight it is to become one of them, and like becoming a lawyer, you may as well just kill yourself first.
If I were in the CAA just now I would feel a deep, deep sense of shame and can only assume that those responsible are the nasty little middle management types with no heritage in British aviation, not anyone who has been in the RAF or UK airlines for any length of time.
Truly contemptible.

[doubleu-anker]

We have been comprehensively lied to since we joined up with that lot over the Channel, in the mid '70's. Mark my word, if you think it is bad now, wait for another 20 years or so! It will be unbearable.

[DFC]

The proposals from EASA for the licensing of pilots has been available for ages.

There is no mention of RTF in those proposals - all trainng oganistions will have to be approved from LPL training providers to ATPL providers (however the requirements are different).

Anyone who had read the proposals will be fully aware of that.

The proposals from EASA for training organisations is also available on their website and has been for quite some time.

It is clear that current reputable RTFs provding decent professional training in accordance with the industry standards will have nothing to worry about.

Of course, there is going to be profiteering by organisations who try to convince people who don't know about the system - prospective students - that months of expensive work went into getting the approval to train them and consequently they are havng to pay an extortionate rate.

Advice to student - if you hear that it is probably true which means that the organisation was below the minimum standard before - and probaly will be again.

The CAA, AOPA and several other organisations were involved in the draftng of the proposed requirements and also everyone still has time to comment - see the EASA website.

One of the primary reasons why you have longer to comment on the licensing proposals is that some of us were awake to the issues and were unhappy to have the licensing proposals considered in isolation from the organisations proposals.

If organisations actualy need to make serious changes to conform to such a basic standard as is required under the proposals for approval to train PPLs then those organisations should not be doing that training now.

Regards,

DFC

[Whopity]

Eddietcapt
I take it that you have registered your concerns with EASA because unless we all make our concerns known Europe will take over on their terms! You have until the end of February. This might be of interest!
www.halldale.com/Assets/Files/EATS%202008/Proceedings/Petteford.ppt

All instructors with a PPL with grandfather rights will be forced to stop instructing or work under a CPL chief pilot and the next thing will be the need to have a CPL to instruct. If you actually read the EASA proposal you will see that it actually makes it easier to instruct on a PPL, no CPL knowledge required and you can be remunerated!

[VFE]

Ok, I can't be the only one who glazes over everytime this topic comes up?

The problems seems to be that everyone has their own take on how this European malarky is gonna affect Joe Instructor in the UK.

Just wish someone would spell it out in plain english instead of posting scaremongering soundbites to attract attention.

VFE.

[ifitaintboeing]

It is spelled out in english, here:

Rulemaking | Notices of Proposed Amendment (NPAs) (http://www.easa.europa.eu/ws_prod/r/r_npa.php)

I pointed out the issue of RF/FTO/ATOs to the CAA at the initial meeting with the industry. The additional burden, both in terms of paperwork and cost, on the UK Flight Training Industry is unnecessary and at no proven safety benefit.

It is the responsibility of all CFIs at RFs to make representation to EASA before the deadline (currently 28th February 2009), in a sensible coherent manner. The link above also takes you to the Comment Response Tool where you can register your agreement or otherwise to the various EASA NPAs.

Regards,

ifitaint...

[pembroke]

I agree with DFC, any RF , properly run will only be subject to minimum changes. The NPA goes though the obvious provisions and requirments that would be normally found at a flying school/ club. There may be an audit of premises, qualifications, paperwork and aircraft etc but as I say , that shouldn't be a problem. Students pay a lot of money for a PPL and if it avoids some of the splapdash and unprofessional outfits I see occasionally, all the better.
The big advantage in this NPA is that it will require a Head of Training or CFI as a "post holder", for all training including RF,or what they will then be called. Often on these forums the word CFI is used and assumed at RF's but it has never been a statutory requirment, and this for a key member of any training team, and often the necessary counterbalance to flying school owners!

[belowradar]

What utter nonsense ! This will mean unnecessary increased bureaucracy and cost. Do you think that they will audit for free ? Bad news for flight training.

If it ain't broke :ugh:don't fix it !

If you think that this is a good idea why not read the proposed rule change and then post a comment, that will take up an evening of your time. The proposed change and feedback process is ridiculously difficult to read, understand and action.

[chrisbl]

Belowradar said:

If you think that this is a good idea why not read the proposed rule change and then post a comment, that will take up an evening of your time. The proposed change and feedback process is ridiculously difficult to read, understand and action.

Really, I did not have much trouble understanding it. Perhaps the problem is you. I bet you take your socks off when you want to count beyond ten too.:ugh:

[Say again s l o w l y]

How in the world will this make anything better in the flight training business?

Stuff it, I'm off to microlights...................

[DFC]

Stuff it, I'm off to microlights...................

To teach for the LPL.............at an approved training organisation according to the EASA requirements.

Some people just don't get it!

The EASA is not trying to improve things - although in some places it will be an improvement - but to harmonise and basically remove all the differences that remain even after the JAA has been round for years.

Unless the UK removes the requirement to hold a licence from some part of the pilot community then everyone will eventually be trained and tested under EASA.

-------------

Whopity,

I laughed the first time I saw that presentation and even without the talk to go with the pictures it is still a joke.

Who in their right mind stands up in front of the regulator and peers to say that they have to train in a country outside the UK because there are not enough instructors in the UK but there are plenty of instructors in this other country..........did they never investigate employment legislation specifically the bit about what one can do when one is not able to find suitable candidates in the EU?

Seems that these very suitable instructors available in the US are not suitable enough to be offered positions in the UK! Which by definitin makes then unsuitable for what they are doing already.

If these US instructors are truly knowledgable in what they are teaching then it should be no problem to pass the EASA CPL or ATPL exams. Especially after completing the bridging course.

Revolver - Foot - Aim.

The only part of the proposals that they could have had a legitimate issue with and they made a total ass of their complaint to the point where mouch of it is dismissed.

Regards,

DFC

[eddietcapt]

All RF have had to register and follow all the rules all is running smothly we all take our students for the GFT they pass or they dont. We all had to jump through all the hoops to get our permisions to train. Now our CAA are set to allow the rules to be changed. I along with everyone in the industry are strugling to earn a living. NOW if all you do gooders are making a fortune from trainning you must be cutting corners or sitting there and topping the hours up or subsidising your wages sum way. I have no big outgoings I have no outstanding bills running on I pay as I go my students get value for money and have done for 23 years. If the CAA impliment these or any changes to the rules I will be forced to close and I will take the CAA to court for allowing this to happen. If when I started building hours to be an AFI the CAA had said that one day we may send you a memo saying this may effect your business and after reading find that I will have to stop instructing, I would not have started down the long and expensive road. How many RFs will be prepared to start again jumping through hoops. We should be left alone and given an exemption on the grandfather rights. If you have a TRO keep your negative comments to yourself you would profit from this rule being enforced. E

[Say again s l o w l y]

Really DFC, have you seen any plans to make microlights come under EASA? According to NPA 2008-07 the intention is to not affect microlights, though there does seem to be some leeway to potentially force them to be moved into the ELA1 category at a future point.

eddie, I know what you mean, most RF's simply cannot afford any more expense and this will be a significant expense. It will utterly decimate this business.

I just hope that the proposals to allow teaching from unlicenced fields comes to pass. That would make a massive difference to the business.

[Whopity]

If the CAA implement these or any changes to the rules I will be forced to close and I will take the CAA to court for allowing this to happen.
Why will you be forced to close? If you have managed to keep going for 25 years, you can clearly fund the training you do, you can be Head of Training; the rules only require that the HT ensures compliance with the rules, it specifies no other requirements at the non professional level. Tear up your Registration Certificate and replace it with an Approval Certificate; there is no inspection required, and in any event the CAA do not have the resources to inspect all ATOs. Presumably, they will charge for approval but realistically that is likely to be around £350 looking at other fees. How will you sue a regulator for complying with the Law? The CAA are not in a position to have any significant influence on it.

Yes its all unnecessary and will contribute nothing to safety but unless we all tell the European politicians that, we will be stuck with it.

I just hope that the proposals to allow teaching from unlicenced fields comes to pass. The EU legislation makes no provisions for the licensing of aerodromes, so if the ANO is totally replaced by EU Directives, then licensed airfields will in theory no longer exist!

Microlights come under Regulation (EC) 216/2008 ANNEX II, page 32 Aircraft referred to in article 4 (4) and are excluded.

[Say again s l o w l y]

Lovely, that sounds like a plan to me. I reckon that might change though!

[belowradar]

chrisbl

Really, I did not have much trouble understanding it. Perhaps the problem is you. I bet you take your socks off when you want to count beyond ten too.

Oh dear another fairly typical response from a pruner who hides behind anonymity and allows a bad attitude to interfere with open and honest debate.

The Notice Of Proposed amendment is definitely not clear and transparent, the mechanism for feeding back comments is not clear and transparent, as a result many people (myself included) will not waste hours trying to provide this cryptic feedback and so this nonsense will be passed into law. I guess that is why it is so convaluted.

I want to spend no more than a few minutes reading about a proposed change and I wish to comment quickly and easily. I don't wish to employ a lawyer, translator and consultant just to understand this rubbish.

Chrisbl - IF THIS IS EASILY UNDERSTOOD BY YOU THEN YOU MUST BE JUST AS BIG AN £$%SSH&*£ AS THE GUYS WHO WROTE IT !

[BEagle]

I was discussing the current UK Microlight weight limit with a senior BMAA chap and asked whether it would be an idea to press the CAA for an increase to the 600 kg 'Light-sport aircraft' limit used in the US. My thoughts being that this would make Microlighting more attractive to some people as it would be free of the idiocy of the ridiculously €urocratic 'Leisure Pilot Licence'.

However, he thought that this would actually be detrimental to his organisation as it would merely make it a more obvious target for the €urocratic legislators...... I can see his point!

The UK NPPL is (at last) a model of what can be achieved by synergy between legislators and industry. However, all the benefits of the NPPL will be swept away by EASA unless enough people object to the LPL.

All you have to do is to state that you 'recommend that EASA part-FCL shall only apply to ICAO licensing and that individual Member States shall retain competency for sub-ICAO pilot licensing where so permitted under national law'.

All that is required for €vil to prevail is for good men to do nothing. Don't be one of them!

[DFC]

Really DFC, have you seen any plans to make microlights come under EASA?


Not Yet!

However, microlights need certification, maintenance and on-going airworthiness- all outside EASA control for the moment.

Pilots on the other hand are a separate issue and need a licence of one sort or another plus some form of medical. All the issues related to getting and keeping such licenses are covered by the EASA NPA we are discussing.

You are not the first to assume that since microlights are outside EASA for airworthiness purposes that the pilots are likewise excluded. Unfortunately the Basic LPL and the LPL are designed with such pilots in mind.

I think that you will find that many of the microlight schools - especially those that teach instructor ratings (for which they already pay the CAA an approval / inspection fee) are looking forward to the changes and the opportunities that will bring when coupled with EASA no longer requiring that training be completed from licensed airfields in the case of anything heavier than a microlight.

Regards,

DFC

[BEagle]

DFC, part-FCL does not apply to the regulation of pilot licensing for aircraft of less than 450 kg. That was made quite clear at the Gatwick EASA meeting a few weeks ago.

The infernal LPL appears to have become some one-size-fits-nobody €urocratic farce intended to be attractive to pilots of aircraft which, in the case of single pistons, fall more or less into the SSEA category. But which offers far, far less than the UK NPPL currently does.

All that it will do is to polarise people either 'down' to Microlight level or 'up' to PPL level. The only real benefits to the Microlight world will be the numbers of people driven out of the SEP/SSEA world by pointless €urocracy.

[LH2]

Just one general question, if I may:

How come nobody else in Europe seems to have a problem with the changes related to EASA, which incidentally are not exactly new or surprising? I have asked this question many times in the past and none has offered any explanation at all, let alone a convincing one.

Incidentally, I find EASA's NPAs are eminently clear and legible for a legal document. It is bemusing how much opposition to the rules comes from people who freely and adamantly acknowledge they haven't read them ("because they are too difficult"). Also, often this point of view is presented with poor spelling and grammar, which clearly makes one wonder. :ooh:

Anyhow, that old joke about a plane full of Brits comes to mind :E

[Whopity]

1. Pilots involved in the operation of aircraft referred to in
Article 4(1)(b) and (c), ....., shall comply with the relevant ‘essential requirements’ laid down in Annex III.
Article 4
Basic principles and applicability
4. Paragraph 1 shall not apply to aircraft referred to in
Annex II.
Annex II. Aircraft referred to in Article 4(4)
Article 4(1), (2) and (3) do not apply to aircraft falling in one or more of the categories set out below:
(e) aeroplanes, helicopters and powered parachutes having no more than two seats, a maximum take-off mass (MTOM), as recorded by the Member States, of no more than:
(i) 300 kg for a land plane/helicopter, single-seater; or
(ii) 450 kg for a land plane/helicopter, two-seater; or
As confirmed by Cologne a week ago.

[belowradar]

Great example of how not to write new aviation regulations

If I had time to go from one paragraph to another trying to piece together the meaning and intent that would be fine but I don't. Why can't EASA have a look at the American FAR's and then take a leaf out of that book ? the old acronym KISS should apply.

By the way does anybody know when we can train from unlicensed airfields ?- I have looked on CAA website, searched EASA PROPOSALS and called CAA they haven't got a clue

[chrisbl]

Belowradar, you are a waste of space.

[belowradar]

ChrisBL

What'sthe matter ? don't like a taste of your own medicine ?

Suggest you re-read the terms of PPRUNE, you certainly did not join this site to make unnecessary personal attacks on people you don't even know.

This is a forum for Professional Flying Instructors and Examiners.

If you don't have anything positive to add to this debate fair enough but no need to get upset when you started the negativity.

[Say again s l o w l y]

Children, can I make a suggestion?

Shut it.

[belowradar]

SAYAGAINSLOWLY


NO ! This is a thread for debate, views and information sharing. Too often the message is lost because of rude arrogant posts so I am sorry but you can shut up unless you have something constructive to add to this debate.

:ok:

[DFC]

The problem is that firstly one has to read the complete set of proposals.

Secondly, when asked a question, Authorities (EASA / CAA etc) provide an answer that is correct in relation to the question as asked. They do not expand into areas that they do not want to even if it may be relevant to how such a question would be answered in the near future.

I have highlighted the relevant part of ther NPA below;

The BMAA and European Sport Aviation have spent quite a bit of money to ensure that the Basic LPL / LPL suits them when it comes and that the transition is fair to their members.

Grandfather rights are covered by the NPL if one reads the document. So too is the principle of right of access to a profession.

Please read all the documents.



47. In the case of licences or other certificates that were issued on the basis of national rules
noncompliant
with JARFCL

, similarly to the case of Part66

, national licences and
certificates could be converted into PartFCL
licences and certificates. In the case of
aeroplane and helicopter licences, this conversion would take place in accordance with
Annex IV to the Licensing Cover Regulation, which was drafted on the basis of Appendix
1 to JAR–FCL 1.005 and Appendix 1 to JARFCL
2.005. This Annex would also apply after
the end of the transition period for the conversion of pilot licences issued by Member
States in accordance with national rules for aircraft that are currently in Annex II to the
Basic Regulation. The Agency also considers the requirements in this Annex to be
adequate for application to holders of national pilot licences for Annex II aircraft used in
commercial air transport.

Don't forget that once this is over the CAA will not be issuing any national licenses so unless it removes the requirement for a microlight pilot to have a licence (which would be a breach of EU law anyway), then in the future, every pilot regardless of what they fly will be trained, tested and licensed under EASA.

Regards,

DFC

[belowradar]

Contrast the European approach to open and honest debate ? with the well established and proven FAA method Recently Published Rulemaking Documents (http://www.faa.gov/regulations_policies/rulemaking/recently_published/)

Here you get to make any comments you like regarding the proposed change, there is a named individual who "owns" the change and who you can contact, and lo and behold it is written in straightforward English that is easily understood. You also get to choose your preferred method of feedback.

Why do EASA even have to screw up their NPR process, could it be because they don't wan't open and honest comments but merely wish to bulldozer their new regulations onto the aviation community ?

[eddietcapt]

Getting back to the start of this thread!
Please note that consultation period for NPA-2008-22d "Authority and Organisation Requirements - Certification Specifications for Aeroplane Flight Simulation Training Devices "CS-FSTD(A)"" has been extended until 15 Apr 2009.

See: http://hub.easa.europa.eu/crt/docs/viewnpa/id_55

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

For further information please contact Rulemaking Process Support at [email protected]
If you have a PPL and you are instructing you should look at this and make your comments known. If these rules are passed training will be too expensive in the UK and we will all end up with US ratings or going to USA to get trained.

[theavionicsbloke]

An interesting debate.

Folks, you may or may not be aware that engineering has just (in the last five years) converted to EASA.

So now... well, I’m afraid ... it's the pilots turn !!

However, you may gain some comfort from my short story of changes that I have experienced as follows: (Sorry for the length !!)

As a CAA Licensed Engineer and having just started to settle into the JAA way of life I suddenly found my world turned upside down by this new, out of the blue EASA contraption ....

Overnight our work places went from JAR 145 approved maintenance organisations to Part 145. Our licences went from CAA BCARs A & C, X & R Category licences to EASA A,B1, B2 & C licences. C of A’s have now become ARC’s !

Although sceptical and anxious before the changes we have undergone, now we are somewhere on the other side I must confess that I rather like the EASA approach. EASA seem to be a little better organised, and once understood it appears that there is very little change in the actual requirements but things are split up, given new names, put into logical order and clarified.

Now free of the old CAA ambiguity! Legislation and procedures, have suddenly been bought clearly into focus.

One fall out from this, that has become very evident is that there is no longer any room for the individual to exercise discretion or judgement any more. It’s either In the Box or it’s Out the box. The grey areas and good old ‘room for interpretation’ have all but disappeared !

Although we were told that the CAA would be no more, this has now been halted. The National Authorities (CAA etc) are now referred to as the EASA ‘Competent Authority’ and assumes some EASA duties. Issuing Licences is one of them for example. So you may still be ringing up good old Gatwick for sometime to come yet.

When I have challenged the ‘Competent Authority (CAA)’ their final comments to me have been “The requirements have not changed. We are now just enforcing how things should have been done in the first place”

What we have learned is that If you are currently doing things free from convenient interpretation or through squints of the eye, using the paragraph that the CAA missed in your documentation submitted for approval, then you will have nothing to worry about. If you are not, as either an organisation or an individual then you will l have to make changes and tow the line.

[Mickey Kaye]

Have the CAA now stopped accepting applications to set up registered facilities? and gone over to ATO.

Does anyone know what the differences are in both set up and running costs and any extra administration thats involved.

[SkyCamMK]

For clarity and interest:

Glider pilots "tow the line" the rest of us are supposed to "toe the line" A line that is a broadsword's length from the opposition in front of the Dispatch Boxes in the House of Commons and sewn into the green carpet as red stripes.

[S-Works]

I am not sure they have gone to an ATO at all. We had to re register our RTF recently and that just says certificate of registration and our OCP number.

God knows why we have to register as an RTF, FTO and TRTO when we use the same staff, same premises and same ops and training manuals........

[WestWind1950]

Just one general question, if I may:

How come nobody else in Europe seems to have a problem with the changes related to EASA, which incidentally are not exactly new or surprising? I have asked this question many times in the past and none has offered any explanation at all, let alone a convincing one.

.........

Anyhow, that old joke about a plane full of Brits comes to mind

no, you guys are NOT the only ones balking about the EASA stuff. Since I can only read in English and German, I have no idea how the French, Spanish, Italians, etc., look upon this.

Oh, and to add to OUR problems.... since most documents are only in English, most of the authority personal in other countries besides Great Britain have trouble reading and understanding them. Only the final drafts get translated. So that makes it quite difficult for people from other, non-English speaking countries to read proposed ammentments and comment.

In one of the above mentioned EASA documents... I believe it was this one (http://easa.europa.eu/ws_prod/r/doc/NPA/NPA%202008-22d%20-%20CS-FSTD%28A%29.pdf)... it mentions the requirment for aerodromes for trainign and one point mentions being a controlled airfield!

I wish the EASA homepage was easier to navigate.... the use too many abbreviations! :ugh:

[BillieBob]

Have the CAA now stopped accepting applications to set up registered facilities? and gone over to ATO. No. The EASA Implementing Rules do not come into force until 8 April 2012 and the UK CAA have declared a 3 year transition period to allow Registered Facilities to become fully compliant. Consequently, there is no obligation on a current RF to become an ATO until 8 April 2015. The CAA have recently had to require all current Registered Facilities to re-register (at a cost of £100 per year) because they failed to keep track of how many facilities were registered.
Does anyone know what the differences are in both set up and running costs and any extra administration thats involved. Not precisely. The intended requirements have, until now, been detailed in Part-OR but this has not yet completed the Comment/Response process and so nothing is certain. In any case, EASA has now decided to do away with Part-OR and to include its ATO-related provisions in Part-FCL, which has completed CRD and is currently undergoing the comitology process.

On the basis of the Rules already published in Part-OR, it is likely that an ATO, even if only offering the PPL and LAPL, will have to produce (and obtain approval of) an Operations Manual, a Training Manual and a Safety Management and Quality System as well as complying with formal staff training requirements. Since the approval process will require CAA involvement, there willl clearly be a fee imposed over and above the costs of initially meeting the requirements and thereafter maintaining compliance.
God knows why we have to register as an RTF, FTO and TRTOBecause the UK CAA seems incapable of reading and understanding the requirements. Registration is required solely for organisations conducting only PPL training and nothing precludes an FTO from offering type rating training without also being a TRTO.
In one of the above mentioned EASA documents.... it mentions the requirment for aerodromes for trainign and one point mentions being a controlled airfield!Your link leads to the Certification Standards for FSTDs, which is hardly relevant. The proposed rules for airfields to be used for flight training are, for the moment, detailed in Part-OR. The relevant hard law (OR.ATO.140) does not mention controlled airfields at all; it simply requires that an ATO shall use aerodromes or operating sites that have the appropriate facilities. An air traffic control service is, however, mentioned in the associated AMC, which currently reads "....an air traffic service except for uncontrolled airfields or operating sites where the training requirements may be satisfied safely by another acceptable means of air-to-ground communication" Interpretation of this is left to the 'competent' authority, as is the option to accept an alternative acceptable means of compliance, potentially removing the requirement for any form of air-to-ground communication.

Bear in mind also that, under EU law, an alternative AMC accepted by any competent authority becomes automatically acceptable in all member states (i.e. if an alternative AMC that does not include any requirement for air-to-ground communication is accepted by, say, the Bulgarian authority, the UK must accept it as well)

[WestWind1950]

sorry, I posted the wrong one... NPA 2008-22c (http://easa.europa.eu/ws_prod/r/doc/NPA/NPA%202008-22c%20-%20Part-OR.pdf) is the one I meant. Under AMC to OR.ATO.135 AERODROMES (page 48) is says:

AMC to OR.ATO.135 Aerodromes
1. Except in the case of balloons, the base aerodrome and any alternative base
aerodromes at which flying training is being conducted should have at least the
following facilities:
a. at least one runway or takeoff
area that allows training aircraft to make a
normal takeoff
or landing at the maximum takeoff
or maximum landing
mass authorised, in the following conditions:
(i) under calm wind (not more than 4 knots) conditions and temperatures
equal to the mean high temperature for the hottest month of the year in
the operating area;
(ii) clearing all obstacles in the takeoff
flight path by at least 50 feet;
(iii) with the powerplant operation and the landing gear and flap operation
(if applicable) recommended by the manufacturer; and
(iv) with a smooth transition from liftoff
to the best rate of climb speed
without exceptional piloting skills or techniques.
b. a wind direction indicator that is visible at ground level from the ends of each
runway;
c. adequate runway electrical lighting if used for night training; and
d. an air traffic control service.
2. In addition to 1, for helicopter training sites should be available for:
a. confined area operation training;
b. simulated engine off autorotation;
c. sloping ground operation.
3. In the case of balloons, the take off sites used by the training organisation should
allow a normal takeoff
and clearing of all obstacles in the takeoff
flight path by at
least 50 feet.

In Germany ALL airfields are certified (it's a law) and usually have at least traffic advisory service, not necessarily controlled (which I would interpret at with ATC). So, how would you all interpret the above?

[BillieBob]

sorry, I posted the wrong oneYou are still posting the wrong one although, to be fair, EASA, in line with its aversion to public scrutiny, seems to have suppressed the correct one.

You have linked to the original draft, dated 30 Oct 2008 while the quote above is from the draft Opinion, dated 4 Oct 2010. This later text was published for stakeholder reaction some months ago but has, as far as I can tell, now been removed from the EASA website (at least I can no longer find it), presumably because Part-OR no longer exists. Nevertheless, it is the text that will be included in Part-FCL.

In any case, as previously explained, anyone has the option of submitting an alternative AMC that does not include any requirement for air-to-ground communication and so the perceived requirement for ATC is, in practice, a red herring.

[WestWind1950]

Billie, that's exactly what I meant by the site being horrible to navigate. For me, if something is on the site, then it is the actual version being submitted, especially if another version can't be found (and yes, I tried their search function..... forget it). It's all quite frustrating... to put it mildly.

How are we to be prepared for the new rules getting incorperated in one years time if there's such a mess? :(

[Comfortably_Numb]

Guys

If it has the word "Europe" in it, it is evil and unaccountable. You haven't seen anything yet. this is just the very beginning. Don't believe me? Just stand back and watch.

The treaty of Rome will cost you dear.

[rhwheeler]

My understanding is that my UK BCPL(R) will be treated as a UK PPL on 12 APR 2012 or at some later point when European Law is enacted. At that point I will be able to instruct on EASA SEP class aircraft such as PA-28s and C-172s provided I obtain a JAR PPL. This however will be without remuneration! In the interim it will assist the process if I apply now for a JAR PPL as this converts to an EASA PPL when the relevant law is enacted. My UK PPL will only allow me to be remunerated when exercising my FI and FE(PPL) rating privileges in military and other rare training types. I have just renewed my UK BCPL(R) for £136 and expect to pay £181 for the initial issue fee for a JAR PPL.
In short, at the time of European law enactment I will not be able to cover the costs of providing training services in EASA SEP class aircraft.
AOPA course and IMC rating training and cross channel checks will also become unviable.
Please tell me this is just another scare story!

[Whopity]

Please tell me this is just another scare story! Yes it is. You will be able to continue as before, with your JAA/EASA PPL and FI rating and be remunerated exactly as you are now. Nothing gained, nothing lost. You won't actually need the BCPL as you will also be able to fly Annex II aircraft with your EASA licence according to the CAAs current guidance.

Its interesting that when your BCPL(R) was issued, due to a law change, they did it free of charge, this time you have to pay for the privilege of a law change from an unelected body!

Under EASA I forsee a lot of PPL instructors dropping back to a PPL and saving money on the medical.

[Mickey Kaye]

"Under EASA I forsee a lot of PPL instructors dropping back to a PPL and saving money on the medical"

Yep and I will be one of them.

How much money have a wasted renewing a class one every year. Only to find out that it will again be "safe" to instruct on a class two.

[RVR800]

..but what happens when you want to exercise the extensive privileges of your hard worked for, unrestricted Basic Commercial Pilot's licence?

e.g. Pleasure flights, Aerial Photography etc..

....the list is endless :sad:

[BillieBob]

The 'unrestricted' BCPL will be deemed to be a UK national CPL, which may be converted to an EASA CPL in accordance with the terms of Annex II to the enabling regulation. If you have more than 500 hrs PIC and a night rating, then it's a paper exercise (the folding sort and lots of it, no doubt).

[dobbin1]

I have an FI rating and a restricted JAR CPL. The restrictions are no public transport, day only, radio required at controlled airfields, UK airspace, UK reg. All due to colour vision issues.

I asked the CAA what will happen to my license and I recieved this response:-

...... as your current licence is restricted to G-registered aircraft, it will become a UK CPL(A) - which is then convertible to an EASA licence.
You will have to demonstrate knowledge of flight performance and planning as required by FCL.310 for that conversion.
The proposed text of FCL.310 refers to the theoretical knowledge examinations for CPL.
If you have valid passes in the required examinations that have not lapsed by the time the conversion takes place, then these will allow you to meet that part of the conversion requirements. CPL exam passes have a validity of 36 months.

I would also point out Annex II to the EASA regulation stipulates that you will also need to:
- Have a valid proficiency check;
- Demonstrate knowledge of Part-OPS and Part-FCL; and
- Demonstrate language proficiency



So if the conversion takes place more than 36 months after my exam pass in performance and planning, I will have to do the exam again! On top of that, I may need to fly a proficiency check (hopefully my IMCr rewnewal check ride will meet this requirement). All this seems a little unfair, since the folks who sat the same exams and had the same training as me but who have unrestricted CPLs will not have to do anything. Descrimination?

And after all this, will EASA be prepared to issue me a CPL with night and public transport restrictions?

[Whopity]

it will become a UK CPL(A) - which is then convertible to an EASA licence.The restrictions are ....... All due to colour vision issues.
Oh dear, they really are getting themselves into a mess. They have failed to identify the "Restriction" probably assuming you have the JAA CPL (Restricted) and have answered a different question.

As your "Restriction" is due to medical reasons, nothing is going to change and you won't be able to get an EASA licence for the very same reason!

I would reply pointing out their error and request the correct answer.

[dobbin1]

Thanks Whoppity. I will double check with them.

[Whopity]

It might be worth raising this with the Medical Dept as it will affect a number of pilots.

[dobbin1]

Further to my earlier post - I went back to the CAA and made it clear that my restriction was medical. I recieved the following response:-

.....In future all medical restrictions will be shown on the Medical Certificate only, not on the licence.

EASA will not issue licences. EASA Part-FCL licences will continue to be issued by the National Aviation Authorities - in your case the CAA.
Any medical limitations will be those shown on your medical certificate, which will apply to all licences you may hold.

So it looks like I can get an EASA CPL if I jump through all the hoops, although the hoops remain illogical and unfair.

[Whopity]

It still dsoesn't address the question, how do you get an EASA CPL if you don't hold an unrestricted Class 1 medical certificate?

[rhwheeler]

Quote:
Please tell me this is just another scare story!

Yes it is. You will be able to continue as before, with your JAA/EASA PPL and FI rating and be remunerated exactly as you are now. Nothing gained, nothing lost. You won't actually need the BCPL as you will also be able to fly Annex II aircraft with your EASA licence according to the CAAs current guidance.

Its interesting that when your BCPL(R) was issued, due to a law change, they did it free of charge, this time you have to pay for the privilege of a law change from an unelected body!

Under EASA I forsee a lot of PPL instructors dropping back to a PPL and saving money on the medical.

Your advice is much appreciated.
Since this post it has been pointed out to me in a recent conversation that the conversion from restricted UK BCPL to EASA PPL will involve the surrender of the UK licence with any pertaining "grandfather rights".
So the best licensing strategy appears to be to do nothing!
This, I recall, is what happened with the CAA to JAR-FCL transition!
This strategy presumably can be extended to remunerated flying on a PPL, instruction in sole ownership aeroplanes, Registered Training Facilities, IMC ratings and so on.
The European Parliament is subjugating National rules and the CAA in turn advising PPL holders to convert to Part-FCL to mitigate legislative problems.

[Whopity]

conversion from restricted UK BCPL to EASA PPL will involve the surrender of the UK licenceNo need to surrender the licence, they will just issue a new one.Registered Training Facilities, IMC ratings and so on.No, neither of these will exist, so you will only be able to teach for a PPL, class and type ratings whilst being remunerated on your PPL, and aerobatics if qualified, but probably not night, unless you hold an IR, and all training will have to be conducted at an Approved Training Organisation.
Just remember the "S" in EASA has nothing to do with "Safety" and should be replaced with Shyster.

[rhwheeler]

My RTF was cancelled last week. This was due to a name change. I am now required to make an initial application.
I read this morning that an Aerobatic Rating AR is being introduced by EASA. The requirement is PPL + 40 hours before starting the course. What advice is to be given to pilots wanting to do an aerobatic course. I assume that without an AR aerobatics will not be permitted in EASA aeroplanes.

[BillieBob]

FCL.800 Aerobatic Rating

(a) Holders of a pilot licence for aeroplanes, TMG or sailplanes shall only undertake aerobatic flights when they hold the appropriate rating.

(b) Applicants for an aerobatic rating shall have completed:

(1) at least 40 hours of flight time or, in the case of sailplanes, 120 launches as PIC in the appropriate aircraft category, completed after the issue of the licence;

(2) a training course at an ATO, including;

(i) theoretical knowledge instruction appropriate for the rating;

(ii) at least 5 hours or 20 flights of aerobatic instruction in the appropriate aircraft category
The requirement is PPL + 40 hours before starting the course.No, the requirement is to hold a licence (may be a LAPL) and to have flown 40 hours PIC since licence issue.
What advice is to be given to pilots wanting to do an aerobatic course.Go to an ATO that is approved to provide the course. However, there is currently no indication of course content, and won't be until the associated AMC and GM is published next year.
I assume that without an AR aerobatics will not be permitted in EASA aeroplanes.Your assumption is correct.

It is to be hoped that the UK will take advantage of the option of a 1 year derogation from all Annexes that was agreed at the last EASA Committee meeting.

[oldspool]

Hello,

I'm looking for some advice.

I have a JAA-PPL(A) and have recently completed the JAA ATPL theoretical exams, and hold a current Class 1 medical. I took the exams simply because I wanted to complete a Flight Instructor Rating.

My current plan involves completing the JAA CPL in October and the JAA FI-R in Nov/Dec.

However I'm a bit concerned about how the EASA might affect me; the truth is I'm unsure what the implications are? Should I wait until April 2012? Reading some of the posts seems like that exams was effort wasted. Is there somewhere that provides a summary of the changes and the implications? Doing a CPL and an FI involves raiding the piggy bank so I want to make the best, most informed decision possible. Any advice/information would be greatly appreciated.

Rgds,
Colin.

[blagger]

Colin

You will still need the CPL level knowledge to do an FI anyway under EASA so you haven't wasted anything. If you've done the exams, it would then be pretty brave not to do the CPL course before the exams expire. I'd carry on as per your plan. All info is on the CAA website, they have a good summary doc on there.

[oldspool]

Thanks Blagger,

I just found the CAA FAQs on the Part-FCL proposals on another thread which has answered some Qs. Thanks,

Colin.

[rhwheeler]

Name changes for registered facilities are treated as an initial application. One unexpected requirement:

The use of any shared planning and briefing facilities requires permission written on headed company notepaper.