EASA FCL - Latest from Brussels

[proudprivate]

Hi all,

1. With the latest session of the Transport Committee over, most MEP's are going on holiday's till mid-August now. Since quite a few of them belong to more than one Committee, they will probably still be in town until the end of the week.

This means that you still have until Friday to contact them and to voice your concerns about the EASA FCL proposal (the IMC-regulation; the N-reg issues; the onerous FTO requirements; etc...). After that, it will become more time critical (time to draft the resolution for objection; get everyone aligned; etc...)

You can find the list of TRAN MEP's here (http://www.europarl.europa.eu/members/expert/committees/search.do?language=EN&committee=2868)

Your MEPs : List of MEPs (http://www.europarl.europa.eu/members/expert/committees/search.do?language=EN&committee=2868)



2. A friend of mine told me that the Commission is holding a review of the EASA rulemaking procedure(s), with meetings taking place over the course the course of last week, presided over by Baldwin. I think such an initiative can only be applauded, as it could mean
- more efficiency
- better transparency
- appropriate stakeholder input
- more accountability
- improved consistency

Anybody else heard about this ? Or what the status / potential outcome is likely to be? Flies on the wall ?

Proudprivate

[Pace]

pushing this back up the list

[proudprivate]

I guess it should be a sticky :E

From experience, I've noticed that talking, in combination with writing letters, works best. I guess most people with a concern will have written an letter to a TRAN MEP at some stage.

Calling their office and speak to one of their assistents as a follow up is very useful : it allows you to clarify points, rebut the biggest Commission bull**** with specific and convincing arguments and it helps you gauge their true interest. Every MEP or MEP's assistent I've spoken with is motivated to engage with you. So while it is not much, in contrast to what a lot of people have declared here in a defeatist way, you all individually do have leverage over these people.

You can find phone numbers of their offices easily on the individual MEP's website (that is, if they keep an office as not all of them do).

Good luck with your marketing campaign :ok:

[Pace]

whoops accidental post again ;)

[David Roberts]

PP wrote: "A friend of mine told me that the Commission is holding a review of the EASA rulemaking procedure(s), with meetings taking place over the course the course of last week, presided over by Baldwin......Anybody else heard about this ? Or what the status / potential outcome is likely to be? Flies on the wall ?"

This sounds like the 'high level group' that was set up last year by the EC, and which is due to finish its work about now. The GA rep on it is the President of the Deutscher Aero Club, and the UK CAA is there too I think.

[proudprivate]

This sounds like the 'high level group' that was set up last year by the EC, and which is due to finish its work about now. The GA rep on it is the President of the Deutscher Aero Club, and the UK CAA is there too I think.

Nothing on the DAeC website.

Interestingly, I saw their 8.3.2011 note :

Auf der EASA-Website gibt es jetzt die deutsche Übersetzung zum „Draft Regulation on Part-FCL“–Pilotenlizenzen. Die EASA hat in den vergangenen Jahren an der Entwicklung europäischer Lizenzen gearbeitet. Der DAeC und Europe Air Sports haben sich intensiv am Konsultationsprozess beteiligt. Jetzt befindet sich das Regelwerk im Abstimmungsprozess der nationalen Vertreter bevor es vom EU-Parlament verabschiedet wird.

Which process would that have been ? The EASA committee meeting was on the 7/8 December and then the topic was supposedly to go for "translation" to Parliament. Incidentally, the translated text has now been effectively presented to Parliament. Is the "Abstimmungsprozess" then a discussion about the various translations of the draft proposal ? Why would that take 7 months (from 9th December to the 9th of July) ?



the UK CAA is there too I think


My friend mentioned the French DGAC. So wouldn't be surprised of the CAA or DofT showed up too.



This sounds like the 'high level group' that was set up last year by the EC, and which is due to finish its work about now.


Could you elaborate a bit about the precise purpose / action plan of the "High level group" ? What would be the ideal outcome of such a meeting series ?

[trevs99uk]

I sent Mr Baldwin and e-mail asking several questions and got this response.

Dear Sir,
Thank you for your email dated 26 May 2011 concerning issues linked to general
aviation. Pursuant to the Commission's Communication of 11 January 2008 on Agenda
for Sustainable Future in General and Business Aviation, the Commission supports a
proportionate regulation of this sector, including the safety aspects.
With regard to licensing, I would like to draw your attention to the fact that there is a
clear legal mandate in Regulation (EC) No 216/2008 that requires pilots residing in the
European Union (EU), including pilots flying n-registered aircraft, to comply with the
European licensing requirements. This Regulation also mandates the Commission to
propose common rules in the area of pilot licensing and medical certification.
Secondly, you refer to the potential socio-economic impact of the proposed rules. The
proposals have been made to ensure that throughout the EU the same criteria and
procedures are applied to determine the technical competency of pilots. It is only through
common and harmonised requirements and procedures that we will be able to achieve
both a uniform high level of safety and a common undistorted market where pilots can
exercise everywhere in the EU their activities without hindrance.
As to several issues raised in your email including the medical requirements for pilots
and general aviation instructors, the current Commission's proposals are based on
currently existing Joint Aviation Requirements (JAR FCL 1 and 3) and were subject to a
wide consultation process during which interests of all stakeholders were duly
considered. The proposals were agreed with the sole aim of ensuring an appropriate level
of safety and provide with sufficient flexibility in order to disrupt as less as possible
existing national systems.
In response to your comment on Annex II aircraft, the decision to exempt them from the
FCL requirements – except in some cases when operated commercially - was taken by
the Member states and the European Legislators based on the principle of proportionality
and subsidiarity. This allows Member States to apply softer or more adapted rules to
Annex II aircraft but does not prevent Member States from applying harmonised EU

FCL.
Ref. Ares(2011)681438 - 24/06/2011
2
The same principle of distribution of competences applies to language proficiency
requirements, as the new FCL Regulation mandates only a certain language proficiency
level; however, detailed organisational aspects of who and how should perform the tests,
as well as their cost, are left to the Member States in line with the principle of
subsidiarity.
Concerning the review of instrument rating requirements aiming at their simplification,
this issue is the subject of a currently ongoing EASA task. A public consultation (socalled
Notice of Proposed Amendment for NPA) is due to be launched in the second half
of 2011 and the final EASA proposal could be transmitted to the Commission in 2012.
Please, feel invited to participate in this consultation and contribute to the swift adoption
of the appropriate EU rules.
With regard to your question on part M, the Commission already introduced in 2008,
with Regulation (EC) No 1056/2008, a first adaptation of the continuing airworthiness
requirements of Regulation (EC) No 2042/2003 which brought some alleviations to the
pre-existing requirements. The Commission has also mandated EASA to work further on
the matter and has underlined repeatedly that it was one of the priorities of EASA
rulemaking activity. EASA has initiated a number of tasks to propose alleviations where
considered possible, without impairing the level of safety, in particular task MDM.032
which has been recently concluded in the form of EASA Opinion No 1/2011. On the
basis of this Opinion, which I hope takes into account the concerns that you have
expressed, my services are currently working a further adaptation of the airworthiness
requirements of Regulation (EC) No 1702/2003 and Regulation (EC) No 2042/2003. It is
expected that this amendment could be adopted in the second half of 2011 or early 2012.
This future regulation will provide another opportunity to address your concerns related
to continuing airworthiness.
You also referred to the need for harmonisation of night flying rules, which is indeed an
issue that needs to be tackled at EU level. We have moved ahead on this issue with the
new Standardised European Rules of Air (SERA), which will standardise the conditions
under which night VFR flying will take place if it is allowed at all by the Member State
in question. It was however impossible to decree that Night VFR would be allowed all
over the EU as many Member States felt that there is a need for flexibility in order to
take into account local conditions, such as geography or typical weather. The new SERA
rule is due to enter into force at the end of 2012.
In addition, on this subject EU-OPS1 contains strict limits for the commercial operation
of single-engine aeroplanes and prohibits such operations at night or under instrument
meteorological conditions (IMC) except under special visual flight rules. Nevertheless,
some Member States have authorised an exemption from the limiting rule, founded on
the need to maintain this type of operations on specific or remote areas and following the
enhanced standards of the International Civil Aviation Organisation (ICAO).
1 Council Regulation (EEC) No 3922/91 of 16 December 1991 on the harmonization of technical requirements and
administrative procedures in the field of civil aviation, OJ L 373, 31.12.1991, p. 4, as last amended by Commission
Regulation (EC) No 859/2008, OJ L 254, 20.9.2008.
3
The International Civil Aviation Organisation (ICAO) allows since 2005 the operation of
single-engine aeroplanes by night or under IMC under certain conditions. EASA foresees
to study further this issue with the view of proposing harmonised conditions under which
the operation such operations could be allowed in the EU.
Further you commented on the plan to mandate the carriage of new radios that are
capable of operating in the 8.33 KHz channel division. Admittedly this is an expensive
mandate, but at the same time it is also an unavoidable measure. The growing congestion
in European airspace has led to a shortage of frequencies, which can be most efficiently
alleviated by splitting the available frequency band into smaller increments. This will
also benefit General Aviation operations as they will be able to continue to operate in
controlled airspace and to use the various radio-related services in uncontrolled airspace.
Unfortunately, unless all airspace users migrate to the new radios, none of these
advantages are achieved. Taking into account this possible financial burden, my services
have decided on a strategy of drawn out implementation over a period of many years to
minimise the cost. This allows radios to be swapped for new units as the old radios come
to the end of their useful age, hence reducing the additional investment need. The actual
date of final retrofit has not yet been decided, but is expected to fall around 2017 or
2018.
As regards differing access control measures at EU airports I would like to recall that EU
rules on aviation security provide for the possibility to create demarcated areas for
operations with smaller aircraft at EU airports. It is up to national authorities, based on a
local risk assessment, to adopt alternative security measures that provide an adequate
level of protection for such areas as long as these are separated from the rest of the
security restricted area of the airport. Depending on local circumstances and their risk
assessment, authorities therefore may or may not create such demarcated areas.
You have also mentioned the important issue of translation mistakes included in some
EU safety legislation. Let me inform you that both the Commission and EASA are
working together in order to improve the quality of translations and that my services are
at your disposal for addressing urgently any translation mistake identified.
Last but not least, concerning ageism, the rules contained in FCL Regulation for
commercial operations follow what is prescribed by ICAO. Nevertheless, in certain cases
- e.g. balloon pilots - some alleviations have already been made to address the concerns
raised by the general aviation, allowing these pilots to fly longer.
Finally, it is my conviction that the Commission has widely accommodated the concerns
of the general aviation community in the proposals described above.
Yours sincerely,
(Signed)
Matthew Baldwin

[bookworm]

Bear in mind Silvaire that this only applies to commercial air transport operations. There are no restrictions on private ops. I don't know Part 121 very well, but it appears that FAR 121.159 similarly prohibits Part 121 carriers from using singles.

[David Roberts]

Having had meetings with the said gentleman on three occasions in Brussels since mid April (he took up his new post in February) I can assure you he is no 'idiot bureaucrat'. Far from it. Sharp, quick, well-informed.

The quoted reply from him was clearly not written by him, but by a member of his staff whose native language is not English (UK version). That I can tell easily from some of the phraseology and syntax. Mr B, as a senior European civil servant, a Brit and ex UK DfT, would personally write such a reply slightly differently. The fact that he appears to have signed it (unless someone else did on his behalf) merely reflects the fact that as Director of Air Transport, he has a very busy diary.

Turning to the content of the reply, I think is is perfectly comprehensive (given I have not seen the letter to him) and inevitably the author has to refer to the relevant legislation.

[patowalker]

English as she is spoke : " in order to disrupt as less as possible existing national systems."

[robin]

Further you commented on the plan to mandate the carriage of new radios that are
capable of operating in the 8.33 KHz channel division. Admittedly this is an expensive
mandate, but at the same time it is also an unavoidable measure.

A fairly typical reply from EASA.

You might be right in saying these guys mean well and that something gets lost in translation. But this is fairly clear in any language - they don't appreciate the excessive burdens they are placing on GA and don't even apologise for the fact

[BillieBob]

We have moved ahead on this issue with the new Standardised European Rules of Air (SERA), which will standardise the conditions under which night VFR flying will take place if it is allowed at all by the Member State in question.That's all very well but SERA A is not due to become law until at least the end of 2012 whereas an IR becomes mandatory for all flight under IFR from April 2012. Unless the UK acts independently to allow flight under VFR at night in the next 9 months, the night skies are going to be very quiet (which some may say is no bad thing)!

[IO540]

The proposals have been made to ensure that throughout the EU the same criteria and procedures are applied to determine the technical competency of pilots. It is only through common and harmonised requirements and procedures that we will be able to achieve both a uniform high level of safety and a common undistorted market where pilots can exercise everywhere in the EU their activities without hindrance.

That's typical Euro-bollox. There is no evidence of reduced safety under e.g. FAA regs. But what would one expect?

There is absolutely no point in asking an EASA or EU official to explain himself. You will always get the standard line trotted out.

You will achieve more by writing to them and asking them if the UK can leave the EU, or whatever.

Further you commented on the plan to mandate the carriage of new radios that are capable of operating in the 8.33 KHz channel division. Admittedly this is an expensive mandate, but at the same time it is also an unavoidable measure. The growing congestion in European airspace has led to a shortage of frequencies, which can be most efficiently alleviated by splitting the available frequency band into smaller increments. This will also benefit General Aviation operations as they will be able to continue to operate in
controlled airspace and to use the various radio-related services in uncontrolled airspace. Unfortunately, unless all airspace users migrate to the new radios, none of these advantages are achieved.

That has been comprehensively proven to be total bollox.

The frequency allocation issue is 100.000% a national radio spectrum authority job protection scheme. If frequencies were allocated centrally in the EU (or with equivalent co-operation between countries) 25kHz spacing would be fine (as it is in the USA) but perhaps a dozen jobs would be lost around Europe.

It's a very ignorant email for a Brit who ought to know better.

[BEagle]

...as many Member States felt that there is a need for flexibility in order to take into account local conditions, such as geography or typical weather.

Strange, though, that the same logic wasn't applied to the IMC rating?

The quote is explicitly allowed for under the provisions of JAR-FCL 1.175(b); however, that has not been taken into part-FCL. Had it been, all the argument about the UK IMCR would have been unnecessary.

[proudprivate]

The frequency allocation issue is 100.000% a national radio spectrum authority job protection scheme. If frequencies were allocated centrally in the EU (or with equivalent co-operation between countries) 25kHz spacing would be fine (as it is in the USA) but perhaps a dozen jobs would be lost around Europe.


I know that national authorities want to sit on frequencies they rarely use (or use alternatingly with others they could also give up), so it is clear that the "sharp, quick, well-informed" Matthew Baldwin is bull****ting again, most likely deliberately deceiving the general public in this case.

But why is it a job protection issue ? Who's jobs depend on whether a frequency is allocated to a tower or another ATC facility ?


The quoted reply from him was clearly not written by him, but by a member of his staff whose native language is not English (UK version). That I can tell easily from some of the phraseology and syntax. Mr B, as a senior European civil servant, a Brit and ex UK DfT, would personally write such a reply slightly differently. The fact that he appears to have signed it (unless someone else did on his behalf) merely reflects the fact that as Director of Air Transport, he has a very busy diary.


He is not a Director General, or a Commissioner, or a Transport Minister is he ? The latter two will sign everything their cabinet tells them to sign. I know they pulled a joke on the Belgian Research Minister in the 80-ties by having him sign a decision to re-open the Antartic King Boudewijn base (which, at the time, was covered under a 30 m ice layer :)).

But at director level, which is two or three steps below that in the administration, you're supposed to read what you sign. If it is gibberish (like the above letter) and you sign it, then you deliberately obfuscate a citizen's concern. The correct thing to do it to send it back and insist on more clarity from your subordinates. [I've just realised : the letter was probably written by Seebohm :eek:]


A fairly typical reply from EASA.


In this case, it's the Commission. While I haven't had the benefit of 3 meetings with Baldwin since april, I'm beginning to get a clear idea on the Commission's "vision" on general aviation. It consists of flying locally, in class G or E airspace, on Saturday (not on Sunday for noise abatement reasons. Then only gliding is allowed - unless the neighbours complain of the noise).

Instead of being considerate and balanced (what Mr. Baldwin always claims to be), he doesn't give a toss about the costs or burdens on the aviation community.

When he writes

It is only through common and harmonised requirements and procedures that we will be able to achieve both a uniform high level of safety and a common undistorted market where pilots can exercise everywhere in the EU their activities without hindrance

he proves that he doesn't understand economics and that he abuses safety as an argument to push a protectionist agenda. Where are the safety statistics to support this FCL draft proposal ?

Without hindrance ? Is he proposing to abolish his money grabbing agency or something ? Maybe we should all write to the Polish transport minister and propose him to cut the EASA budget by 20-30 Million or so. I'm sure we can find sufficient arguments to make the case.


Strange, though, that the same logic wasn't applied to the IMC rating?

The quote is explicitly allowed for under the provisions of JAR-FCL 1.175(b); however, that has not been taken into part-FCL. Had it been, all the argument about the UK IMCR would have been unnecessary.


Exactly. Proves my earlier points about deception and the Commission's "vision".

[David Roberts]

PP wrote: [I've just realised : the letter was probably written by Seebohm ]

Good guess I would say...

I'll have a word with Mr B to suggest he reads all letters put in front of him for signature.

[fireflybob]

Folks, until we get a (hopefully peaceful) revolution then nothing will change!

I defy anyone to really understand this bureaucratic nonsense.

After all, what is a licence? Merely a piece of paper which proves you are qualified!

[tdbristol]

It may be that Baldwin (like many others in Brussels) are:

Sharp, quick, well-informed.and in fact in my experience of these people they almost all are very bright and often hard working.
The problems however - with Baldwin and most others involved - are that:

a) they have little real experience or understanding of the issues for those involved
(as evidenced by the statements that Baldwin makes about 8.33KHz radios, night flying, and others.)

b) they are so far into 'the bureaucratic process' that they do not step back and take a holistic view of what is actually right to do for those involved.
Take the point that Baldwin makes about
clear legal mandate in Regulation (EC) No 216/2008 that requires pilots residing in the European Union (EU), including pilots flying n-registered aircraft, to comply with the European licensing requirementsApart from the fact that this is stretching the truth [the Basic Regulation actually says no such thing] the real issue - that Baldwin and others appear not to grasp (deliberately or otherwise) - is that there is no safety or other reason to target N-reg pilots, therefore why is he and others so keen on pursuing law that works on a clearly mistaken assumption, particularly when the results will be so detrimental?
Anyone with real gumption and the real interests of those concerned would take the view that "the proposed law is daft, therefore let's change it". However Baldwin and many others seem so follow the approach:
- there is some general EU law
- therefore we should implement it to the extreme, even if it makes no real sense (and please don't bother us with the facts either)

c) And more generally, my own experience is that these people have their own agenda foremost in their mind - typically furthering their careering and/or scoring political points - and whatever 'collateral damage' occurs commensurate with this [such as N-reg and GA generally], well so be it. (In my experience this is typically the most important criteria in decision-making.)

Cynical, but that is my view.

So I think the only way to change things is to make it advantageous for the careers of those involved to change, by making it politically uncomfortable for them to continue in the same vein - so letters and phone calls to MEPs, UK DfT, the CAA...

[IO540]

Apparently, approximately 1 job in each country's CAA is concerned with aviation frequency allocation, and this is the only thing which is driving the 8.33 proposition in Europe.

The proposition is traditionally trotted out by Eurocontrol, whose blindly arrogant presentations (especially ones done by a chap going under the name of Hendrix) have to be seen to be believed.

The last one I was at, in 2009 or so, they trotted out another piece of blind faith which was thousands of VLJs clogging up the skies. I advised them that the VLJ market was just about dead, Eclipse had gone bust, the air taxi proposition discredited, etc. They were quite shocked. Afterwards, an executive from Eclipse walked up to me and congratulated me for talking sense which none of those present could have done under the names of their organisations.

This is the kind of garbage and blind arrogance which is driving regulation in the EU.

Unfortunately, the EU is quite successfully exporting its regulatory garbage outside the EU. Some of the Far East is going Part M, and one clue-less Eurocontrol speaker I saw was straight off to some S. American country "to show them how it's done". Obviously the EU is trying to push the USA out of its de facto world domination of aviation regulation, and the poor sods who are buying into this garbage do not know any better.

- there is some general EU law
- therefore we should implement it to the extreme

That was deliberate. You propose a vague law which nobody can vote against, and then you build on the back of it. A very old tactic.

[Pace]

Apart from the fact that this is stretching the truth [the Basic Regulation actually says no such thing] the real issue - that Baldwin and others appear not to grasp (deliberately or otherwise) - is that there is no safety or other reason to target N-reg pilots, therefore why is he and others so keen on pursuing law that works on a clearly mistaken assumption, particularly when the results will be so detrimental?

I am pretty sure the informed do grasp that! Sadly we presume wrongly that our industry is at the mercy of some big bad wolf.

sections of our industry wrongly see N reg as competition and have been lobbying for its removal instead of lobbying for less regulation which has created their high cost situations in the first place.

EASA is a safety body so people like Baldwin will spout that mandate whether its true or not.

They cannot spout on demonstrated threat (ie the stats) so they spout on percieved threat. ie no demonstrable threat but a broader picture of safety being achieved by control and intervention which we all know is not the case.
IE more regulations more intervention more oversight has to equal better safety. The reality is that a major reason for Europes imminent collapse has been on the mass of non productive government created positions in the UK alone amounting to 25 % of all employment.

Without regulating and then creating more jobs in sub organisations to implement those regulations all those millions of jobs in Europe would not be sustainable hence the expensive and strangled situation Europe is in now.

http://www.pprune.org/biz-jets-ag-flying-ga-etc/457241-part-91-operators-hassled-lfpb.html

Have a look at the above link to see how stupid things are going

Pace

[proudprivate]

Have a look at the above link to see how stupid things are going


VAT (in France) and ramp (in Germany) checks are more and more common (maybe because there are more civil servants) but I've never seen them turn ugly yet.


no demonstrable threat but a broader picture of safety being achieved by control and intervention which we all know is not the case


I believe that is a more problematic issue. More politicians and civil servants are out to intervene and control simply because it fuels their self-aggrandissement.

Some of the anti-N-reg brigade simply don't realise who their newlyfound bedfellows are. Luckily they are not a majority, but there are politicians (and not the ones you would expect) out there who are supporting the EASA-FCL proposal because it will lead to less people flying (yes they do grasp that) and hence reduce carbon emissions !

Last time I checked painting a G on your empennage did not reduce CO2, so private flying as a whole will be next, at least according to those politicians' agenda.

[N1/TOGA]

Nigel farage at the EU parliament july 6, 2011

‪Nigel Farage..i want you all fired. what the EU should be 06/07/11‬‏ - YouTube

:D:D:D

[mad_jock]

On a flight ops inspection the CAA bloke said they were ramping up there inspectors as well. And they are intending that there will be more ramp inspections and engineering inspections in the UK including GA and schools.

[Whopity]

The number of CAA FEs is at an all time low and with the closing of Flight Test Centres one wonders how and where they will train new staff!

[proudprivate]

Nigel Farrage is most certainly entertaining. Good for democracy, most probably, as he points out some of the more painful disconnects between European politicians and European citizens.

In that sense, there is a parallel between the workings of EASA and the of the Commission in the Basic Regulation and subsequent FCL files.

But to rally behind Nigel Farrage would not be my cup of tea. Apart from a few well documented controversial statements made by EFP members, I also happen to like the Schengen agreement a lot. I think we should cherish the freedom it gives us. For private pilots on the continent that means a lot less paperwork (none if you file the flight plan online) when flying into Reims, Geneva, Peenemünde or Maastricht. Good about the Schengen agreement is that you don't have to sign it if you're not comfortable with it. I think the Danes are a bit daft in first signing up to it and then wanting out. You're not going to stop illegal immigration by putting a couple of clowns in a booth in Padborg. And nothing is stopping the Danes from clamping down on drugs : but you can also do that 30 km inland with a few targeted checks. So all in all, unlikely bedfellows for me.

That being said, Morten Messerschmidt, also of the EFD fraction, was at least friendly enough to send a pertinent letter to the Commission asking about N-reg instrument ratings.

Coming back to UKIP : Mike Nattrass is the transport committee rep, now sitting independently from Farrage after major disputes last year as to the future stance of the EFD. Nevertheless, just like Morten Messerschmidt, Mike Nattrass is also favourable to exposing the Commission and EASA and curtailing their undemocratic behaviour (as well as cutting their budget - "EU’s budget skal reduceres og under kontrol").

I've noticed that some of you on this forum have strongly negative views on Europe (which I can empathise with, but do not share). If that is the case, it certainly can't hurt to give Mike Nattrass' office a call and ask him whether he would support the resolution for objection, show up at the vote and could he maybe convince some others to to the same thing ?

Happy landings,

Proudprivate



On a flight ops inspection the CAA bloke said they were ramping up there inspectors as well. And they are intending that there will be more ramp inspections and engineering inspections in the UK including GA and schools.


I think its a good idea for the civil service at all levels to assess which tasks need revamping and which ones should be cut in an overall effort to increase efficiency. But maintaining regional flight test centres seems like a no-brainer ?

[IO540]

The number of CAA FEs is at an all time low and with the closing of Flight Test Centres one wonders how and where they will train new staff!I thought that initial IR checkrides will now be done by FTOs? Or ATOs, or whatever they will be called.

Re Schengen, this never meant much in mainland Europe because border checks became ineffective decades ago. It is largely a symbolic thing. Of course, for private aviation, it is wonderful (unless you live in the UK :) ).

But e.g. Greece always ignored it anyway, for anybody coming in a "vehicle". The only way to get the advantage of Schengen was to walk there, or swim there. There is just one airport there (LGKC) which seems to know about how the system should run, and accepts Schengen traffic despite having no Customs.

N-reg checks have always taken place, mostly in France and Germany, mainly looking for the dreaded certificate of free circulation for VAT. This is a huge issue for UK pilots who have got this piece of paper because UK Customs no longer issue them (they are acting illegally (http://www.peter2000.co.uk/aviation/faa-nreg/docs.html) but thus far nobody has spent the money to challenge them). I got mine in the nick of time in 2005 and anybody who bought their plane after that without knowing about this is stuffed. Denmark offered a route for company owned planes till 12/2009. There only UK route now is via a declaration of market value and paying VAT on that value, which works out very expensive.

That post in the bizjets forum was probably looking for illegal charter. The UK CAA have done the same thing: they interview the passengers separately (out of sight of each other so they cannot straighten out their stories) to find out of they paid. Also, the issue of cabotage can be raised in some cases. You have to watch this and, for example, take NO money from passengers flying in an N-reg and be very explicit about this. The traditional PPL Cost Sharing scheme is legal in a G-reg in UK airspace, and is legal in an N-reg in US airspace.

[proudprivate]

EASA is a safety body so people like Baldwin will spout that mandate whether its true or not


For added safety, they are gonna get a 50-odd extra people it seems (http://www.europarl.europa.eu/meetdocs/2009_2014/documents/tran/dv/2012_tran_budg_amends_txt_/2012_tran_budg_amends_txt_en.pdf)
Things can only get better from here :E
Or maybe it is a reward for their flawlessly tailored legislative work thus far...

[Whopity]

I'll have a word with Mr B to suggest he reads all letters put in front of him for signature. Reading it is one thing, understanding it is another. Most of the drivel from Europe reveals a universal lack of understanding across the board.

[proudprivate]

Most of the drivel from Europe reveals a universal lack of understanding across the board.


I personally believe it is a painful symptom to trying to "Europeanize" something that most member states seem reluctant to let go.

The result is then an awful "compromise" that is likely to create havoc and decrease overall air safety. So either you agree on something like "European Air Law", and that implies
- that a Bulgarian Examiner is as good as a Latvian one
- that the semicircular system in Italy is going to be the same as in France
- that you don't invent obstacles to flying that have nothing to do with safety (the 8.333 kHz radio springs to mind)
- ...

or you don't touch it and leave things the way they are.

Also, the way EASA operates now is totally unacceptable, with prominent figures like Goudou or Sivel going about sprouting complete nonsense, with rulemaking technicians like Cluzeau (aka "the Frog Einstein" on this forum) just collecting input without a clear vision and then claiming that some piece of junk is "the best compromise for a legislative proposal that was obtainable". The cherry on the cake is then some classical civil service bickering between the Commission officials (Mr. B's superiors, predecessors and subordinates) and EASA about who fulfills what role...

Add to that complete intransparency of the rulemaking process and the lack of vision with many member states' CAA's and Transport Ministeries and pretty soon politicians start wondering about the "disconnect" between citizens and politics (or citizens and Europe).

[IO540]

It is such a pity that EASA is run by a load of crooked people.

The previous system, JAA, was a mishmash of bodged regs where each country did more or less what it wanted anyway, and the same anti American sentiment (as EASA is running) prevailed in most of Europe.

JAA gold plated loads of ICAO requirements, inflated costs to everybody, and played a big hand in crippling private IFR capability. The elimination of the 700hr route was just one small piece of this.

But before JAA, it wasn't a bed of roses either. Speaking to some old-timers, the theory exams were only a bit better than the present JAA "90% garbage" which I gather is about to become "95% garbage" under the new EASA question bank.

To be charitable, one can see the EASA motivation in trying to standardise things across the EU, to curb the excesses of JAA, but they lost control of the process very early on (years ago).

This comes as no suprise since the biggest gold platers were the national CAA gravy train riders who left their jobs and went to work in Cologne :) I've had some correspondence (on component certification matters) with some Brits there whose replies were sickeningly arrogant - as well as unhelpful. They may have been ex UK CAA, or ex CAA approved design company people. They all come out of the same mould (ISO9000 quality manager types).

EASA was doomed as soon as it got going, as a result of an excessive political mandate, and as a result of stupid recruitment of just the personnel who were going to cripple its objectives.

It would have been fairly easy for EASA to do the obviously desirable things. For example they did one (just one) of them by grandfathering national modification certification to a pan-EU system. They could have accepted FAA STCs. They could have converted FAA papers to EASA ones, as a one-off conversion, which would have caused much of the N-reg scene to dry up. But instead they got infiltrated by a load of America-haters who have been running private anti-American projects from inside the place.

[BillieBob]

Most of the drivel from Europe reveals a universal lack of understanding across the board.You have only to read the NPA 2008-17 CRD to see just how little understanding of aviation exists within EASA. Perfectly reasoned comments from highly experienced and professional individuals received some quite ludicrous and insupportable responses. Subsequent reactions filed through the CRT were studiously ignored.

[Whopity]

with rulemaking technicians like CluzeauAh, the Pink Panther! Some of us remember his Uncle Jacqueshttp://29.media.tumblr.com/tumblr_lcf1qtN0sC1qaun7do1_400.jpg