IAOPA sets out its stall on PPL licensing to the US and Europe

[proudprivate]

IAOPA-Europe and AOPA-US have made a joint presentation to an EASA-FAA conference on harmonisation of licences between America and Europe which it is hoped will lead to a simple, low-cost route to recognition of qualifications at the PPL level across the Atlantic. Craig Spence of AOPA US and Martin Robinson of AOPA UK outlined IAOPA's position on licensing to European and American delegates at a conference in Cleveland, Ohio, which is part of the process of establishing bilateral agreements on aviation between the continents. Both sides have agreed to make action on recognition of private pilots licences a priority.

IAOPA is asking that recognition processes be kept simple, and that unless there are serious safety issues to address, the regulations of one authority should hold good in the territory of the other once they have been validated. Validation is important because it allows a national authority in Europe to 'take ownership' of an individual's qualifications, and to amend or suspend them as necessary – something national authorities complain they cannot currently do.

In an ideal world, the holder of an American PPL would be able to take a European Air Law exam, have it certificated by a local examiner and pay a small fee to a national authority before it can be used in Europe. In the case of holders of FAA Instrument Ratings, they could be validated for use in Europe on the condition that the holder undergo an annual check ride with an instructor. European authorities look on the rolling renewal system used by the Americans as a game-stopper and an annual renewal may be the price that has to be paid for recognition.

From the American standpoint, there is a problem with validation because under their law, licences are only valid in the state in which they are issued. If, say, an FAA licence was validated in France, the holder would only be able to fly within the boundaries of France; America does not recognise Europe as a political entity. But the FAA representatives in Cleveland are willing to look at solutions to this problem and Craig Spence will be pursuing the issue. The presentation was positively received by both sides; IAOPA has been asked to write to the FAA and EASA setting out our proposals, and Craig Spence and Martin Robinson are working on that document, which will pertain solely to private licences and ratings – professional tickets will be dealt with separately.
IAOPA is also talking to the FAA about the position of holders of FAA 61.75 licences, issued on the basis of their European qualifications. These will lapse because they are issued on the basis of the number of your European licence, and this will change when you get an EASA licence. IAOPA is working on ways to get 61.75 licences reissued without the holder having to go through the security clearances and other hassles now involved.


In the ideal world, you would set licensing standards at ICAO level and you would recognise ICAO licenses and convert them at national level for a fee, commensurate with the administrative work involved (i.e. something like £ 10 -20 max). There would be no additional air law exam, there would be no "certification" by a local examiner.

I fail to see why an annual renewal of an instrument rating would be a necessary condition to ensure flight safety. There obviously is no safety statistic to support this. And despite the recent announcements by the EASA supervisory board to the contrary, the "authority" continues to use bogus safety arguments to perpetuate job schemes for flight examiners.

By contrast, I would have nothing against national authorities wanting to "take ownership" of individuals' qualifications. But is there a history of the FAA actually acting up when a European CAA comes along with a reasonable claim ? Is the processing time inordinately long ? Lets take the example of the Dutch CAA wanting to take action against an American licensed Dutch citizen flying an N-reg into class D airspace without establishing two-way radio communication (I'm taking a typical offence for which your run of the mill CAA would like to see a license suspended for 3 months or so). Is that now "not happening because Dutch CAA can't be bothered" or "not happening because the FAA FSDO in Brussels can't be bothered" ? Or is this "take ownership" complaint yet another example of Eckard Seebohm style dog**** ?

[Fuji Abound]

If you have flown in various parts of the world there is no doubt that some of the local practices can be quite alien. Whether this justifies an air law exam or a check ride with an instructor is perhaps debatable but given that not unreasonably national authorities want some evidence a pilot has proved their knowledge I can see the justification for this requirement. Unfortunately our air law exam for example is not a very good model for demonstrating that a pilot that has only flown in the US understand the differences here.

I agree with regards the annual instrument check flight - its a complete nonsense but realistically I suspect you would be paddling against a very strong tide to get that changed!

I am afraid Martin struggles to get to grips with these sort of issues after his debacle over the IMCr and EASA changes in general but I suspect he has been more expertly guided by AOPA US who really do know their business. We can only hope it produces some results.

[peterh337]

I agree with your comments PP but I think the reality is in the politics and the emotions surrounding these issues in Europe.

Forget aviation and accident stats. Just look at the politics.

In the USA, the default position is to vest authority in an individual and let him get on with it. Hence the A&P/IA system, the DER system, the DAR system. Only at the top end (jets) does one have to get into FAR Part 145 Repair Stations. It's a system which works very well, although obviously it does require the govt authority to be able to bust individuals who play up (and the FAA certainly does do that, and they do it in Europe as well, often acting much faster than the CAA).

In Europe, the default position is to presume all individuals are crooks and fraudsters, and you vest authority in an organisation. You make the organisation go through various approvals whereby certain steps make it "difficult" for a crook to operate (you force the organisation to appoint separate individuals for separate functions which makes collusion necessary, and since collusion is regarded as antisocial, it is deemed unlikely to happen in Europe) and then you can let the system run with minimal top-level supervisory activity; you mainly set up an office to collect the approval fees. So, we have the European situation where maintenance companies can do what they like (including document forgery) and virtually never get busted. This extends to stuff like ISO9000 which is now a complete farce and a purely marketing tool (albeit one that impresses only complete mugs, and ISO 9000 quality managers employed by the company doing the purchasing).

So, we will never have Europe accepting the FAA IR 6/6 rolling currency. It's obvious that all FAA licensed pilots are forging their licenses, after all :ugh:

US AOPA is excellent and superbly organised. If they can apply some of their resources to the European situation, they can achieve a great deal. I once watched an ageing Phil Boyer totally demolish a bunch of Eurocontrol officials at a presentation, and they slinked out as fast as they could before somebody could ask them questions.

An air law exam is a fairly standard thing for license conversions/validations, notwithstanding the fact that the present one in Europe is stuffed to the brim with complete bollox like this (http://www.peter2000.co.uk/aviation/jaa-ir/morebull.gif) and addresses virtually nothing to do with actually flying over here.

[Whopity]

In the ideal world, you would set licensing standards at ICAO level and you would recognise ICAO licenses and convert them at national level for a fee, commensurate with the administrative work involvedThe UK has recognised ICAO licences since the late 1940s, there is no fee and no work involved. Of course this doesn't suit the beaurocrats of Europe so it is about to end. AOPA are really only proposing that we go back to where we were pre JAA but lets not forget who dragged us into JAA in the first place, not the beaurocrats of Europe, it was not in their plan until AOPA put it there!.

Despite all the hype there is no such thing as a EASA PPL, only a series of National PPLs with an EASA sticker on them. Maybe the rest of the World should tell EASA that their licences will not be acceptable as EASA is not a member of ICAO; we could then forget them and continue with our National ICAO licences.

[proudprivate]

Whopity :


The UK has recognised ICAO licences since the late 1940s, there is no fee and no work involved.


Agreed. But I was referring to a conversion. That is, you have someone who has lived and flown all his life in Brazil and now wants to fly G-reg in Europe. It would be reasonable for the UK CAA to charge a small conversion fee for that (i.e. issuing a new UK CAA license).


Maybe the rest of the World should tell EASA that their licences will not be acceptable as EASA is not a member of ICAO; we could then forget them and continue with our National ICAO licences.


Yeah but even when you fight the Neazis, you still try to abide by (the Geneva and) the Chicago convention. Otherwise you become a bit like them.


Fuji :


If you have flown in various parts of the world there is no doubt that some of the local practices can be quite alien.


True. But that is even true inside Europe.

- I got b*llocked at an Italian regional airport when I was requesting taxi to the fuel pumps without having requested a startup clearance first.
- I've flown to airfields in Germany and France where the local language is required for A/A communication
- You can file IFR departures (not just Zulu) from VFR only airports in the Netherlands
- etc...etc...

Are you arguing that a G-reg PPL (IR) should go through differences training to fly in Italy / Germany / the Netherlands ??? No of course you're not. And what evidence do you have that that G-reg PPL knows f*ck all about Italian Air Law ? Makes the right circuit calls in German ?
But the N-reg flyer should sit an Air Law Exam ? Come off it, mate...


I am afraid Martin struggles to get to grips with these sort of issues after his debacle over the IMCr and EASA changes in general but I suspect he has been more expertly guided by AOPA US who really do know their business. We can only hope it produces some results.


That I hope too. What bugs me is that he writes the underlined as if it is "commonly accepted". To any logical logically thinking pilot without some sort of pecuniary conflict of interest, it is not.


I agree with regards the annual instrument check flight - its a complete nonsense but realistically I suspect you would be paddling against a very strong tide to get that changed!


I agree with all the lobbying and the artificial job creation it is a strong tide to row against. Nevertheless, if the EASA board claims that in any GA-relevant regulation safety has to be weighed against burden and cost and that safety arguments have to be supported by real statistics, one can only point that out to them. At the very least, they will look ridiculous in front of everyone if they persist.

[Fuji Abound]

You raise an interesting points with regards differences in europe. I suppose there is rightly a much greater common denominator between class a (and tmas) and "international" commercial airports throughout the world enabling much the same standards of air law to be applied. Differences are far more common at small non commercial airports, and ifr traffic very rarely has to worry about airspace and other local perculiarities. For that reason demonstrating familiarity is perhaps even more important for pilots of ga vfr traffic than cat pilots.

Never the less easa ga pilots are free to roam although as you rightly say the organisation of airspace and local procedures can be quite different throughout europe. In fact of couse this was true before easa. From europe's point of view like it or not i guess it would be impossible to impose the need to pass an air law exam for each member state and i also guess easa would say thats why they intend even greater harmonisation.

On the other hand i equally guess australia would say the way we do business is sufficiently different that we are going to impose an air law requirement on foreign pilots.

Whether they would be justified is more difficult. We all know you can just go fly in america under a 61.75 but you do need to pass a flight test and you will (or should) be closely questioned on many of the essentials of air law. There is undoubtedly plenty to catch many the private pilot out in terms of the differences between the way they and we do things. On the other hand we give faa pilots (at least at the moment) complete freedom without having to demonstrate any knowledge what so ever of our air law. You could argue we are more generous. Is there any evidence a pilot is better off for passing a local air law exam? I have no idea. I guess it forces everyone to at least review local procedures sufficiently to pass whereas without while the vast majority will have the common sense to do so its surprising how stupid a small minority can be.

[proudprivate]

From europe's point of view like it or not i guess it would be impossible to impose the need to pass an air law exam for each member state and i also guess easa would say thats why they intend even greater harmonisation.


Of course. My point is that EASA, when arguing the need to impose an air law exam on non-EASA ICAO rated pilots for safety reasons is a bit hypocritical, in the sense that air law in different member states is very different and most of these things you just learn on a need to know basis in your preparation and by experience.

The intention at harmonisation is nothing but lip service. Have a look at Italian semicircular regulation and you quickly get the message. And the EASA proposals on harmonisation of transition levels are downright farcical.

So unlike Australia, Europe doesn't have a unified air law and hence requiring knowledge of it through an air law exam is a bogus argument: the common denominator of air law in Europe is amply covered by what they teach you in an ICAO country, be that in Belize, Brazil or Bolivia


We all know you can just go fly in america under a 61.75 but you do need to pass a flight test


You don't : you need to have a BFR, which is quite different from (and a lot less expensive than) a flight test. All the questions you get on air law from an instructor are going to be relevant ones, unlike the air law exams in Europe. I must say the question Peter came up with made me smile. It is so typical for that twisted JAA attitude.


On the other hand we give faa pilots (at least at the moment) complete freedom without having to demonstrate any knowledge what so ever of our air law.


You're obviously only talking about the UK, I presume, which allows flying G-reg on an FAA PPL VFR only ? Because if you fly into the US with a JAA license on a G-reg, you have complete freedom too, without ever having demonstrated knowledge of "their" air law. That is the whole point of ICAO and the Chicago convention: establish a common standard with minimum requirements for safe operation worldwide. Thats why ICAO regularly audits countries, so that licenses can't be "bought" from some corrupt official in Ulan Baatar or Gatwick.

And the rest of Europe isn't that generous at all : To convert, even at PPL VFR level, requires a wrist of exams (you got to love those questions on inner ear anatomy or the number of rods in the eye !) and a flight test, even for competent pilots with 100 hours of PIC time.


I guess it forces everyone to at least review local procedures sufficiently to pass whereas without while the vast majority will have the common sense to do so its surprising how stupid a small minority can be.


Everyone, that is, except the UK EASA pilot flying in France, or the ICAO EP level 0 Air Bulgaria pilot flying to Amsterdam. But seriously, I don't buy that as an argument to need an air law exam.

You can reasonably assume that someone who has sat through an up to ICAO standard airman certification process will have been taught to prepare for a flight. The FAA certificate holders for instance are taught to familiarize themselves with all elements relevant for the flight.

And if you are a foreign pilot renting some local equipment, you can be sure that the operator will have the renter pilot checked out, not only in the aircraft but also in pertinent local procedures. That is actually the point of the BFR in the 61.75 conversion.

[Whopity]

It would be reasonable for the UK CAA to charge a small conversion fee for that (i.e. issuing a new UK CAA license).
WHY? what on earth has that got to do with safe operation? If a Brazilian pilot goes to a UK club he will be checked out to their satisfaction. Having an unnecessary piece of papers serves no useful purpose. The UK has complied with ICAO Annex 1 in both spirit and practice unlike many other countries. It has not caused any safety issues in doing so.
1.2.2.2 Recommendation.— A pilot licence issued by a
Contracting State should be rendered valid by other
Contracting States for use in private flights.
As far as Airr Law exams are concerned. they ceased having any relevance to flying an aeroplane years ago.

[dublinpilot]

You're obviously only talking about the UK, I presume, which allows flying G-reg on an FAA PPL VFR only ? Because if you fly into the US with a JAA license on a G-reg, you have complete freedom too, without ever having demonstrated knowledge of "their" air law. That is the whole point of ICAO and the Chicago convention: establish a common standard with minimum requirements for safe operation worldwide. Thats why ICAO regularly audits countries, so that licenses can't be "bought" from some corrupt official in Ulan Baatar or Gatwick.

And the rest of Europe isn't that generous at all : To convert, even at PPL VFR level, requires a wrist of exams (you got to love those questions on inner ear anatomy or the number of rods in the eye !) and a flight test, even for competent pilots with 100 hours of PIC time.

Not that it's wholly relevant, but for the record, Ireland is just as generous a the UK, automatically rendering an ICAO licence valid on EI reg aircraft.

[Fuji Abound]

Proudprivate

Not nick picking but a BFR is a flight test. Yes, I was only talking about the UK and yes you could fly a G reg in the US but you will struggle to find one (I know, there are a few).

I don't disagree with anything you say, my post was to give both sides of the coin without necessarily drawing any conclusions. However as is so often the case there is what we all think or know makes sense and what is realistic or likely to happen.

Its debatable whether pilot medicals achieve anything, but they aren't going to disappear any time soon. Its debatable whether Europe needs control over everything that gets off the ground in its airspace but in reality the Euro mind set cannot contemplate anything else.

Of course it would be wonderful if any pilot could fly any where in the world on their ICAO license but its not going to happen any time soon and it definitely isn't going to happen in Europe -I wish it wasn't so but that is the only realistic conclusion unless you want to give the next five years of your life to a campaign which even then is unlikely to succeed. I spent six months campaigning to keep the IMCr, I think it was worthwhile and I would like to think it contributed to the present state of play but that was only one very small and possibly achievable element.

That is all I have to say really. ;)

[peterh337]

Pilot medicals seem to do nothing that is statistically detectable :) but they make the pilot papers ICAO compliant...

Ireland is just as generous a the UK, automatically rendering an ICAO licence valid on EI reg aircraft.

Interesting; I didn't know that :ok:

What about the rumour that Ireland does not recognise FAA Class 3 medicals?

[BEagle]

What are these mysterious 'pilot papers', peterh337? Why not use correct terminology?

Incidentally, the requirement for periodic demonstrations of competency is enshrined in the EASA Aircrew Regulation - and quite rightly so too!

I am afraid Martin struggles to get to grips with these sort of issues after his debacle over the IMCr and EASA changes in general but I suspect he has been more expertly guided by AOPA US who really do know their business. We can only hope it produces some results.

To which 'struggle' and 'debacle' do you refer? Where is your evidence for this nasty little comment?

[peterh337]

You must know exactly what I mean

- license (licence)
- rating(s)
- medical

No use writing e.g. license when the medical is always required also.

[dublinpilot]

What about the rumour that Ireland does not recognise FAA Class 3 medicals?

That is correct. The IAA don't recognise FAA class 3 medicals, believing them to be sub ICAO. They are perfectly happy though with an FAA class 1 or class 2 medical.

[peterh337]

They appear to be incorrect; they are sub-ICAO only if special conditions are imposed.

Still, as they say, possession is 9/10 of the law and the IAA owns the aircraft registry :)

[patowalker]

What about the rumour that Ireland does not recognise FAA Class 3 medicals?

The UK trumps that. It does not recognise French and German JAA Class 2 medicals.

http://www.caa.co.uk/docs/49/JAAMemberStatesScheduleJul2010.pdf

[peterh337]

Do you mean it doesn't recognise them for the issue of a UK JAR-FCL PPL, or it doesn't recognise them for use in conjunction with a French or German JAR-FCL PPL to fly a G-reg?

The latter would be most suprising.

[proudprivate]

Do you mean it doesn't recognise them for the issue of a UK JAR-FCL PPL, or it doesn't recognise them for use in conjunction with a French or German JAR-FCL PPL to fly a G-reg?


They don't recognise the French, German [and Belgian, for that matter] medical for the issuance of a UK JAR-FCL PPL.


Incidentally, the requirement for periodic demonstrations of competency is enshrined in the EASA Aircrew Regulation - and quite rightly so too!


I don't think anybody is debating a requirement for periodic demonstrations of competency. After all, a biannual flight review with an instructor is just that.

What we are arguing here is
- that it shouldn't have to be demonstrated to an examiner
- that recent flight experience should play a role in setting the requirements
- that EASAs unholy Aircrew Regulation contains a lot artificial job creation that is not supported by any safety statistics
- that IAOPA is apparently advocating some quite unnecessary restrictions which aim at perpetuating this job creation to the detriment of the flying community as a whole

@ whopity : you're quite right. In an ideal situation, the ICAO member state would simply recognise ICAO papers and allow its planes to be flown on those alone.

@ Fuji : I think it is an absolute disgrace that the IMCR rating is discontinued. Again an example of EAZIsm imposing themselves regulation wise without any safety statistic in support. A lead poisoning from their carnival masks is what those Cologne clowns deserve...


The IAA don't recognise FAA class 3 medicals, believing them to be sub ICAO. They are perfectly happy though with an FAA class 1 or class 2 medical.


Is this for conversion, or to fly EI aircraft on an FAA certificate in Ireland ?

[BEagle]

@ Fuji : I think it is an absolute disgrace that the IMCR rating is discontinued. Again an example of EAZIsm imposing themselves regulation wise without any safety statistic in support. A lead poisoning from their carnival masks is what those Cologne clowns deserve...

The IMC rating is not 'being discontinued'.

It will be available (under a new name - 'IR(Restricted)') for new issues until 8 Apr 2014 and possibly thereafter. Anyone obtaining one before then will be able to use it on both EASA and non-EASA aeroplanes into the future.

The IR(Restricted) was originally my idea, but the CAA has done the spade work to make it happen. Hopefully my other proposal (adoption of JAR-FCL 1.175(b) into FCL.600.IR - General) will be accepted; if not, the fight will go on!

[dublinpilot]

The IAA don't recognise FAA class 3 medicals, believing them to be sub ICAO. They are perfectly happy though with an FAA class 1 or class 2 medical.

Is this for conversion, or to fly EI aircraft on an FAA certificate in Ireland ?

Irish law automatically validates all ICAO licences for use on EI reg aircraft for private day VFR flight (without geographic restriction, though there is a confusing AIC which tries to limit it to Ireland).

Obviously any such licence needs to be accompanied by an ICAO level 2 medical or above (the standard required for private flight licences under ICAO).

The IAA have taken the view that an FAA class 3 medical is not an ICAO level 2 medical or above, and therefore cannot be used as the basis for flying an EI reg aircraft on an FAA PPL.

dp

[peterh337]

They don't recognise the French, German [and Belgian, for that matter] medical for the issuance of a UK JAR-FCL PPL.

OK; that business is going to get more complicated under EASA because the license issuance country will have to be the same one which keeps your medical records.

I've been trying to get my head around that one but presumably it is to cut down on people doing their initial medicals (especially CV tests) in certain well known locations ;)

OTOH can't the initial CV test be done in any ICAO country?

Also EASA is refusing to recognise pilot papers from e.g. Croatia which was formerly a JAA country.

[patowalker]

Do you mean it doesn't recognise them for the issue of a UK JAR-FCL PPL, or it doesn't recognise them for use in conjunction with a French or German JAR-FCL PPL to fly a G-reg?

For the issue of a UK JAR-FCL.
http://www.caa.co.uk/docs/49/SRG_Med-UK_JAR_PPL_Mar-2010.pdf

[Fuji Abound]

Beagle

As you well know the proposed eir is not the same as the imcr and the irr may not be available throughtout easa.

As to my comments regarding martin he rufused to lend aopa uks support to the imcr or to the campaign to save it to which i quote he said it was as much use as a chocolate teapot. He then changed aopas stance when he realised the tide had turned, aopas stance was very unpopular and they had little choice but jump on the band wagon. Personal opinion it maybe but aopa uk has lost its way under martin resulting in an organisation very poorly supported (with less than 10 % of the pilot population being members) and with few friends amoung the other representative organisations. I have no idea why he has clung on for so long and a change is well overdue - its not a job for life, although it does seem otherwise.

I appreciate you will disagree, but you did ask. ;)

[BEagle]

Fuji, virtually all of that rant is utter nonsense!

As you well know the proposed eir is not the same as the imcr and the irr may not be available throughtout easa.

The proposed En-route IFR Rating is totally different and is not a substitute, I agree. But the IR(R) will have the same privileges as the UK IMC rating and will not be valid outside UK airspace.

As to my comments regarding martin he rufused to lend aopa uks support to the imcr or to the campaign to save it to which i quote he said it was as much use as a chocolate teapot.

AOPA has always supported the IMC rating very strongly and neither Martin Robinson nor any other AOPA representative has ever wavered from that position.

The 'chocolate teapot' term was my description of the original EIR which hadn't been properly defined and was very vague and imprecise.

He then changed aopas stance when he realised the tide had turned, aopas stance was very unpopular and they had little choice but jump on the band wagon

Again, complete nonsense. Although AOPA's position on the retention of the UK IMC rating most certainly did NOT change, the position on the EIR changed once the NPA 2011-16 proposals made it clear that most of the originally unacceptable vagueness and safety issues had been addressed. If you want to see the full details of both the IAOPA(EU) and AOPA(UK) actual position with regard to the EIR, you will have to wait until the CRD is released.

Personal opinion it maybe but aopa uk has lost its way under martin resulting in an organisation very poorly supported (with less than 10 % of the pilot population being members) and with few friends amoung the other representative organisations.

Nonsense though it is, you are of course entitled to your own opinion. However, you might care to know that AOPA has been working closely with the 'other representative organisations' on a number of issues without any friction or other difficulties. It also has a good standing with the senior levels of the CAA.

Before writing such bile-ridden garbage, it might have been better if you'd done rather more research.

[bookworm]

I don't think anybody is debating a requirement for periodic demonstrations of competency. After all, a biannual flight review with an instructor is just that.

What we are arguing here is
- that it shouldn't have to be demonstrated to an examiner

Instructors are trained to instruct. Examiners are trained to examine competency.

- that recent flight experience should play a role in setting the requirements

How exactly would that work? A shorter test if you've logged instrument currency?

[BillieBob]

Fuji - You are not, perhaps, confusing Martin Robinson with Jim Thorpe, are you?

[Fuji Abound]

Beagle

I am not going to pursue this particular discussion as I know well of your involvement with AOPA and your opinions. I guess I would expect nothing less than for you to support them. That is fine with me and I have no intention of making it personal. Martin has a job to do and I just happen to think he doesn't do the job very well which means that an important organisation like AOPA UK doesn't have the support it enjoys or deserves.

I have been careful to confine my comments to the facts, facts of which you are clearly unaware because you have jumped to the wrong conclusions or made references which are not relevant. That is understandable because I am guessing you were not aware of some of the correspondence between us at the time and correspondence with other parties.

FWIW (and I guess not a lot) I have the emails and since not surprisingly they are in writing I am quite satisfied as to the position taken at the time and the views expressed with which it should be obvious I was very upset and felt it sold GA short. I make no apology for feeling strongly about this matter because I do and I know so do many others.

[proudprivate]

Instructors are trained to instruct. Examiners are trained to examine competency.


What utter claptrap to suit your monetary self interest!

Instructors are of course also trained to assess competency. They are certainly capable of assessing competency. And they are required to assess competency, when they have to sign student pilots' off for written tests and checkrides. And they assess competency during the flight reviews.

Using an instructor for recurrent assessment as opposed to an examiner just saves a lot of money ($45 /hour vs $200 / hour).

Re the statement "that recent flight experience should play a role in setting the requirements" your asking the question is answering it:

How exactly would that work? A shorter test if you've logged instrument currency?


If you've logged instrument currency (where the approaches and holds during normal flight time can be verified - they are on ATC tape and on record at the airports) you shouldn't be re-tested at all, it's as simple as that. And it saves time and money for the pilot community.

But that is obviously something you don't give a monkey's about...

And if the BFR came up for an instrument rated private pilot, even if current, I would throw in an approach or a hold just to see how things are going, but that is fun and at minimal cost.

Any relevant safety statistic you want to throw into this Bookworm ? I didn't think so.

[Pace]

Proudpilot

Instructors are trained to instruct and are a pretty mixed bag going from very good to very poor.
Examiners are there to examine and should be detached from the person they examine.
You should not have an instructor who teaches you builds a relationship with you and then examines you.
Cost is another thing.
Nothing we do get from EASA will be what we want as there is little common sense in how they operate.
Anything which we do get which is less than that which is on the table at present will be a bonus.
If you can continue your FAA IR in Europe but are required to sit an airlaw exam and take a flight test with a designated Examiner that has to be a lot better than what is there at present.

Pace

[bookworm]

What utter claptrap to suit your monetary self interest!

I've come across very few other people on PPrune who not only personalise the debate but also make fallacious assertions about the motivation of other contributors to the discussion. If I don't agree with you, proudprivate, the only conceivable explanation is that I'm corrput and self-serving, right?

Instructors are of course also trained to assess competency. They are certainly capable of assessing competency. And they are required to assess competency, when they have to sign student pilots' off for written tests and checkrides. And they assess competency during the flight reviews.

Using an instructor for recurrent assessment as opposed to an examiner just saves a lot of money ($45 /hour vs $200 / hour).

So why does the system bother with examiners at all then? Why not just get the hour-building kid who just qualified to teach students to assess your competence to do something that you've been doing for the last 20 years, and take that privilege away from you on a whim?

Why do examiners cost more than instructors?

If you've logged instrument currency (where the approaches and holds during normal flight time can be verified - they are on ATC tape and on record at the airports) you shouldn't be re-tested at all, it's as simple as that. And it saves time and money for the pilot community.

Well why stop there? If I made it to the end of my PPL course alive, and did a few take-offs and arrivals (some of which might be described as landings), why both with a checkride? You shouldn't be tested at all, it's as simple as that. It saves time and money for the pilot community. Come to think of it, if I make it up the stairs to my AME's office without having a heart attack, why bother with the medical examination? You shouldn't be tested at all, it's as simple as that. It saves time and money for the pilot community.

[Fuji Abound]

Well why stop there? If I made it to the end of my PPL course alive, and did a few take-offs and arrivals (some of which might be described as landings), why both with a checkride? You shouldn't be tested at all, it's as simple as that. It saves time and money for the pilot community. Come to think of it, if I make it up the stairs to my AME's office without having a heart attack, why bother with the medical examination? You shouldn't be tested at all, it's as simple as that. It saves time and money for the pilot community.

Bookie

Tongue in cheek I am sure but I guess there is a serious point. As societies / communities develop they tend to accumulate ever more legislation and regulatory requirements; the danger is that either while they were justified at the time, they no longer are, or, on any proper examination of the evidence they were not justified in the first place.

The FAA monitor instrument proficiency in a different way to us we all know, but is there any evidence our system reduces the number of accidents / incidents? Conversely the BFR in FAA land is a test whereas in theory our nearest equivalent isn't and is works quite differently if you can demonstrate currency. Is one system better than another? Some aircraft in the UK require the pilot has a full CAA medical but other aircraft just as fast and perhaps more difficult to fly do not require the pilot to have a medical to the same standard. Moreover arguably they attract pilots who wouldn't get a CAA medical for one reason or another. Is there any evidence to suggest they have more incidents / accidents as a result of medical issues which would have been screened during a CAA medical? I don't know the answers but they are all valid questions me thinks.

[Pace]

Fuji

Tongue in cheek I am sure but I guess there is a serious point. As societies / communities develop they tend to accumulate ever more legislation and regulatory requirements; the danger is that either while they were justified at the time, they no longer are, or, on any proper examination of the evidence they were not justified in the first place.



Have you just realised the reason Europe is going down the drain is that it is a victim of its own burocracy?
A vast Army of government jobs, gold plated pensions big expense accounts all to be paid for. Regulators every way you turn with their research departments all heavily paid and all looking for new ways to regulate to justify their own jobs? A monster of a machine out of control and costing Billions all in the name of big brother Europe!
We cannot afford it anymore!

I find that completely unacceptable. A friggin publicly funded €100 million+ budget a year organisation should show common sense and should operate to serve the community

Just one tiny example of why we are going down the drain. They could have taken the FAA well tried and tested system adjusted for European issues and saved a fortune.
EASA common sense??? They regulate for their own benefit not the community

Pace

[proudprivate]

I've come across very few other people on PPrune who not only personalise the debate but also make fallacious assertions about the motivation of other contributors to the discussion.


I notice that your assertions trivialise the debate. Some of your previous interventions do not mark you as particularly stupid. It's therefore only logical to question your motives.

Now tell me, are you or are you not making money from Aviation Regulation in Europe, be it as a consultant to the UK CAA on regulatory matters, a temporary agent at EASA, or a similar occupation ?


So why does the system bother with examiners at all then? Why not just get the hour-building kid who just qualified to teach students to assess your competence to do something that you've been doing for the last 20 years, and take that privilege away from you on a whim?


Again, you trivialise the debate.

First, notice the absence of any safety statistic in your argument.
A system with examiners for initial check rides and instructors on a biannual basis has been tried and tested. The safety record of such a system per flown hour certain beats yours. Furthermore, it is cheaper on the pilot community. Therefore, it is superior.

Next, you propose to do away with examination altogether, and in the same sentence you question the competence of an instructor of your choice.

Finally, you describe the threat of an hour building kid to take away your flying privileges. This threat doesn't exist. You cannot "fail" a biannual flight review. The kid might refuse to sign you off, but if it is the kid of your choice, I would assume the dialogue and debrief would give you a clue as to why he would refuse this. But that is not "taking away flying priveleges". After some proper review, you would probably get the sign off. If the original examination was anything to go by, remedies are likely to be light.

Why do examiners cost more than instructors?

I don't have a definite answer to that one. Some possibilities could be:
a) because the examiner is usually a more senior pilot
b) because sometimes the local CAA charges add-on fees
c) because they have an oligopoly which they exploit


Well why stop there? If I made it to the end of my PPL course alive, and did a few take-offs and arrivals (some of which might be described as landings), why both with a checkride? You shouldn't be tested at all, it's as simple as that. It saves time and money for the pilot community. Come to think of it, if I make it up the stairs to my AME's office without having a heart attack, why bother with the medical examination? You shouldn't be tested at all, it's as simple as that. It saves time and money for the pilot community.


Again, you are purposely trivialising the debate. An intial check ride ensures that you have performed up to test standards. Just ignoring your drivel on the PPL and the medical, let me try to enlighten you on the Instrument Currency :

You've been thoroughly tested on various procedures, which at that time you knew how to fly within private or commercial standards. By regularly flying approaches and holds, you retain a sufficient level of competence. Sufficient studies in comparable educational domains prove that. The advantage is that the basic instrument skill set can be logged and verified by a competent authority (on its own behalf or on behalf of an insurance company for example).

The whole point of the debate lies in a cost/benefit balance, where the benefit is safety. It is certainly worthwile doing an impact study (a real one, not an EASA one where you twist assumptions to suit your needs) about the need of a medical for private flight, but that is not the issue here.

By contrast, FAA studies show deteriorating pilot skills with inexperienced PPLs, which is their main motivator for a BFR. I would guess that, based on the skills affected (some are affected more than others, and some are more safety related than others), an impact study would reveal a statistically significant accident increase in the absence of a BFR. This should then be weighed against the alternative of having pilots log particular exercises in lieu of a BFR. The conclusion would probably be that, systematically logging a bunch of unverifiable items would not outweigh a one off cost of a BFR.

@ Pace :


You should not have an instructor who teaches you builds a relationship with you and then examines you.

Why not ? I happen to have a long standing relationship with my instructor. He would not sign me off if he felt I were deficient, and the BFR would certainly be a good learning experience.


Nothing we do get from EASA will be what we want as there is little common sense in how they operate.

I find that completely unacceptable. A friggin publicly funded €100 million+ budget a year organisation should show common sense and should operate to serve the community.

[421C]

So why does the system bother with examiners at all then? Why not just get the hour-building kid who just qualified to teach students to assess your competence to do something that you've been doing for the last 20 years, and take that privilege away from you on a whim?
......
Well why stop there? If I made it to the end of my PPL course alive, and did a few take-offs and arrivals (some of which might be described as landings), why both with a checkride?


BW
You are doing something that I wouldn't expect of you - repositioning a sensible alternative view into an absurdity.

The position I think we should be debating is the EASA/JAA vs FAA/ICAO one of the role of instructors vs examiners and the requirements for currency. I am qualified under both, although I have only a little ad-hoc instructing experience.

My characterisation of the two models is as follows:

Under the FAA, there are effectively only 2 "ranks" - Designated Pilot Examiners and Instructors. A DPE is needed for only one type of event - the initial issuance of a Certificate or Class Rating. Absolutely every other requirement for a pilot's revalidation or renewal or differences training can be met by a plain vanilla CFI (with CFII and MEI privileges as required). A CPL/IR ME could have stopped flying 10 years ago, and a plain CFI-II-MEI could sign off his complete and full set of privileges without any reference to an examiner or the FAA or any paperwork other than logbook endorsements.

The instructor has a vital role in assessing competence. The FAA I think would say a greater role (albeit less formal) than a DPE. The endorsement an instructor gives a candidate is taken as a formal assessment that the candidate meets the skills, experience and knowledge standards for the privileges he seeks. The DPE's role is to perform a "check" that this is the case, but it is emphasised that a single check ride can only test so much, and that the instructor is exercising a significant responsibility in endorsing a candidate and giving this message to the DPE and the FAA. In the award of new qualifications, there are thus two independent "gates" (the instructor and the DPE). In the revalidation/renewal, it is entirely down to the instructor's assessment.

I happen to think the system works well, its virtue is an obvious simplicity and practicality and, most importantly, a safety outcome as good or better than the best European countries. Of course, there is some small risk that a "bad egg" gets through, but the safety record suggests this is more than mitigated by avoiding the vast unproductive bureaucracy associated with flight training and testing in Europe, and consequently making flight training more accessible and less expensive. By less expensive, interestingly, that does not apply to instruction. The typical US rate is $50/hr flight and ground time. A much fairer rate than the pittance many European instructors work for. But, the avoidance of the huge regulatory cost makes flight training cheaper overall. Basically every penny you spend goes on training and practically none on the overheads and approvals needed in Europe.

Conversely, a "flight instructor" in Europe sits at the bottom of a multi-layered hierarchial pyramid, with NAA inspectors and examiners at the top, senior examiners and examiner examiners below them, then normal examiners, then heads of training and CFIs and then finally the "plain" instructor (with the "restricted" instructors below that), who are basically empowered to execute some training roles in an FTO and that's it. There is no comparison between that role and an FAA CFI, who has all of the privileges of European examiners in the realm of revalidation and renewal.

The hierarchy and multiple layers of paperwork checking may appeal to a certain kind of mentality, but I think it achieves nothing relative to the US model for flight training and safety.

brgds
421C

[peterh337]

The FAA monitor instrument proficiency in a different way to us we all know, but is there any evidence our system reduces the number of accidents / incidents?

No.

The JAA annual IR test does nothing to improve safety.

[421C]

Beagle

I am not going to pursue this particular discussion as I know well
of your involvement with AOPA and your opinions. I guess I would expect nothing less than for you to support them. That is fine with me and I have no intention of making it personal. Martin has a job to do and I just happen to think he doesn't do the job very well which means that an important organisation like AOPA UK doesn't have the support it enjoys or deserves.
Unfortunately Fuji, you are the one who posted what Beagle described as a "nonsense rant" and it needs pursuing in order to refute it.

I am a member of AOPA and nothing more. I don't want to start an argument, but I can't think of how to counter the personal attacks you have made on Martin and AOPA's role in the IMCr in any other way. I think you both have some sort of grudge and elevated self-importance. In my opinion, Martin and AOPA (and Beagle!) have done absolutely sterling work from day 1 in support of the IMCr, and any positive outcomes are due to their efforts, as well as the supportive role of the CAA/DfT and other pilot organisations. I would guess your contribution, on balance has been zero, because anything positive that your long-forgotten petition achieved has probably been negated by your endless criticism of AOPA on pilot forums for years since. I agree that AOPA doesn't have the support it deserves. I would attribute that to several factors on the whole
- useless apathy amongst many GA pilots
- unrealistic expectations of what a small voluntary organisation can achieve
- the egocentric view of "if it doesn't conform to my exact preferences in instance X, Y or Z" then I will stroppily refuse to join

In addition, I would add that a certain kind of anti-AOPA grudge-holder can be particulary vociferous on pilot fora, and I suspect this has some minor effect on negativity entering the collective pilot psyche. You are such a grudge-holder.

I value many of your interesting contributions on fora, but not your anti-AOPA campaign. If you have your doubts, the more constructive way would be to engage directly with the AOPA Member's working group etc, and stop rubbishing AOPA whenever the opportunity pops up. Of course, we are all entitled to an opionion, but when the number of times I have read an opinion of this sort from you approaches the 100 mark, as it probably does, I start to think it is vindictive, egocentric and unfair.

[proudprivate]

I don't think it is particularly helpful to to discuss actions of Martin Robinson or IAOPA in the past nor the advantages and disadvantages of joining IAOPA. I'm an AOPA member myself, and I see clear benefits to me.

I started this debate because Mr Robinson / IAOPA communicated to me on the current negotiations. I think it is not unreasonable to ask for a cost & effort conscious simplification of private aviation regulation in Europe. Some of the points mentioned in his communication seemingly contradict this rather straightforward view.

Replacing examinations with currency requirements for the instrument rating is an obvious one. Honouring ICAO papers another one.

[Pace]

Why not ? I happen to have a long standing relationship with my instructor. He would not sign me off if he felt I were deficient, and the BFR would certainly be a good learning experience.

Proudpilot

We agree on many things ;) You may have a great instructor who is more than capable That to me is what an instructor should be.
Instructor conjures up an image of a grey haired guy with that knowing twinkle in his eye who passes down years of hard earned experience to lesser mortals ;) Sadly an instructor can be the hour building kid with limited ability, hours and experience.
That does not mean that there should not be an instructor plus rating which qualifies more experienced instructors to examine? A sort of halfway house between an instructor and examiner.
Regarding the relationship between an instructor and carrying out examinations as well it is often good to have a second eye or opinion of your flying and an unbiased one at that.
Your instructor knows you well, knows your flying good and bad habits and is more likely to turn a blind eye. You dont go for a driving test and do it with the guy who taught you to drive you need an unbiased outside view of your abilities!
If we are expecting IR privalages in Europe rather than actually attaining and holding equiavalent licences is it not better to satisfy a European examiner representing EASA that we are up to the standards expected and save a fortune in the process.
I cannot see EASA letting an 18 year old with 200 hrs total give that approval!

Pace

[Fuji Abound]

421C

I have read an opinion of this sort from you approaches the 100 mark, as it probably does, I start to think it is vindictive, egocentric and unfair.

Fair comment.

I don't wish to pursue this is a vindictive manner. You will have gathered I feel strongly, but perhaps that is academic if it crosses the line.

For the record AOPA and Martin have done sterling work in many areas. In some I may think otherwise but for now and the future from my point of view it is best left there, you are right.

[peterh337]

I cannot see EASA letting an 18 year old with 200 hrs total give that approval!

Well, yes (although an FAA CFII won't be 18 with 200hrs; that is a European speciality ;) ) but that is just the reality of European politics.

One can debate the fundamentals but they will never change.

The US system, demonstrably "at least as good and mostly safer" will never be adopted here, partly for job protection reasons and partly because it is American.

So, instead of flying 6 approaches within the last 6 months, I have to fly with a CRE/IRR and spend £150, once a year. (In fact I have to do both because I have both IRs to maintain). That's about the cheapest way to do it. Plus the cost of actually flying, so a renter will be paying lots more than that. For nothing.

[proudprivate]

Your instructor knows you well, knows your flying good and bad habits and is more likely to turn a blind eye. You dont go for a driving test and do it with the guy who taught you to drive you need an unbiased outside view of your abilities!


First of all, I dispute the need for a test. As Silvaire is pointing out repeatedly, the BFR is not a test. It is an opportunity to iron out potential deficiencies, and your trusted instructor is the perfect person to help you with that.


If we are expecting IR privalages in Europe rather than actually attaining and holding equiavalent licences is it not better to satisfy a European examiner representing EASA that we are up to the standards expected and save a fortune in the process.


No. I would expect
- my aviation authority to respect ICAO papers
- instrument privileges to be maintained through verifiable currency requirements


I cannot see EASA letting an 18 year old with 200 hrs total give that approval!


- Who needs the approval of an 18 year old ?

- EASA is costing the taxpayer (you and me) € 105 Million a year. I think we deserve EASA to accurately weigh cost / benefit effects in the regulatory drafting process. And the weighing should be based on a real analysis, not some "sentiment" like in the preamble of the Basic Regulation.


...partly for job protection reasons and partly because it is American.


disgraceful ! If they did their job properly, no private pilot in Europe would want an FAA certificate.

[mad_jock]

I wonder what the pass rate is for renewals in Europe.

Even commercially there is some failures of pilots that are weekly doing 6 IFR approaches.

[421C]

What is the point of conjecturing why the FAA system might not work in principle (200hr 18year old CFIs, rolling currency etc) when it so self-evidently works in practice, and, to my knowledge, there is no evidence that the various conjectured problems actually manifest themselves? It's not as if the "sample size" is inadequate, since the US has probably 100x the volume of private IFR in Europe.

[mad_jock]

Try 1000x if not 10 000x in GA aircraft.

And even the much touted 65000 FAA pilots in europe. I suspect that there in less than 1500 flying IFR on there FAA tickets including commercial.

[bookworm]

If I don't agree with you, proudprivate, the only conceivable explanation is that I'm corrupt and self-serving, right?

I notice that your assertions trivialise the debate. Some of your previous interventions do not mark you as particularly stupid. It's therefore only logical to question your motives.

So if I don't agree with you, proudprivate, the only conceivable explanation is that I'm either stupid or corrupt and self-serving, right? Sorry I got that wrong first time.

Now tell me, are you or are you not making money from Aviation Regulation in Europe, be it as a consultant to the UK CAA on regulatory matters, a temporary agent at EASA, or a similar occupation ?

I am not. I give what feel like copious amounts of my own time to attempt to protect the interests of pilots like you. I have to confess that occasionally I wonder why.

You keep trotting out the statistics thing:

First, notice the absence of any safety statistic in your argument.

Aviation accidents are fortunately sufficiently rare that it's almost impossible to find any statistically significant result, particularly when comparing systems with many other differences. Your default seems to be to suggest that in the absence of statistical significance, everyone must do it your way. I'm afraid that doesn't wash.

The UK for example has a much more flexible approach to fuel planning than the FAA's 91.151 etc., and you'll find that the incidence of fuel exhaustion accidents is no higher in the UK than in the US. Will you petition the FAA for repeal of 91.151 then?

By contrast, FAA studies show deteriorating pilot skills with inexperienced PPLs, which is their main motivator for a BFR. I would guess that, based on the skills affected (some are affected more than others, and some are more safety related than others), an impact study would reveal a statistically significant accident increase in the absence of a BFR. This should then be weighed against the alternative of having pilots log particular exercises in lieu of a BFR. The conclusion would probably be that, systematically logging a bunch of unverifiable items would not outweigh a one off cost of a BFR.

In pre-JAA days, there was no "BFR" in the UK for PPLs, just a bi-annual requirement for a few logged hours. The CAA has analysed the "statistics" (http://www.caa.co.uk/application.aspx?catid=33&pagetype=65&appid=11&mode=detail&id=2820), and of course demonstrate that there is no significant difference in safety since the introduction of the requirement for a bi-annual instructional flight. Yet you seem to be content with the idea of a BFR as being a reasonable and cost-effective safety measure taken by the FAA, and you "guess" it has an impact. I think you "guess" wrong.

The whole point of the debate lies in a cost/benefit balance, where the benefit is safety. It is certainly worthwile doing an impact study (a real one, not an EASA one where you twist assumptions to suit your needs) about the need of a medical for private flight, but that is not the issue here.

Let me end by agreeing with you. The cost of a medical affects vastly more pilots in the EU than an IR prof check. There is precious little evidence of its efficacy as a safety measure in private aviation. Why don't you focus some effort there?

[bookworm]

The position I think we should be debating is the EASA/JAA vs FAA/ICAO one of the role of instructors vs examiners and the requirements for currency. I am qualified under both, although I have only a little ad-hoc instructing experience.

Indeed, and it is the blurring of the instructor and examiner roles that I find difficult to accept (though not as difficult as EASA's insistence that the examiner can not have given the student a single lesson). I salute you as an instructor 421C, as I've seen your teaching skills. I'd fear you as an examiner, but I suspect that's more about me than about you. ;)

Provided needless bureaucracy is eliminated, I see no reason why the examiner system should not be cost effective. I pay mine about £60/hour, which given the differences in other aviation prices between the US and the UK doesn't seem unreasonable.

[421C]

Fuji
Thank your for your very decent reply #41 above, following my rather blunt words.
brgds
421C

[peterh337]

the incidence of fuel exhaustion accidents is no higher in the UK than in the US.

That could be simply due to the typical UK GA mission profile, which due to the severely crippled utility value in UK GA (airports closing ~6pm, lack of IAPs, etc etc etc) comprises mostly of short local burger runs, on which fuel doesn't matter unless you depart with practically empty tanks.

One only has to briefly dive into any US pilot forum and see the discussion topics there, versus the UK ones :) It's a different universe.

[Pace]

The UK for example has a much more flexible approach to fuel planning than the FAA's 91.151 etc., and you'll find that the incidence of fuel exhaustion accidents is no higher in the UK than in the US. Will you petition the FAA for repeal of 91.151 then?

Bookworm

I enjoy your posts which are very detailed and informative especially on legal matters :ok:
Peter has a very valid point re fuel as the mission profiles tend to be very different in the USA to Europe with larger distance spreads.
This usually means that fuel considerations are more critical than the majority (not all flights) Over here.
You would expect the incidence of fuel shortage would be higher in the USA! If it is the same that would infact give the USA a better record.

Pace

[proudprivate]

Aviation accidents are fortunately sufficiently rare that it's almost impossible to find any statistically significant result, particularly when comparing systems with many other differences. Your default seems to be to suggest that in the absence of statistical significance, everyone must do it your way. I'm afraid that doesn't wash.


No. In the absence of statistical evidence or relevant anecdotal evidence (such as documented accidents or incidents), you choose the most cost effective way. I don't care whether that is my way, or Whopity's way, or 421C's way or Goudot's way, or even Seebohm's way.


I give what feel like copious amounts of my own time to attempt to protect the interests of pilots like you.


Sorry I got that wrong. I must say you have a great cover.


The UK for example has a much more flexible approach to fuel planning than the FAA's 91.151 etc., and you'll find that the incidence of fuel exhaustion accidents is no higher in the UK than in the US. Will you petition the FAA for repeal of 91.151 then?


No. Because I make it my personal rule to always land with an hour of fuel on board, even when VFR.

I'm sure you can find other differences where 14 CFR is more restrictive than LARS. They're just not very relevant to the discussion here.


Yet you seem to be content with the idea of a BFR as being a reasonable and cost-effective safety measure taken by the FAA, and you "guess" it has an impact. I think you "guess" wrong.


I haven't done the impact study. If there isn't a significant impact, there is a case for getting it scrapped. My guess was based on
- some FAA statistics on accident rates vs pilot hours
- an FAA study about deteriorating skill sets in low hour PPLs (but admittedly, that study was more qualitative and certainly not normalized for minimum logged hours)

But if the BFR isn't even necessary, why are you then advocating annual sessions with an examiner ? I would be in favour of a minimum logged hours regulation in lieu of a BFR or an annual check ride.


The cost of a medical affects vastly more pilots in the EU than an IR prof check. There is precious little evidence of its efficacy as a safety measure in private aviation. Why don't you focus some effort there?


Because that is an ICAO requirement, with a powerful medical lobby; much more powerful than the flight school lobby at EASA. Why don't you suggest your contacts at EASA to table it ? I'm sure the GA community would welcome it.

But in absolute money terms, the annual IR proficiency check is much more expensive than even an annual medical. We're talking a factor 3-4 here. The fact that there are so few IR rated JAA private pilots in Europe (why would that be ?) shouldn't distract us from the fact that the maintenance cost of this privelege, which is essential if you want to go places by plane, is simply much to high.

[Pace]

Bookworm

EASA are dealing with the private pilot part first. I have it on good authority that while 2014 is the official deadline, That EASA already have accepted that 2014 will be extended to 2016!

Commercial licences will be addressed after the private Pilot FCL aspect.
Yet from what i have also heard Commercial FCL is a bigger headache for EASA as far as legality regarding dual licence requirements.
It would be interesting to have your take on how you think the commercial CPL and ATP on FAA in Europe would be treated in a Bi lateral agreement? as well as the enforcement of the existing structure on employed pilots flying FAA aircraft within Europe?
Should an agreement occur regarding private licences how would that effect the legality of enforcing dual licences on commercial pilots??

Pace

[bookworm]

Peter has a very valid point re fuel as the mission profiles tend to be very different in the USA to Europe with larger distance spreads.
This usually means that fuel considerations are more critical than the majority (not all flights) Over here.
You would expect the incidence of fuel shortage would be higher in the USA! If it is the same that would infact give the USA a better record.

But that, Pace, is the point. There are always lots of complicating factors. And demanding that we do something the FAA way just because there is no statistically significant evidence that a different way is better is not a reasonable position to take.

[Pace]

Bookworm

I take your point to a point:E But still think we have a cancer of state created jobs in Europe where their own interests are priority rather than the interests of the industry they serve.

Ie they regulate for regulation sake which all turns out as needless expense both to the tax payer and industry.

EASA could have copied the tried and tested FAA system obviously with European needed adjustments.

They would have saved a fortune, freed up the industry and made a bi lateral a simple affair as was the case with the FAA and Canada.

Rather than that they took the route that suited their own and political interests rather than that of the industry and their mandate of safety.

Pace

[proudprivate]

And demanding that we do something the FAA way just because there is no statistically significant evidence that a different way is better is not a reasonable position to take.


Actually, that is an reasonable position to take, because of two important considerations :

(1) Trying to minimize regulatory burdens in the absence of valid documented anecdotal evidence or statistically verified evidence that significantly impact safety.

(2) Trying to harmonize Aviation Regulation worldwide (which is both an ICAO and an EASA concern).

Now you have just given us two good examples that it doesn't have to be the FAA way (fuel considerations and the necessity of a BFR).

But the way you formulate it reeks of an unhealthy anti-American sentiment. And the fact that certain elements complicate an interpretation of statistical data shouldn't be used as an excuse to impose a more burdensome regulation.

Recall the Seebohm quote :"We need this regulation because at present there isn't one". Now that is what I would call not a reasonable position to take !

A lot of the Euroland regulatory stuff is there not because of a specific safety consideration, but because "we can do it differently". It is this European Identity Crisis fueled regulatory drive that we should stop.

[bookworm]

Quote:
The UK for example has a much more flexible approach to fuel planning than the FAA's 91.151 etc., and you'll find that the incidence of fuel exhaustion accidents is no higher in the UK than in the US. Will you petition the FAA for repeal of 91.151 then?

No. Because I make it my personal rule to always land with an hour of fuel on board, even when VFR.

Right. And I make it a personal rule to get checked out by an experienced pilot once a year, in exchange for a fee for his time of course. Rules seem to be fine with you as long as they're consistent with your own habits and practices, even though, in a carbon constrained world with AvGas at £2/litre, they seem to be a profit creation scheme for fuel companies. But the ones that are consistent with mine are "bogus safety arguments to perpetuate job schemes for flight examiners".

I'm not quite sure where you get your impression of costs from. My annual MEP/IR renewal costs me about £180, for which I tend to get about 3 hours of the examiner's time, and I almost always derive useful insights. If I didn't have to do the exam, I'm be doing equivalent time in the air practising anyway. And the requirement for an annual IR prof check affects a tiny proportion of the private flying population. And you'd have to offset the cost of the BFR that you're proposing in its place.

My medical costs me £120, just like the other hundred thousand EU pilots (not to mention US pilots) who have to go through the process. For that I get about 30 minutes, and my AME has never found a problem. It's not that I'm ungrateful, but that's a much lower value-cost ratio than I get from the checkride.

Your habit of loading an extra 30 mins of fuel costs you too. CAT burnoffs are of the order of 5% per hour, SEP/MEP probably a bit less as we fly faster relative to best L/D. But if you call it 3%, then carrying an extra 30 mins of fuel than you need will cost you of order 1 minute of fuel per hour you fly. That's of the same order of magnitude of annual spend as a medical or a prof check. But I'm sure the value you get from it is in peace of mind and the time you save not having to do the math...

proudprivate, I'm a firm believer in the idea that regulation should bring a positive benefit-cost in terms of safety. The principle is worth repeating to EASA, and we do, again and again. But you're fixating on a single issue, which doesn't deserve the priority that you want IAOPA to give it. Is it possible that you're as nervous of "demonstrating your competence" to an EU examiner as I would be of demonstrating mine to 421C? ;)

[bookworm]

But the way you formulate it reeks of an unhealthy anti-American sentiment.

Ah the rationalisation (sorry, I mean "rationalization") of my motives continues. Not self-interest, not corruption, not stupidity, what's left? Ah, must be xenophobia. Hardly worth looking up from the ballgame I'm watching to dignify that one with a response.

One only has to briefly dive into any US pilot forum and see the discussion topics there, versus the UK ones It's a different universe.

Indeed, I think you missed the glory days of rec.aviation, but I learned more from rec.aviation.ifr than I ever have from PPrune.

[Pace]

BookWorm

You should not be nervous of 421C very nice informed guy ;) I have not done a Bi Annual for years as keeping a current annual type rating negates the need for the Bi Annual.
But I do renew my JAA multi and its always good to go into any flight test with the thought of getting the max out of it.
The better the instructor/examiner the better and more you learn from the experience. We need to be pushed and challenged.
I always remember being checked out for a Citation position as then a co pilot.
The check pilot on the trip was an ex squadron leader. On meeting him he appeared to be a total pussycat and I got into the aircraft with absolute confidence.
My God what a change! The Guy was a total Rottweiller, very precise very demanding and by the end of the flight I felt I knew nothing.
I was about to thank him for the experience and slink off tail between my legs when he commented no you were fine.

So dont go by appearances only attitude! Yours ;)
Surely 421C is not that fear invoking? Is he? :E

Pace

[bookworm]

Commercial licences will be addressed after the private Pilot FCL aspect.
Yet from what i have also heard Commercial FCL is a bigger headache for EASA as far as legality regarding dual licence requirements.
It would be interesting to have your take on how you think the commercial CPL and ATP on FAA in Europe would be treated in a Bi lateral agreement? as well as the enforcement of the existing structure on employed pilots flying FAA aircraft within Europe?
Should an agreement occur regarding private licences how would that effect the legality of enforcing dual licences on commercial pilots??

I guess I owe you an answer to this one. AFAIK, flight crew of commercial operations based in the EU already need EASA licences. So I guess you mean non-commercial ops using remunerated flight crew, like corporate ops. I wasn't aware that CPL/ATP was being treated any differently from private licences in that regard.

I've always hoped that the FAA-TC bilateral would be the model for an FAA-EASA bilateral on licensing. Rumour has it that progress is slow, and I'm awaiting further reports from the Cleveland get-together.

[Pace]

I've always hoped that the FAA-TC bilateral would be the model for an FAA-EASA bilateral on licensing. Rumour has it that progress is slow, and I'm awaiting further reports from the Cleveland get-together.

Sorry to clarify ATP and CPL on corporate hence private GA! What I have heard is that there is an acceptance that 2014 will not be met and that is likely as long as there is progress towards a Bi Lateral that that will change to 2016.

I have also heard that due to some previous agreement that EASA can not go ahead with the existing structure without FAA blessing ????
Something which they totally missed

Pace

[flybymike]

Biennial Biennial Biennial BIENNIAL GODDAMMIT!

[bookworm]

But you're happy with me saying "bilateral", or does that mean something different too? ;)

[flybymike]

No (am)biguity there at all...;)

[Pace]

You ry wirting on an e pun : )

[peterh337]

Indeed, I think you missed the glory days of rec.aviation, but I learned more from rec.aviation.ifr than I ever have from PPRuNe

Maybe I missed the glory days but I remember it well. Quality discussion has moved to web forums but there has been a huge drop in quality over the years - I think partly (initially) due to the old hands having got bored with going over the same old stuff, and more recently because so many people post with Iphones which reduce postings to banal one-liners because (even assuming the user can actually write) writing anything meaningful is too much bother.

I've always hoped that the FAA-TC bilateral would be the model for an FAA-EASA bilateral on licensing. Rumour has it that progress is slow,

As I have always said, any bilateral treaty on FCL cannot possibly deliver anything substantially better than the "standard European way" of converting FCL papers.

There will always be some exams, and there will always be a flight test. There may be acceptance of foreign training (like in the CBM IR proposal, but FTO pressure all but killed that route by demanding 100hrs instrument time, which probably equates to 1000+hrs TT, and ensures FTOs don't lose revenue by ATPL cadets doing FAA CPL/IRs in the USA first) but the fact that you have to pass the UK IRT, with its NDB work, means that such a concession is moot since practically nobody will pass the IRT without being in the clutches of an FTO (or fly with a freelance CRE/IRR) for many hours....

So you may get the treaty but it won't mean much in practice, to the actual process.

[Fuji Abound]

flybymike
*
Join Date: May 2001
Posts: 1,466
Biennial Biennial Biennial BIENNIAL GODDAMMIT!


I think you will find it is God dammit. ;)

[flybymike]

I forsaw the possibility of some pedant like me raising the spelling of that expletive, and therefore Googled the most popular spelling before I posted. At that time it seemed to be the way wot a rote it! However, latest Google shows approx 50/50 split with two separate words! or even three (God damn it!);)

[proudprivate]

Ah the rationalisation (sorry, I mean "rationalization") of my motives continues. Not self-interest, not corruption, not stupidity, what's left? Ah, must be xenophobia.


No. The impression comes in part from your trivialising the debate on cost benefit with making dismissive remarks style "So it has to be the FAA way, huh, well that just doesn't wash" that convey an impression of anti-americanism. The impression was fuelled many months ago with your rants about US congressional protectionism.

I don't think xenophobia would a motivator for your stance. There are plenty of both stupid and xenophobic people on PPrune, but I at least think you are neither.

But I do know some people in this debate (at the European Commission for instance) that are so frustrated with some parts of US diplomacy that their emotions get in the way of common sense during a negotiation. If it were just Seebohm, that wouldn't be problematic, but the number of people at key positions who are keen on "getting even with the US" has risen too much.

A true advocate of positive cost benefit in general aviation would still support burden relief, even if it meant losing an opportunity to get even.


The topic of this discussion is IAOPA seemingly accepting a need for annual re-examination, which I find difficult to understand, let alone underwrite.

You say

I'm not quite sure where you get your impression of costs from.


Well, a private pilot needs a medical every 2 years (or every 5 years for an FAA pilot under 40). That takes an appointment, a 30 minute drive, a 15 minute wait, a 30 minute examination (including the typing up) and another 30 minute drive home, for a cost of € 90 (£ 80), or € 45 per annum.

A check ride with my favourite JAA examiner costs me € 200. That is for a 1.5 hour flight and another 1.5 hours of preflighting, taking the plane out of the hangar, answering a few oral questions and the debrief. The 1.5 hour flight time cost me, depending on the plane I'm renting, about € 200 wet.
That adds up to € 400 per annum, or a factor 8-9.

As I fly regularly and almost systematically fly a variety of instrument approaches, I normally retain currency just by traveling, because one of the regular ones includes a hold. Admittedly, at times I could have saved money and time by requesting a visual, and it is indeed the currency regulations that make me do this, so in all honesty I have to concede that I'm adding about € 150 in extra costs flying vectored VOR approaches for the sake of regulation. That would make it a factor 2. But it is a lot more convenient than having to schedule and maybe reschedule an appointment with an examiner to get the obligatory annual check ride out the way.


Then you go on a tangent again as regard fuel costs and carbon constraints in relation to 14 CFR 91.151 (VFR fuel requirements), which frankly make me wonder whether you weren't reading rec.humor as opposed to rec.aviation.

I'm flying regularly relatively long stretches with small aircraft, so that wind actually becomes a factor in the range and the actual time recorded at progressive waypoints in the flight log becomes a meaningful contribution to flight safety. (If the 5 knot tailwind that I currently have were to turn into a 35 knot headwind, I would run into trouble 4 hours from now).

During the few "emergencies" that I've encountered (airport closed after a 3 1/2 hour flight because I had read the wrong notam source; a vacuum pump failure at night; a landing gear problem that required manual extension) I was really glad to having adhered to that principle of flying around with 4 -12 gallons "too much". I'm a big fan of Rod Machado, and he is also advocating "landing with one hour of fuel".

If someone were to propose a regulation change that would lower the minimum fuel requirements, I for one wouldn't object. But I don't feel the urge to petition it myself. I wouldn't think Rod is sponsored by the oil companies either.


Is it possible that you're as nervous of "demonstrating your competence" to an EU examiner


I hope you're not questioning my competence here. Having demonstrated my competence to a JAA examiner in the past, I didn't find the experience particularly nerve racking. And it shouldn't, unless of course you're referring to that C170 chip on the shoulder nutter that Peter was talking about the other day.


And the requirement for an annual IR prof check affects a tiny proportion of the private flying population.


This is, as I've already told you, a bogus argument. Why do you think there are so few JAA IR private pilots ? Because the theoretical part of the training is expensive and to a large extent irrelevant. And because the maintenance is such a bother. In fact, if it weren't for the 700 hour conversion in the old days, the proportion of the private flying population affected would even be tinier.


In conclusion, I continue to find it strange that IAOPA, which would have more members if it took a more principled stance on trying to minimize regulatory burdens in the absence of valid evidence of a regulation requirement and on trying to harmonize Aviation Regulation worldwide, seems to accept annual examinations and air law exams as if it were the normallest thing in the world.

[mad_jock]

You lot are making the mistake yet again thinking any of this is to do with safety.

Its purely to get european residents flying with european licenses.

You can argue up down left right and even if you are right it won't matter a bollocks.

[Fuji Abound]

Mad Jock

That strikes a cord.

The older and more stupid I get the more I find myself finding we have these discussions here (and they are interesting) but do our discussions make any difference? Does anyone of note read them, and if they did do they have any influence what so ever on the process? I suspect they don't, so as interesting as it maybe, its all rather academic.

I think in so many walks of life people feel they are disconnected from the political process and to make matters worse I am not even sure this is a political process.

I hate to say it because I am a passionate believer in discussing and "fighting" to preserve our rights but I suspect all the debate on here will come to nowt. I campaigned fervently with regards the IMCr including using the good services of this forum and I think it kicked up enough discussion to be worthwhile but it takes a great of effort and has to go well beyond the type of discussions we usually have here.

So Proudprivate as interesting as it is I would caution you not to spend to many hours over the keyboard or expect much to come of the views you and others have expressed however sensible some of them may seem. If you want to achieve anything your time would be better spent in other ways (but expect to devote a great deal of it), but if you just enjoy the debate then all well and food. Whatever you do don't get wound up over it because most of it is for fun's sake, albeit some on here may get there fun from debating in different ways. ;) So whatever you do don't take it too much too heart and don't expect it to achieve very much if anything in the real Euro world

Sad to say but there it is.

[mad_jock]

Tis true Fuji.

The other thing thats laughable is that the pilots of europe are going to unite to save the rights of N reg pilots. When really most of us really don't give a toss if they get to fly or not.

We can disgagree or agree about the requirement of a nations right to oversee its own residents.

But the idea that pilots across europe are going to take a united front against EASA is in the planet Zanussi FIR.

You can't get 2 pilots to put a united front up against a urinal never mind bring a legal action. 3 pilots and then one of them will start pissing on the others shoes.

[peterh337]

I don't think discussing anything on any forum ever changes the political process, but it does raise awareness of an issue in the wider community.

There are plenty of people who are in positions to apply pressure in the right places, who would not have heard of it otherwise. Most of them don't post on forums. The countless emails I receive from other pilots are a witness to that.

Business jet pilots in particular are notorious for having their heads stuck in the sand.

When really most of us really don't give a toss if they get to fly or not.

You mean YOU don't give a toss if anybody else gets to fly or not. That much is self evident. Fortunately not everybody holds that position.

[Fuji Abound]

peterh337

Yes, you are right, I receive similar messages (particularly in the past in relation to the IMCr); there is no doubt some of our discussions do raise awareness. Having said that I think it does tend to be on the more subtle elements of legislation that are often intended to have far wider implications that at first blush might appear the case (lets see if we can slip this one through). The more obvious stuff is usually quite well picked up by AOPA and the other representative organisations.

Unfortunately Mad Jock is right for whatever reason pilots seem to be the most disconnected fraternity when it comes to mounting any sort of front as you and I well now with regards the IMCr. I have never understood entirely why, may be it is something to do with the mentality of too many pilots. Whatever the reason the community is a very easy target for the technocrats and in Europe despite some of the huffing and puffing quickly roll over. It is as you know a very different story in the States.

Sorry to be despondent.

[mad_jock]

Nope pretty much all of the 450,000 pilots in the EU don't give a toss because basically it doesn't effect them one little bit if the FAA pilots get shafted. For a very small percentage of Biz jet pilots it may allow them to either get a foot in the door if they are quick

I do give a toss though for

Permit aircraft
Microlights
Gliding
IMCr (and its replacement)

And the instruction of exercises 1-13 done properly for the PPL students in Europe.

[peterh337]

pilots seem to be the most disconnected fraternity when it comes to mounting any sort of front as you and I well now with regards the IMCr. I have never understood entirely why, may be it is something to do with the mentality of too many pilots.

It's indeed an interesting social phenomenon...

I think the explanation starts with anybody who wants to fly having to be a pretty obscessed individual - due to the grotesque over-regulation one has to put up with.

My son (16) more or less gave up getting on with the PPL, once he saw the contents of the books. I would say 90% of the stuff is not relevant to any form of aviation.

So only the most determined individuals make it through and hang in there long term.

The pressure continues through one's flying life. There are license renewals, medicals (every time you visit the AME you have no idea whether your aviation days will be over that day), and more fun for aircraft owners :)

Then you get the standard "volunteer organisation nightmare" whereby often the most obnoxious tend to rise to the top, because nobody else wants to (or is able to find the time to) do the job.

That's why there is so little social cohesion in GA.

You see (saw) the same thing in the communist regimes. Because everybody was under constant pressure (in the form of surveillance, even in the office, and general hassle through one's life, just making ends meet, etc) most people were quite ready to stab each other in the back to get any advantage. People in e.g. East Germany and Czechoslovakia were horrid towards each other.

[proudprivate]

Its about

- IAOPA representing a specific point of view as regards ICAO conversion and annual re-examination, which I could understand if it came from the "National Association of Examiners" but not from them.

- The need for regulatory burden relief for pilots and the overarching necessity to consider cost vs benefit (Mode S, 8.333 kHz, Part M etc in Europe, but also semi-annual medicals for FAA ATPs (although that is not related to private flying) and medicals "tout court" for private flight)

and to a lesser extent

- the ICAO wide regulatory harmonization effort.

It is not about

- the effects of the implementation of part FCL on EU resident operators.

[mad_jock]

It is not about

- the effects of the implementation of part FCL on EU resident operators.

But it is, its all part and parcel of the grand plan.

Get the legislation through on a promise then ensure that the condition can never be met.

To get what you want would then allow the critiria to be met for a one to one transfer which will never happen come hell or high water.

Give it 10-15 years and the numbers of N reg based in europe reduced to a small fraction of what it is just now there maybe some agreement. But I doudt it because the yearly check is pretty enshrined in the way things are done in Europe. Just like doing a high content of theory.

[Fuji Abound]

I thought it was about the four pages of discussion as to why we should or shouldn't have check rides or hop through other regulatory hoops because you (and others) consider the hoops have no safety benefits nor any other good reason for the hoops to be there in the first place.

I was simply pointing out that you shouldn't spend too much time on the discussion in the expectation of changing anything because it is already very well rehearsed and very unlikely to change any time soon. Aviation is full of hoops and guess what the regulators will probably go on creating a few more, because if they don't they wont have a job!

So as I said earlier enjoy the discussion for discussion sake but don't fall out with anyone over it or get upset. If you really want to achieve anything you will need to go about it another way. If you do (go about it another way) I wish you the best of luck.

[bookworm]

The impression comes in part from your trivialising the debate on cost benefit with making dismissive remarks style "So it has to be the FAA way, huh, well that just doesn't wash" that convey an impression of anti-americanism. The impression was fuelled many months ago with your rants about US congressional protectionism.

For what it's worth, I remain convinced that the EU needs an independent regulatory system, because the FAA has the dual mission of both regulation and promotion of US aviation interests. To allow the FAA to dictate regulation globally would be akin to allowing the Yankees to write the MLB rulebook (Home runs now count double -- because the fans want it, of course, not because it favors the Yankee lineup, no sir ;) )

That doesn't mean that we shouldn't learn the lessons of a much larger aviation market, particularly for GA. But there are social, political, economic and structural factors that affect the insights gleaned.

The topic of this discussion is IAOPA seemingly accepting a need for annual re-examination, which I find difficult to understand, let alone underwrite.

Cost-benefit rears its head not just in optimal regulation, but also in optimal lobbying. There's an element of realpolitik, and it might be better to strive to drive down the cost of examination rather than try to change the examiner/instructor roles. I also remain convinced that there is merit in separation, but not at the expense of creating, as you put it, an oligopoly.

I hope you're not questioning my competence here. Having demonstrated my competence to a JAA examiner in the past, I didn't find the experience particularly nerve racking.

I was questioning your confidence, not your competence. I think you make too much of the difference between a prof check and a flight review.

This is, as I've already told you, a bogus argument. Why do you think there are so few JAA IR private pilots ? Because the theoretical part of the training is expensive and to a large extent irrelevant. And because the maintenance is such a bother. In fact, if it weren't for the 700 hour conversion in the old days, the proportion of the private flying population affected would even be tinier.

The disincentives are the TK and the very long flight training course for those who may already have good skills. Maintenance costs (beyond the sensible requirement to stay current) are minimal in the context of most EU-based IR pilot's flying spend.

In conclusion, I continue to find it strange that IAOPA, which would have more members if it took a more principled stance on trying to minimize regulatory burdens in the absence of valid evidence of a regulation requirement and on trying to harmonize Aviation Regulation worldwide, seems to accept annual examinations and air law exams as if it were the normallest thing in the world.

I don't think you'd say that if you'd read the joint EAS/IAOPA submission on regulation of GA and the corresponding working group paper for the EASA Management Board (which is being finalised today I think). But if I were running such an organisation, I'd be thinking about the value to my members of a principled loss compared to a compromised win based on the art of the possible.

[peterh337]

I remain convinced that the EU needs an independent regulatory system, because the FAA has the dual mission of both regulation and promotion of US aviation interests. To allow the FAA to dictate regulation globally would be akin to allowing the Yankees to write the MLB rulebook

Yet, that argument is totally spurious because the fact is that the FAA does not abuse the system.

The FAA provides US-taxpayer-subsidised "more or less everything"... pilot licensing, aircraft and equipment certification, certification of modifications, you name it.

Nearly all of it is totally free. I have just got an FAA FSDO to approve a custom AFMS for my GPS, allowing me to fly GPS approaches. (The aircraft was always OK; it was just a paperwork exercise, which 3 or 4 UK avionics shops failed to achieve in past years). Cost to me? Zilch. Well, I had to pay the UPS document return cost because a got a friend out there to present it on my behalf. Before that, I got a fairly nontrivial EHSI installation (http://www.peter2000.co.uk/aviation/sn3500/index.html) approved, also free. In EASA-land, that would have been into 4 digits, as a starting point. With certain negatives (hassle, in essence, unless you have "contacts" out there) this great system is accessible to FAA pilots worldwide.

If you were to call that "promotion of US aviation interests" then please can I have some more! Let's shut down EASA while we are at it; it doesn't do anything useful, despite pretending to preserve "safety" in this little corner of the globe.

Instead, EASA abuses the ICAO licensing/certification system. It is staffed by people who ostensibly do their best, and this may be true for the most part at the individual level where I dare say they believe in their mission, but the organisation as a whole is set up to deliver a gold plated system which is for the most part not based on safety data or any other evidence, and is particularly set up to channel business to a small number of EASA Part 21 approved companies, who are able to make nice money out of certification, and out of developing EASA STCs which are their "intellectual property" even though they are almost totally based on stuff immediately found in the FAA approved installation manuals...

EASA also runs some heavily and completely unashamedly politically motivated agendas... discussed here already.

[mm_flynn]

... But I doudt it because the yearly check is pretty enshrined in the way things are done in Europe. Just like doing a high content of theory.

And I think that is the nub of the issue. An important fraction of the European aviation community likes the 'high touch, high cost' approach to aviation in Europe and are not at all fussed that it results in a system with higher intrinsic cost, lower utility, and generally worse safety records. But, it has rigour!

I think that despite the protestations by many as to the lack of objective basis the European position, poor cost benefit, comparable alternative approaches, etc. Some aspects of this are so deeply entrenched in the regulatory mind set that it would be reasonable for an organisation such as IAOPA to conclude they can not be shifted for any feasible amount of money are effort. As such, you conclude that any attempt to achieve a bi-lateral agreement that exempts certain pilots based in Europe from one of these touchstones (the annual revalidation) is going to sink the greater project.

I am only an observer, but in all my time in Europe, I have seen almost no evidence of European organisations rolling back the level of cost/intrusion of regulation and as such, agree IAOPA's approach is pragmatic. The list of onerous regulations is long and an annual flight review is not that high up the list in my book.

[mad_jock]

I am of mixed feelings about it.

If I had never heard of anyone failing said check I would be quite happy to say bin it.

But you do hear of people failing the check.

In the twin world you do need a practise at the single engine stuff. I certainly don't begrudge doing my 6 monthly checks but yet again I don't pay for them.

[Pace]

MadJock

Other than with the N reg issue I am sure we would get on extremely well. Your attitude on this is sad and misplaced.
You take the attitude of a football team supporter of them and us rather than US or what is in all our best interests in aviation so that we have a thriving industry.
You and many others have for a long time had a misplaced snobbish attitude to JAA licences (they have to be harder and far more expensive so that makes us the Elite of worldwide pilots far superior to anything out there.Every other licence authority churns out sub standard pilots.)
Sadly the reverse has been shown to be the case and no statistical evidence can back up to european training and burcratic interference equalling better standards.
So my friend stop being a football hooligan and realise where the real threat to your livelyhood comes from! It is not the FAA but your beloved EASA.
Your point re european pilots should fly European licences? Any sensible person would have taken the opporunity that EASA had and made things so attractive that no one would want an FAA reg aircraft here in Europe.
Yes you may win out in the end and have a regulation and burocratic riddled industry with no more than people carriers gracing our skies and you will state with glee that you won but sorry mate we all will have Lost.

Mad Jock this is what you are fighting for to create

The airline industry - in serious financial trouble - Public Service Europe (http://www.publicserviceeurope.com/article/2082/the-airline-industry-in-serious-financial-trouble)

Pace

[bookworm]

Yet, that argument is totally spurious because the fact is that the FAA does not abuse the system.

Of course it doesn't. Because it can't. But if the US becomes the country that writes the world's aviation regulation, it can and will abuse that position to the competitive advantage of US industry. Not because it's evil, but because it can, and it's not stupid. It's the role of a government.

[Pace]

Of course it doesn't. Because it can't. But if the US becomes the country that writes the world's aviation regulation, it can and will abuse that position to the competitive advantage of US industry. Not because it's evil, but because it can, and it's not stupid. It's the role of a government.

Bookworm

Is not the biggest abuse of the system and crusher of competative advantage strangulation of the aviation industry caused by excessive regulation and burocratic intervention as well as any political and tax loading to pay for a big brother state?

Surely in any free market the market dictates? create freedom for that market and the competativeness comes naturally.

Was it not the Mrs T policy to load industry with the least amount of government and state intervention as possible now its gone the other way with maximum government intervention and needless interferance in every walk of life all costing the industry a strangling fortune and the very reason Europe is collapsing like a pack of cards? We cannot afford all that expensive rubbish anymore.

As for competativeness why do you think any labour intensive production goes to places like China India etc. With that argument you may as well put trade blocks to imports from those areas

Pace

[bookworm]

Is not the biggest abuse of the system and crusher of competative advantage strangulation of the aviation industry caused by excessive regulation and burocratic intervention as well as any political and tax loading to pay for a big brother state?

Yes.

Surely in any free market the market dictates? create freedom for that market and the competativeness comes naturally.

Yes, with caveats about the nature of the market. But we don't have a free market. We don't have a free global market. We don't have a free market between the USA and the EU. We don't even have a free market within the EU if different states play by different rules, which is the motivation for standardisation of rules at the EU level.

Was it not the Mrs T policy to load industry with the least amount of government and state intervention as possible now its gone the other way with maximum government intervention and needless interferance in every walk of life all costing the industry a strangling fortune and the very reason Europe is collapsing like a pack of cards? We cannot afford all that expensive rubbish anymore.

So "Europe is collapsing like a pack of cards" because the banks were overregulated?

[peterh337]

But if the US becomes the country that writes the world's aviation regulation, It already is, and always has been.

The bulk of EASA regs are FARs, copied/pasted, usually (not always) with the paragraphs renumbered :)

it can and will abuse that position to the competitive advantage of US industry. Not because it's evil, but because it can, and it's not stupid. It's the role of a government.Yet there is no evidence of the USA ever trying to cripple European plane makers by writing the FARs to suit its own makers.

It is EASA that has done that, by blatently defining "complex" to be (IIRC) > 18 seats, or ME turboprop, or jet, which lets in the TBM and the PC12, while sticking a finger up to Beech's King Air. If Europe had a light jet industry, EASA would not have done that, for sure. Diamond's SE jet has been stillborn for years... not a shock given its MTOW being > 2T and its certified ceiling of FL250 :E

The FARs have been pretty much fixed for donkeys years, with the meaningless 12500lb (5700kg) limit for a Type Rating, etc. The USA doesn't change things for the sake of it. If it works, they usually leave it.

The rest of the world, including the darkest Africa, runs its own CAAs, and if you didn't like the FAA, and there was no EASA, and Europe's CAAs contracted certification to the FAA, you could always reg your plane in the People's Democratic Republic of Upper Volta, etc.

But the fact is that Europe has always had its own certification regime so how exactly could the USA change its FARs to suit US business? You can fly a Euro-reg plane worldwide, if you have matching pilot licenses, and that includes keeping it on US soil. The reason why almost nobody keeps Euro-reg planes on US soil is because they would fail their next medical (lack of a brain).

If the USA was to ban Airbus selling in the USA, or selling to the US military, it would be due to bribery of US officials by Airbus.

This discussion is worse than the similarly contrived argument for Galileo.

So "Europe is collapsing like a pack of cards" because the banks were overregulated? The EU is collapsing because career-focussed Euro politicians who could not see past the end of their noses created the Eurozone, invited the southern countries to join it even though everybody knew it would wipe out the little export business they had, and the southern countries did the obvious thing which was to borrow billions at ~1%, which they could do because everybody "knew" that Germany would always pay it off (and anyway the bankers got their bonuses early so a later default wouldn't matter) and they had a huge mexican party (http://www.partyrama.co.uk/mcp/Mexican_Fiesta_Party_Supplies.html) with it :E ... oh and bought a few tens of thousands of German cars while they were at it. Germany paid massive bribes (http://www.focus.com/briefs/bribery-scandal-siemens-ag/) to lubricate business down there, too, which probably didn't help. Come to think of it, they did the same in the USA too.

[mad_jock]

As I said if nobody ever failed it I wouldn't have an issue with it being by experence.

But I do know of several people who have failed it while doing way more than the minimum experence that is required by the rolling setup.

I really haven't lost anything. And its only a very very small amount of the 450 000 pilots in the EU that this is going to be even a passing glance for.

Either way it is going to have zero effect on my life.

I have never had an issue yet getting my JAR license either converted or validated and like it or not it is seen as a gold standard in alot of places especially a UK one.

[bookworm]

The bulk of EASA regs are FARs, copied/pasted, usually (not always) with the paragraphs renumbered

And if they all were, you wouldn't be so pissed off, would you? ;)

It's not about them all having to be different, it's about having control.

Clearly, I'm not going to convince you of the rationale behind the need for EU aviation regulation. So you'll just have to continue believing that it's all the fault of corrupt and stupid EU politicians, many of whom have a personal vendetta against you. Good luck if you're right.

[peterh337]

Yes; Italy has a lot of industry, especially chemicals. I buy acetal resin in a custom shade of green from there, 2000kg at a time :)

I think Italy is really what Germany is worried about; Spain a bit less, and the rest much less...

The euro has damaged everybody down there. Bizzarely, it is currently in Germany's interest for the eurozone to be packed with virtually bankrupt countries, because that keeps the euro weak and enables Germany to export. What Germany doesn't want is a resolution to the crisis, either way. It doesn't want the zone to go actually bankrupt and need bailing out, and likewise it doesn't want the zone to strongly export-recover as that would revalue the euro and make German exports less competitive - as would a shrinkage of the euro to the north only.

450k pilots in the EU? Only if you count kites, MJ, and kitesurfers. The UK has the biggest GA scene, about 20k pilots with valid medicals (CAA figure), along with Germany which is probably similar. France #3, the rest of Europe much less. 450k is nonsense.

[Pace]

Peter/ Bookworm

The commission and other EC bodies are unelected while up to now have had powers they should not have had.
There have been recent changes which has given those powers back to the EC Parliament.
That is the reason AOPA have employed a full time Lobbyist in the last few weeks.
Anone know anything about this and the likely impact it could have?

Pace

[mad_jock]

Know nothing but think its to late to change things.

The faceless ones that have been driving this have had ten years which to plan and fine tune there process.