Six sittings to pass all the PPL exams

[Mickey Kaye]

Just reading the revised Standards Doc 11 issued 19th December and section 2.10.6 page 10 states

"The applicant is allowed six sitting to pass all examinations. A sitting for the PPL and LAPL is defined as the attendance at an examination centre for the purpose of taking or writing a single or set of examinations in one day. Only one attempt at each paper may be made in any one sitting"

Is this new or have I missed this in the past? Seems a bit silly to me.

And SRG2155 Respect of failure of theoretical examination has mutated into a rainforest. Two pages and three copies are needed. Was the wheel broken before?

[Whopity]

The 6 sittings is a new EASA FCL.025 requirement. FCL-025 (3) If an applicant has failed to pass one of the examination papers within 4 attempts, or has failed to pass all papers within either 6 sittings or the period mentioned in paragraph (2), he/she shall re-take the complete set of examination papers.
The CAA now propose 9 examination papers. They don't however seem too concerned about this requirement:
AMC1 FCL.215; FCL.235
THEORETICAL KNOWLEDGE EXAMINATION AND SKILL TEST FOR THE PPL
(a) Theoretical knowledge examination
(1) The examinations should comprise a total of 120 multiple-choice questions covering all the subjects.So much for "STANDARDISATION"! The RT practical appears to remain separate and presumably, is not considered in the term "all"!

Stds Doc 11 V10 was only issued in October and in less than 2 months has had to be replaced with V11! Is it any wonder that nobody can keep up.

The CAA never mastered the administration of F252s so what chance for the 2155 especially as many PPL students do not have a reference number!

Reading Doc 11 para 2.12.6 it states that a candidate who fails the 4th paper will have to resit all PPL Exams at Gatwick or a CAA Exam Centre. They do not appear to have invented a form for this one yet. SRG 2165 only caters for the 4th attempt. The cost of the resit £350 for 7 papers or £450 when they go to 9 papers. Will an ATO want to administer this process as they won't derive any income from it, will it be left to the candidate or will the CAA administer it until completion?

[AOJM]

Air Law and Operational Procedures is now split I hear? So you sit the same exam but gain two certificates? Odd because no papers have changed and that would bring it up to 8 examinations surely.

[Cows getting bigger]

I'm pretty close to giving up with all this nonsense. We are now at a point where we are questioning how many exams a PPL student should take. FFS! Many of the papers are so out of date the subject matter is irrelevant. (When did the UK get rid of RAS, RIS and FIS?).

Pick an SRG application form and it is three time bigger than it ever used to be and is probably wrong.

Ask a TI for an opinion on something (that is if you can ever get hold of one) and he won't give you one before telling you how overworked he is. You may be lucky and get an answer - it is a 50:50 whether he is right.

Try to get an ATO approval variation and expect a long long wait; I suggest a year's sabbatical, that is if you have the cash because you paid the CAA up front.

Wait at least two months for a licence to be turned-around. It will be wrong. You will be issued a seaplane rating when you applied for a helicopter CPL.

Pay in time and money for any mistakes you make on an application (yes, those same long-winded irrelevant forms which don't even use correct grammar - "proceeding" instead of "preceding"!). Of course, it was an acceptable oversight the other day when I received a regarding my ATO which quoted a wrong approval number and confused me with a third ATO some two hundred miles away!

Take a step into the more exotic stuff (you know, class/type ratings, examiner authorizations etc) and things get even worse. Speak to a helicopter guy and you wonder why he hasn't considered a kamikaze attack on Gatwick!

Enough is enough. It is time for the GA industry, especially those involved in training, to get together and publically tell the CAA that it is completely failing. Which bit of "your're killing us" are they not getting? They are a bleedin' shambles and the timerity behind the latest scheme of charges consultation(?) is astounding.

[Whopity]

Perhaps you should contact the Chief Sandwich Maker Dame Deirdre who by her own admission admitted she knew nothing about aviation or the Chief Executive who left the disaster at South West Trains.

A letter to Dame Deirdre from the Philip Hammond Secretary of State here (http://www.caa.co.uk/docs/286/Feb2011Objectives_signedfinal.pdf). If she's not hacking it perhaps he's the person to inform!

[Cows getting bigger]

Perhaps I should. Looking at my iPhone enabled rant of earlier just reinforces my view that the whole affair is so frustrating and suffocating from an industry perspective.

Hammond's letter to Deirdre makes interesting reading.

[40&80]

I converted my FAA ATR licence to a UK ATPL in 1975...later having observed the newer CAA organisation staff at Gatwick compared to the staff they employed at the Strand in London...well... I never bothered with my British licences ever again..too much hassle and too expensive.

[turbine100]

Perhaps make a compliant via the ombudsman for public bodies?

The CAA is listed as a government organisation to file against. Below is the link for raising compliants.

Welcome to the Parliamentary and Health Service Ombudsman (http://www.ombudsman.org.uk/home)

Also heard that some organisations would like to tryand get a government review of the CAA due to their services and pricingincreases.

[Whopity]

A Parliamentary Review of the CAA took place in 2006 details are published here (http://www.caa.co.uk/docs/33/Strategic_Review_Fact_Sheet.pdf) But, that was 6 years ago and if we were to subtract the numbers of competent professional staff who have left since then, the picture would look very different today.

The most striking issue evident from the bungled paperwork and information they circulate is that nobody is in charge; nothing is checked before release and there are a number of loose cannons firing in different directions. In many departments there is no relevant professional knowledge or experience between the workface and the Chairman who by her own admission knows nothing about aviation. She can be looked up under Queen of Quangos (http://www.air-passenger-rights.co.uk/dame-deirdre-hutton-cbe-queen-of-quangos-or-fingers-in-too-many-pies/)!

[S-Works]

They are piling incompetence on top of ignorance.

I have a situation with one of our pilots who is transferring his licence from another EU country to the UK. Story is that he is old school pre JAA. When his country became JAA he was grandfathered and then subsequently grandfathered into FCL. So holds a full current Part FCL licence which he fly's for us on now.

CAA are requesting copies of his JAA FCL CPL exam results before they issue his new licence!! I pointed out that as he never did JAA exams how is he supposed to provide the exam results!

[Mickey Kaye]

Perhaps what worries me most is that they are so out of touch with the industry.

It’s been obvious for some time that the current questions are out of date and I would also question some of the content. What year was the Chicago convention – WTF has that got to do with safety?

I also felt that what was actually needed was the exams to be streamlined rather than increased in number.

At present the CAA actions are hitting my bottom line and I am seriously concerned that this will only increase over the next few years.

[Whopity]

I doubt that AOPA have made any representations to the CAA regarding exams since Des Payton tore up the AOPA agreement over 15 years ago! By only claiming to deal with them, the CAA are able to put the telescope to their blind eye and say "I see no ships" How convenient!

[Whopity]

AOPA administered the PPL Exams, the Flight Tests and appointed and controlled all PPL Examiners through the medium of the Panel of Examiners made up of FIEs. When the agreement was torn up, control of the Panel of Examiners moved from Capt Paddy King at the Bournemouth Flying Club to the CAA CFE in the Tower. A few years later the Panel faded away.

PPL Examiners used to issue pink chits to candidates when they passed and the counterfoils all went back to AOPA. Rumor had it they all finished up in Ron Campbell's garage! One or two examiners didn't bother!

[BillieBob]

It would appear that the UK CAA is in breach of EU law:
ARA.GEN.200

(a) The competent authority shall establish and maintain a management system, including as a minimum:
(1) ....;
(2) a sufficient number of personnel to perform its tasks and discharge its responsibilities. Such personnel shall be qualified to perform their allocated tasks and have the necessary knowledge, experience, initial and recurrent training to ensure continuing competence. A system shall be in place to plan the availability of personnel, in order to ensure the proper completion of all tasks;

So, perhaps someone should help them to comply with at least this bit:
ARA.GEN.125


(a) The competent authority shall without undue delay notify the Agency in case of any significant problems with the implementation of Regulation (EC) No 216/2008 and its Implementing Rules.
Of course, any means of doing this is a well kept secret - we can't possibly allow anyone to hold us to account!

[MrAverage]

OK. I've read the relevant sections of Standards Doc 11 and FCL-025 over and over, several times, to try and make sense of this 6 sittings thing. I've also discussed it with others who seem to read it differently. (I have to warn you that, although I managed Level 6 proficiency, I didn't get further than O level English)

The way I read it, if Bloggs fails Air Law on Monday and then passes it the following Monday, having not attempted any other subjects before or on either of those two days, he's used up two of his 6 sittings. He then has four full days left to pass the remaining six exams.

If, say, he then fails Nav twice - again having not taken any other subjects on those two seperate days - does he only have two sittings (days) left to pass those remaining six?

[keith williams]

The way I read it, if Bloggs fails Air Law on Monday and then passes it the following Monday, having not attempted any other subjects before or on either of those two days, he's used up two of his 6 sittings. He then has four full days left to pass the remaining six exams.

If, say, he then fails Nav twice - again having not taken any other subjects on those two seperate days - does he only have two sittings (days) left to pass those remaining six?

This whole matter depends upon what exactly will be the definition of a "Sitting".

You appear to be assuming that a sitting will be defined as "One visit to the examination room". If this really is the intention, then it will obviously cause the kind of problems that you have described in your post.

For many years JAR ATPL students have been required to pass 14 exams within 6 sittings. In the UK the exams were presented by the authorities in four-day blocks during the first week of each month. A sitting was effectively defined as "One examination week". This meant that 6 sittings added up to 24 examination days. This made it much easier to pass all 14 within 6 sittings, although some candidates failed to do so.

The new PPL system is clearly largely a copy-and-paste job based on the existing ATPL system. But the authorities do not appear to have thought it through very well. In the case of PPL exams for example the authorities do not manage the running of the exams, and it is unlikely that there will be any regular timing (such as once per month) for them.

I have not yet seen an approved definition for a "PPL exam sitting" but it is unlikely to be a single visit to the examination room.

[MrAverage]

Thanks Keith.

Rightly or wrongly I understood a sitting to be one day from this line in Standards Doc11:

"A sitting for the PPL and LAPL is defined as the attendance at an examination centre for the purpose of taking or writing a single or set of examinations in one day."

I sincerely hope my understanding is wrong.............

[keith williams]

I must confess that I hadn't previously seen that definition.

It looks like the "enthusiasts" who are putting this stuff together were not content that they had dug themselves into a deep enough hole.....so they kept on digging.

I understand that there is also to be a limit of four attempts at each exam. Based on the intended 9 exams this gives a total of 9 x 4 = 36 attempts. Trying to squeeze 36 exam attempts into 6 days is being a bit a bit optimistic.

Candidates chances of passing will now be maximized by going to a school that provides very long examination days.....18 hours or so.

[keith williams]

This guff is written for Euroland, where you have to go to a local CAA examination centre to do even the PPL exams. In Ireland, for example, you can only sit them once every two months.

Here is the UK they can of course be taken at the convenience of a student with an examiner who is the CEP at the local club.

You are of course correct in saying that "This Guff is written in Euroland", but the Standards Documents are the products of the UK CAA.


A "sitting" has always been accepted at JAR as being a one week period, so it would be be quite possible for someone to sit 3 or 4 exams in a week and use up only one sitting.

That was true in the past, but according to the latest version of Standards Document 11 (issued by the UK CAA in December 2012)

"A sitting for the PPL and LAPL is defined as the attendance at an examination centre for the purpose of taking or writing a single or set of examinations in one day."

As far as I can recall this definition was not in the previous version. The authors appear to have tarted up the document by adding some of the new EASA stuff.......Probably without considering the consequences.

If the CAA staff are awake (unlikely I know) they might well look at a PPL application form and reject it if the exams are spread over more than six individual days.

[BEagle]

Re. exams, from the AMC &GM:

AMC1 FCL.025 Theoretical knowledge examinations for the issue of licences

TERMINOLOGY

The meaning of the following terms used in FCL.025 should be as follows:

(a) ‘Entire set of examinations’: an examination in all subjects required by the licence level.

(b) ‘Examination’: the demonstration of knowledge in one or more examination papers.

(c) ‘Examination paper’: a set of questions to be answered by a candidate for examination.

(d) ‘Attempt’: a try to pass a specific paper.

(e) ‘Sitting’: a period of time established by the competent authority within which a candidate can take an examination. This period should not exceed 10 consecutive days. Only one attempt at each examination paper is allowed in one sitting.

AMC1 FCL.215; FCL.235

THEORETICAL KNOWLEDGE EXAMINATION AND SKILL TEST FOR THE PPL

(a) Theoretical knowledge examination

(1) The examinations should comprise a total of 120 multiple-choice questions covering all the subjects.

(2) Communication practical classroom testing may be conducted.



So why hasn't the CAA complied with this....:hmm:

[keith williams]

So why hasn't the CAA complied with this

They probably haven't even read it! But if challenged their reply would probably be "well one day is not more than 10 days, so it complies with the EASA definition".

But even if they sort out the definition of a sitting there are more problems ahead. For example;

(1) The examinations should comprise a total of 120 multiple-choice questions covering all the subjects.

Some people have interpreted this as meaning that the 9 new exams will be made up of a total of 120 questions. That's an average of 13.3 questions per exam. That is a massive decreases compared to the number of questions in the current exams.

An alternative interpretation might be that each exam will be made up of 120 questions, covering all of the subjects in that exam area. But this will be a massive increase compared to the number of questions in the current exams.

I wonder if the "enthusiasts" who came up with these new rules ever asked themselves "What exactly is wrong with the number of questions in the current exams?"

[keith williams]

The document below was issued by EASA some time before December 2012

AMC1 FCL.025 Theoretical knowledge examinations for the issue of licences

(e) ‘Sitting’: a period of time established by the competent authority within which a candidate can take an examination. This period should not exceed 10 consecutive days. Only one attempt at each examination paper is allowed in one sitting.

The new Standards Document 11, which included the material below was issued by the UK CAA in December 2012. So we can assume that it is the UK CAA interpretation of the EASA document.

"A sitting for the PPL and LAPL is defined as the attendance at an examination centre for the purpose of taking or writing a single or set of examinations in one day."

The UK CAA "One day" definition is within the limits set by the EASA "10 days" definition, so it conforms with the new rules.

As Beagle says, a sitting can be up to 10 days...so the whole sittings thing becomes a bit meaningless.

That is true only if the competent authority has established 10 days as their definition. But the UK competent authority (The CAA) has selected one day as the duration of a sitting.

I suspect that this will turn out be like so much of the other material in the standards documents....the CAA will publish it, but they will take on action to enforce any of it.

[Whopity]

but they will take on action to enforce any of it. More to the point how could they take any action to enforce it when examination papers are handed out to organisations to run themselves.

Lets say Blogs sits 2 exams on Friday and 2 on Saturday; does that constitute 1 day? A day is 24 hours, unless you specify a calendar day, and if the exams are all taken within that period the requirement has been met, but the dates will be different! Of course there may be some fine penciling and who would ever know? There could be the exam failed which is quietly forgotten about and another paper given. It all happens! If the student subsequently killed himself or someone else, the examiner would then by liable to get 6 months, which seems to be going rate!

Unenforceable rules are pointless rules!

[Level Attitude]

when examination papers are handed out to organisations to run themselves
No they're not. Exam papers are only issued to one person (the nominated
"Custodian of Exam Papers") who must be an authorised Ground Examiner.

Blogs sits 2 exams on Friday and 2 on Saturday; does that constitute 1 day
A sitting is defined as attendance at an Exam Centre for one day. If Blogs
goes home and comes back in morning then that is two attendances, and
therefore two sittings.


Unenforceable rules are pointless rules!
They are enforceable by 1) The ATO/Examination Centre and
2) The Ground Examiner

What you are saying is that you think the CAA have to police ATOs and
Examiners activities because these organisations/people are not capable or
trustworthy.

In that case the CAA should not delegate out this function but rather run
PPL Ground Exams themselves at set Centres on set dates.

[BEagle]

A sitting is defined as attendance at an Exam Centre for one day.

That might be the CAA's gold-plated interpretation, but it is NOT the EASA definition!

AMC1 FCL025 para e):

(e) ‘Sitting’: a period of time established by the competent authority within which a candidate can take an examination. This period should not exceed 10 consecutive days. Only one attempt at each examination paper is allowed in one sitting.

[keith williams]

a period of time established by the competent authority within which a candidate can take an examination. This period should not exceed 10 consecutive days.

Well this all comes down to who is the "competent authority". I believe that it is the national aviation authority in each member state. The CAA here in the UK.

If I am correct, then the above quote is EASA giving the UK CAA the authority to define the term "sitting" for use here in the UK, subject to a maximum duration of 10 consecutive days. This means that the "one day" definition has the authority of both EASA and the UK CAA.

If the term "competent authority" does not mean the national aviation authorities in each member state, what does it mean?

[Level Attitude]

As KW points out the CAA have not put a "gold-plated" interpretation
on anything - they meet the exact EASA definition.

For PPL a sitting = 1 Day
For ATPL a sitting = 4 Consecutive Days (Mon - Thurs)

Why did EASA specify a sitting should not exceed 10 consecutive days?
(Remember this rule applies to theoretical examinations at all levels)
Possibly because, previously, some countries were allowing candidates to
take one ATPL exam a week and this was deemed to be too easy and
hence not a true reflection of knowledge gained.

For PPL candidates the only real difference, compared to JAA, is that they
should study so that they can take at least two subjects in one day.
(plus, I seem to remember, candidates have to be "put forward" for exam
by their ATO/RF so their knowledge will need to be checked prior
to actually sitting any exam(s).

[BillieBob]

Whatever the merits (or otherwise) of the requirement, it must be taken in the context of PPL training & testing throughout Europe. In all other EU member states (as far as I am aware) the PPL examinations are run by the national authority and, in this context, the requirement for all exams to be passed in 6 sittings is of little consequence.

The Aircrew Regulation was always going to be a compromise, with some States' opinions winning in some areas and nobody entirely satisfied. In the case of the PPL theoretical knowledge examinations, it was clearly not the UK's position that prevailed, not least because the CAA was unique in the way that PPL examinations were handled. In fact, it was pretty unique in the way that it generally ignored PPL training organisations unless or until they drew themselves to its attention (I'm not sure there's another authority in Europe that would have had to admit that it had no idea how many RTFs there were in operation!). The fact is that the resulting text satisfied the majority of member states and is now EU law - the UK will just have to live with that.

Given the requirements for PPL training organisations to become ATOs, it will be quite simple for the CAA to require that the management system documentation includes a process for managing theoretical knowledge examinations. The management process having been approved by the competent authority, continued compliance will then be a subject for audit and a requirement of continued approval. After all, there is already a requirement for the ATO to provide 100 hours of theoretical knowledge instruction and, before recommending him/her for the examination, to confirm that all elements of the training course have been completed to a satisfactory standard.

My understanding is that the 9 exams are currently in course of production and are due to be introduced in March/April, despite not being in compliance with the Regulation. It is also rumoured that plans are well advanced to do away with the current system of designated custodians and to centralise the PPL examination process, possibly on-line, which will better enable the monitoring of attempts and sittings, not to mention the security of the examination papers.

[BEagle]

It is also rumoured that plans are well advanced to do away with the current system of designated custodians and to centralise the PPL examination process, possibly on-line, which will better enable the monitoring of attempts and sittings, not to mention the security of the examination papers.

As many RFs and ATOs charge for the exams, any change in the current system will surely require a RIA - given that it will directly affect the organisation's income stream?

As for any computerised system being more 'secure', it would only take a few people to take screenshots before the security was compromised.....:\

[Whopity]

If the term "competent authority" does not mean the national aviation authorities in each member state, what does it mean?
From Part FCL:
FCL.001 Competent authority
For the purpose of this Part, the competent authority shall be an authority designated by the Member State to whom a person applies for the issue of pilot licences or associated ratings or certificates.
And the exams can be taken in a State other than the one that issues the licence.

[Whopity]

What you are saying is that you think the CAA have to police ATOsNot at all. I am saying that the current rules are no more enforceable than the previous ones. You don't have to look far to see the anomalies.

An online exam system would be more preferable and those who administer them could charge a sitting fee however; that would require a decent question base which could be EU wide, but that's a step too far as it involves dirty words like standardisation; heaven knows someone will want to standardise the flight training next.

[Level Attitude]

A "sitting" should be sufficient to sit all the exams in one go

That's rather sensible and logical (and complies with EASA).

Unfortunately it is not law as EASA says a "Sitting" is a period of time
for a candidate to take an "Examination" not for them to take
an "Entire set of examinations".

Maybe CAA thought one (very long for the candidate) day was sufficient
to take all PPL exams?

Maybe they thought it didn't matter if a PPL candidate, who wanted to
take all their exams "in one go" used up 2 or 3 sittings - as it still left at
least 3 more should they not be successful in any paper(s)?

Maybe they haven't considered it at all and a Ground Examiner should suggest it to them?

[keith williams]

For the purpose of this Part, the competent authority shall be an authority designated by the Member State to whom a person applies for the issue of pilot licences or associated ratings or certificates.

So for the UK the competent authority is the CAA. This means that their "one day" sitting is legal.


A. Maybe CAA thought ........
B. Maybe they thought........
C. Maybe they haven't considered...

I'd go for option C every time!

[Whopity]

Sorry, you have to have Four Answers

D. All or none of the above

[keith williams]

The CAA have been looking at using online exams for the ATPL/CPL exams for at least four years.

Don't hold your breath.

[Whopity]

As one of the EU objectives is to avoid duplication surely any on-line exams would have to be operated by EASA; that would blow the CAA out of the loop and there would be one price across Europe.

[Mickey Kaye]

and that would be even better the same exam for the whole of Europe.

but what we really don't want is what i suspect we are going to get is nine ppl exams

[2close]

As one of the EU objectives is to avoid duplication surely any on-line exams would have to be operated by EASA; that would blow the CAA out of the loop and there would be one price across Europe.

This history is that one of the remits of EASA was to centralise ALL professional examinations under the control of one body, which would be legally RESPONSIBLE and LIABLE for the security of the question bank, thus avoiding a repetition of the JAA CQB debacle.

The invitation to tender went out to industry for a very lucrative contract (100 Euros per question) to produce an initial database of 10,000 questions with the ultimate aim of providing 30,000 questions within 3 years. The short list of two was finally decided in favour of a European mainland software company NOT directly involved with training but who have experience in database development and management. The system was to be centrally managed with all national aviation authorities managing their own students locally in terms of provision of examination rooms etc but the control of the exams would lie with the contract winner.

They produced an initial trial database of approx 1,000 questions, with a very strict quality control process to ensure compliance with the Learning Objectives and then...............drum roll.............EASA turned around to the EU Transport Minister and said,"Err, can we have some more cash please?". "What have you done with the load we gave you last week?". "Err, we've spent it?" "FFS, on what?" "Bratwurst mit pommes weiss und ein grosses Bier.....oder funf.......no sorry, on re-writing all of JAR-FCL and all the other JARs". "That's not what we told you to do, now, is it?" "Well, no, but some really clever lawyer types told us it would be a really good idea if we did, as it would keep them really busy..........and they mentioned something about needing a yacht in the Maldives and a Learjet in the Cayman Islands".

So, net result, no cash available, contract binned, no centralised question bank and all national authorities to sort their own lives out, and one very p***ed off software company, haivng put a lot of resources into what promised to be a very nice earner (and which would probably have proved to be a far better system than we have to deal with now).

*Note artistic licence with dialog! ;)

[Whopity]

and which would probably have proved to be a far better system than we have to deal with now I have seen the quality of questions they produced. Probably the worst I have ever seen so good riddance to them, they deserve to starve!

[keith williams]

The short list of two was finally decided in favour of a European mainland software company NOT directly involved with training but who have experience in database development and management..............They produced an initial trial database of approx 1,000 questions, with a very strict quality control process to ensure compliance with the Learning Objectives...

I have seen the quality of questions they produced. Probably the worst I have ever seen......

Only EU bureaucrats could imagine that a company who's sole expertise is in the field of databases should be able to produce good quality questions.

The problem with the existing CQB isn't that it does not comply with the learning objectives. It is that the questions are of very poor quality. This problem is compounded by the fact that many of the subject-matter experts in the FTOs cannot agree on what constitutes a good question.

[2close]

I'm not here to defend them but they didn't actually write the questions - that was contracted out to an aviation expert and agreed, a great deal of them left a lot to be desired (in the form they were last left, at least).

The contract was axed before these questions ever finished the QC process so we have no way of ever knowing whether those 'dodgy' questions would have made it to the final DB in their 'dodgy' form so it would be a tad unfair to criticise the author at this point. We are all capable of writing questions in a first draft which, on reflection at second or third pass, we would cringe at.

It was the quality control process I was referring to, something which is seriously lacking at present, to the point of non-existence.

There are questions currently in use which have been around for donkeys years which are either questionable in their own right or simply wrong.

The point I was originally making was one of a historical nature - there was going to be a potentially effective system but in good old Eurocrat fashion, they wasted the money elsewhere, thinking they could tap into a bottomless pit of cash for more.....does that sound like any other organisations? Oh, yes, they can tap into a bottomless pit of cash, it's called the Scheme of Charges.

A single EU charge was mentioned - look at the system and charges in some countries, e.g. Greece.

A computerised system with immediate reporting - a 10 working day period (as per the AMC) to take the exams - FIVE Euros per exam (SEVEN for resits!) - and YOU choose which exams you take NOT the regulator. Log on, pick your exams and off you go. Stand by for Greek economy comments - again, that is not the point, the issue is the charges passed on to the client. There are similar charges in many other EU countries.

Do FTO SME's have any say in the content of the questions, any more? I was under the impression that it was one FTO only - I stand to be corrrected.

The problem is not the SME (or SME's) in any case. It is the simple fact that the authority, whether that be the CAA, JAA or EASA, has never mandated a single reference source for each subject, on which the LO's are based and the questions drawn. That's where the agreement needs to be - one single composite reference source, be it Jepessen manuals, whatever....oh, no, now we have to get a bunch of EU member states to agree to something else!!! :ugh:

Might be easier to get rid of EASA. :ok:

Have a good day.:)

[dobbin1]

For PPLs we should just adopt the FAA system. One exam, 60 questions out of a published bank of 600 or so, all done on a computer system. I did my FAA PPL in 1996 and they had the computer stuff sorted out then. It is shocking that we still rely on pencils and manual marking in 2013!

[Mickey Kaye]

Ditto, Ditto

[RVR800]

Ditto, Ditto also

[S-Works]

I see we have to supply our own ed39 charts to go with the new exams.

[MrAverage]

Also rather confusingly described as "South West of England and Wales".

So 9 x 3 = 27 + 9 attempts at the Belgrano = 36 - all in 6 days.........

[Level Attitude]

So 9 x 3 = 27 + 9 attempts at the Belgrano = 36 - all in 6 days.........

I think the purpose of taking exams is to try and pass them......anyone
who has to go to Gatwick to re-sit all 9 exams was obviously not
at all ready to take any of them and should/would not have
been recomended by their school in the first place.

[keith williams]

I think the purpose of taking exams is to try and pass them......anyone who has to go to Gatwick to re-sit all 9 exams was obviously not at all ready to take any of them and should/would not have been recommended by their school in the first place.

But if the authorities were acting rationally when constructing the new regulations, they would surely have included only those events that they considered to be reasonably likely to occur. The alternative is that they included things which they considered to be virtually impossible.

The new regulations specify that candidates are entitled to four attempts at each of the 9 exams. The same regulations specify that candidates must be recommended by their school before taking the exams and that all attempts must be completed within 6 sittings. The real problem arose when they decided to define a "sittings" as being a maximum of one day duration.

[BillieBob]

So, what you're saying is that everything was fine while EASA had control but it all turned to ratsh1t when the UK CAA got involved. Sounds about right, actually.

[keith williams]

Not quite.

My view is that EASA introduced a number of totally unnecessary additional requirements, such as 9 exams, but their ideas were at least workable.

Then the UK CAA came along and came up with their unrealistic (one day) definition of a "sitting", which has made the situation unworkable.

[BillieBob]

EASA have not insisted on 9 exams, they have simply required that an applicant for a PPL demonstrates a level of knowledge, appropriate to the privileges granted, in nine subject areas. There is no requirement relating to the number of examination papers at all and it would be fully compliant to have a single examination paper of 120 questions covering all of the subject areas, as stated in AMC1 FCL.215; FCL.235.

It is the UK CAA alone that has decided to have 9 separate papers, containing significantly more than the required number of questions and to define a 'sitting' as one day. My understanding is that the UK papers will comprise between 15 and 20 questions each. That being the case, the minimum possible number of questions would be 15x9=135 whereas the AMC states "the examinations should comprise a total of 120 questions".

[dobbin1]

Letter from Ray Elgy (head of licensing & training standards at the CAA) in Pilot magazine. A sitting will be defined as "a maximum of three consecutive days" and the number of questions will be 16 or 20 per paper x nine papers.

[Whopity]

and the number of questions will be 16 or 20 per paper x nine papers. So they are failing to comply with: AMC1 FCL.120; FCL.125 THEORETICAL KNOWLEDGE EXAMINATION AND SKILL TEST FOR THE LAPL (a) Theoretical knowledge examination (1) The examinations should be in written form and should comprise a total of 120 multiple-choice questions covering all the subjects. in contradiction of their own letter dated 13 February 2013: The EASA Aircrew Regulation (Regulation (EU) No 1178/2011 as amended by Regulation (EU) No 290/2012) was implemented by the UK CAA on the 17 September 2012, This required the CAA to carry out a complete revision to the existing PPL Aeroplane and Helicopter examination papers to comply with Part-FCL, Part-ARA and their AMCs and GM.
Part FCL says that the examinations "should" comprise a total of 120 multiple choice questions. That means that there does not have to be 120 questions but, there cannot be more than 120 questions or that would be more stringent than the basic regulation!

[Sepp]

The CAA don't have to comply with an AMC, because it is just that, an Acceptable Means of Compliance, not the Only one. i.e., if one does what's in the AMC, one has demonstrated compliance with the rule and will not have to cope with further, local, opinion/suggestion/requirement but, just as Operators' compliance with operating rules, one can elect to do otherwise. In that case, what one does will have to be acceptable to (or approved by) the Authority and is subject to the (local) Regulator's interpretation of the requirements. As that means CAA in the UK, if they accept their own method of compliance, they comply.

The "120 questions" is part of the AMC, not the Regulation, which makes no stipulation as to the number of questions. FCL.120 does mention nine subjects to be examined, however, so perhaps it is not unreasonable for the CAA to set nine separate papers.

[Whopity]

The CAA don't have to comply with an AMC, because it is just that, an Acceptable Means of Compliance, not the Only one.But as they have not published an alternative AMC, they do have to comply and as they cannot be more stringent than the basic regulation, even if they produced their own its still 120 questions!

[Sepp]

I am more than happy to bow to others' superior knowledge of the subject, but as the requirement when drawing up an alternative means of compliance is to demonstrate no less than equivalent safety to that present in the published AMC, rather than to match it exactly, it would appear that the CAA could quite happily require 1500 questions if they chose but could not require 119. This requirement is then binding solely on CAA, and no other Regulator has to comply with it - indeed, should another Regulator wish to adopt the same stance, they would have to draw up their own version of it; they could not simply say "we'll do what the CAA does". The attendant disparity between the implementation chosen by the various Regulators is completely within the requirements of the Basic Regulation, provided that each demonstrates the required equivalent safety.

I grant you, the whole system is one gigantic cock-up that offers no guarantee of EU-wide standardisation in any area EASA has chosen to oversee. Fortunately, my interest is now academic and I don't have to administer/apply/cope with any of this or related Euro-crap.

[Level Attitude]

AMC1 FCL.120; FCL.125 THEORETICAL KNOWLEDGE EXAMINATION AND SKILL TEST FOR THE LAPL (a) Theoretical knowledge examination (1) The examinations should be in written form and should comprise a total of 120 multiple-choice questions covering all the subjects.

I don't think EASA defines "should"

But the CAA does (or did) - I cannot find the references where I have seen it
but, from memory:

"May" = Complete choice to follow, or not follow, a course of action.
"Should" = Course of action recomended, but not mandatory.
"Must" = Course of action must be followed - No exceptions.

Therefore, to me, the CAA seems to be fully complying with Part-FCL

[Whopity]

As you said should is recommended but not mandatory however; its establishes a recommended maximum and if you exceed that, you are being more stringent than the regulation intended. The whole point of this is to establish a level playing field and stop individual States setting their own standards. Where did the original requirement come from? The FAA! so their model was probably what the originators had in mind.

[Mickey Kaye]

Yet another missed opportunity.

Pretty well every one I know feels that one paper of 120 questions covering all PPL subjects would be the way to go.

Flight training in the UK competes with no user fees flight training in the states and VAT fee flight training in sunnier southern Europe.

Flight training also competes with other leisure activities golf, fishing , water skiing etc

This is yet another change which makes the cost of obtaining a license in the UK more expensive and less convenient.

Will the never ending regulatory strangulation ever cease?

[keith williams]

Whopity,

should is recommended but not mandatory however; its establishes a recommended maximum and if you exceed that, you are being more stringent than the regulation intended. The whole point of this is to establish a level playing field and stop individual States setting their own standards.

they cannot be more stringent than the basic regulation

You appear to be taking a rather one-sided approach to this.

If individual authorities are permitted to be less stringent, but not more stringent than the basic regulation, then the whole thing becomes a "race to the bottom".

If individual authorities are permitted to be more stringent, but not less stringent than the basic regulation, then the whole thing becomes a "race to the top".

If the overall objective is to ensure flight safety, then a race to the top would be the more productive of the two approaches......but it does risk driving training providers into financial ruin.

[Sepp]

It is indeed a widely held belief that the Law provides a level playing field, but it does not; rather, it provides a straight starting line. True, one cannot depart from what is written in the Law, but an AMC does not form part of the Law and nowhere is it written that a regulated person - in this case the local Regulator itself - cannot exceed the provisions contained in a published AMC, only that they must demonstrate that what they propose to do does not fall short of the level of safety that would be provided by following the published AMC to the letter. [edited to add: The provisions of an AMC should not be taken to be suggested maxima, rather, they are suggested minima].

In this case the Law only states that candidates must be examined in nine stated areas of comptence, there is no indication of how this might be achieved. The AMC gives ONE way in which a regulator might comply; but there is absolutely no requirement for them to not exceed any provision in the AMC. What a Regulator cannot do, is refuse to recognise a Licence issued by another that did choose to follow the AMC, or one that exceeded the AMCs provisions.

A similar situation exists in soccer. One might assume that all pitches are the same size, but in fact the rules provide only for a minimum width and length; there is nothing to stop a club exceeding these dimensions - but any game played on a pitch that meets or exceeds the minimum dimensions, counts.

[BEagle]

Pre-JAR-FCL, UK CAA PPL examinations consisted of 6 exams with a total of 153 questions. Out of interest, how would people feel about the following exam structure:

http://i14.photobucket.com/albums/a341/nw969/PPLQs_zpsd703e7de.jpg

This would be fully compliant with part-FCL AMCs.

The first 2 exams should be taken before solo, the next 2 before solo navigation and the last 2 before Q X-C.

[BillieBob]

There is a basic misunderstanding here about the way that EU law works. The requirements of EU Regulations and their annexes are what is termed 'hard law'. and must be complied with. There may be a number of acceptable (to the Agency) means of complying with each requirement and these AMCs are published as 'soft law'. This means that where only one AMC is published in relation to a requirement, that is the only acceptable means in which one may comply, notwithstanding the use of the word 'should'.

It is open to anyone to propose an alternative means of complying with a regulatory requirement and there is a specified process by which this is done. If the proposed alternative means of compliance is accepted by the competent authority, and by the Agency, it becomes available to all as an alternative to other published AMCs. Of course, one gets 'owt for nowt' and the UK CAA will charge, I believe, £2000 to consider a proposal - no refunds if it is rejected of course.

There is, as yet, no alternative to AMC1 FCL.120; FCL.125 and so the UK CAA is in breach of EU law (again).

[Whopity]

If the overall objective is to ensure flight safety, then a race to the top would be the more productive of the two approaches......but it does risk driving training providers into financial ruin.There is little evidence of any consideration for flight safety in any of the EASA regulation, it simply assumes that if there are enough rules safety is assured! European regulation sets the bottom line not the top line; that is the highest uniform level, better known as the LCD. Since when have EASA or the CAA shown any concern about driving traders to financial ruin? Their objectives include reference to regulatory efficiency but little they do achieves this.

Beagle, go for it, Mr Haines says they are working closely with AOPA, so maybe he will listen to reason.

[Sepp]

BillieBob, I have to disagree.

EASA itself states in its AMC FAQs (bold signifies text from FAQ titles):

2. Definition

AMCs are defined as non-binding standards adopted by the Agency to illustrate means to establish compliance with the Basic Regulation and its Implementing Rules.
The AMCs issued by the Agency are not of a legislative nature; therefore they cannot create obligations on the regulated persons, (etc.)

and

5. If a competent authority intends to accept other means of compliance than those adopted by the Agency or if it intends to develop its own means of compliance, is there any obligation on the competent authority to submit these means of compliance to EASA for approval?

There is no such obligation: Except in cases where the Agency is itself the competent authority, the implementation of rules rests within the sole remit of Member States.

and from (4)

Whenever a competent authority decides to issue their own national alternative means of compliance, such means only commit itself. Other competent authorities are not required to follow them. Moreover, such alternative means of compliance issued by the competent authority do not in any way alter the presumption of compliance provided by the Agency AMCs.

and (3):

It is important to note that this approval will be granted on an individual basis: Other applicants wishing to make use of the same alternative means of compliance must obtain individual approval for that from their competent authority. The burden of proof of compliance fully rests with the applicant.

---

If EASA regard AMCs as non-binding, why should CAA not also do so?

[Sepp]

Whopity: I agree completely with [edited to add: the sentiments of] your first paragraph.

[Sepp]

G-RICH: No Ops procedures? Not required to comply with EASA Ops? EU-Ops may not have applied to you, perhaps, but OPS-GEN is going to have a damned good try at doing so - and more, depending on what you fly, and why. Apologies if I missed the thrust of your argument, having mentioned pre-JAR.

I don't have a problem with the number of exams; it makes no difference if you ask a candidate 120 questions in one splurge, or 1 question on 120 subjects cleaved apart by a sharp razor; separation is a matter of convenience for the Regulator... unless they charge per exam. Now, they'd not up the exam numbers just for more dosh, surely? :E

[Whopity]

If EASA regard AMCs as non-binding, why should CAA not also do so?Because they have to comply with Part ARA:

AMC1 ARA.GEN.120(d)(3) Means of compliance
GENERAL
The information to be provided to other Member States following approval of an alternative means of compliance should contain a reference to the Acceptable Means of Compliance (AMC) to which such means of compliance provides an alternative, as well as a reference to the corresponding Implementing Rule, indicating as applicable the subparagraph(s) covered by the alternative means of compliance.

GM1 ARA.GEN.120 Means of compliance
GENERAL
Alternative means of compliance used by a competent authority or by organisations under its oversight may be used by other competent authorities or organisations only if processed again in accordance with ARA.GEN.120 (d) and (e).

The CAA don't get anything for PPL Exams, except the 4th sitting!
I see examiners have to buy their own map now!

[Sepp]

And they do:

the first instance applies once EASA has approved (i.e., adopted) your/my alternative as an "official" alternative - it does not obviate your/my right to adopt the alternative with the approval/agreement (as necessary) of the local competent Authority, and that does not require EASA's nod; [edited to add: (Actually, this reference is itself an AMC, so not binding, either!)]

the second is the basis of the FAQ (3), as stated, [edited to add: and is Guidance Material only (GM) ]

[I suspect that your reply may have occured whilst I was editing my previous post].

[Sepp]

CAA not getting a slice of the pie? Someone in the Belgrano is asleep!

[keith williams]

Whopity,

There is little evidence of any consideration for flight safety in any of the EASA regulation, it simply assumes that if there are enough rules safety is assured!

I agree entirely!

You then say

European regulation sets the bottom line not the top line; that is the highest uniform level, better known as the LCD.

But here.

Part FCL says that the examinations "should" comprise a total of 120 multiple choice questions. That means that there does not have to be 120 questions but, there cannot be more than 120 questions or that would be more stringent than the basic regulation!

And here.

But as they have not published an alternative AMC, they do have to comply and as they cannot be more stringent than the basic regulation, even if they produced their own its still 120 questions!

You appear to be arguing that national authorities are not permitted to set standards higher than those set be EASA.

Since when have EASA or the CAA shown any concern about driving traders to financial ruin? Their objectives include reference to regulatory efficiency but little they do achieves this.

Once again, I agree entirely.

[Whopity]

You appear to be arguing that national authorities are not permitted to set standards higher than those set be EASA. You've finally got it! That is the way it now is! The National Authority cannot be more stringent than the basic regulation.

[keith williams]

Whopity,

Your statement that

You've finally got it!

Suggests that you are becoming a bit exasperated with this discussion. If you set your exasperation aside for a moment you might see the point that I am trying to make.

You have said

European regulation sets the bottom line not the top line; that is the highest uniform level, better known as the LCD.

If this is true then national authorities cannot set a lower standard (because EASA has set the bottom line) but can set a higher standard (because EASA has not set the top line).

But you have also said

The National Authority cannot be more stringent than the basic regulation.

If we put these two statements together it means that the national authorities must do exactly (nothing more and nothing less) what is specified by the EASA AMC.

But quotes provided by SEPP indicate that this is not the case.

[BEagle]

Once I've seen some greater detail about the latest CAA PPL exam structure (no. of exams, no. of questions, 'sittings' etc.), if they have been adorned with CAA 'gold plating', I will be pursuing the issue through AOPA with the CAA.

Being compliant with part-FCL is one thing, doing so in a disproportionate manner is quite another.

The topic is also on the agenda for the next FCL Implementation Forum at the instigation of the IAA.

[Whopity]

Keith,
If we put these two statements together it means that the national authorities must do exactly (nothing more and nothing less) what is specified by the EASA AMC. That is pretty much as I understand it. Its the European way of doing things. They lay out a fairly vague regulation and so long as you have fulfilled that requirement in one of its many possible interpretations you have complied and nobody can ask you to do any more.

[Level Attitude]

Posted by Mickey Kaye
Pretty well every one I know feels that one paper of 120 questions covering all
PPL subjects would be the way to go.
ONE paper covering ALL theorectical knowledge required by AMC1 FCL.210.FCL.251!!!!!
Stressful or what! The PPL is, after all, a leisure qualification.
I could see many failures arising - and only 4 attempts allowed.


Posted by G-RICH
Any gaps can be filled in with a stiff oral exam as part of the Skills Test.
I disagree with this.
The Skills Test should be the final element of a PPL Course and should
test the practical application of knowledge already obtained.
Which tends to be pretty poor already:
"You are required to plan the following VFR flight....You must maintain
VMC at all times"
Candidate then decides to fly straight through the middle of the only
cloud in the sky because it happens to lie on their planned track.

[Mickey Kaye]

G-RICH it was hardly my idea. I knew that the FAA have one paper and by all accounts it works very well.

My suggestion was simply the obvious interpretation of the requirement;

AMC1 FCL.215; FCL.235
THEORETICAL KNOWLEDGE EXAMINATION AND SKILL TEST FOR THE PPL
(a) Theoretical knowledge examination
(1) The examinations should comprise a total of 120 multiple-choice questions covering all the subjects

Also one paper would sit nicely with the six sittings requirement.

How an earth we managed to dream up some scheme of nine papers with only six sitting allowed. With a sitting being one week or whatever is simply beyond belief.

Where is the common sense?

[Whopity]

The real problem is that the UK has always gold plated everything, The CAA had the remit to issue National Licences as it thinks fit and originally used experienced staff to do that. Now it is confronted with a set of vague rules, very few staff that know anything about PPL training or exams, and a plethora of old material that don't know what to do with so their natural reaction is to reuse it.

The CAA ground examiners were deemed unnecessary as long ago as 1996 when the JAA proposed a CQB therefore; no need to employ dedicated examiners to write questions. The PPL was never considered in the JAA transition so consequently, there has been nobody dedicated to this task ever since. Prior to 1996 AOPA also had an involvement in the examination process process, but this was also removed prior to the JAA transition.

The BMAA in contrast has always produced its own exams to suit its own requirements, the CAA printed the papers for them.

We are now seeing the result of 15 years of neglect combined with a new concept the CAA are failing to grasp in an efficient manner.

[jez d]

There is, as yet, no alternative to AMC1 FCL.120; FCL.125 and so the UK CAA is in breach of EU law (again).

I gather there are currently in excess of 100 alternative means of compliance filed with EASA. Presumably most of them came from the UK CAA given it was one of the first national authorities to adopt Part-FCL. All of the amcs have been passed onto the EU Commission who, to date, have done nothing about them. EASA meantime has permitted these amcs to be adopted. It's not only the UK CAA that's in breach of EU law therefore.

[Level Attitude]

Also one paper would sit nicely with the six sittings requirement
Although it would comply with the six sittings requirement it would also need to comply
with the more stringent requirements of only four attempts at an examination
(with the fourth being organised by the CAA)

What is wrong with Mickey's idea of one exam ?
Under JAA candidates could elect to take any of the seven exams, plus any resits required,
whenever they liked, provided all exams were passed within an 18 month period.

Originally this thread seems to have been suggesting that the EASA requirement
for only 6 sittings for 7 exams (9 exams once the new ones have been published)
was too restrictive for PPL level.

To me: One exam, testing the whole EASA PPL theorectical syllabus in one go, seems even more
restrictive - and hence more (too?) difficult for someone seeking to obtain a "leisure" Pilot's License.

That's what they have under the FAA system (60 questions)
Good for them - But it doesn't change my opinion expressed above.

and in Canada (100 questions, with resits for failed sections possible).
Retaking Sections - Sounds like splitting the "Entire Set of Examinations"
in to separate "Examinations" to me - with the exception that the first
attempt has to be the "Entire Set".

Nothing currently stopping a candidate, who wishes to, taking the
"Entire Set of PPL Examinations" in one go
(assuming an invigilator will agree to run all exams in one day).

If, as an earlier Poster suggested, the CAA is going to define one sitting
(for PPL exams) as "3 Consecutive Days" then I cannot see any problem
going forward.

[S-Works]

Here is an idea...... Lets leave it to the discretion of the Ground Examiners as they do now. After all it's us that sign the forms at the end of the day......

[BEagle]

Lets leave it to the discretion of the Ground Examiners as they do now.

Noo - discretion? That would cause panic in €uroland. Particularly amongst those nations which need to have a rule telling them with which hand to wipe their own backside.

[2close]

Why is there opposition to one exam covering all subjects?

After all, flying, whether it be for leisure or professionally, requires the participants to use all relevant skill-sets at the same time. You have to use your knowledge of Operational Procedures, Mass & Balance, Met, Navigation etc. when flight planning, in exactly the same way as you may need to use Air Law, Aircraft Systems and more Met and Navigation knowledge during flight.

Having trained in several professional areas during my ageing years, I have found the best exams to be NON-multiple choice, scenario based exams, using "real-life" situations with questions based around those situations.

Personally, I would like to see one exam, with two or three "flights" including a pre-flight regulatory phase, a flight planning phase, an en-route phase, a technical phase, a diversion phase and any other phases that may be considered relevant. The student's knowledge of all areas involved in the operation of light aircraft could be tested, with a mix of multiple choice and calculated solutions.

Surely, potential PPLs should be able to cope with the 'stress' of one exam covering all the areas that they could face in a single flight?

Or am I being too hard? :E

[Whopity]

One has to ask the question, What is an EASA PPL and WHY do we need one? In reality, there is no such thing as an EASA PPL apart from the label, because each State is different. We don't need one because ICAO Annex 1 makes suitable provision for recognition of all others. So we must ask what is this nonsense all about? Either EASA should provide the means to have a common European Licence or leave well alone and comply with Annex 1, a declared EU objective! Failing that just give everyone an EASA sticky label, job done.
AOPA claims to be making representations, but historically they were the original cause of the problem!

[BEagle]

AOPA claims to be making representations, but historically they were the original cause of the problem!

Rubbish. The AOPA proposal was simple enough, but your erstwhile employers at the Belgrano made a dog's dinner of the detail - as well you know!

[Whopity]

Beagle, its not Rubbish, if it had not been for Ron Campbell there would never have been a JAA PPL. There was no intention to include the PPL in JARs until AOPA suggested it. In those days they controlled all Examiners and believed that by inventing the Registration process they would be allowed to control that too, thereby increasing their membership. Then their agreement was torn up and the mess began.

[BEagle]

It is complete rubbish as you well know.

In recent times all you seem to have done is to bad mouth both AOPA and your previous employer, the CAA.

Perhaps now is the time to come up with constructive, rather than destructive comment and suggest some sensible proposals?

[Whopity]

Perhaps now is the time to come up with constructive, rather than destructive comment and suggest some sensible proposals?Funny, thats what AOPA was told to do, and from that the NPPL was born. Check your history, sometimes the facts are conveniently forgotten.

[BEagle]

There was no consultation with anyone before the CAA launched its new PPL exam proposals. However, AOPA is in direct discussion with the CAA at the very top level to soften the impact where we can. The IAA has already raised the subject for the next FCL Implementation Forum and if we find that the new CAA exams are disproportionate (e.g. requiring more questions than the AMC calls for, or making the 'sitting' period shorter than 10 days), we will be requesting justification. The current industry-wide call is for 'CAA gold plating' to be stripped away, so that nothing more demanding or restrictive than EASA AMCs is in place.

Regarding the JAR-PPL, the idea was to modularise the whole licensing process. However, Whopity's colleagues rushed into a ridiculous haste to introduce JAR-level requirements in the UK long before they were ever needed. Chaos then ensued and the person repsonsible was encouraged to take early retirement.

The NPPL was born, much to Whopity's criticism, as a direct result of the CAA realising that its JAR-FCL PPL was wholly disproportionate and was killing PPL training - AOPA was then asked for an alternative, which we delivered.

Anyway, good luck with representing your own objections, G-RICH. Have you voiced them to any aviation organisation at all? It might help your case.

[BillieBob]

Having been closely involved in the early days of the JAA, I can confirm that the original intention was not to include requirements for the PPL but to leave it to national authorities to regulate in accordance with ICAO Annex 1. It was only intense lobbying by AOPA UK that resulted in the PPL being included in JAR-FCL 1 at the last minute and, in my view, without adequate consideration. However, this is all a red herring in the current context as the PPL would have been brought under the EASA umbrella irrespective of its status under the JAA.

The behaviour of the UK CAA since its twice bungled introduction of the Aircrew Regulation provides ample evidence of the arrogance and incompetence that now pervades the upper reaches of Aviation House. There is now a clear strategy to cast the flight training industry adrift while endeavouring to retain as much of its previous power as possible, whether or not this complies with EU law. The issue of the PPL exams is only one symptom of a much wider reaching disease.