New poblem with EASA and ATO certifying base training touch and goes.

[Dewoitine]

Hello,
I must undergo a corporate jet type rating course. The problem is that since the 8 of april the Spanish Aviation Authorities (AESA)want the ATO that gives the simulator to certify the base training. Flight Safety International, who must give me the course, tells me they can not do that, they only do the sim part. Spanish AESA tells me that these are the new European rules and that this is the way to do it. I left my previous job to start to fly in a new aircraft so my situation is critical. Any of you knows something about this in your European countries or is having the same problem?

[ZFT]

I assume then that it isn't an EASA approved course?

[Dewoitine]

Yes, it's an approved course, with Flight Safety International. The problem is that with new EASA rules the ATO must certify the base training, it's new stuff, and FSI does not want to do that. There are several pilots with this problem. They told me in the spanish civil aviation authorities that this is like this in all EASA state members, but I'm not sure if this is true or it's only in Spain...

[ZFT]

See AMC2 ORA.ATO.125 (n) which seems to cover your case. Trouble is with EASA, who knows.

[Miles Magister]

The advice given by ZFT is correct. Use that reference to get FS to certify the training they have given you then find another ATO to complete your landings. You may find that many European TRTOs have not yet converted to ATO status but this should not be a problem if you check with your FCL department before hand. Take both completion certificates with you when you get the type added to your Licence.

MM

[Dewoitine]

Hello ZFT and Miles Magister, many thanks for the information.
I've been reading AMC2 ORA.ATO.125 (n) and here is the parraf that I think is where I can find some light:

"The ATO is permitted to contract elements of training to a third party training provider. In such cases the contracted organisation should normally be approved to conduct such training. When the contracted organisation is not an ATO, the competent authority should, within the approval process of the ATO, include the contracted organisation and be satisfied that the standard of training intended to be given meets the requirements. The other obligations of the ATO, such as student progress monitoring and an adequate management system, can be exercised by the ATO seeking approval and which retains responsibility for the whole course."

I'm not english and I have a problem understanding it correctly, Could you please explain me what do they mean when they say " When the contracted organisation is not an ATO, the competent authority should, within the approval process of the ATO, include the contracted organisation and be satisfied that the standard of training intended to be given meets the requirements". Does it mean that in my case, Flight Safety could contract the company that is hiring me, who is not an ATO to do the landings with our plane?

[Miles Magister]

Your understanding is correct but it is very unlikely that FS will allow another unknown company to complete training on their certification. You should get a completion certificate from FS for the elements they have completed and then do your 6 landings with a local ATO or TRTO under their approvals with the agreement of your FCL office.

MM

[BizJetJock]

Actually this has been the rule for years, it hasn't changed. What is new is EASA auditing the NAA's and making them enforce it.
Go back to FSI and tell them you're going to sue for the cost of the course back if they can't deliver a type rating. Their standard contract says that you must provide an aircraft for any flight (as opposed to sim) training, but if you are working for an operator that shouldn't be an issue. They just have to provide a suitably qualified instructor. They don't want to because they are pretty rare and charge lots of money!

Good luck:ok:

[jtelling]

As a UK TRTO (ATO) (Bristol Flying Centre) on the B200 & C525 and as a TRI/TRE on both I receive quite a few inquiries of this nature. The problem is that companies such as Flight Safety who provide excellent training are all sim based and don't seem to let their JAA/EASA students know that they still need to complete 6 landings in the aeroplane then a base check (OPC). This can cost as much as £3k

A TRE through an ATO can deal with this however if for example I am examining for a Spanish license holder we usually have to give 5 days notification to the license holders aviation authority.

You will find that most sim based courses are not conducted by type rated pilots and they rarely have them on their books. I wouldn't say TRE's are expensive just good value but hiring the aircraft is expensive.

Hope this helps

[ZFT]

jtelling,

A couple of issues:-

If you refer to a TRTO it can now lead to confusion as there is no such thing under EASA

You will find that most sim based courses are not conducted by type rated pilots

I would disagree as SFIs have to be - FCL.910 SFI (a) & FCL.915.SFI(b) refers

[Dewoitine]

Thank you Miles Magister, BizJetlock, Jtelling and ZFT. The cost of the plane is not a problem, nor finding a TRI, but FSI is reluctant for the moment to certify the base training on the plane of my company. The problem is I can not contract any other ATO for the touch and goes, there's no one in Europe for the moment for that plane, or so have they told me. I still haven't done the sim, so I can't sue anyone... I'm sure that if I had done the sim part they would give me a solution.
I'm thinking of sending my licence file to another AESA state member such as the UK or France and do my Type Rating after, as it looks like only the spanish civil aviation authorities are giving so much trouble with this.

[NilDesperandum]

I've recently completed a european rating on a jet, which was signed off on a new EASA license by the United Kingdom Civil Aviation Authority. The type rating course was signed off by Bombardier training, the landings were signed off by an Austrian TRE. There were a couple of minor problems but I did not have the issues you mention. There were 2 separate forms, one completed by Bombardier, the other by the TRE.

Regulatory authorities can be difficult to deal with, especially at a distance. My suggestion would be either :

a) to find a Spanish TRE, or someone similar who deals with the authorities there regularly, and get their advice

b) to go and see the authorities yourself and insist on seeing someone in the relevant department to explain the issue to and come up with a solution.

I doubt that Flight Safety are going to change their mind. If you look at it from their side, why should they sign off some training they have no control over or visibility of ? You probably need to tackle it from the Spanish end.

US and Canadian license holders dont have any of these issues because they dont have to do the touch and gos !

ND

[Max Payne]

Dewoitine, that is silly.

a) Suing FSI will not help you as - if the claim is admitted - it will take longer than the six months that the ground school / simulator part of the type rating is valid for.
b) Once you have done the simulator part, FSI will forget about you because they have fulfilled their part of the contract.
c) Transferring your licence to another state takes about one month and half and is only permissible if you or your employer are based in that state.
d) As the other state's CAA will enforce the same EASA rules you will not have gained anything.

[Dewoitine]

Hi Nildesperandum and Max Payne, thank you for the help.That's what I'm trying, to find a solution from the spanish side. I'm in contact with them but they do not want to hear nothing, they say the only thing to do is to get the base training certified by FSI or by the ATO who gives me the sim. I don't want to sue anybody, and even if I wanted I couldn't, I have not signed any training agreement with anybody, I haven't done the sim part yet. To transfer my licence to another state would be a solution, because as far as I know even if it's EASA rules only the Spanish CAA is applying it to the last extreme. I've been told in this same forum that to live or have my employer in another state is no longer a requisite to transfer my licence. Even if it is, I will go to live anywhere the time it takes to get my licence transferred, my situation is desperate, I find myself with no job after resigning and without being able to get the type rating I need for the new job. The people who are hiring me won't be able to wait for me months...

[Baywatcher]

I heard of someone who did the course and did check flights under EASA and FAA and after several hours on type with FAA License he applied to UK with the EASA check form with proof that landings had been done by virtue of FAA license flights and was given the endorsement.

[Miles Magister]

Dewoitine,

Mate, do not fret. FS have never and will never will certify the 6 landings on their ATO. This is not part of their service and will never ever assume the legal responsibility for some organisation they have never dealt with. They only do the ground school and the sim.

The procedure is to do the rating at FS then come back to Europe and do the landings with any European ATO / TRTO. Just over a year ago a friend of mine did a type rating in Holland on a Dutch TRTO under Dutch JAA approvals with a Danish examiner on a Danish licence and the landings in England with an English AOC company and got an EASA type rating whilst everyone was meant to be using EASA! It can be done. You just have to check that the authority will accept the TRE you are going to use for the LST and the landings. The TRE may have to contact the Spanish CAA for a briefing.

Best wishes

MM

[Max Payne]

Those "several hours" are 500, then one will get an unrestricted endorsement. If it is less than that, the endorsement will be restricted to US-registered aircraft. As those four (respectively six) landings are an integral part of the type rating, an EASA-certified TRI has to "teach" you how to land the aircraft - "learning by doing" does not suffice.

I heard of someone who did the course and did check flights under EASA and FAA and after several hours on type with FAA License he applied to UK with the EASA check form with proof that landings had been done by virtue of FAA license flights and was given the endorsement.

[Baywatcher]

Max Payne

Is there a time limit for the 500 hours as I would think the EASA check form is only valid for 6 months?

[Max Payne]

Frankly, I do not know; but the regulation does not mention any:

Commission Regulation (EU) No 1178/2011

ANNEX III

C. ACCEPTANCE OF CLASS AND TYPE RATINGS
1. A valid class or type rating contained in a licence issued by a third country may be inserted in a Part-FCL licence provided that the applicant:
(a) complies with the experience requirements and the prerequisites for the issue of the applicable type or class rating in accordance with Part-FCL;
(b) passes the relevant skill test for the issue of the applicable type or class rating in accordance with Part-FCL;
(c) is in current flying practice;
(d) has no less than:
(ii) for aeroplane type ratings, 500 hours of flight experience as a pilot in that type;

[Dewoitine]

Thank you guys for the help, I got a call from some people working for FSI and there may be a solution soon, the spanish caa is interpreting the rules differently from the other european aviation authorities, several pilots and companies are affected, and it can not stand much longer... When I know something new I will let you know.

[EasaSpecialist]

on this topic? We are anxous to see what others are doing about this. Now, apparently, LBA is also asking for the same thing.

Any information would help.

[tempesta]

same shàit in Italy guys....
they are interpreting the rules in the more restrictive way and they re scared of taking responsibility .... so much bull**** in southern europe with EASA:ugh:

[ginopino]

.. Just spoken to the Italian CAA (our Company Tutor).... for them nothing changed... there is still the possibility to do the full type-rating course through an ATO (like FSI/CAE) and to attend the touch&go landings part through another ATO or Operator.... :ok:

Cheers !

[ZFT]

so much bull**** in southern europe with EASA:ugh: As much as it pains me to say this, EASA aren't the problem. The NRAs are for not implementing Part ORA correctly. (They keep trying to implement either their own interpretations or 'requirements').

[BizJetJock]

I think you've got that completely back to front. The requirement is quite clear, and hasn't changed from JAR. EASA are telling the NAA's that they can't just sweep it under the carpet, they have to enforce it. So they are.
Like so many EASA things, it is highly debatable whether there is any value in the requirement, but "rules is rules"!

[No RYR for me]

so much bull**** in southern europe with EASA I agree! Why can't we cheat anymore like we used to... :}

[His dudeness]

So Germany is southern Europe now ? (see IKON....)

[radudumb]

I have a question and I hope this is the right place for it.
My ME IR has expired 1 week ago and I'm wandering if it make sense to re-validate it. Do I need valid ME/IR if I will attend a B737 Type Rating in 5 or 7 months?

[g5tom]

No doubt, the rules ask for the landings to be done within an ATO/TRTO. However, for not “airline type” operators without an integrated ATO/TRTO this is almost impossible to comply with. The problem for third party providers (CAE, FSI etc) is the fact that they are not able/willing to be held liable for training conducted on a multimillion dollar jet, which they are not in control of. This is one (of many) examples, how the rules are written for the big players and are almost impossible to be complied with for the rest of the aviation community.
Spain started a query amongst EASA member states related to this particular problem, last week. Interestingly, the practice to deal with this problem within the NAA’s varies from strictly enforcing the landings to be done within a TRTO/ATO to accepting the landings when completed with a JAR/EASA licensed TRI. However, all Authorities have the possibility to file a derogation in accordance with article 14 of the basic regulation and shall give reasons demonstrating the need to derogate from the rule concerned, as well as the conditions laid down to ensure that an equivalent level of protection is achieved. This is probably what’s going to happen once the NAA’s have agreed to a common procedure.

Cheers,
g5tom

[g5tom]

Radudumb

Yes, as per FCL.720 (d)(2), you are required to have a valid ME/IR:

FCL.720(d) Multi-pilot aeroplanes. An applicant for the first type rating course for a multi-pilot aeroplane shall be a student pilot currently undergoing training on an MPL training course or comply with the following requirements:
(1) have at least 70 hours of flight experience as PIC on aeroplanes;
(2) hold a multi-engine IR(A);
(3) have passed the ATPL(A) theoretical knowledge examinations in accordance with this Part; and
(4) except when the type rating course is combined with an MCC course:
(i) hold a certificate of satisfactory completion of an MCC course in aeroplanes; or
......


Cheers,
g5tom

[muntisk]

Could you please share your experience with authorities regarding base training, in Latvia it is almost impossible to add new business jet type anymore. They interpret the rule only ATO must sign base training, but there is no EASA approved ATO for business jets all. :ugh::ugh::ugh:

[Aslak]

This is also the case in Finland right now.
Initially, Finland informed EASA, that they will continue to issue permits for AOC holders to conduct the required landing trainings as before. This information was also passed to the operators.

Around 1,5 months ago, National Authorities had a EASA standardization meeting where EASA pushed everyone to follow the requirement that all the type rating training has to be done thru ATO.

Shortly after this, around a month ago, all the Finnish operators received a notification stating, that as of that day, NO more permits for AOC holder's landing trainings will be issued!!!! :ugh:

The regulation is clear. The problem is that ATOs conducting simulator training do not generally have any aircraft. And then using the 3rd parties..., well..., then the liability questions come into the play.

On the other hand, it is my understanding, that f.ex. in the UK, the landing practise after the type rating course and the passed check ride is not even considered as a part of the type rating course, and therefore does not need any kind of approval.

Go figure, Europe and EASA, one happy family with the same rules and same treatment for everyone. Or not...:E