Creation of new flying schools effectively suspended for 3 years?

[Mach Jump]

http://www.caa.co.uk/docs/33/InformationNotice2014188.pdf

This Information Notice provides an overview of the changes that will be made by this amendment and their implications.

It seems to me that one of the most significant implications of the 'changes to the changes' to be introduced on 8th of April 2015 has either not been realised, or been ignored.

Despite having delayed the forced 'upgrade' of RTFs to ATOs for 3 years, whilst the very need for this change is reconsidered, anyone who wants to start a new flying school will still have to create an ATO, with all the investment of time and expense this implies. This, in the knowledge that there is a better than even chance that the ATO requirement will be dropped in three years time!

Under these circumstances, who, in their right mind, would be prepared to do that?

It would surely make much more sense to revert, in the meantime, to creating new RTFs (in their original form, not the later CAA 'gold plated' version) while the need for ATOs is reconsidered.

While we're reconsidering the need for ATOs, how about returning the teaching of the MEP Rating to RTFs as well?

Sadly, I suspect that, when the ATO requirement is eventually dropped by EASA, the CAA will just 'gold plate' the RTF requirements to match the then defunct ATO. :suspect:


MJ:ok:


Ps. Mods: Feel free to shift this to the Instructors forum.

[BEagle]

Mach Jump wrote: This, in the knowledge that there is a better than even chance that the ATO requirement will be dropped in three years time!

Not necessarily true for aeroplane and helicopter flight training. But if a 'new' organisation wants to sit on its hands for 3 years and allow others to benefit from their inaction, that's their look out.

The CAA will not be accepting any new RF applications - which is no secret given that they said as much some 2 years ago now.

Revised (simpler) requirements for non-complex ATOs will come into effect by 8 Apr 2015; such non-complex ATOs will (assuming they have suitably qualified instructors) be able to offer training for the MEP Class Rating, EIR, C-bM IR and FI / CRI certificates - because those are all ratings/certificates which can be included in a PPL.

We are keeping a close eye on the CAA's policy for non-complex ATOs providing such training, in order to ensure that they do not try to gold-plate the Aircrew Regulation by deeming it 'complex' and subject to full-fat ATO oversight.....:=

[Mach Jump]

But if a 'new' organisation wants to sit on its hands for 3 years and allow others to benefit from their inaction, that's their look out.

'New' organisations won't sit on their hands, they will just not get created at all, if the people who might create them think that the requirements are going to be far less onerous in three years time.

The people who have spent huge amounts of time and money on the ATO fiasco so far must be absolutely furious, and if I were one of them I would be seriously considering suing the CAA and EASA for compensation for my loss due to their unbelievable incompetence.

Revised (simpler) requirements for non-complex ATOs will come into effect by 8 Apr 2015...

Well, these will need to be essentially no more onerous than the requirements were for an RTF to persuade people that they should bother starting a new business at all.


MJ:ok:

[TheOddOne]

Is there not some kind of solution whereby those wishing to become involved in running a flying school can find an existing RTF that isn't trading at the moment and change the names of the Head of Training and Accountable Manager? I know of schools that are 'trading as' a different name for marketing purposes with the old RTF's name in the small print. Provided no fraud is intended and the old RTF doesn't come with some unpleasant baggage (oh, I see where the idea is falling down already!)

There must be SOME legit RTFs where the principals simply wish to retire and new blood could take over - why not seek out one of those and buy it out?

Cheers,
TOO

[xrayalpha]

Find an existing and buy it out...... Costs time and money.

Create an ATO...... costs time and money.

So same difference.

It is big boys and established schools crowding out new operators, who by necessity will be small to start with.

It is why we have not started to offer light aircraft training.

A couple of years ago, I thought: should I spend £100 quid registering as a RTF. Then I thought, we'll not be introducing light aircraft training for a few years, so we'll let this ATO stuff settle first.

Now we are in a position to do NPPL M to SSEA or LAPL conversions, but - since I failed to spend that £100 - have been priced (and paperworked) out of the market.

Sue the CAA? Ha! I have better things to do with time and money - and that cash will now, more than likely, get invested outside aviation.

[ChickenHouse]

That sounds familiar ... I just had a friend telling me that he is not able to extend his flight school offerings by the new EASA IR, due to the fact that the german LBA might not start even looking at his papers before 9-12 month time ... he is now planning to relocate the whole school.

[Mach Jump]

...should I spend £100 quid registering as a RTF

Introduction of the CAA £100 charge and it's daft room configuration requirements for registering as an RTF was the (fully intentional) beginning of the end for small (one peron band) flying schools.

There must be SOME legit RTFs where the principals simply wish to retire and new blood could take over - why not seek out one of those and buy it out?

Nope. I know of an instructor who tried to take on the RTF of the flying school he worked for when it was about to close down, but the CAA wouldn't allow it.


MJ:ok:

[keith williams]

The CAA will not be accepting any new RF applications - which is no secret given that they said as much some 2 years ago now.

They also said that "all FTs had to convert to ATOs by April 2015", and look how that has changed.

If they could change the second statement it is not unreasonable to expect them to change the first.

[Bob Upanddown]

Someone from the CAA once chastised me that I had had plenty of time to get my application in (for some approval, I forget what) and it was my fault I now had to wait because they were so busy dealing with all the other organisations who had also waited until the 11th hour to apply.
Said CAA person could not understand that, as the goalposts not only keep moving but sometime disappear completely, there was no point applying for something (with all the costs in writing manuals, etc) that might change before implementation date until it was almost certain the legislation was not going to be changed.

The CAA and EASA should STOP!. Stop now. Stop all moves towards change, stop putting dates back, just STOP.

Let everything run as it is now. Allow flying schools to be set up as they were. Allow people to continue to use their FAA licences in the EU. In the meantime, complete all these reviews of General Aviation, admit EASA has screwed up and come up with some more appropriate regulations that will allow GA to actually grow under EASA.

No-one in their right mind will set up a flying school at the moment. I think you will find that some big boys in that game are no longer with us (Cabair, etc) so being big does not protect you from the effects of recession or changes in legislation.

[BillieBob]

If they could change the second statement it is not unreasonable to expect them to change the first. You are comparing apples and oranges, Keith. It is a change in EU law that changes (will change) the second statement and it is only a change in the same law that can change the first. There is nothing whatever that the UK CAA can do about it.

Introduction of the CAA £100 charge Not just £100. I am aware of at least one RTF that, having submitted their application using the CAA template (that was accepted without question) subsequently received a bill for an additional £1600 for 'investigations'. It was only when the club got one of their members (a barrister) involved that the CAA backed down.

training for the MEP Class Rating, EIR, C-bM IR and FI / CRI certificates - If a 'non-complex' ATO can teach the Competency based course for the IR, why not also the full modular course? After all, they both lead to the issue of precisely the same rating. The Cb-IR course is nothing more than the full modular course with credits applied for previous experience.

- because those are all ratings/certificates which can be included in a PPL.That's a specious argument - so so can an IRI or STI certificate or any other rating.

[keith williams]

You are comparing apples and oranges, Keith. It is a change in EU law that changes (will change) the second statement and it is only a change in the same law that can change the first. There is nothing whatever that the UK CAA can do about it.

Yes I am aware of the fact that these things are not within the gift of the CAA.

But BEagles post implied that any statement made by the CAA immediately becomes set in stone and will inevitably come to pass. The point of my post was that none of these things are ever that cut and dried. How many of the recent changes have actually taken place on the predicted date?

The real problem is that when the option of delaying the implementation was being considered the people involved, including the CAA rep, should have considered the knock-on effects of any delay.

[BEagle]

The real problem is that when the option of delaying the implementation was being considered the people involved, including the CAA rep, should have considered the knock-on effects of any delay.

Which is why I recommended only a 12 month delay, rather than 3 years....:rolleyes:

[Bob Upanddown]

Which is why I recommended only a 12 month delay, rather than 3 years....:rolleyes:To whom?

If to EASA, why are you only recommending that it should be delayed rather than postponed indefinitely? I don't know anyone that supports the move to the ATO instead of an RTF.

[BillieBob]

Which is why I recommended only a 12 month delay, rather than 3 years.Given the number of differing (and often conflicting) opinions of the way forward, the time needed to prepare an NPA and the subsequent time taken to negotiate the arcane legal processes required to produce an amending regulation, 3 years sounds rather optimistic.

[BEagle]

The draft NPA.FCL.014 has been submitted for proof reading and the amended AMC & GM are planned to be in effect on 8 Apr 2015.

Indefinite postponement of the requirement for RF-to-ATO conversion wasn't on the table. The only option was to continue within the present legal framework, but to make compliance easier. The original intention was to ensure that the new requirements would be in place as soon as possible; however, the Commission doubted whether this could be achieved by Apr 2015, so it was agreed that a delay would be advisable.

3 years came about for other reasons.....:rolleyes:

Incidentally, it's 'RF', not 'RTF'.

[Mach Jump]

'RF', not 'RTF'.

You're right, I know. I'm just going with the flow.;)

Introduction of the CAA £100 charge

I meant the introduction of the £100 charge for registration as an RTF. Oops RF :)


MJ:ok:

[Mickey Kaye]

Is there not some kind of solution whereby those wishing to become involved in running a flying school can find an existing RTF that isn't trading at the moment and change the names of the Head of Training and Accountable Manager?”

Sadly that’s not the case. The CAA won’t accept a change in legal entitiy. They make you reapply as an ATO. Which of course EASA has now delayed/scrapped as it’s deemed to be inappropriate. A fellow instructor wanted to take over a flying school as the owner decided to retire but the added cost and the delay which at the time was something like 4 months to get his ATO application approved scupper it - so much for promoting the industry

The CAA will not be accepting any new RF applications - which is no secret given that they said as much some 2 years ago now

But things have changed significantly since then so perhaps the CAA should revisit this topic for the benefit of the industry

Revised (simpler) requirements for non-complex ATOs will come into effect by 8 Apr 2015

Why? The CAA themselves say that there was no safety case for the change from ATO to Rf in the first place. Why don’t we go back to how things were (which worked and made the setting up a new flying school relatively quick and cost effective) and wait to see what EASA conclude. They could after all scrap the whole rf/ato setup although

[Mach Jump]

3 years came about for other reasons.....:rolleyes:


Care to share the 'other reasons', BEagle?


MJ:ok:

[BillieBob]

The draft NPA.FCL.014 has been submitted for proof reading and the amended AMC & GM are planned to be in effect on 8 Apr 2015.We are clearly talking about two different regulations. But things have changed significantly since then so perhaps the CAA should revisit this topic for the benefit of the industryThe CAA has no power to revisit the topic; that was given away some years ago.They could after all scrap the whole rf/ato setup althoughThat is a very real possibility.

[rgsaero]

Reading this thread is very, very sad!

This seems to be as discussion / argument about how/ when / who is rearranging the deckchairs on the Titanic of the flight training industry! For surely that industry is sinking, or indeed compared to the activity levels of 25 years ago only has the inverted keel showing.

That this has been "achieved" by the joint strictures and continuing over-regulation / goldplating of CAA and EASA cannot be contested. 25 years ago when I learned to fly as a very mature student there was a lot of competition between many flying schools. I don't recall masses of students dying or being injured because their teachers / clubs weren't properly regulated back then!

Have you all contributed to the various "Cut the red tape" initiatives? I hope so! If not you have little to complain about!

[Mach Jump]

I think that many of the regular contributors on here have been involved in the fruitless battle against CAA/JAA/EASA 'Red Tape' for many years, long before we started calling it a 'Chalenge'. Only now do we apear to be making some small progress, but I don't know if it is too little/too late.


MJ:ok:

[172510]

What about NPPL?
Would the CAA accept an application from a new organisation willing to train for NPPL only?
As a LAPL can be obtained on the basis of a NPPL, that would be a solution to train most private pilots

[Mach Jump]

Would the CAA accept an application from a new organisation willing to train for NPPL only?

A nice thought, but for the time being at least, the NPPL/A SSEA can only be issued until 8th April 2015. After that, training will be only for the LAPL, although you will now be able to continue using your NPPL on EASA aircraft until 2018.


MJ:ok:

[Mickey Kaye]

Would the CAA accept an application from a new organisation willing to train for NPPL only?

For the NPPL microlight you don’t even need to do that!

All you need is a qualified instructor, suitable aeroplane and airfield to learn from. Which is the same as it was in the UK pre europe.

No wonder there was 1800 two seat microlights sold in Europe last year.

[Prop swinger]

What about NPPL?
Would the CAA accept an application from a new organisation willing to train for NPPL only?
As a LAPL can be obtained on the basis of a NPPL, that would be a solution to train most private pilotsYou have to be an RTF to provide training for the NPPL(A) SSEA anyway. Any RTF that trains for an NPPL(A) will be able to train for LAPL(A) after 8/04/15.

[xrayalpha]

MJ

Is that no new NPPL SSEAs after April, so no more conversion route via NPPL to LAPL. Or if someone has an NPPL M can they still get an SSEA on it after April 2015?

[Mach Jump]

Technically you can't add an SSEA class rating to an NPPL(M), you convert it to an NPPL(A)SSEA

From 8th April 2015, if you already have an NPPL(A)SSEA you will continue to be able to convert that to a LAPL.

As far as I know, the original CAA policy that no NPPL(A)s will be issued after 7th April 2015 has not changed.


MJ:ok:

Ps. In my opinion it would make sense to continue to issue the NPPL(A), if only for those who just want to fly Annex II SSEA aircraft, but also to ease the transition from NPPL(M) to the LAPL.

Of course, there is still time for this to change before April. Four months is a long time in the world of CAA/EASA!:rolleyes:

[Mach Jump]

Here's a question that occured to me when reading the Information Notice.

The requirement is to be amended so that an examiner may test a student to whom they have given up to 25% of the instruction required for the licence, rating or certificate.

What, exactly will this mean?

25% of the total time the student takes to complete the course?

25% of the total 'dual' time the student takes to complete the course?

25% of the minimum time required for the course?

25% of the minimum 'dual' time required for the course?


MJ:ok: