Flying Instructors & ExaminersA place for instructors to communicate with one another because some of them get a bit tired of the attitude that instructing is the lowest form of aviation, as seems to prevail on some of the other forums!
FCL.025 Theoretical knowledge examinations for the issue of licences
(a) Responsibilities of the applicant
(1) Applicants shall take the entire set of examinations for a specific licence or rating under the responsibility of one Member State.
(2) Applicants shall only take the examination when recommended by the approved training organisation (ATO) responsible for their training, once they have completed the appropriate elements of the training course of theoretical knowledge instruction to a satisfactory standard.
and from the AMC
Quote:
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.
Since it mentions ATOs, I assume this must be for the PPL ?
Am I correct in saying that ATOs are just the replacement for RFs (by 2014), and that the current system of FTOs will continue ?
I understand that in Canada there is a requirement for 45 hours of groundschool (and that many of the local technical colleges can offer this course) - but they just do one exam at the end of it, with a pass mark of 60%.
Who will decide the number of hours(100, or whatever), if it comes to this ? I have courses for each subject: my split in the classroom is:
AL - 8 hours AGK 14 HPL 4 FPP 8 Met 10 Nav 12 RT 8
....giving a total of 64. That's assuming no prior knowledge (or any prior reading, a wise precaution !). So where has this 100 hours figure come from ? Seems very artificial. I would have though 45 to 50 would be better.
And who will do it ? I am a RF for TK only, it works well. I certainly do not want a bill for the minimum CAA approval fee of £1,000 for ANY course approval post EASA, just to do something I already can do now.
The other issue is - just who will do this ? Most club instructors are just not interested in doing ground studies, and I think there are only 4 or 5 of us RFs for PPL Theoretical Knowledge in Standards Doc 30 when I last looked.
If it ends up being the preserve of the ATPL/CPL TK FTOs doing this as Distance Learning for the PPL it is a lot of expense for no gain, especially as there are at least 3 complete sets of PPL textbooks out there for people to self-study already. If they operate under the "10% done in the classroom" rule I can see them charging say £500 for a course,for in effect 10 hours effective tuition, which could only be done at certain locations.
Is there a Working Group anywhere actually looking at this ?
‘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.
Has the competent authority for the UK established what this period will be?
Am I correct in saying that ATOs are just the replacement for RFs (by 2014), and that the current system of FTOs will continue ?
No, under EASA all FTOs become ATOs and have until April 2014 to become fully compliant. RFs have until April 2015 to become ATOs. All organisations approved to conduct training for engineering, pilot licences type ratings etc will be ATOs
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Who will decide the number of hours(100, or whatever),
The ATO.
Quote:
once they have completed the appropriate elements of the training course of theoretical knowledge instruction to a satisfactory standard.
The emphasis is on satisfactory standard not a specific number of hours
Quote:
I certainly do not want a bill for the minimum CAA approval fee of £1,000 for ANY course approval post EASA, just to do something I already can do now.
If you want to do anything that requires an ATO approval, that's the starting price.
Quote:
Has the competent authority for the UK established what this period will be?
If so they have not published it but that will probably accompany the new exams when they finally produce them.
Quote:
Is there a Working Group anywhere actually looking at this ?
Very unlikely!
Most of this stuff is laid out on the CAA website for all to read.
The amount of training is not up to the FTO, it is set at 100 hours in AMC1 FCL.210; FCL.215. Of course, you could put forward an alternative means of compliance with fewer hours, I understand that the CAA will give it due consideration for as little as £2,000.
That's what I was looking for but missed it in the rather appallingly laid out document. These bits add some relevance:
Quote:
This theoretical knowledge instruction provided by the ATO should include a certain element of formal classroom work but may include also such facilities as interactive video, slide or tape presentation, computer-based training and other media distance learning courses. The training organisation responsible for the training has to check if all the appropriate elements of the training course of theoretical knowledge instruction have been completed to a satisfactory standard before recommending the applicant for the examination.
Quote:
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.
Ah, BEagle. Thought you would fly in at some point.
The CAA do have a habit of following these recommendations, be they from JAR or EASA, so it may be that they can be ignored...but chances are that they will not ?
I think there is some merit in simplification of the number of exams; the current number does encourage a "byte sized" approach to learning. When I started there was Air Law, Nav, Met, and AGK. And it was not long after Nav & Met had been split into two exams, so 12 months before there were just 3. A "Nav" and a "Technical" paper would be ideal. How many people interested in a PPL give up when 7 exams are mentioned, especially when some b/s merchant says that they "are like doing a GCSE".
The FAA PPL requires one exam of 60 questions - and that is ICAO compliant, and in Canada it is one exam of 100 questions, with 45 hours groundschool, so I think it is a move in the right direction.
100 hours groundschool is over the top and if it is just watching videos etc not a lot of point. A more modest figure in a classroom could be far more benficial.
The problem is that there is a fundamental difference in the treatment of AMCs between JAR-FCL and Part-FCL. Whilst it was true that large chunks of the JAA AMCs could be and were ignored, the same is not true under EU law. Where there is only one AMC, that is the only acceptable means of compliance. Anyone is at liberty to put forward to the competent authority a proposal for an alternative means of complying with the regulations which, if accepted, will be published (in the UK's case in CAP 804) and available for everyone to follow.
At the moment, the only acceptable means of complying with FCL.210 and FCL.215 is detailed in AMC1 FCL.210; 215. There may well, in the future, be other means that do not include 100 hours of theoretical knowledge instruction but they will not be usable until accepted and published by the competent authority. The UK's proposed fee for processing an alternative means of compliance, whether accepted or not, has been quoted to me as £2,000.
if accepted, will be published (in the UK's case in CAP 804) and available for everyone to follow.
Not quite the way EASA see it:
Quote:
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 you comply with the AMC you have complied with the Law and the CAA cannot be more stringent.
Quote:
The AMCs issued by the Agency are not of a legislative nature; therefore they cannot create obligations on the regulated persons, who may decide to show compliance with the applicable requirements using other means. However, as the legislator wanted such material to provide for legal certainty and to contribute to uniform implementation, it must commit competent authorities so that regulated persons complying with an Agency AMC must be recognised as complying with the law.
So, if an enterprising individual came up with an alternative to the 100 hour TK groundschool requirement and got, say, 100 schools to append their names to it, the CAA could be spurred into action at a cost of £20 per signature ?
jez - they could be spurred into considering it but not necessarily into accepting it.
Whopity - Good spot! perhaps someone should point out to the UK CAA, therefore, that one of the reasons for having CAP 804 is invalid.
Quote:
1.3 This CAP 804 is:
• a guide to the European flight crew licensing rules;
• the means by which the CAA notifies its information, guidance and Alternative Means of Compliance with the European Rules; and
• the means by which the CAA notifies requirements and guidance material for National flight crew licences.
The FAA PPL requires one exam of 60 questions - and that is ICAO compliant, and in Canada it is one exam of 100 questions, with 45 hours groundschool, so I think it is a move in the right direction.
A 100 hours of ground school is R-I-D-I-C-U-L-O-U-S.
Actually, the whole concept of having to go to ground school (Canadians and JAA/EASA) to sit a theoretical knowledge exam is flawed. Even having to be signed off by a ground instructor (as in FAA land) is over the top.
There are sufficient materials available for self study. The exam fee itself is probably a sufficient deterrent for unqualified applicants.
The people who thought up these rules are either self serving flight school owners or people who haven't got a clue about the theoretical background required from a competent private pilot. Probably both.
The outcome will be that
- less and less people are going to become part of our community, making facility costs (from club aircraft to airfields) more expensive and eventually unbearable.
- ATO's producing their own video material of substandard quality to comply with this stupid rule while desperately competing for the last remaining PPL candidates.
Thank you Pat Ricketts for ruining it for all of us.
Last edited by proudprivate; 2nd Sep 2012 at 02:12.
Actually from a future business issue this is not good news, however as an instructor I get so tired of motivating students to do the exams, a little structure for the study would not be a bad thing. I have students that spend more time booking their summer holiday than opening PPL books, so from that stance I think its good, but many will be put off because of the formalities and cost of it all, which in the long run will be bad. However good schools will just build it into the course and cope with it. Lets maybe see it as a positive and not get too down about it. This I would think is only a small issue in the overall picture of GA PPL training surving the next few years.
I get so tired of motivating students to do the exams, a little structure for the study would not be a bad thing.
Let's see if we can follow your logic here. You have difficulties in motivating students to study for the exams. That can have many reasons, but lets focus on the charitable ones, i.e.
- the exam questions are dross and require the use of a question database to memorize all the stupid trick questions that are in there.
- a significant part of the subject matter is irrelevant to flight or practical flight safety.
And your solution is...
...give them 100 hours of ground school in it and make that requirement compulsory.
How exactly would that motivate students to go for their license ? I for one wouldn't have had a license if that had been the requirements.
Let's look at the business model here. A motivated UK PPL candidate needs to budget £10,000 + 60-ish hours for flight training + a significant amount of time lost on rescheduling because of changing weather. That means balancing spare time (spent with family and friends) with a reasonable income. With 100 hours of ground school, it becomes an unsurmountable task. That is precisely the reason why there were so few JAA PPL IR candidates.
Has it occurred to you that some of the Brussels (and London) bureaucrats actually have as an objective to lower carbon emissions and are using Part-FCL to get the job done ? For your's sake, I hope you don't have to make a living as flight instructor, because it's looking bleak, and it's not just the avgas price, believe me.
Last edited by proudprivate; 2nd Sep 2012 at 06:48.
