NPA 2015-20 : a chance to get rid of dead wood
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B61 is entirely right.
Nevertheless it seems to me that the BTO achieves almost the same thing.
Edit: According to the document called NPA 20,
The approval is automatic, it is in fact a registration process, not an approval process. The difference with RF is that the approval automatically granted may be withdrawn at a later date.
To set up a BTO you don't even have to have a fleet (according to NPA20). Any Instructor can setup a BTO, with two documents
- A training program which must be approved, but you may use one which has already been approved.
- A safety policy which should be easy to develop for a single instructor BTO.
It's probable that every instructor will soon use the same two documents.
A single instructor may be the legal representative of himself (he or she is anyway), there is no requirement to setup a company (although that may be advisable for legal protection).
The paperwork is minimal: keep some record of your training (I suppose you would do it anyway) and spend some time each year to self audit your operation (e.g. check that your ratings are current, that you paid your insurance bills etc.)
Unless I have missed something, this BTO thing will be my Chrismas gift.
A last question: what is Basic IR?
Nevertheless it seems to me that the BTO achieves almost the same thing.
Edit: According to the document called NPA 20,
The approval is automatic, it is in fact a registration process, not an approval process. The difference with RF is that the approval automatically granted may be withdrawn at a later date.
To set up a BTO you don't even have to have a fleet (according to NPA20). Any Instructor can setup a BTO, with two documents
- A training program which must be approved, but you may use one which has already been approved.
- A safety policy which should be easy to develop for a single instructor BTO.
It's probable that every instructor will soon use the same two documents.
A single instructor may be the legal representative of himself (he or she is anyway), there is no requirement to setup a company (although that may be advisable for legal protection).
The paperwork is minimal: keep some record of your training (I suppose you would do it anyway) and spend some time each year to self audit your operation (e.g. check that your ratings are current, that you paid your insurance bills etc.)
Unless I have missed something, this BTO thing will be my Chrismas gift.
A last question: what is Basic IR?
Last edited by 172510; 27th Dec 2015 at 14:00.
The Basic IR Concept Paper is here: http://easa.europa.eu/system/files/d...0Issue%202.pdf
The UK CAA issued an Information Notice concerning NPA 2015-20 yesterday: http://publicapps.caa.co.uk/docs/33/...ice2015120.pdf
The UK CAA issued an Information Notice concerning NPA 2015-20 yesterday: http://publicapps.caa.co.uk/docs/33/...ice2015120.pdf
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I have had a look at the CAA Information notice.
They are trying to goldplate the BTO requeuirement with b/s like "head of training" and "safety representative" even when it only states "if applicable" in the NPA.
Looks like it is the usual CAA reaction to go for the more extreme end with maximum regulation of an EASA requirement which is actually quite flexible in intention.
172510 has the right idea in that any instructor should be able to set himself up as a BTO.
The important bit to me is that some corporate body should NOT be able to set themselves up as a BTO if they do not have anybody in place who can actually provide the training.
Having some unqualified Rsole set up as "accountable manager" of some corporate shell with approvals, and then use those with the qualification to do the job on some zero hours contract, is unacceptable.
When is someone at the CAA going to grasp that the PPL is a RECREAtIONAL licence, not the first rung of a ladder to a CPL, and does not require organisations to be set up to provide the civiliN equivalent of CFS, or playing at being a public transport operator ?
They are trying to goldplate the BTO requeuirement with b/s like "head of training" and "safety representative" even when it only states "if applicable" in the NPA.
Looks like it is the usual CAA reaction to go for the more extreme end with maximum regulation of an EASA requirement which is actually quite flexible in intention.
172510 has the right idea in that any instructor should be able to set himself up as a BTO.
The important bit to me is that some corporate body should NOT be able to set themselves up as a BTO if they do not have anybody in place who can actually provide the training.
Having some unqualified Rsole set up as "accountable manager" of some corporate shell with approvals, and then use those with the qualification to do the job on some zero hours contract, is unacceptable.
When is someone at the CAA going to grasp that the PPL is a RECREAtIONAL licence, not the first rung of a ladder to a CPL, and does not require organisations to be set up to provide the civiliN equivalent of CFS, or playing at being a public transport operator ?
Perhaps we should analyse what has been acheived in the 15 years that Registered Facilities have been in existance. There has been no measurable improvement in safety and no improvement in quality of the end product however; over the same period costs have soared and numbers reduced by around 50%. On top of that, the Authority totally lost control of the "Registration Process" and were forced to go out to Industry to find out who was and wasn't registered. Clearly registration was of little consequence.
Most instructors teach as they were taught to do on their FI Course, playing with the syllabus has little or no bearing on what or how they teach.
It was never the JAA's intention to include the PPL in their plan, consequently there was no plan to produce exam questions. The EASA PPL is a myth, it is nothing more than a comon label on a National licence which varies considerably from State to State and follows historical precident rather than any centralised European standard or concept.
FIs are probably better trained now than they ever were, so why are they not trusted to do their job without being subject to commercial pressures that exist in any RF or BTO? Such pressures can actually undermine their professionalism.
Policy statement for a one man BTO; Not to have an accident! If we had a check list for going to the toilet, we would all need twice as many pairs of trousers!
EASA has reduced the experience requirements for FIC instructors and Examiners by 80%, this cannot be compensated for by encasing training in a cocoon of bureauracy and manuals.
Option 2 has been tried and failed!
Most instructors teach as they were taught to do on their FI Course, playing with the syllabus has little or no bearing on what or how they teach.
It was never the JAA's intention to include the PPL in their plan, consequently there was no plan to produce exam questions. The EASA PPL is a myth, it is nothing more than a comon label on a National licence which varies considerably from State to State and follows historical precident rather than any centralised European standard or concept.
FIs are probably better trained now than they ever were, so why are they not trusted to do their job without being subject to commercial pressures that exist in any RF or BTO? Such pressures can actually undermine their professionalism.
Policy statement for a one man BTO; Not to have an accident! If we had a check list for going to the toilet, we would all need twice as many pairs of trousers!
EASA has reduced the experience requirements for FIC instructors and Examiners by 80%, this cannot be compensated for by encasing training in a cocoon of bureauracy and manuals.
Option 2 has been tried and failed!
BTO.GEN.200 and its associated AMC identify BTO personnel. The rule requires the appointment of a representative acting as focal point for the CA.
The BTO, through its legal representative, is responsible for the allocation of sufficient resources in order to ensure activities and essential functions.
In addition, the AMC identifies a head of training responsible for ensuring compliance with the Part-FCL training requirements.
The AMC also specifies that the legal representative is responsible for the safety awareness function and may be assisted by a designated safety adviser.
Finally, it should be noted that GM1 BTO.GEN.200 allows combinations of the above functions in order to offer the maximum flexibility to adapt the BTO concept to small entities (including one-man entities).
The expression 'legal representative' came at French insistence and was not supported by other Task Force members.
Option 2 is the only feasible way by which an RF can be freed from the more formal ATO requirements within the available timescale. Options 1 and 3 would require a Basic Regulation amendment - which would probably take 5 years under European legal processes....
The BTO, through its legal representative, is responsible for the allocation of sufficient resources in order to ensure activities and essential functions.
In addition, the AMC identifies a head of training responsible for ensuring compliance with the Part-FCL training requirements.
The AMC also specifies that the legal representative is responsible for the safety awareness function and may be assisted by a designated safety adviser.
Finally, it should be noted that GM1 BTO.GEN.200 allows combinations of the above functions in order to offer the maximum flexibility to adapt the BTO concept to small entities (including one-man entities).
The expression 'legal representative' came at French insistence and was not supported by other Task Force members.
Option 2 is the only feasible way by which an RF can be freed from the more formal ATO requirements within the available timescale. Options 1 and 3 would require a Basic Regulation amendment - which would probably take 5 years under European legal processes....
Seems to me we could save ourselves a lot of grief by just issuing BTO Approvals with every Full Instructor rating, automatically nominating that Instructor as 'Head of Training', 'Legal Representative', and 'Accountable Manager'.
If Individual Instructors then want to work together, as a group, and form a multi-instructor School, the onus would be on them to combine their BTOs, produce standard procedures, and nominate the roles amongst themselves, or they could choose to work as individual BTO's, from the same building!
New Instructors would then have to nominate a Full Instructor(BTO) under who's supervision he would operate, until upgraded.
Keeping things simple, and, at the same time, complying with Option 2 isn't rocket science. It just requires that the people who will implement the new rules, have the will to do so..
MJ
If Individual Instructors then want to work together, as a group, and form a multi-instructor School, the onus would be on them to combine their BTOs, produce standard procedures, and nominate the roles amongst themselves, or they could choose to work as individual BTO's, from the same building!
New Instructors would then have to nominate a Full Instructor(BTO) under who's supervision he would operate, until upgraded.
Keeping things simple, and, at the same time, complying with Option 2 isn't rocket science. It just requires that the people who will implement the new rules, have the will to do so..
MJ
Last edited by Mach Jump; 24th Dec 2015 at 16:37.
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Can we expect this to happen, latest 2018 or will it be postponed? Opts outs here, opts out there, this is a joke.......
Easa and its bureaucrats have failed royally, thanks to the British and the French who have fought this battle....OK for option 2, without delays, the industry is in a bad shape, the bureaucracy is wiping out everybody around...
Dernière option pour l?EASA? ? aeroVFR
http://www.easa.europa.eu/system/fil...%202015-20.pdf
Easa and its bureaucrats have failed royally, thanks to the British and the French who have fought this battle....OK for option 2, without delays, the industry is in a bad shape, the bureaucracy is wiping out everybody around...
Dernière option pour l?EASA? ? aeroVFR
http://www.easa.europa.eu/system/fil...%202015-20.pdf
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Thanks for the link to aeroVFR. Tres informatif!
Interesting to see what the French for GA Road Map and Basic Training Organisation are. Great selection of webcams.
TOO
Interesting to see what the French for GA Road Map and Basic Training Organisation are. Great selection of webcams.
TOO
