found this from the IAOPA europe
Flight Crew Licensing
EASA’s deadline for comments on its plans for Flight Crew Licensing has been extended to December 15th, largely because its proposals on Operations have not yet been published, and one should not be considered in isolation from the other.
Jacob Pedersen of AOPA-Denmark reported to the IAOPA-Europe Regional Meeting in Zurich in October that there’s a lot of good in the EASA proposals. In particular, EASA will revert to ICAO medical requirements, which the JAA abandoned, causing much misery and dislocation in general aviation. All those who lost their licences to JAR medical requirements would be able to retain them under EASA. It also reintroduces the PPL instructor, killing off the need to show a “CPL level of theoretical knowledge” before you can be paid to instruct.
But there is a certain amount in the NPA that is truly dreadful and is being strongly opposed by IAOPA. The proposals would effectively render it impossible to base an N-registered aircraft in Europe and fly it on an FAA licence, which would render the FAA Instrument Rating useless here. IAOPA’s position is that the reasons why so many FAA licenses, ratings and aircraft are in use in Europe is because of the manifest deficiencies of European regulation, and these fundamental problems cannot be ignored. European pilots have been forced by bad regulation to go abroad for their flight training, and the solution is to improve the regulation, rather than simply to ban the better system.
It is expected that the Operations proposals will make the problem worse, requiring foreign-registered aircraft to conform to EASA rules, even if they invalidate their Certificates of Airworthiness. Removing the opportunity to operate on an FAA IR would be especially harsh as EASA’s own moves towards a reasonable and feasible IR seem to be running into the sand. EASA cannot be allowed to take the easy option (for them) of banning third country aircraft and licenses. Such an action would impose massive costs and disruption on general aviation, and make flying in Europe less safe.
IAOPA-Europe was making common cause with the business aviation lobby, with flight training organisations and with companies like FlightSafety, who would be effectively forced to close down if EASA has its way.
Five more concerns with the EASA FCL Proposal
Apart from foreign-registered aircraft and licenses, there are five main issues of concern in the 647-page FCL document on which IAOPA Europe has established a common position.
More paperwork
The extensive requirement for management and quality control systems will be completely overwhelming for small training organisations. The current “registered facilities” will have to be fully compliant with much more onerous regulations, while the definition of “commercial operation” seems to include a number of activities that used to be considered non-commercial. The full text on this is, however, not yet available.
LPL safety?
Some of the provisions of the new Leisure Pilots Licence for SEP aircraft up to 2000 kg would seem to raise safety issues. The basic LPL allows a pilot to take a passenger after 20 hours flying, ten of them dual. Is it sufficient? Emanuel Davidson of AOPA-France said the French brevet de base, with similar requirements, was not noticeably more dangerous than an ICAO-compliant licence. While some delegates thought the law should prevent a 20-hour pilot flying an aircraft as big and complex as a Seneca V, others thought it should be left to the good sense of the GA industry; no buyer of a Seneca V would fly it with 20 hours experience, and no renter of Seneca Vs would let him have it, either. No law was required.
Examiner checkride
The recurrent “flight with an instructor” is apparently being turned into a checkride with an examiner on every third renewal. With 70 percent of PPL holders not renewing after five years, this was seen as a further disincentive. It will be less useful than an instructor flight, where pilots can practice manoeuvres instead of just flying for a ‘pass or fail’ with an examiner. There is no evidence that the current system was deficient, and in many countries there is a severe shortage of examiners. This proposal is a backward step.
Sensible IR
There is still no solution for a simplified instrument rating targeted at the PPL pilot, and also no solution for the holders of a UK IMC rating who risk losing their current privileges. This problem already has been recognised and EASA is now forming a working group specifically to deal with these issues. Whether anything will come of it is another matter; often, working groups are simply a smokescreen for a lack of action.
What’s in a name?
The name of the Leisure Pilots Licence, which IAOPA has criticised from the start and which EASA’s Eric Sivel told us would be changed, has not been changed. IAOPA has always said that the name misrepresents the nature of the licence and will be a gift to those who would stop us flying and shut down aerodromes. It was promised that the name would be changed to Light Aircraft Pilots Licence, but this has been reneged upon. It is deemed vital to convince the European Commission that a name change is relevant and necessary. Martin Robinson of AOPA-UK stressed the need for delegates to go back to their national authorities and make them aware of IAOPA-Europe’s standpoint on these matters. The national authorities would then reinforce IAOPA’s voice at EASA and the Commission