As all FIs should know, to revalidate your FI Rating nowadays you have to complete 2 out of the 3 options of ‘experience’, ‘seminar’ and ‘test’. This seems to have settled down quite happily over recent years; previously you needed only 5 hours experience every 6 months and had to fly a FI check every 2 years.
However, under NPA-FCL 1-16 (Aeroplane), a proposal is now being made to the JAA that ‘For every second revalidation of a FI(A) rating the holder shall pass, as a proficiency check, the skill test set out in Appendices 1 and 2 to JAR-FCL 1.330 & 1.345’.
This is yet another example of the JAA attempting to shift its own goalposts. There has been no consultation with current FI(A)s or UK/FE PPLs over this proposal - only with the FIEs who, perhaps unsurprisingly as they would be the ones to benefit financially from such a proposal, are in support.
I consider that this is a wholly unsatisfactory situation. No Regulatory Impact Assessment has been conducted and certainly no safety case has been demonstrated. As a result I will be writing to Mike Dobson (UK CAA delegate on the JAA Licensing Sectorial Team) to register my objection to this proposal as he will be the one who will supposedly be responsible for presenting the UK’s view. Should anyone else feel as I do, perhaps they might also care to write to him. His e-mail is:
[email protected] . If you don’t make your views known, don’t then complain if the JAA introduces this unwelcome and wholly unnecessary amendment.