At a press meeting past Jan. 11th 2011, Mr. Goudou stated in front of about 50 European journalist and representatives of international press agencies that
"we have realized, much to our surprise that there are more than 68,000 pilots in Europe who could be affected by this rule" (Mr. Goudou was referring only to FAA licences holders); Furthermore Mr. Goudou stated
"that in light of the unprecedented concert of protest, EASA is willing to use the grace period until 2014 to launch and finance a study to understand the differences between FAA (american) licenses and Current European licenses".
Therefore, EASA has recognizedthat that EASA advised the commission without having a clear understanding of the situation, from a safety, economic or technical standpoint.
If it where not so dramatic it could best fit the the joke of the day section !
ICAO Annex 1 excerpt:
1.2.1 Authority to act as a flight crew member.
A person shall not act as a flight crew member of an aircraft unless a
valid licence is held showing compliance with the specifications of this
Annex and appropriate to the duties to be performed by that person.
The licence shall have been issued by the State of Registry of that
aircraft or by any other Contracting State and rendered valid by the
State of Registry of that aircraft.
The FCL is not respecting internatinal rules accepted and signed by all EU countries.
The FCL impose to maintain 2 licence (one based on the ICAO rules issued by the state where the aircraft is registered and a second one based on residence of the pilots)
A rule based on domicile is not only a discrimination, but also a total non-sense ! and never EASA proof a safety progress.
Write to your MEP's, we already have done it, and we will keep doing it as long the text is not voted, it's not too late to act.
EASA has not yet released the final text to the parlement.
Here are some arguments from the MEP's to our written:
- BASA agreement are signed !!
Yes that's trough a BASA agreement was signed on the June 30, 2008
the content of this agreement not yet in force is all about technics like aircraft airworthiness, repairs, reconizing from aircraft and parts certification.
Yes, the article 2, The parties may agree to additional areas of cooperation and acceptance by written amendment of this Agreement in accordance with Article 19;
This Article 19 is all about technic matters
AND NO, this BASA is absolutely not applicable for crew licencing !
FAA confirmed that there is NO disscussion and NO draft with regards to crew licencing or licences validation / convertion
- Delay, the EU will set new delay before application of the new rules until BASA agreements are in force
NO, that's not the true,
The modified text say specifically (Article 10, point 4) Member States may decide not to apply the provisions of this Regulation to pilots holding a licence issued by a third country involved in the non-commercial operation of aircraft specified in Article 4(1) (b) or (c) of Regulation (EC) No 216/2008 until 8 April 2014.
- May decide, is no obligation form in the text
- Until 8 April 2014 is no option given for a later date if licences validation / conversion agreement are not in force at this date.
- This rule is also in force in the USA where FAA require US based pilots to fly with FAA licences
Yes, if flying on N-registration
NO if flying on G, F, PH, HB registration, but anyway I thing they are just a few pilots flying in the US with a G-reg ! (maybe a few F in the Caribbean
Write to your MEP's and urge them to reject this text.
If you need some more arguments:
- Expect € 15'000 and above for only IR conversion
- 2000+ pilots jobs lost (corporate pilots)
- Mr. Goudou misinformed the commission (TRAN meeting Nov. 9, 2010)
- 850 millions Euros market value lost of GA aircraft (due too massive increase of aircraft for sale, so your G-reg will suffer from this too.)
- 200 millions Euros turnover lost by manufacturers, repair station and related jobs lost
- Working group on FCL 008 is still far away from a substantial and viablee improvement for a relevant and cost-efficient EU IR rating
- Hypothetical BASA agreements, even IF a base would be drafted, which is not the case yet, 3 years is far too short to complete a such agreement
At the TRAN meeting Nov 9, 2010, Mr. Goudou stated that he will support the maintain of the UK IMCrating;
There is no mention about it in the proposed text, what about the issued rating and rules for the PPL willing to pass this rating ?
This is just another unrespected statement from the EASA.
Below just released the answer given by Mr. Kallas to the question asked by MEP Mr. van Dalen vice-president TRAN:
1 February 2011
E-010837/2010 Answer given by Mr Kallas on behalf of the Commission The Commission is aware of concerns raised by holders of pilot licences issued by third countries.
Current EU legislation
(1) as adopted by the Parliament and the Council on common rules in the field of civil aviation and establishing a European Aviation Safety Agency mandates the Commission to regulate the issue of third country licences for pilots residing in the European Union (EU). Pilots residing in the EU and involved in the operation of an aircraft into the EU need to comply with European licensing requirements. These may be satisfied either by specific rules or by the acceptance of licences issued by third countries in case of operating non‑EU‑registered aircraft.
The Commission's proposal for the regulation on flight crew licensing (pilots) largely reproduces the standards commonly applied in Member States and developed previously by the International Civil aviation Authority (ICAO) and the Joint Aviation Authorities (JAA). Based on the opinion issued by EASA on 26 August 2010, the Commission's proposal was discussed on 7-8 December in the Committee established by Article 65 of Regulation No 216/2008 (‘EASA Committee’). The Committee unanimously agreed on a slightly modified text of the regulation on 8 December 2010.
The modified text proposes a transitional period until April 2014 for pilots flying in the EU with third-country licences (e.g. licences issued by the US Federal Aviation Authority). This time will allow for further discussions on the recognition of non-EU licenses within the framework of bilateral aviation safety agreements between the EU and third countries.
Such agreements have already been signed with the United States, Canada and Brazil but have not yet entered into force. Once these agreements enter into force, the necessary work can be done towards an agreement on simplified conditions for mutual acceptance of pilot licences issued by those third countries.
(1)Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC (Text with EEA relevance), OJ L 79, 19.3.2008.
