A number of people have been concerned regarding the tone and content of the letter that effectively washes their hands of any responsibility.
We have seen licence changes in the past, and where these are a direct result of legislative changes, licences have been re-issued free of charge, but this time holders are expected to pay, not just a re-issue fee, but an initial issue fee. For an organisation that is concerned with workload, why is it inviting people to go through a double change which increases the workload even further.
All of the guidance letters have contained errors, one hinted that pilots had not entered into the spirit of JAR-FCL and obtained a JAA licence, yet it was the very same CAA that 10 years earlier had advised industry that there was no need to obtain a JAA licence as the National licence would be valid and available for the lifetime of the holder. Furthermore, why would anyone in their right mind want to pay more for less?
The EASA regulation states that the NAA is responsible for replacing both JAA and National licences with EASA licences, and I would have thought that they had a duty of care to ensure that all pilots are correctly licensed; it would appear they have delegated this responsibility to individual pilots.
At the professional level the changes will be minimal but for private pilots the level of complexity has assumed nonsensical proportions following successive bungled law changes and poor administration surrounding the introduction of new licences. ICAO Annex 1 recommends mutual recognition of contracting States licences at the private level therefore, all that is required is to re-issue every existing ICAO PPL holder with an EASA one; we have after all maintained them in accordance with JAR-FCL for over 10 years. They could even have sent out paper stickers with these letters with EASA printed on them! What else is going to change at the end of the day?
2 years ago they re-issued every licence free of charge to include the newly introduced ICAO requirement for English Proficiency, but failed to include the already published EASA requirement for a validity date. The whole process now has to be repeated to rectify this omission, an ideal opportunity to comply and change all the licences in one shot!
It appears the CAA are hell bent on making the transition as complicated as it can be, safety doesn't come into the equation. What is most concerning is that material of a dubious quality is coming from the Belgrano, without it appears any form of checking or monitoring from above. Policy was once made by pilots and promulgated by the Policy Dept, now it appears non pilots make policy and promulgate it without supervision.