I have a copy of the template ATO Manual
On initial reading, it contains three worrying developments:
PPL TK study requirement
Early on in the document, AMC FCL.210; FCL.215 is correctly quoted with reference to the 100 hours theoretical knowledge requirement for the PPL course, stating '... the theoretical knowledge instruction should include a certain element of formal classroom work.'
Fine. However, on page 77 of 79 there is the following statement: 'CAA policy is that no more than 33% of the total instructional time may be devoted to computer based training and other media distance learning courses... self-study may be acceptable as an 'other media distance learning course'.
In other words, 67 hours of the 100 hour TK requirement must be conducted in a classroom because 'CAA policy' says so.
Who came up with this policy? What is the safety case for the introduction of the policy? When was the Regulatory Impact Assessment carried out for this new policy and what were the findings?
The minimum classroom requirement for ATPL TK is 10% (65 hours out of 650). Why is it 67% (67 hours out of 100) for private pilots?
67 hours of classroom work will add approximately £1700 to the cost of a PPL.
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Aircraft MEL
If your training aircraft is fitted with a transponder but it is inoperative then no solo student flying is permitted, even if it's just circuit work.
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Exam invigilators
All students sitting PPL exams will have to be overseen by an invigilator. Another cost for the school, and ultimately the student.
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Anyone attending the CAA RTF-ATO roadshow tomorrow (Weds 13 Nov) at Sywell might like to ask the Authority why it is apparently continuing to gold-plate EASA AMCs despite multiple assurances from CAA CEO Andrew Haines that "there will be no more gold-plating of regulations".
Additionally, roadshow attendees might like to ask how this overblown manual and its attendant gold-plating regime sits with Minister without Portfolio Grant Schapps. In a recent statement concerning the GA Red Tape Challenge he said:
"We have identified a number of areas where existing regulations are unduly onerous, or where the CAA could improve its approach. The measures we are announcing today (6 November 2013) will ensure that the regulatory framework is proportionate - deregulating completely wherever possible, and minimising regulation where it is still necessary."
In the same press release, Aviation Minister Robert Goodwill stated:
"...making sure that, where appropriate, we ease the burden on what are often smaller operators and businesses who find navigating a complex regulatory framework particularly challenging."