EASA-FCL is coming! Get your comments in!

[NorthSouth]

The EU will soon be taking over regulation of flight crew licensing from JAA. Take a look at the proposals. More details at:

http://www.pprune.org/forums/showthread.php?s=&threadid=135199

[Aim Far]

I just had a quick look through these proposals to see what EASA said with regards the much-longed for European IMC rating, if anything. They don't, of course, say anything concrete.

The proposals focus on the concept that the amount of theoretical knowledge and pilot proficiency would depend on the complexity of the aircraft and the nature of the flight operations (ie commercial or non-commercial). The idea being that there could be one stringent set of requirements for the commercial ops and a less stringent set for private ops in light aircraft, and even the requirements for private ops being set by organisations other than EASA, though not, it seems, national authorities.

On one level, I find that quite encouraging. If implemented in a benign manner, the proposals could quite easily accomodate a full-on IR for commercial ops plus the IMC for private ops. I could see that being used to justify continuing to allow IMC-style flying in the UK which would otherwise seem to be outlawed since CAA will no longer have the power to set FCL rules.

On the other hand, they also mention using the existing JAR FCL rules for "more complex" operations; if IFR, even private IFR, is classified as "more complex" we may all need a full IR even for IFR in the UK.

What do people think?

[FNG]

I was alarmed to see that "A person undertaking training to fly an aircraft must be sufficiently mature educationally, physically and mentally to acquire, retain and demonstrate the relevant theoretical knowledge and practical skill training.", as that probably grounds me.

More seriously, I note the requirement for pilots to be trained in:-

"• flight at critically slow and high airspeeds, and associated “upset” manoeuvres"

Does this mean the return of compulsory spin training?

[shortstripper]

I'm always sceptical so I'm sure we'll all loose out somehow. It does, however, raise the possibility of non CPL exam qualified instructors again at last :D

SS

PS. FNG ... Oh I do hope so :E

[G-KEST]

Have just finalised my own responses to the EASA NPA 2/2004. I had a total of 23 response forms to complete in the format supplied and required by EASA if my submission was to be taken into consideration. The form template takes around 500KB and my own text averaged around 6KB each time or just over 1% of the total amount to be transmitted by email. In my case over 12MB with my non-broadband snail internet/email modem. What an utter foulup in terms of encouraging a reasonable level of response from all of us so-called EASA "stakeholders". What do you think?
Trapper 69
PS - It really is vital for all of us in GA to get a response into EASA either direct or through your own representative body in your own country. Our views must be taken into account as GA represents by far the greatest number of people involved in civil aviation in the EU countries. The EASA website has all the details so if you want to influence policy and escape the usual GA level of apathy get stuck in with a plain Word document comment to your GA representative body such as PFA, BMAA, BGA, AOPA(UK) etc. No need to use the EASA format and a huge emailing phone bill if you send it to the above organisations.

[G-KEST]

I am extremely disappointed at the relative lack of interest in this thread either by contributors or those who just look over it. In many cases in the past apathy has ruled with the result that we are saddled with such disasters as JAR-FCL and the PPL in particular.

Surely this thread would enable folk to pose queries where they can get some feedback?

Your representative organisations such as PFA, BGA, AOPA(UK) and BMAA are the ones that need YOUR input and opinions and they need them NOW since it does take time to collate and submit a collective view that might influence EASA opinion. If you go direct to EASA then hope you have broadband as it will be a looooong download. Input to the GA organisations can be in plain text without using the dreadfully extravagent (in KB terms) EASA response proforma.

Trapper 69
:cool:

[S-Works]

I dont think it is apathy it is more that the damn document is so unweildy and unclear!

[robin]

Quite - I can't see much in there that I can understand, let alone comment on.

Can anyone provide headline points that would indicate areas of concern

[G-KEST]

Sorry to promote another website however Todays Pilot's website home page has a lead in to their own version of a response which they intend to forward to EASA and, hopefully, the GA representative bodies. It aint perfect but it is an awful lot easier than going the EASA response route.
Cheers,
Trapper 69
PS - To moderator do please let this through as it is of vital importance to GA.

[MichaelJP59]

The form template takes around 500KB and my own text averaged around 6KB each time or just over 1% of the total amount to be transmitted by email. In my case over 12MB with my non-broadband snail internet/email modem. What an utter foulup in terms of encouraging a reasonable level of response from all of us so-called EASA "stakeholders". What do you think?

G-KEST, why don't you just delete their unnecessary graphic logo from the header of the Word response form? That reduces it from 510KB to 27KB.

I agree though about the document. It certainly is unwieldy.

- Michael

[Aim Far]

GKEST

I have to say I don't find this document particularly unclear. It says what it says clearly enough. Its just that, as is often the case with consultation papers, it doesn't say very much. Or at least not very much that is concrete.

As an example, they are asking for comments about whether to leave FCL as it is or make more of a distinction between commercial and non-commercial. That has so many possible implications, its difficult to know where to start and the paper gives no guide as to where EASA's thinking is going. Your stance would have to depend on how benign you thought the implementors of the policy would be. Eg it sounds like a great idea to free up private flying from restrictions so maybe I should support it. But it could mean that non-commercial flyers are even more excluded from decisions about airspace, avionics requirements, and general decision making than they are at the moment.

With something that vague, its difficult to make constructive comments because there is nothing to hang them on. If you are going to have consultation, you need something to consult on.

Which means that any response is effectively just a wish list, the same wish list we've always had.

Well OK, here's my wish list.

Let me convert my FAA IR into a JAA one without the full test and groundwork requirements.
Or let me fly round Europe under IMC-style rules, and change the airspace rules to make it feasible.
Give me a radar FIS everywhere, VFR or IFR.
Make it worth my while to get a mode S transponder by giving me traffic and weather info.
Develop GA as a viable transport alternative
Get a single set of rules for all european airspace which are not far off the British version.
Make all airports free to land.
Let the Heathrow airtraffic controllers go on strike so it becomes class G and lets have a pprune fly in there.

[benhurr]

Aim Far

Let me convert my FAA IR into a JAA one without the full test and groundwork requirements.

Fair enough.

Give me a radar FIS everywhere, VFR or IFR.

Kind of makes me think that you might need to do a bit of groundwork.;)

[G-KEST]

Thanks for the advice on reducing the number of KB on the response form template. That will reduce the size of my personal submission to EASA by around 9MB - well worth while.
Trapper 69

[IO540]

I wrote in telling them to make an IR which (like the FAA IR) is appropriate to PPL type private flying.

Not that I think anybody will take any notice. Their questions are too vague to be usefully answerable.

[Justiciar]

People are being very negative about all this. How often in the past have the aviation communities been given the opportunity to have a say. Allowance has to be made for the fact that this is a europe wide consultation and so the document will almost certainly be translated into several different languages.

There are revealed some very interesting ideas in there, such as the possibility that not only will recreational licences be devolved to (or remain with) national organisations but that the requirements may actually be relaxed. Not only that, but differing levels of qualification may exist for different catagories of commercial licence. This could, for example, make it easier for instructors to train and instruct for remuneration.

There are already some benefits beginning to come through in the field of C of As issued by EASA which have Europe wide validity, whic may please the owners of Yak 18Ts in due course!

[trevs99uk]

I like the wish list idea.

But what we as sports pilots really need is one unified european wide standard and that all countries have to accept.
Allowing free access to all pilots and aircraft.
The rules need to cover not only GA , but Microligthing, ballooning and Gliding.

To which...
NPPL to be the European standard for a pilot. with seperate condition for Microlighters, balloonist and glider pilots.
Additional rating can be added like the IMC and Night rating, wobbly prop and retractable undercart.

Night VFR to be the night classification.

The currency rules to changed back to 5 hours every 13 months
with 2 yearly BFR. (who the hell came up with 12 hours in the second year).
Also because somebody missed getting a signature or did,nt do the required hours by the given date should,nt mean having to do a Skills test.
3 landing in 90 day should also allow for a check pilot.
Cross creditation of hours across all licenses.

Medicals as per the NPPL you own Doctors sign off.

aircraft certification as per FAA.
Permit aircraft one set of standards across europe.

Instructors.
Should not need to have a commercial license to instruct.
Instrution from unlicensed airfields as per microlights with a few restrictions.

Insurance requirments set at a sensible level.

o well
there probably more.

[robin]

There seem to be 2 schools of thought

1) that for GA we can get a relaxation of onerous restrictions such as JAR

2) EASA want to take on board all regulation for all flight groups

How do we reflect that in the consultation document when we have little idea of the reasons behind it

In gliding the EASA regs are becoming much less friendly than before, yet there is little sign of them relaxing their powers, and who would trust a governmental organisation to give up powers??

[GK430]

You should bear in mind that many government backed papers out "for consultation" have been rubber stamped somewhere before the "consultation" phase. Either that, or someone has a hidden agenda.

Call me a sceptic:rolleyes:

Why does everything have to be changed - call me old fashioned, but what is so terribly wrong with what we have and understand?

I still think cloud cover should be broadcast in Oktas:ok: :ok:

Oh well, maybe have to vote for UKIP one day and that will mean change!

[Irv]

Robin:
Quite - I can't see much in there that I can understand, let alone comment on.
Can anyone provide headline points that would indicate areas of concern
That hits the nail on the head! It needs the questions separated and discussion of each point so that people can feed off others and suddenly (maybe) realise how it could hit them (or improve their lives!)

I've separated out all 15 questions and been given discussion space for each one separately in a corner of the Flyer server, so people can feed off each others' comments.

There's a whole range of things from the 'how do we define GA' to do we need to licence 'sport/recreational flying' to should we regulate cabin crew and flight dispatchers. Also they seem
to be angling towards having 'corporate aviation' as a group.
See EASA Questions (http://forums.flyer.co.uk/viewforum.php?f=12). If the link upsets the powers, apologies, I'll remove it, but as Robin says, 'separation' and discussion is needed to see
what is going on.

[S-Works]

Irv, thanks for breaking them out but I am still unclear to what a lot of the questions refer. For example the 3rd country question, I am assuming refers to FAA and equivalent type aircraft?

If EASA have authority of these then we could see the end of N-reg aircraft and the use of the FAA IR?

[Penguina]

As comments must be offered by July 31st, I will set aside a day or two in the last fortnight to get my head round all this. Irv - your breakdown helps, thank you.

:bored:

[Irv]

For example the 3rd country question, I am assuming refers to FAA and equivalent type aircraft?
Well - I haven't had time to search for definitions just now, but I read this to mean that a 3rd country aircraft or 3rd country pilots would be those registered or licensed in coutries outside EASA (EASA may include EC treaty states, not just EU, but obviously not USA).
therefore yes, I read 3rd country as 'N' reg, and FAA licences when it is used. I assume they use '3rd' as they are thinking that 1st and 2nd would be from one EASA country in another EASA country, leaving countries such as the USA being '3rd countries'.

Also, the other term is STAKEHOLDER - this means YOU! (anyone potentially effected by EASA)

(GK430 and 'rubber stamps') - I do know EXACTLY what you mean, it is a worry and of course discussion is somewhat directed by the questions they have asked, but on certain 'fronts' (eg; recreational flying and medicals) they might really be looking for an excuse NOT to get involved and may want to show 'x' % of feedback agreed - lesson learned from JAR perhaps which I think was an acknowledged mistake to cover recreational stuff, hence our NPPL soon after.

[smarthawke]

I've just received the latest Today's Pilot in the post today and I see there's an article concerning this very subject - that'll give me something to read over the weekend then!

[WestWind1950]

Also, the other term is STAKEHOLDER - this means YOU isn't there a different expression that can be suggested? this one sounds more like for gold diggers (ok, flying is expensive, and we are looking for our piece of the sky to call our own ;) ). I think a lot of non-English speaking people would have a problem with this word.... I know it threw me the first time I saw it used and I had to read it twice over :bored: any suggestions? the FAR's use "person" I believe... even THAT sounds better then Stakeholders! :uhoh: where's my big dictionary......

Westy

[Irv]

isn't there a different expression that can be suggested?
Yes, I gagged on 'stakeholder' too, but I'm sorry to say I think its too late to 'worry about words' - they've obviously spent a lot of time and money already on those for starters. It's the main 'meat' course we need to tuck into, we've missed the hors d'oeuvres.

[Irv]

Having lived in France a while back I was very suspicious that if anyone downloaded the '.doc' comment form then just deleted the logo (thereby reducing the size down from approx 500KB to 15KB for retransmission back, the powers that be would not accept it as it was "no longer their form". (Some might think this suspicion is odd, but Believe me, that would have happened in France when I lived there!).

So I checked, and this morning received an email from them apologising and saying that the logo can be deleted and still be acceptable. (I notice they didn't say they'd delete it at the source - so I have asked them to amend that for a smaller logo now!)
Irv

[Irv]

same day service!:


Dear Mr. Lee,
As asked I've put a new, smaller logo into the form. Now, it should only take a few seconds to download the doc.

Best regards

IT Assistant
European Aviation Safety Agency (EASA)
Rue de Genève, 12, off. 2/17 B-1049 Evere

[skydriller]

I have just seen this on the Flyer forum (dont always have access to the internet in my job!), and was goint to start a new thread, but found this old thread with search.

So, Just to remind everyone that the closing date for comments is 31st July, so if you dont know about it or still have something to say, you need to get your finger out!!

Check out the EASA Consultation proceedure (http://www.easa.eu.int/rulemaking_en.html) and have your say before its too late!!

Regards, SD..

[WestWind1950]

am I imagining things or did they get rid of that dumb word "stakeholders" ? :cool:

Westy