Why does everything take so long

[Fuji Abound]

The talk of a realistic PPL / IR has been going on here for as long as I can remember. It has extremely important safety implications. In my opinion the authorities may well be negligent by effectively preventing private pilots gaining the necessary qualifications to operate safely in Europe given the type of weather we enjoy! (Discuss?)

Four of five months ago there was an announcement in Pilot that AOPA were in discussions with the CAA. I wrote to them some while later asking them what the outcome had been. I still have not received a reply.

In "Loop" further recent discussions were reported with EASA(?) and it was suggested the matter was under consideration.

Well it has been under consideration by the authorities for as long as I can remember whilst in fact over the last ten years it has become more difficult to get the rating not less. It is pathetic. If we ran a business that way it would have gone bust years ago. Why do we allow our regulatory authority to be so hopelessly ineffective?

[Genghis the Engineer]

I'm not going to defend the position, but I can go some way to explaining it. I've been negotiating rulechanges with CAA (on behalf of various GA players) for quite a few years, and with more success than most - but a great deal of frustration.

The order in which you negotiate a rulechange with the CAA is something like this:-

(1) Put together your proposal, together with justification (which primarily needs to show a minimisation of liability to the CAA).
(2) Via an appropriate organisation's representation put the proposal to the relevant regular steering group - these meet somewhere between 3 monthly and annually.
(3) Probably wait some months (my personal record is over 18) for CAA to decide what they think.
(4) Repeat stages (2) and (3) as many times as necessary to get it right.
(5) CAA will then put the proposed rulechange firstly to it's senior management, then out to public consultation. This takes a few more months.
(6) If there isn't major disagreement from anybody, make a few tweaks, and a few months later it becomes law.

The fastest I've ever managed a significant rulechange was 18 months, and 5+ years is not unusual. Of course, when it gets that long, there are generally personnel changes, industry reps losing the will to live, and a constant need to re-educate people at CAA and elsewhere in what you wanted and why. There's also the risk that the steering group that you were routing it through might get abolished en-route, requiring you to start again.

It's an absolute nightmare of a system, but generally NOT the fault of the individuals with the CAA. The organisation's senior management have never seen any benefit in either delegating real power to it's working level managers, nor in a major streamlining of the system. (There are many ways in which it could be). That said, it is getting harder, as the authority is becoming less competent, meaning that you are often negotiating with staff who don't properly understand what you are telling them - this is particularly frustrating.

EASA has streamlined it a bit, but then messed the whole thing up further by insisting that they'll now only negotiate with pan-european organisations. So, your proposals have to go through 2 or 3 layers of "organisation" outside EASA before you can start to negotiate properly.

I am not defending this process, as an aerospace manager I can see many ways of making it all work far better - and I suspect so can much of CAA's middle management. But, that's how it is at the moment.


In the meantime, if you want to negotiate with either CAA or EASA you must:-

- Understand the process, and who is involved in it as far as possible.
- Speak on behalf of a UK/European organisation, and have their political backing.
- Have an absolute and dogged determination to make it happen, and be prepared for several years of repeating yourself at meetings to changing or bewildered authority staff.
- The ability to justify what you want in excruciating detail, with particular reference to achievability, minimising liability to CAA/EASA, and precedent.

G

[Aussie Andy]

If we ran a business that way ... They aren't a business...

Why do we allow or regulatory authority to be so hopelessly ineffective? Is there another way? I don't think there are many examples of government bureaucracies / regulators that behaves otherwise. It's like turning an oil tanker.

It's just a different culture than in business and it is not about to change. Not all business changes quickly or is always responsive either... look at e.g. Telewest, BT etc :) And their job is in some ways more difficult than in business, in that they are not autonomous and cannot simply decide then act: even when there is strong resolve to change things, it can take ages to liase with other government bodies (UK and EU and others), cater for regulatory assessments, impact studies and the like.

I don't disagree with what you want, nor that we should have it, but I just aint going to burn too many cycles wishing for the impossible, i.e. a swift response to what we perceive we want: it is the nature of these organisations to ponder, attempt to balance a range of external interest (and their own!), and to move slowly.

Let's put our energy into useful endeavours, like supporting the AOPA and others in their efforts to lobby and influence the regulators on our behalf by making the case for GA and aspirant PPL-IR holders such as ourselves - I just think this'll be more useful than wishing for the impossible, no matter how frustrating!

Andy :ok:

[IO540]

Last I heard on this, from a JAA official at a meeting, was that some country's representative always vetoes any reduction in the IR requirements. Germany has been quoted a number of times as the culprit. And JAA (will be EASA when they take over FCL) need a consensus; it isn't a majority vote.

Various proposals have been prepared, reportedly perfectly workable, including ones for accepting FAA licenses/ratings. They just get vetoed by somebody and that's the end.

One problem is that GA is practically nonexistent outside a few EASA states. The incentive just isn't there to do anything. If private pilots were rich (to the extent of having powerful friends) then something would get done, but the rich pilots (with powerful friends) fly around in turboprops and bizjets and they usually have the full commercial licenses, so there is no pressure to improve matters on the "PPL/IR" front.

Also any proposal that for example UK AOPA is going to back needs to satisfy the requirements of the training industry.

[Genghis the Engineer]

Presumably the way ahead would be a "PPL/IR", which looks something like a cross between the UK-IMC and FAA-IMC, and is ONLY valid for use with PPL privileges, requiring the full JAA/IR for any commercial use. That would presumably avoid any concerns about airline safety.

Of course, and as I said, the problem isn't saying what a good idea it is, but successfully negotiating it.

G

[Fuji Abound]

Interesting comments as ever and not too surprising.

Oil tankers like government agency do move slowly but ten years - thats more like it is in dock.

AOPA - yes, but how long do they need.

Any chance of it changing - sadly no.

Worth having a moan about - well yes, because it is unacceptable and we are paying these people. If enough of us really sort to do something about it change might come - as it is I doubt I will ever see it - but I fully intend to go on moaning about it :D

[IO540]

Something is currently happening, slowly. The incentive is the number of foreign (mostly N) aircraft based in Europe.

UK and Germany have 1000+ each and that is two powerful votes with an incentive to do something.

Getting rid of these planes (which are seen to be depriving the local CAAs of license fees, and depriving flying schools of training income) with a UK DfT-style stick but without creating a legal and admin nightmare is just about impossible, so a carrot is likely to be the only way.

So we might get an accessible IR yet, but it is years away at best. A recent statement by some EASA official was that they want to create an IR which can be swapped for the FAA one. Sounds hugely promising. So long as somebody doesn't veto it.

Unfortunately this tackles just FCL. Certification is the other half; EASA will have to accept FAA cert unconditionally.

However - all you need is just one EASA member State to validate the FAA PPL/IR for use it its own registered aircraft, and not require the aircraft to spend any minimum time in that State, and does not require the owner/pilot to be a citizen, and the need for another IR goes out of the window. This is closer to reality than you might think ;)

[FullyFlapped]

Just out of interest, is there anywhere in the world where either the FAA IR or the JAA IR is not accepted ?

FF :ok:

[360BakTrak]

North Korea? They don't seem to be too welcoming........:}

[IO540]

is there anywhere in the world where either the FAA IR or the JAA IR is not accepted

In ICAO terms, if the IR matches the aircraft reg, probably OK everywhere.

If it doesn't match, there is very little one can do with it. IFR in Class G in the UK is one option I know of (yes, really useful :O )

The Greeks validate an FAA IR, noncommercial flying, in an SX (Greek reg) aircraft, provided the owner is a Greek I believe, and that is currently the best deal I know of. I think there is a time limit, too.

[Fuji Abound]

I understood the JAR qualification (in its present incarnation) is a SEP IR. In other words it is no use in itself for multi operations. Given therefore it is inconceivable that a significant part of the theoretical knowledge is relevant how can its content be justified.

I appreciate it cannot, but at a wider level can a regulatory authority justify setting an exam of irrelevant content. In other words could the Law Society justify requiring theoretical knowledge of Australian law before granting a UK practising certificate.

On challenge I wonder if they could defend their stance - it all sounds a bit dubious to me.

[Whopity]

"I understood the JAR qualification (in its present incarnation) is a SEP IR. "

NO! a PPL IR is an IR on a PPL it is no different from an IR on any other licence, it can be SE, ME, SP, or MP!

The only room for scope in amending the IR is amending the ground examinations to make them more relevant; this process is under way at JAA committee level. Hopefully, this will be completed before the JAA packs up and hands it all to EASA. There will be no change to the flying syllabus.

There has been a lot of discusion regarding the DfT wishing to eliminate N Reg aircraft in the UK. The driving force behind that is not safety based, but is intended to prevent UK pilots from using a FAA IR in the UK!

[Fuji Abound]

"NO! a PPL IR is an IR on a PPL it is no different from an IR on any other licence, it can be SE, ME, SP, or MP!"

Interesting I wasnt sure.

I had always understand an IR on a multi was not valid on a SEP?

[IO540]

Fuji Abound

This stuff doesn't have to be defended; this is politics and, worse, it comes from anonymous committees who have nobody to answer to.

Whopity

The ME IR is an extra 5 hrs (55hrs min training) so there is a slight difference. A SE IR is not valid on a multi.

"The driving force behind that is not safety based, but is intended to prevent UK pilots from using a FAA IR in the UK!"

Indeed but why? Visiting pilots will always be able to. Politics, CAA funding, and lobbying from the flight training industry :O

[Fuji Abound]

I)540 - exactly and that was the difference I had in mind.

.. .. .. and so my practical point was that with a SEP IR all the ATPL theoretical knowledge material aimed at multi operations is pretty academic in any event given that the SEP IR cannot be used for that purpose. That means imposing that level of theoretical knowledge is a breach of the regulatory bodies duty because it is impossible for them to argue the content is relevant. Presumably the content is there for some other purpose??

[IO540]

Fuji I think that owners of twins who fly on a PPL/IR would complain :O

A better way to separate it would be for a PPL/IR to have the abbreviated ground school (and a purely Class 2 medical, like is OK for the IMC Rating, with no pointless Class 1 add-ons), and for a CPL/IR or ATPL to do all the exams.

That would make sense relative to the proposed usage.

[cubflyer]

All this talk of the ATPL exams having some relevance to commercial flying is misplaced. I can only comment about the CAA exams that I did just before it changed to JAA, the JAA ones might be better! I can tell you that the CAA ATPL exams are just as irrelevant for Airline flying as they are for a PPL/IR! 99% of the subject matter is irrelevant, all it end up being is a test of your memory. A history of aviation course would be just as useful!

No doubt the main reason for continuing with all these exams is that there are people employed in the CAA and other authorities who write, mark, invidulate etc these exams and without them they would be out of a job, someone's department would shrink and might get absorbed into another dept and so they loose their job.
Just like the medicals when the ECG machine which does the tests is perfectly capable of saying if its a good ECG or not, but the doctor still had to send them to the CAA to be read and charge you for the process. The CAA agreed that the machine could do the job, but wouldnt approve its use until an alternate source of funding was found- so now the doctors are a CAA franchise and have to pay CAA £40 for every medical in lieu of the ECG reading charge!

Its all jobs for the boys and particularly in the CAA where they employ a lot of ex military people who cant get a job in the airlines or elsewhere. They have no idea of what the real world is like and havent a clue about GA. There are a few good ones but they are not the rule!

It is interesting that when the manufacturers or airlines want to get something done, they have far more success. As Genghis says most of the time the people from the CAA are not up to speed with what you are trying to put forward. Perhaps when a powerful manufacturer puts forward a convincing case they will believe them, thinking that the manufacturer must know what they are doing, whereas they wont belive someone from GA. It was interesting working with both the DGAC (France) and the CAA, the French were much more switched on and also much more willing to make a decision.

There is some light at the end of the tunnel with some things though. We do have the NPPL and it is looking positive that the rules about having to train from a licenced airfield might be changing.

Good luck to those wanting recognition of a FAA PPL/IR or getting an IR without all the pointless ground exams!
Doesnt bother me, I dont want to fly IFR in a GA aircraft, I get enough of that at work!