JAA fails to raise GA pilot safety

[A and C]

One more time the JAA or EASA as it is now called has dispite the cost to the industry has proves that it has done nothing to improve GA safety.

This is not a personal opinion or rant but a report from the UK CAA!

The CAA study concludes that the "introduction of JAR-FCL has had no significant effect on the number of serious incidents and accidents involving fixed wing GA single engine aircraft".

The conclusion that I draw is that the "old" PPL with an instructor rating was doing just as good a job as the "new" JAA CPL instructor at a much lower cost to both the instructor pilot and the industry.

For the issue of the PPL, IMC and night ratings the report shows that industry should go back to PPL instructors and bring down the cost of flying training as this is likely to encourage PPL holders on a limmited buget to fly more often.

It would also be interesting to see the picture on MEP training but I expect that the JAA has priced that one so far out of the PPL market that a realistic report could not be made!.

From the point of veiw of the JAA/EASA these peope should remember that they have jobs that are reliant on the GA industry and if they destroy GA with over regulation they will be without a job!

[mazzy1026]

AaC I agree with everything written, but due to the laws of logic/sod, the following statement:

For the issue of the PPL, IMC and night ratings the report shows that industry should go back to PPL instructors and bring down the cost of flying training as this is likely to encourage PPL holders on a limmited buget to fly more often.
will probably never happen, mainly because it makes a lot of sense and would save a lot of people a lot of money. Maybe if I come up with something stupid, costly and time consuming then it may get taken on board :ouch:

Rant over :ok:

[IO540]

I don't doubt for a moment that report is correct, but we need to remember that the CAA has every incentive to slag off EASA, because EASA will take over most CAA functions.

If one was to get into safety studies like this, and go down the road of "no regulation unless it is based on evidence" then a vast amount of GA regulation would have to be stripped out - simply because there is no evidence that it does anything whatsoever. And we can't do that, because a lot of people would lose their jobs.

The indications so far are that EASA wishes to strip out a lot of CAA- and JAA-inspired nonsense, so ... so far so good.

[mazzy1026]

Sorry, I was a bit one track minded there and focussed on one thing. I don't actually agree with the safety comments, although I am inclined to believe this:
The conclusion that I draw is that the "old" PPL with an instructor rating was doing just as good a job as the "new" JAA CPL instructor at a much lower cost to both the instructor pilot and the industry.

[G-KEST]

The paper can be accessed though this URL and is well worth a look -
http://www.caa.co.uk/application.aspx?catid=33&pagetype=65&appid=11&mode=detail&id=2820
My own views have been expressed to the members of the CAA General Aviation consultative council which has its next meeting tomorrow, Wednesday 18 July. We shall see if the CAA representatives are suitably embarrassed.
The final paragraph of the executive summary of this paper states -
"The main findings of this study is that the changes to revalidation requirements for pilot licences, which JAR-FCL has implemented, have had no significant effect on the number of serious incidents and accidents involving general aviation aircraft in the UK."
From this can be read across that the whole impact of the introduction of JAR-FCL has had no significant effect on the number of serious incidents and accidents involving general aviation aircraft in the UK.
I personally find this most disappointing since it would seem that the introduction of JAR-FCL had the effect of increasing the cost of obtaining pilot licences and ratings in the private sector by some 30%. It has caused a marked reduction in flying training activity in the UK as a direct result. This with no significant safety benefit.
The responses to the RIA on this matter at the time from the general aviation industry and a huge number of individuals forecast that this might well be the case.
What a tragic state of affairs. One where influence from the CAA via the DfT on the JAA might have prevented this disastrous piece of needless gold plating on an established and proven system of pilot licencing such as existed in the UK.
Comments appreciated prior to tomorrows meeting.
Cheers,
Trapper 69
:ugh:

[Chilli Monster]

The responses to the RIA on this matter at the time from the general aviation industry and a huge number of individuals forecast that this might well be the case.


1) We told you so

2) How about pulling your heads out of your ar$es and listen to people who might have as good, if not a better idea of how the GA world operates.

Comments wise that would do it from me ;)

[sternone]

The conclusion that I draw is that the "old" PPL with an instructor rating was doing just as good a job as the "new" JAA CPL instructor at a much lower cost to both the instructor pilot and the industry.

I have a problem with statements that MORE and HEAVIER training is bad for a certain 'sport' ...

In heard many European pilot's stating to me "PPL ? No problem, as long as you don't got it from the UK or the US.. because their pilot educational level is sooo low..."

[G-KEST]

Sternone -
It might be quite interesting to compare GA accident rates and numbers right across the EASA states before and after the introduction of JAR-FCL. In the UK it would seem there has been no change. In any case I believe the accident rate in the UK is better than in most EASA states.
If it ain't broke, why the hell fix it.......... especially if it is going to cost around 30% more.
Both the UK and the USA are ICAO contracting states issuing licences which comply with Annex 1 and this was the case both before and after JAR-FCL.
Cheers,
Trapper 69
:mad:

[Say again s l o w l y]

Very true.

However, one point I must pick on from an erlier poster is this For the issue of the PPL, IMC and night ratings the report shows that industry should go back to PPL instructors and bring down the cost of flying training as this is likely to encourage PPL holders on a limmited buget to fly more often.


The cost is high for many factors, but bringing down the cost of an FI is the daftest idea around. Maintenance, insurance and especially fuel is what is killing our industry, not those multi-millionaire FI's. I often find myself wondering whether to take the Porsche or Ferrari to the club. The same as all my other colleagues.....:rolleyes:

I can't see how the JAA has had any impact on what we do at all, apart from seemigly making it more complex and expensive. Have we all become better pilots since we traded our UK licences?

[G-KEST]

SAS -
You are right.
However the introduction of the BCPL(R) in 1988 and the move to JAR-FCL in the early 2000's certainly meant the eventual destruction of that part of the club instructor cadre represented by PPL's. Folk with an AFI or FI rating. Many of these guys and gals were gainfully employed outside aviation but were happy to put something back into the GA pot, while not avidly pursuing the right hand seat of a jet.
Today we have a large proportion of our instructor fraternity in it on a highly temporary basis while inevitably thinking of their huge debt burden. Not a scenario for real enthusiasm to inspire their students I fear. Or for the continuity of a students instructor. Both vital factors in a students progress.
Cheers,
Trapper 69
:mad:

[Say again s l o w l y]

Another recent problem is the fact that virtually every airline pilot is doing 900hrs a year and very few companies allow their staff to "moonlight."

So another pot of potential FI's aren't available anymore and they are usually enthusiastic and want to be there.

Mind you I have to say that I've met very few hourbuilding FI's who haven't tried to do a good job, they are usually very inexperienced however.

But continuity and enthusiasm are vital in the end and lets face it something needs to change. I'd ike it if I could treat being an FI as a real job that provides me with the wherewithall to pay my bills and have a life. If that ever happens, then things will get better.

[IO540]

I only started flying in 2000 (which is when the JAA PPL came in) but all indications I see is that the substantial decline in the annual PPL issue numbers (as one can see on the CAA website) over the past 10 years or so is something that has happened concurrently with JAA and not as a result of it.

There have been big social changes in the West over the past 20-30 years and these have come to a head particularly over the past decade. Individual wealth has increased but those that have it are spending their money more strategically.

The number of people who are willing to participate in what most people perceive as a largely anorak-dominated scene flying machinery which is usually so old that pleasure flight (oops I mean trial lesson) punters quietly wonder if it will last the flight, is going down all the time. Naturally I don't expect anybody here to agree - they are all happy participants already!

It's no use blaming JAA for the decline. They don't help but if somebody wants to reverse the trend they will need to do fairly drastic measures.

I would start with improving GA utility, by changing planning legislation to have a presumption towards small low-use air strip development. This will counter the virtually certain gradual closure of most present-day GA airfields over the next 20 years (due to developer sharks) which will wipe out most GA other than farm strip activity.

Next, allow GPS approaches without ATC. This will dramatically improve the overall utility of GA for real travel. Then and only then can things start to gradually pick up. It's true that most present UK GA is VFR only but airfields need the whole range of traffic to make money.

Nothing can be done quickly - this will take many years.

I think the proposed EASA changes may take a lot of cost out of VFR-only flying, which is a good thing. If they introduce a pan-European ultralight category around the 750kg mark that will be very good.

[bookworm]

One more time the JAA or EASA as it is now called has dispite the cost to the industry has proves that it has done nothing to improve GA safety.

This is not a personal opinion or rant but a report from the UK CAA!

Yes, it is a personal opinion. What the report says is:

The introduction in 1999 of new revalidation requirements contained within JAR-FCL had no significant effect on the number of serious incidents and accidents involving fixed-wing GA

That is very different from proving that the revalidation requirements have done nothing, and vastly different from proving that the overall JAR-FCL training regime has had no effect.

What neither you nor the report point out is the level of change, in either direction, that would remain undetected because the data consists of a very small sample. In fact, it would entirely consistent with the occurrence rates that the underlying rate may have increased or decreased by 10 to 20%. In fact it would be utterly extraordinary if a change of that magnitude took place merely because of a change in the training regime, which affects a relatively small number of pilot.

I am no great fan of the JAR-FCL regime, and I doubt the benefit-cost has been positive. But you shouldn't abuse the statistics.

You further cloud the issue by confusing JAA with EASA, which, far from being what JAA "is now called", was created with a completely different remit because JAA failed.

[G-KEST]

IO540 said -
"It's no use blaming JAA for the decline. They don't help but if somebody wants to reverse the trend they will need to do fairly drastic measures."
To which I would respond that no one is solely blaming the introduction of JAR-FCL for the decline but the instant imposition of around 30% increase in the cost of acquiring a PPL sure as hell did not exactly improve things.
Cost is a major factor in determining how any individual chooses to spend disposable income. We desperately need more of our potential students to gain their licences here in the UK.
Cheers,
Trapper 69
:rolleyes:

[G-KEST]

Bookworm said -
"The introduction in 1999 of new revalidation requirements contained within JAR-FCL had no significant effect on the number of serious incidents and accidents involving fixed-wing GA
That is very different from proving that the revalidation requirements have done nothing, and vastly different from proving that the overall JAR-FCL training regime has had no effect."
I must beg to differ. The various statistics in the paper are applicable to the whole JAR-FCL nausea as far as the UK GA safety record is concerned, not merely the new validation requirements.
Cheers,
Trapper 69
:mad:

[Say again s l o w l y]

Where do you get the 30% increase in costs due to the JAA? I'm assuming that this is 30% above the rate of inflation.

[G-KEST]

SAS -
The 30% was generally accepted as the increase by those who responded to the CAA regulatory impact assessment carried out prior to the change in UK legislation which gave effect to JAR-FCL.
The CAA's expert opinion set out in the RIA at the time revealed just how far removed from reality their estimate was.
Hope this helps your appreciation of the situation that has led to the reduction in training done in the UK and the increase in that done abroad. The impact on UK general aviation has been enormous.
Cheers,
Trapper 69
:ugh:

[bookworm]

I must beg to differ. The various statistics in the paper are applicable to the whole JAR-FCL nausea as far as the UK GA safety record is concerned, not merely the new validation requirements.

Well you obviously know a lot more about the purpose of the paper and its findings than the authors do then! :rolleyes:

Given that the vast majority of pilots flying in 2002/3 were trained pre-JAR-FCL and had no interaction with the JAR-FCL system except revalidation, what level of change in occurrence rate would you expect to observe in 2002/3?

The one statistic in the paper that verges on significance is the rate of recency-related occurrences, which decreased from 31 to 18 (i.e. it almost halved after the introduction of the 90-day requirement for carrying passengers). Yet all the report does is point out the small sample size!

Furthermore the 42% reduction should be treated with caution since there were few occurrences in this category; the number of occurrences reduced by 13 from 31 to 18.

You'd have thought that they might get the hint from that that the overall sample size of about 40 Training Related Incidents was way too small for this to be an experiment with useful sensitivity.

In May I drank alcohol in my normal (moderate) way. In June I gave up alcohol entirely.

May death rate: 0
June death rate: 0

Am I therefore entitled to assume that alcohol has no effect on health? That it has no significant effect on health? That it has no significant effect on my health? That it had no significant effect on my health in May and June?

[G-KEST]

Bookworm -
I fear I am not swayed by your comments. Along with the majority of those GA organisations I am involved with and all those people involved with GA who have discussed the problems with me the consensus is that JAR-FCL was a disaster.
With over 50 years involvement in GA in the UK and over 13,000 hours as pilot, instructor and examiner having been CFI at and managed 5 flying clubs I think my views have a reasonable amount of experience behind them.
I am more than pleased to be operating now on an NPPL.
With my sense of humour I could comment that perhaps the worm should repair to his books.
Cheers,
Trapper 69
:mad::mad::mad:

[IO540]

To which I would respond that no one is solely blaming the introduction of JAR-FCL for the decline but the instant imposition of around 30% increase in the cost of acquiring a PPL sure as hell did not exactly improve things.

Can you offer a breakdown of where this 30% comes from? Since you have managed five flying schools, that should be an easy exercise.

It's indeed the case that GA is suffering more from a "death by a thousand cuts" rather than from one single assault (an example of the latter might be an increase in avgas to say £5 per litre) but I don't see where a 30% rise would come from.

I've been owning/operating a complex single both on G-reg and N-reg and I am thus intimately familiar with piston aircraft operating procedures, costs and how they break down.

To a businessman of some 30 years, it's obvious that the 3 main things that affect flying school finances are utilisation, utilisation and utilisation. The factors that continually eat into this are

- lack of customers
- UK weather
- disorganised instruction provision, utilising mainly ATPL hour builders
- disorganised management generally, with an awful lot of downright crooked operations operating around the edges
- old poorly maintained planes which keep going "tech"

Cost is a major factor in determining how any individual chooses to spend disposable income. We desperately need more of our potential students to gain their licences here in the UK.

That's true but looking at the active PPL population I don't see a huge crowd of pilots hovering around the UK who did their training in the USA. In fact the only distinct group of pilots I see having trained in the US are high-hour pilots operating nice N-reg planes on FAA PPL/IRs; many of them bypassed the UK system entirely, but these are a very tiny group. I reckon that those PPLs that trained in Florida etc pack it in just as quick as those who trained here. TBH, those that did that to save money will pack up fast because the cost saving will be insignificant on the scale of long term flying. Moreover, the cost differential is at most 50% i.e. about £4000 and that is only if you put a zero value on your time and (the now considerable) hassle. I did my IR in the US so I know a bit about that too.

We should all be on the same side and fighting the same battle, but I feel that claims like JAA having increased the PPL cost by 30% just undermine a lot of good work being quietly done by others.

[G-KEST]

IO540 -
Please see my response to SAS timed at 1927 today. I do however agree with some of your posted points. On others I do beg to differ.
Cheers,
Trapper 69
:ugh::rolleyes::{

[IO540]

The 30% was generally accepted as the increase by those who responded to the CAA regulatory impact assessment carried out prior to the change in UK legislation which gave effect to JAR-FCL

G-KEST, referring to others' opinion is not good supporting evidence.

It's true that PPL issue numbers fell some 30% after JAA took over, and continued to fall, but that doesn't mean JAA caused it.

Most PPL training in the UK is discretionary spending i.e. people who are not doing it too seriously. This is evident from the very high attrition rate, and this is incidentally true in the USA as well. Loads of other factors could cause the drop referred to.

I would like to see a cost breakdown.

[bookworm]

I fear I am not swayed by your comments. Along with the majority of those GA organisations I am involved with and all those people involved with GA who have discussed the problems with me the consensus is that JAR-FCL was a disaster.
With over 50 years involvement in GA in the UK and over 13,000 hours as pilot, instructor and examiner having been CFI at and managed 5 flying clubs I think my views have a reasonable amount of experience behind them.


G-KEST

I wouldn't argue for a moment that the JAR-FCL was anything other than a disaster. As I said earlier in the thread, based on personal and anecdotal experience, I very much doubt that the benefit-cost of the JAR-FCL transition has been positive. That's one of the reasons why EASA exists.

My point is much more limited: that you cannot infer from the cited paper that the underlying rate of training related incidents has not changed, either for the better or for the worse. The paper proves nothing, and it's verging on irresponsible of the authors not to point out that the limited sample size condemns the analysis from the outset to fail to find any significant result, even if the underlying rate has undergone a quite meaningful change in safety terms.

[mazzy1026]

I think this may be getting over-analyzed.

I mirror what Gemma has said, and believe that if I would have been better off in achieving an FI rating then (which I can't do now because of cost etc blaaa) then I cannot find any reason to disagree. I have read your paper GK, and personally I can't understand why anyone would want to disagree with it. You could spend all day arguing about statistics and who just farted, but I think the big picture says it all.

I for one stand by you.

[Say again s l o w l y]

When a report is written, every single stat and opinion has to be backed up, otherwise it renders the whole thing meaningless.

I'll agree that JAR-FCL hasn't helped matters, but neither do I think it has stuffed things up that badly.

I'm very much in IO540's camp when it comes to the 1000 cuts rather than one big problem.
I can identify a huge number of areas that put the industry in danger. I simply don't think JAR has had that much of an effect.
GA was dying in this country long before JAR came along and it is a bit churlish of the CAA to now say its all the Europeans fault, when they are just as responsible for the utter mess that GA finds itself.

Over-regulation is not a new thing. We have "enjoyed" it in the UK for a lot longer than 7 years.

I get tired of the constant preaching that things were better years ago, when they so obviously weren't.
The only difference is that GA hasn't kept up ith the times as it is constantly looking into the past not the future.

There is a huge need for new blood and enthusiasm in GA, otherwise it'll be left to the "in my day" crowd. Just look at the average age in any fllying club and especially flying club committees. All the young pilots are simply there to get out of it as fast as possible and into flying something big shiny and sexy. Frankly, who can blame them.

GA is so "unsexy" it defies belief. Manky a/c, cantankerous pilots, poor facilities and massive cost. Do you want to know why GA is in a rubbish state. It's because it isn't family friendly, female friendly ,or a lot of the time unless you are part of flying club cliques, friendly to anyone.

There are a few exceptions to this, but on the whole GA's woes are of its own making, JAR hasn't helped, but it hasn't made a rubbish situation any worse.

[IO540]

GA is so "unsexy" it defies belief. Manky a/c, cantankerous pilots, poor facilities and massive cost. Do you want to know why GA is in a rubbish state. It's because it isn't family friendly, female friendly ,or a lot of the time unless you are part of flying club cliques, friendly to anyone

Well put.

[englishal]

"Private" flying in Europe and especially the UK suffers from massive over regulation in the name of safety. This in turn leads to high costs, and this in turn leads to reduced safety. Take the IR as an example - the FAA realised some years ago that many PPL's were dieing in "unintentional fight into IMC" type accidents. This was largely because in the name of safety the FAA had mandated that before you could start on an IR you had to have something like 200 hours TT (I forget exactly). When they dropped the requirement down, they saw a marked drop in this type of fatality. So more IR qualified PPLs lead to less IMC related accidents.

Because the IR is largely unobtainable in the UK for the majority of PPLs (see the stats) then there are a very low number of instrument qualified PPLs compared to places like the states. The CAA has gone some way to address this with the IMC rating, but this could soon disappear.

The CPL is mostly unobtainable for the "Private" flyer who maybe wants to improve their standard or even carry out part time CPL type work. The FI rating is not worth getting unless you are on a career path as you really do need the CPL and the CPL exams first. If I lived in the states I'd have all my instructors ratings by now and would be teaching in my time off - not because I have any ambition of operating the gear and flaps of an airbus but because I'd enjoy the challenge.

Over regulating stuff like maintenance again forces some people to fly less hours (due to cost) and hence they are less current.

The whole system needs a shake down in my opinion:

More pilot-owner maintenance allowed
IFR approval for many PFA types and reduction in other restrictions
Lower fees - Of the JAA IR, there are at least £1000 worth of fees (exams, test, etc)
GPS approaches into untowered fields
IMC rating to be kept whatever

Just my 2ps worth.....back to assembling the Ikea wardrobes :ugh:

[DFC]

The purpose of JAR-FCL was to harmonise the pilot licensing and training in Europe. This harmonisation was designed to and has provided many benifits to the industry.

Harmonisation means harmonisation it does not mean safety improvement.

Perhaps when the author of this report has finished their temporary placement with the CAA they will go to the DVLA and make a long report which indicates that the harmonisation of UK driving licenses with European requirements has not done anything to improve road safety.

Regards,

DFC

[G-KEST]

Just got home from the GACC meeting at Gatwick. I had arranged for the CAA paper to be briefly discussed under any other business since my request was at rather short notice. Most of the "industry" members present had received my email on the subject as had those CAA SRG staff who attend.
The paper was produced at the request of the joint CAA/industry GA Safety working group and funded from the CAA SRG research budget. Though the WG had seen it in draft form no one else had and the final version, now published as a CAA paper, did not take into account comments and urgent suggestions by the WG.
Such a document should have been tabled at the GACC for consideration prior to publication.
As such the CAA SRG staff there seemed most embarrassed that it had been put into the public domain and had already received press comment in "Flight". Red faces all round.
No one present at the meeting made any adverse comment regarding my personal views on the disastrous impact of JAR-FCL on general aviation including the comments on how the apparent lack of safety benefit from JAR-FCL had resulted from a significant increase in the cost and complexity of gaining licences and ratings.
I have now referred to my personal response to the CAA in 1999 following their poorly drafted RIA which preceeded the introduction of the new regime. I find that my research into the likely cost increase resulting from the replacement of our then existing system by JAR-FCL was likely to be in the order of 15%, not the 30% I have mentioned before on this forum thread. Sorry about that, my apologies.
On the other hand the current cost of obtaining an ICAO compliant PPL issued by the FAA in the USA from a Stateside FTO is around 40% of the cost of a JAR-FCL PPL obtained in the UK. No wonder those who can afford the time go abroad for their qualifications.
Hope this puts the present situation regarding the CAA Paper.
Cheers,
Trapper 69
:mad::mad::mad::mad: