Medical changes to CAA PPL.

[straightfeed]

CAA Official Record Series 4 No. 689 announces changes to the medical requirement to some PPLs.
Seems that a GP declaration (as per the NPPL) will do for the old CAA (non JAR) PPL.

What the publication fails to mention is if any restrictions apply as they do to the NPPL SSEA rating. Can one now fly abroad on this arrangement?

Also, the exemption expires on 30th June 2009. If this exemption is not renewed in a timely manner (as it wasnt in the saga over the microlight exemption of some years ago) it could be that pilots may not be legal at the end of June 2009 if they chose to go down this route.
Why put a limit to this exemption that really requires the general public to check that the CAA have extended it so that we all stay legal?

I'm getting to the point with all these changes that one day I'll find myself illegal purely that I didnt understand or know about of all these changes.

[IO540]

Can one now fly abroad on this arrangement?Only if they file a difference to ICAO on this, which is IMHO unlikely given that EASA is "going to" terminate national licenses from 2012 or so.

Whether anybody abroad will notice, I have no idea. But I wouldn't like to argue this with an insurer - the one thing they do is check whether the flight was legal before it got off the ground.

The more interesting Q is why they are doing this. Is this some kind of "EASA pre-emptive" action? It certainly looks like it; it will make the EASA LPL (with a GP medical) look more or less the same as the old CAA (non-JAA) PPL (also with a GP medical), opening the path for various options... which could be interesting since the EASA LPL is a complicated animal whereas the old CAA PPL is a bit of paper which lasts for life.

[jxk]

SF I would agree with your last paragraph entirely. It's not only medicals but licences, maintenance and rules of the air which are in a constant state of flux. How could anyone (except a lawyer) justify the old saying, 'ignorance of the law' is no excuse. It doesn't matter who you talk to, including the CAA, they all have different interpretations of what the regulations are. What happened to the good old British common-sense?

[Jodelman]

Also, the exemption expires on 30th June 2009.

That's how the CAA usually do this sort of thing. The idea is that it gives them 12 months to change the ANO which requires parliamentary time.

[jxk]

Airline captains who have first class medicals have been known to collapse at the wheel - I think there was a case not too long ago where 1st officer had to complete the flight solo. There can't be any medical that can accurately predict your future health so why not just a simple test of eye-sight from Specsavers, hearing test, blood pressure all the things your GP could do?

What are the statistics?

Me being controversial....

[robin]

...it will make the EASA LPL (with a GP medical) look more or less the same as the old CAA (non-JAA) PPL (also with a GP medical), opening the path for various options... which could be interesting since the EASA LPL is a complicated animal whereas the old CAA PPL is a bit of paper which lasts for life.

Interesting. So is this the answer to whether or not we need to sort out a JAR-PPL 'upgrade' for our old lifetime CAA-PPLs?

[IO540]

So is this the answer to whether or not we need to sort out a JAR-PPL 'upgrade' for our old lifetime CAA-PPLs?

I would not do this unless you have a pressing reason to e.g. you want to go to some JAA State, which does not accept the CAA PPL, and rent stuff there.

The counter argument is that it may cost you less to do the swap now than say next year, but the difference is not likely to be significant on the scale of flying costs - even if a checkride is required. If EASA terminated national PPLs in some crude manner, a lot of **** would hit the fan, and of course they cannot do anything to the French.

In this business, people who took drastic action in fear of something happening usually got shafted. For example, those who got scared of the 2005 DfT proposal to end N-reg long term parking and spent £thousands to go back on G-reg were soon p*ssed off because they wasted their money, as well as depriving themselves of IFR privileges of their FAA IRs.

[BEagle]

What the publication fails to mention is if any restrictions apply as they do to the NPPL SSEA rating. Can one now fly abroad on this arrangement?

I am currently awaiting an updated version of the General Exemption from the responsible person at the CAA. This is because the CAA needs to clarify (internally) whether a SSEA Class Rating will have to be included in a non-NPPL for those who use the General Exemption. If they decide that a SSEA Class Rating will be required, the aim is to make it a free issue.

If you use a Medical Declaration with a non-NPPL + SEP Class Rating, you are restricted exactly as a NPPL SSEA holder is.

MTOW 2000 kg
No more than 4 PoB including the pilot
No night
No IMC
No FI Rating

Use outside UK airspace subject to agreement of the other nation. The French have already said "NON!!".

To my mind, the LPL is an utter crock. It brings nothing new, it doesn't allow Microlight pilots to upgrade as the NPPL does and it combines the worst of all options - a rolling 2 year validity period within a 5 year issue period - work that one out!

The EASA PPL proposals have their own flaws, but the LPL is utter poo - read the MDM032 proposals and you'll see what I mean. I propose that all sub-ICAO licences should be down to individual Member States to sort out and administrate; the minimum €urolicence should be the PPL.

[straightfeed]

Thanks BEagle
If you use a Medical Declaration with a non-NPPL + SEP Class Rating, you are restricted exactly as a NPPL SSEA holder is.


Any reference to this under the new medical requirements would be appreciated.
I'm aware of the NPPL restrictions but would like to see where these are quoted legally to apply for this new arrangement.
SF

[BEagle]

To keep you all up to date, I reviewed the latest draft revision to the General Exemption last Saturday and it will make it abundantly clear that anyone using a Medical Declaration with a valid SEP Class Rating will be restricted to the same privileges as a NPPL holder.

[UV]

BEagle...
Do you know whether someone using this arrangement would be regarded as operating on a "Sub ICAO" licence"?
The actual Licence operated on will be a PPL (or higher) issued by the CAA and therefore surely an ICAO licence...
If so could it be used to fly an N Reg, in the UK?
Any help or advice appreciated!
UV

[BEagle]

See LASORS A19.

In addition, before acting as pilot-in-command of a foreign
registered aircraft, the licensing requirements of the state
of registration must be met in accordance with ANO
Article 26(3). For ‘N’ registered aircraft, U.S. Federal Air
Regulations (FARs) 61.3(a)(1) states that ‘when the aircraft
is operated within a foreign country a current pilot licence
issued by that country in which the aircraft is operated
may be used’.

However, the grey area is that a Medical Declaration does not meet the normal standards required by the state of registration (USA) for private flight. So I recommend that you don't attempt to fly a N-reg aeroplane without holding a JAA Class 2 medical until this matter is clarified by the Authority.

UPDATE Advice from a chap at the CAA is that, unless the pilot concerned could provide evidence in the form of a letter, signed by an authorised officer of the FAA, that the FAA would find a UK issued sub-ICAO licence acceptable for the purpose of flying an N registered SSEA in the UK, the answer would be no, you may not do so.

Expect to see some guidance concerning this in a forthcoming Advice Circular from the CAA.

[BEagle]

Please note that the General Exemption pertaining to the use of a Medical Declaration with a CAA-issued non-NPPL, 'ORS 4 No 689' has now been superseded by 'ORS 4 No 711' - see http://www.caa.co.uk/docs/33/ORS4_711.pdf .

This now spells out quite clearly what the restrictions are; later an Advice Circular will be released by the CAA to spell out further the effects to those who are still in any doubt!

[David Roberts]

Beagle,

If or when you fail your JAR Class 2 medical and wish to continue to fly, you will be glad of the NPPL (in future for Annex II aircraft) and the future LPL (for Annex I aircraft). Talk to the thousands who have done so already. Also to the many pilots who do not need a JAR PPL and all the clap that goes with it for basic VFR flying.

For generations the world of private flying has been held back by the inherited thinking of pre WW2 days when it was a 'privilege' (in more than one sense) to fly and the authorities granted you the privilege. They also screened out supposed higher risk candidates by means of applying high medical standards because of the investment being made by CAT and Military organisations in training pilots. The screening should be more appropriate and proportionate to risk for lesser mortals than ATPLs or military pilots. Look at the empirical evidence in other fields. It is compelling.

We must break the assumed link (by the former JAA) between JAR PPL and higher licences. A PPL or LPL should be capable of being seen and accepted as an end in their own right. And with the ability to progress training and experience from LPL to PPL to CPl etc with crediting.

You and others need to recognise that we are trying to reduce the barriers to entry / barriers to continuing flying, based on objective and proportionte risk principles. Otherwise the elite breed will die off gradually without successors from the young taking over the mantle of private flying.

From Cologne where we continue the battle......
Good day

[IO540]

Advice from a chap at the CAA is that, unless the pilot concerned could provide evidence in the form of a letter, signed by an authorised officer of the FAA, that the FAA would find a UK issued sub-ICAO licence acceptable for the purpose of flying an N registered SSEA in the UK, the answer would be no, you may not do so.

This is self evident fact. The FAA and only the FAA can decide what privileges (if any) a particular license confers on the pilot of an N-reg.

FAR 61.3 already covers this but only for ICAO licenses. However, it does not use the word "ICAO" and this is where the ambiguity arises. IMHO, the context of the FARs eliminates this ambiguity, and a non-ICAO license would not meet 61.3 unless the FAA says so.

This is like the other argument which has been done to death already: whether the IMC Rating is good for an N-reg. I have a written reply from the FAA saying it is fine.

But no matter what written reply you get from the FAA, somebody will always stand up and say that anything short of a reply from the FAA Chief Counsel is worthless. I regard this view as ridiculous because it makes any written answer from any official body completely worthless (which is clearly not the case).

David - your point of view is hard to argue with and all VFR-only pilots (which is also a huge industrial lobby around Europe; all those plastic ultralights etc) will love this. However, it brings a risk that it will sideline the whole "private IFR" scene into a commercial-only route, and that is a BAD thing because IFR delivers a huge increment in mission capability specifically, and in the overall value / return one gets from flying generally.

We already have a situation in which the vast majority of new pilots chuck flying in very soon after getting their PPL. Look at some of the reasons why there is this ludicrous attrition rate.

As for the GP medical, everybody would welcome this. All data shows clearly that pilot incapacitation barely features in the accident stats, and most of the things checked in the Class 1 or 2 medicals (I hold both CAA and FAA Class 1s) are utterly irrelevant to sudden pilot incapacitation anyway. The key thing is that this is equally true for VFR and IFR so delivering a PPL which has a GP medical while stripping out any IFR route is worthless to many pilots.

[BEagle]

David Roberts, I know all about the NPPL, thank you very much, as I am the chairman of the NPPL Policy and Steering Committee. I also reviewed and proposed amendments to ORS 4 No 711 - a very reasonable and generous CAA dispensation, to my mind.

The LPL is an utter crock which should be strangled at birth. MDM032 have rolled over to the French and propose an appallingly weak licence - the NPPL is far superior having been the result of industry and CAA synergy.

All MDM032 proposals should be deleted from the EASA part-FCL proposals forthwith; however, with some minor tweaking, the EAS part-FCL PPL will be fine.

As for medical standards, the eyesight requirements for night and/or IMC work are beyond the remit of GPs, so the AME-adminstered part-Medical Class 2 must remain the minimum standard.

[bern444]

It still somehow seems wrong to hide behind a handle if one is an official, rather than an ordinary PPL.

Quite apart from that - it may be beyond the remit of a GP, but not beyond the remit of an optician. If one person can sign a form, so could two. Not that I'm personally interested in night or IMC on my NPPL.

Bernard Newnham
retired Senior Producer, BBC TV

[Gertrude the Wombat]

As for medical standards, the eyesight requirements for night and/or IMC work are beyond the remit of GPs, so the AME-adminstered part-Medical Class 2 must remain the minimum standard.
Does that mean that if

(1) I am currently "temporarily" medically unfit for a class 2
(2) I have a GP declaration
(3) I can thus fly with NPPL priviledges on my CAA SEP licence and class rating

that if I were pass the eyesight part of the class 2 medical[#] I might be able to persuade the CAA to let me use my IMC rating via some personal concession (assuming I complete the course and pass the test)?

[#] My AME is always happy with my eyesight, even though I fail the new standards, under grandfather rules (so I get a "NJC" rubber stamp) - with my glasses on I can see better than some of the people he has to pass under the new rules!

[BEagle]

Does that mean that if

(1) I am currently "temporarily" medically unfit for a class 2
(2) I have a GP declaration
(3) I can thus fly with NPPL privileges on my CAA SEP licence and class rating

Yes. But you will not be permitted to use any other privileges until you regain a JAA Class 2 medical. As the forthcoming advice circular will make clear.

And ex-BBC person, if someone patronisingly writes:

You and others need to recognise that we are trying to reduce the barriers to entry / barriers to continuing flying, based on objective and proportionte risk principles.

then I don't feel it is necessary to conceal my many years of voluntary, unpaid work spent getting the NPPL 'airborne'.

We simply DO NOT NEED a sub-ICAO 'EU' LPL (or rather, to roll over to the demands of the French). EU Member States who wish to do so should be permitted to make their own arrangements for sub-ICAO pilot licences in their own airspace - and the MDM032 recommendations should be binned in their entirity. If the French want to go on killing themselves with their ridiculous 'Brevet de Basse', then they should be permitted to do so - but only in French airspace!

[Whopity]

What the revised Exemption still fails to mention is the requirement under Article 28 to hold a valid Certificate of Test or Experience on the class being flown.

A pilot who normally flies SEP is unlikely to have SSEA rating as well, so what is the procedure for obtaining one? Which criteria are to be used for currency in the change over? As the CAA are the only people who can add a rating then charges will surely apply.

[homeguard]

Whopity, there isn't any difference between the two. They are both the same with different names simply to deliniate between the rating being held by a NPPL holder and a PPL pilot.

The NPPL licence held restricts the privileges to aircraft maximum weights less than a PPL and the number of passengers etc (without any reasonable logic).i.e the NPPL may fly a Piper Saratoga with six seats but only have 3 passengers. The aircraft can be flown at maximum weight but with the two spare seats occupied with anything but not with people.

The exemption as it is now is perfectly reasonable and clear. There can be no justification to require an expensive adninistration process.

[BEagle]

homeguard, originally we were going to recommend that the SSEA Rating should only allow the licence holder to hold privileges on 'Simple SEP aircraft of up to 2000 kg MTOW with seats for 4 PoB, including the pilot'. But we changed this to the more flexible 4 PoB rule as it currently stands to allow for those with larger aircraft.

I recommended to the CAA that, in order to avoid expensive, time consuming admin, it would be a lot simpler just to allow 'SEP + General Exemption' pilots not to need an additional SSEA Rating included in their licence. Fortunately, CAA legal agreed.

Where it gets compicated is if someone decides that they want to relinquish their SEP Rating in perpetuity, but maintain (for example) an old-style UK PPL. The forthcoming advice circular will describe the necessary process - but the good news is that the Authority intend it to attract no charge (apart from postage) and for the applicant to use the existing 'Inclusion of an Additional Class Rating' form available from the NPLG website. Which, incidentally, I designed.

The CAA have been extremely helpful and flexible in getting this General Exemption agreed - good to see that they are fully in favour of reducing administrative burdens wherever that can be achieved!!

[Whopity]

They are both the same with different names simply to deliniate between the rating being held by a NPPL holder and a PPL pilot. No they are not, one imposes limitations that don't exit in the other. For example: A max weight limit and with SEP you can also fly a Microlight; with SSEA you cannot! Article 28 requires that you have a valid C of E or C of T for any rating you are exercising; it was only amended this year.

If your privileges are limited by virtue of this Exemption then you need the appropriate rating in the licence to exercise those privileges unless they issue an Exemption to Art 28.

If a pilot turns up for a revalidation with a SEP rating and is operating an SSEA the examiner could in theory revalidate the SEP rating based on the JAA criteria (no medical certificate is required) but the pilot is now required to meet the NPPL criteria and the Examiner cannot revalidate the SEP on the basis of that i.e. two half hour dual flights nor enter an SSEA revalidation if the rating is not in the licence!

[BEagle]

Whopity, you've left the Belgrano now, so please allow the guys who are there now to decide policy.....

As I've said, the advice circular will make everything clearer.

Or should do!!

[robione]

Im reading this thread with great interest,as a lot of applies to my curcumstances and begs a question.Background-Frozen ATPL,Instructor,Jar licence,all ratings lapsed.Also hold lifetime CAA issued PPL.Currently no class 1 or 2 medical as have an issue with my eyelids possibly barring me from holding class 1 or 2.Had decide to gain an NPPL,then read this.Was considering a share in a PA 28 which is on the D-reg.Cant fly it on an NPPL,but can i now fly it on my CAA PPL with the medical declaration i have.?Sorry if this is a little off the subject but it relates to some of the issues that will be raised.

[BEagle]

robione, the revised General Exemption merely gives you 'NPPL equivalence' when using a legacy UK PPL or CAA-issued JAR-FCL Pilot Licence with a Medical Declaration, rather than preventing you flying without otherwise having to pay for a NPPL.

http://i14.photobucket.com/albums/a341/nw969/Internet/zxzxz.jpg
That means your licence is not ICAO-compliant; if you wish to fly an aircraft which is not registered in the UK, you must contact the State of Registration and obtain their consent to fly the aircraft using a non JAR-FCL Pilot Licence and UK Medical Declaration.

[Zulu Alpha]

Could comeone help with a definition of SSEA?

I have a UK PPL, can I now get my GP to provide me with a medical rather than spending half a day and £200+ for my class 2. I only want to fly my single seat 1300lb 200 HP CS prop aircraft around in the UK in VMC.

If I can get my GP to provide me with this, then will there be any catch in the future if I wish to revert back to my UK PPL and Class 2 medical ie can I just get a class 2 medical at that time and go back to where I am now?

Many thanks
ZA

[homeguard]

The term SSEA means Simple Single Engine Aeroplanes.

The Medical Declaration is a simple form on which you self-certifiy your health but your personal GP (or Doctor within the same Practice), with whom you are registered, is required to countersign it. The form may be downloaded from the NPPL website and has detailed guidance notes attached to inform your GP. However the standards are those of the DVLA Professional Drivers and will be well known by most GP's. The validy periods are included within the notes.

You may have a JAR compliant medical whenever you chose in the future.

There is no requirement to inform the CAA that you will be operating on a Medical Declaration. Your recorded status therefore remains unchanged, although should an official wish to check you will be recorded as a PPL with a lapsed medical. Should you be required to produce a medical cerificate, then you will, of course, be required to show your valid Medical Declaration.

If it all seems too simple then as BEagle saids, don't complain when the CAA choses to be so simply pragmatic. Well done the CAA.

[Zulu Alpha]

Homeguard,

Thanks for the clarification. I should have been clearer, I was asking what the rules were for an aircraft to be an SSEA. ie does it exclude aircraft with a wobbly prop or wobbly wheels which have been called complex before.

ZA

[BEagle]

Provided that you have had the appropriate training for VP, RG and 140+KIAS (if appropriate), then you can indeed fly a single seat 1300lb 200 HP CS prop aircraft around in the UK in VMC using a SSEA Class Rating. ENJOY!!

You won't even need to complete the 1 hr of training flying with an authorised instructor if you don't wish to carry passengers in any SSEA - and your SSEA Class Rating will then be restricted to SSEAs fitted with a single seat!

And before any idiots start, 'single seat' does not include a C152 flown solo!
http://i14.photobucket.com/albums/a341/nw969/Internet/zxzxz.jpg

[Lister Noble]

Homeguard,many thanks for that and Beagle.
Just to make sure I am reading it correctly.
If before my next Class 2 medical renewal date I just get the local doctor to sign a medical declaration,I can then fly as an NPPL with it's restrictions ,and not inform anyone else.
I would out of courtesy inform the group I fly with.
Sounds great!
Lister:)

[BEagle]

That's it! But only if it's a G-reg aeroplane.




.

[md 600 driver]

beagle

any changes for rotorwing or are we frozen out again ?

[BEagle]

No RW changes.


.

[mikebeechsomerset]

May be a dumb question but I've been trying to find out if 711 is being renewed/superceeded after aug 09. I've emailed the CAA and spoken with them. Email gets no reply and when speaking no one knows. Any one out there know what's happening?