Latest news from IAOPA (Europe)

[Mike Cross]

Latest IAOPA e-News is now available here. (http://www.aopa.co.uk/index.php?option=com_content&view=article&id=319:iaopa-europe-e-news-feb-2011&catid=1:latest-news&Itemid=323)

[Pace]

Mike

Thanks for posting
Written on I phone so excuse mistakes.

Firstly this all sounds like a lot of hot air and false promises by EASA.

Talk of working hard on the bi lateral agreement with the USA regarding N Reg a con ? Couple of years" sorry guys we did our best! Not our fault instigate our regulations" ?

The shocking statistics of 60 French deaths pa in France compared to 25 in the UK ? What does EASA as a supposed safety institute read into that ? Will they be rushing to turn out an achievable PPL IR? i doubt it!
IMCR dead what will they do when new UK PPLs bite the dust?
isnt it about time that the UK government and CAA Tell EASA that on safety grounds they have no choice but to issue UK IMCRs until EASA address that issue themselves?

Embarrassed lack of answers from a bunch of overpaid regulators who have a huge budget and appear to want to work out of their mandate which should be safety and only safety. Demonstrated safety issues backed up by stats.
If they dont have the data then a few less expensive lunches and wine bills should pay for it! Plus chopping half of their unneeded workforce.

Tea and Biscuits anyone ?

Pace

[IO540]

I wonder how the 60 French deaths are distributed by type of flying?

There is a lot of mountain flying going on in France, for example.

France also has a miniscule long distance flying community, compared to e.g. UK and Germany.

[Cows getting bigger]

Maybe the French fly more.

[IO540]

I doubt it, speaking purely anecdotally from having flown there lots of times.

Much of their flying is short local hops, club to club, as a group of planes.

[David Roberts]

Having worked throughout 2010 on, and completed in November, a report on microlighting in Europe (and the LSA in the USA), the French total number of microlight fatal accidents (note, not fatalities) in the 10 years 2000-2009 was 147, thus an average of 14.7 p.a. Estimated annual hours - exposure to risk -of the microlight fleet rose from c. 255,000 in 2000 to c. 700,000 in 2009. The fatal accident rate averaged over 10 years was 3.2 per 100,000 hours with an annual peak of 6.0 in 2001 and a low of 2.0 in 2006.

Comparable UK microlighting statistics were 20 fatal accidents / 2.0 p.a. / rate of 1.61 p.a. over 10 year period using estimated exposure data.

Fatal gliding accidents in France averaged 4.5 p.a. in the ten years. The accident rate cannot be calculated due to lack of reliable exposure data.

UK gliding fatal accidents averaged 2.7 p.a over ten years in the UK, a rate of just less than 2.0 per 100,000 hours. In addtion there were 6 fatal accidents / 10 years in UK gliders flying abroad, some of which may be reflected in the French stats above.

Care needs to be taken with the statistics due to inclusion / exclusion of FRA in the data, particularly with gliders as the French Alps is a popular destination for glider pilots from other countries. And mountain flying does tend to produce a higher incidence of fatal accidents.

In both UK and France it is difficult to arrive at fatal accident rates for aeroplanes < say 2mt or < 5.7mt due to lack of reliable exposure data. But there were 46 aeroplane < 2mt UK fatal accidents in the 10 years.

[tdbristol]

It seems EASA is issuing the usual platitudes, but doing a great disservice to European aviation safety. Look at some of the recent EASA track record:

1) Part M maintenance fiasco, causing vastly increased costs with zero safety benefit

2) major EASA PAN OPS proposal document on commercial regulations NPA 2009-02 that British Airways Flight Operations stated was "in its entirety unfit for the purpose for which it is intended and must be withdrawn and reconsidered"

3) aircraft certifications where EASA requires certification on individual model types, increasing costs of manufacturers enormously and also restricting available effective market for equipment

4) mechanic certifications required on specific airplane types, increasing costs and reducing availability of mechanics for less common types

5) suggesting (also in NPA 2009-02) that small helicopters should fit self-inflating floats for over-water flight as this "increased safety" and would be "at little cost". However, of course in reality, fitting self-inflating floats means worse safety as more time over water and more strain on the engines of small helicopters like R22s - where you couldn't even fit these, the cost on other small helicopters would be £50k or more each and wouldn't be certifiable anyway

6) threatening/planning regulations that will affect badly some balloon pilots

7) half-baked plans to require PR-NAV in controlled airspace below FL 95 - at great certification cost. Approach-approved RNAV is accurate to 0.3nm; PR-NAV requires 1nm accuracy, but approach-approved RNAV would not be enough - you would have to pay £1,000s to get PR-NAV certification as well

8) putting forward regulations for commercial cabin crew to have vastly increased medicals [at substantial cost], just in case a member of a cabin crew has a heart attack at exactly the time that an airliner has an accident and cannot help passengers disembark - really, what are the chances?

9) the enormous costs for regulatory response and compliance being heaped not only on GA but on commercial airlines. These additional regulations are not enhancing safety one bit. Commercial operators have to make a profit - additional regulatory costs are spiralling and something has to give. I know at least one regional airline in Europe that has taken the tough decision to scale back a bit on discretionary pilot training, delay some non-essential maintenance etc. - and these are things that REALLY could affect safety.

10) and of course the N-reg / IR issue

In each of the above cases (and many other areas) EASA are reducing safety and increasing costs.
Plus, perhaps worst of all, EASA is saying "safety is their priority" but
a) ignoring the fact that European GA accident rates are much higher than the US and elsewhere and EASA are doing nothing constructive about this
b) and EASA are only adding regulations that will likely worsen the situation, with no justification or meaningful data and RIAs (Regulatory Impact Assessments) that are a joke.
I have written to Brian Simpson, Mike Nattrass and Jacqueline Foster (MEPs on Transport Committee) and Theresa Villiers MP (Department for Transport) pointing out what a failing organisation EASA is, giving some of the above examples.
[B]
I urge all of you to write to these and other MEPs and MPs - it is only if they receive many letters informing them of the ineptitude of EASA and the havoc EASA is wreaking on European aviation that they may do something about it. Pick your own area where EASA are negatively impacting you and write to the MEPs / MPs about it.

[peter272]

Well said.

However it is clear that they are immune from any criticism. They have been told repeatedly not to reinvent the wheel. Brian Simpson and others did a fantastic demolition job on Patrick Goudou.

But they are still there, and the FCL paper is going to the EU fundamentally unchanged.

EASA know they are untouchable and are regularly showing us the finger.

[Pace]

But they are still there, and the FCL paper is going to the EU fundamentally unchanged.

Because they know that in Euro law only the whole can be rejected not the part so why bother to change the part when you know the whole would never be rejected.

A sad joke the whole charade

Pace

[Tetrimmo]

At a press meeting past Jan. 11th 2011, Mr. Goudou stated in front of about 50 European journalist and representatives of international press agencies that "we have realized, much to our surprise that there are more than 68,000 pilots in Europe who could be affected by this rule" (Mr. Goudou was referring only to FAA licences holders); Furthermore Mr. Goudou stated "that in light of the unprecedented concert of protest, EASA is willing to use the grace period until 2014 to launch and finance a study to understand the differences between FAA (american) licenses and Current European licenses".
Therefore, EASA has recognizedthat that EASA advised the commission without having a clear understanding of the situation, from a safety, economic or technical standpoint.

If it where not so dramatic it could best fit the the joke of the day section !



ICAO Annex 1 excerpt:
1.2.1 Authority to act as a flight crew member.
A person shall not act as a flight crew member of an aircraft unless a

valid licence is held showing compliance with the specifications of this

Annex and appropriate to the duties to be performed by that person.
The licence shall have been issued by the State of Registry of that

aircraft or by any other Contracting State and rendered valid by the

State of Registry of that aircraft.


The FCL is not respecting internatinal rules accepted and signed by all EU countries.

The FCL impose to maintain 2 licence (one based on the ICAO rules issued by the state where the aircraft is registered and a second one based on residence of the pilots)
A rule based on domicile is not only a discrimination, but also a total non-sense ! and never EASA proof a safety progress.



Write to your MEP's, we already have done it, and we will keep doing it as long the text is not voted, it's not too late to act.
EASA has not yet released the final text to the parlement.

Here are some arguments from the MEP's to our written:
BASA agreement are signed !!Yes that's trough a BASA agreement was signed on the June 30, 2008
the content of this agreement not yet in force is all about technics like aircraft airworthiness, repairs, reconizing from aircraft and parts certification.

Yes, the article 2, The parties may agree to additional areas of cooperation and acceptance by written amendment of this Agreement in accordance with Article 19;
This Article 19 is all about technic matters

AND NO, this BASA is absolutely not applicable for crew licencing !

FAA confirmed that there is NO disscussion and NO draft with regards to crew licencing or licences validation / convertion

Delay, the EU will set new delay before application of the new rules until BASA agreements are in forceNO, that's not the true,
The modified text say specifically (Article 10, point 4) Member States may decide not to apply the provisions of this Regulation to pilots holding a licence issued by a third country involved in the non-commercial operation of aircraft specified in Article 4(1) (b) or (c) of Regulation (EC) No 216/2008 until 8 April 2014.

- May decide, is no obligation form in the text
- Until 8 April 2014 is no option given for a later date if licences validation / conversion agreement are not in force at this date.

This rule is also in force in the USA where FAA require US based pilots to fly with FAA licencesYes, if flying on N-registration
NO if flying on G, F, PH, HB registration, but anyway I thing they are just a few pilots flying in the US with a G-reg ! (maybe a few F in the Caribbean

Write to your MEP's and urge them to reject this text.The TRAN members list is available here: Transport and Tourism (TRAN) : Members (http://www.europarl.europa.eu/activities/committees/membersCom.do?language=EN&body=TRAN)If you need some more arguments:
Expect € 15'000 and above for only IR conversion
2000+ pilots jobs lost (corporate pilots)
Mr. Goudou misinformed the commission (TRAN meeting Nov. 9, 2010)
850 millions Euros market value lost of GA aircraft (due too massive increase of aircraft for sale, so your G-reg will suffer from this too.)
200 millions Euros turnover lost by manufacturers, repair station and related jobs lost
Working group on FCL 008 is still far away from a substantial and viablee improvement for a relevant and cost-efficient EU IR rating
Hypothetical BASA agreements, even IF a base would be drafted, which is not the case yet, 3 years is far too short to complete a such agreementAt the TRAN meeting Nov 9, 2010, Mr. Goudou stated that he will support the maintain of the UK IMCrating;
There is no mention about it in the proposed text, what about the issued rating and rules for the PPL willing to pass this rating ?
This is just another unrespected statement from the EASA.

Below just released the answer given by Mr. Kallas to the question asked by MEP Mr. van Dalen vice-president TRAN:

1 February 2011 E-010837/2010 (http://www.europarl.europa.eu/sides/getDoc.do?type=WQ&reference=E-2010-010837&language=EN) Answer given by Mr Kallas on behalf of the Commission The Commission is aware of concerns raised by holders of pilot licences issued by third countries.
Current EU legislation(1) (http://www.europarl.europa.eu/sides/getAllAnswers.do?reference=E-2010-010837&language=EN#def1) as adopted by the Parliament and the Council on common rules in the field of civil aviation and establishing a European Aviation Safety Agency mandates the Commission to regulate the issue of third country licences for pilots residing in the European Union (EU). Pilots residing in the EU and involved in the operation of an aircraft into the EU need to comply with European licensing requirements. These may be satisfied either by specific rules or by the acceptance of licences issued by third countries in case of operating non‑EU‑registered aircraft.
The Commission's proposal for the regulation on flight crew licensing (pilots) largely reproduces the standards commonly applied in Member States and developed previously by the International Civil aviation Authority (ICAO) and the Joint Aviation Authorities (JAA). Based on the opinion issued by EASA on 26 August 2010, the Commission's proposal was discussed on 7-8 December in the Committee established by Article 65 of Regulation No 216/2008 (‘EASA Committee’). The Committee unanimously agreed on a slightly modified text of the regulation on 8 December 2010.
The modified text proposes a transitional period until April 2014 for pilots flying in the EU with third-country licences (e.g. licences issued by the US Federal Aviation Authority). This time will allow for further discussions on the recognition of non-EU licenses within the framework of bilateral aviation safety agreements between the EU and third countries.
Such agreements have already been signed with the United States, Canada and Brazil but have not yet entered into force. Once these agreements enter into force, the necessary work can be done towards an agreement on simplified conditions for mutual acceptance of pilot licences issued by those third countries.
http://www.europarl.europa.eu/img/struct/navigation/hr.gif (1)Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC (Text with EEA relevance), OJ L 79, 19.3.2008.
:ugh::ugh:

[proudprivate]

However it is clear that they are immune from any criticism.

I don't think EASA or the Commission are "immune" to criticism in this period of financial and widening economic crisis.

Please write to MEP's urging them to reject the FCL document, mentioning the lack of transparency by the Commission, its abuse of powers and the detrimental effects of the regulation.

Please write to the European Ombudsman, explaining the issue in detail and showing the inconsistencies, lack of transparency and abuse of powers in the decision making process the Commission and more precisely, the Aviation Safety unit of the Transport Directorate General is driving.

Please write to the Council of Ministers (and more precisely, your Transport Minister) about the detrimental effects to Aviation Safety and the Economy that EASA has had since its existence. Please also mention the current EASA budget of more than € 110 Million.

I've heard from my MEP that the FCL issue will be discussed in the transport committee in March, provided the legal service of the Commission and the translations are done by that time. This means that there is still sufficient time to write and mobilise against this grave injustice.

[Tetrimmo]

Granting a clearance to non-European resident private pilots to enter the European airspace with third country issued license on-board of third country registered aircraft and

Refusing that same clearance to European residents private pilots is not a safety progress but is implementing a true apartheid to the detriment of those who reside in Europe which are the most used to fly safely within the European airspace and which additionally pay their taxes.

Write your MEP's and urge them to REJECT the EASA Part-FCL proposal.

MEP's listing here:
http://www.europarl.europa.eu/activities/committees/membersCom.do?language=FR&body=TRAN (http://www.europarl.europa.eu/activities/committees/membersCom.do?language=FR&body=TRAN)

[tdbristol]

Like others, I have written to MEPs (and UK MPs as well).

It seems an uphill struggle to get the vote on Part-FCL into a "No" - may be possible if enough people write to enough MEPs - SO PLEASE DO.

On a more general note, it is worth pointing out how inept EASA is - a simple example is M. Goudou - the head of EASA - (as he himself stated) "not realising" the 68,000 pilots in Europe affected by EASA's stupid changes on foreign licenses.:ugh::ugh:
So, despite having NO IDEA of the real impact, EASA put forward disastrous legislation on foreign licenses/IRs and as it currently stands, it looks like they will force it through - their Regulatory Impact Assessments are a complete joke.
Like the Comitology Committee that pretty much waived it all through (as in a complete joke - where is the over-sight?).

The fact is, if the moderators here were to do a survey asking:
(a) has EASA regulation improved the safety of your flying?
(b) has EASA regulation increased or decreased your costs/paperwork etc.?
I would be willing to bet that almost everyone (whether European registered or FRA) would say that on
(a) there has either been no change at all on safety or that their safety has been drastically badly affected (such as FAA IR pilots, many of whom will lose this vital safety aspect, and also those with a UK IMCr who will likewise lose out)
(b) costs and paperwork have gone up substantially.

The fact is that EASA is a failing organisation of almost breathtaking incompetence, that is a disaster for European aviation - ensure you point this out in the letters to your MEPs (with specific examples).

Only by doing this will
- MEPs realise what is really going on with EASA
- MEPs may, just may, exert sufficient pressure on EASA to start to act with some level of competence and responsibility.

[eurm_ctr]

Since someone here mentioned mountain flying, what is going to happen to the French mountain rating (the general, lifetime, non-site-specific one)? The way I understand it, up till now if you completed the training with a non-French JAA license the regional DGAC office would give you a piece of paper to keep with your license that is equivalent to a rating. What now?

Couldn't the IMCR be handled in a similar way, i.e. the UK keeps on training the way they please, then release a piece of paper to keep with the EASA license that gives IMCR privileges in the UK only, without necessarily issuing an "official" rating?

[Pace]

Eurm

The problem we have with the EU is that anything starting with instrument rating means access into CAS.

They have their beloved IR and all the other professional bits and bobs which add up to Commercial state airline pilot.

No one especially rich Bast~rds may enter this sacred airspace unless they fly people carriers for the masses.

EASA cannot accept any form of instrument rating which waters down their superior rating and training.

If it starts with PPL ie PPL IMCR or PPL IR Lite they dont want to know because it doesnt fit with their vision of aviation in Europe.

Simple as that

Pace

[IO540]

Yes, there are various hacks like that.

One needs to keep the IMCR issue red hot, especially at the appropriate time.

The EASA measures are 99% stuff which nobody (who actually flies) actually wants. It is not often in politics that a proposition has such a lousy payoff. The protagonists are mostly political axe grinders who are too ashamed to come out into the open. This is a positive aspect of all this. NO safety case for any EASA measure, and no objective argument either.

[trevs99uk]

Do we know when the FCL paper is going to be voted on..


trevor s

[proudprivate]

My MEP told me that
- Commission's Legal Service is still looking at the proposal
- Proposal has to be translated and sent to the Parliament
- He expects parliament to receive it end of February
- The next meeting of the Transport Committee is Feb 28, but the EASA proposal will probably not be on the agenda.
- He expects a debate on the EASA FCL proposal in the Transport Committee following that one, i.e. on the 14/15 th March, but not a vote.
- He expects a vote on the proposal in the meeting after that, which is planned for the 11/12 th April


I hope this helps.