Campaign Against Aviation licence changes

[nigelh]

Does anyone understand what is happening re licences ? I thought i had got away from the lunatics by flying on my FAA ticket ...now it looks like they will stop people using what is a very simple and effective licence . ( No type ratings / night rating etc bliss :ok:) If the morons who run the CAA are going to take over ALL licences being used in this country that is a v bad day for aviation . We will have to do all the idiotic nonsense of type ratings, use VOR,s in training that we will never have on our aircraft, have people with thousands of hrs on a type who then have to be trained by someone with 50 hrs ....... etc etc . Hopefully i have got this wrong, but if not, all of us who have flown happily on an FAA ticket will now have to join CAA lala land with all of its nonsense designed to keep the twits in a job and make flying as miserable as they can make it !!!
Can we not just all make a stand and sack the lot and start again with some common sense added ?????????????!!!!!!

[Agaricus bisporus]

Why should you be allowed to use your FAA ticket without any form of validation or periodic checking to operate aircraft maintained (or not) to unpoliced/unpoliceable standards for as long as you wish?
If you bring an EU registered car into the UK you are only allowed to keep it here for a limited time before doing the honest thing and registering it locally. You have to obtain a UK driving licence after, I think, a year. Why should you be able to keep a non Eu reg aircraft here indefinately with no way for the national authority to have any jurisdiction over its maintenance or use?

Sounds fine to me.

[birrddog]

Nigelh, does this affect me coming to visit UK and wanting to use my FAA ticket, or does it only apply to residents?

I always appreciated the blanket ICAO validation in the UK ANO as some refreshing common sense.

Keeping my two tickets up is pain enough without having to add a third JAA ticket for the few hrs a year I do in the UK.

[FSXPilot]

I believe from reading the proposed regs that in one sentence they manage to dismiss your FAA licence and say if you fly an EASA aircraft as designated in CAP747 then you need an EASA licence end of (argument).

[FSXPilot]

http://www.caa.co.uk/docs/620/c-May2011v3.pdf

http://www.caa.co.uk/docs/620/d-FAQMay2011_linked%20to%20paper%20v3.pdf

these two links give you the full low down.

[nigelh]

but as i read it this will apply if you are flying G reg machines that do comply with regs . I fail to see why the CAA, who have shown a complete lack of any understanding of aviation, should decide that they will do a better job !! All of us who have worked with both the FAA and CAA will agree that the CAA makes things unworkable / expensive /complicated ....to the extent that if you are unsure of the legality of a flight and call them .....they will not know the answer and will tell you to do what you think is correct and they will try to prosecute you if they disagree !!! There are a number of very well respected pilots / instructors out there who know this to their cost . Luckily however the stupidity also affects their prosecutions ...thats why they try to prosecute rarely and very often lose . For over 10 years i have flown what some believe are illegal flight,s ......however the CAA have been very aware and i have on record many of my questions and their answers .
Is there a problem with safety etc with FAA pilots ?? As i said earlier , i havent bothered keep my licence up to date due to the cost and confusion as to what i actually have to do to keep all my ratings up to date . Ticking lots of boxes does not make you a safer pilot IMHO .

[nigelh]

Ok so i can fly until 2014 on my CAA ticket and until 2015 , but only if i fly say an MD500 ......but not a 206 . Thats really clear and sounds really well thought out . Well done all you guys and gals at CAA / EASA etc ::D
This is going to be a right f***k up for sure with loads of pilots not knowing if they are legal or not or have an imc or not ........ typical :mad:

[FSXPilot]

no one is arguing with you that a trained pilot with an FAA licence is more dangerous than a pilot with a JAA licence but unless we leave the EU (fat chance) and the CAA are in charge again than I guess we have to comply with regs (OMIGOD do EASA love the phrase comply).
I think for comply you can translate as bend over and make sure you are greased up because for sure they won't care.

[Jarvy]

Ok then, I have a JAA CPL(H) but now live in the US, does this allow me to fly here. No not without a licence issued by the FAA. So all this seems to be doing is fitting in with the rest of the world.

[herman the crab]

And if it was as easy and as cheap to get a CAA/JAA/whoever it is this week/etc. licence based on a foreign (eg FAA) one as it is the other way around most people would have no objection...

HTC

[nigelh]

The problem is that it wont be as easy and cheap and if you fly many types you will have to maintain a rating on each type which can be v expensive:ugh: I think that in this country our usual apathy will ensure we get the system we deserve . Small operators are getting squeezed out of business due to over regulation , and soon there will be none left ( especially the small singles )....prices are getting higher and higher and less people are now flying for business or pleasure . The only people who benefit are the people who operate outside of the system as they can do flights a lot cheaper without all the red tape . I could now do flights profitably charging at least a third less than people saddled with the cost of an AOC ....does that sound fair or logical ??? Time will show who is right ...

[coning angel]

You sound like a broken record. Just man up and get a proper licence, instead of skirting the real world licencing. All very well flying only on an FAA, but only because you can't be bothered and think you're above the CAA system. It works for so many people, but you're obviously a special case?

[nigelh]

You got it in one , v perseptive :D I am also thinking that maybe you only fly one maybe two types ?? If you were flying up to 10 types you would think differently maybe ? There are just so many stories about some of the most experienced pilots in the country having to get new ratings from their own students !!! God forbid if you needed a rating on some of the rarer birds like Allouette / Lama / 430 / Brantly etc you could be on a wild goose chase soon .

[birrddog]

Ok then, I have a JAA CPL(H) but now live in the US, does this allow me to fly here. No not without a licence issued by the FAA. So all this seems to be doing is fitting in with the rest of the world.

Yes, it does.

You can pitch up in the US with any ICAO license and a certified copy of your logbook and the FAA will give you a (restricted) FAA ticket based on your ICAO license (restricted e.g. if you don't have a night rating).

The only difference is instead of going through the process below, the ANO currently gives you an automatic validation without the hassle of paperwork.

The two snags here (aside from potential night restriction) are that it takes 2-3 months for the FAA to validate your license with the relevant authority, and if anything happens to your foreign license your are stuffed (e.g. you are in the US for 2 years and miss a flight test in your home country, or can't get your foreign medical renewed because you are in the US, even though flying and keeping current).

Validations also (in my experience) expire after 2 years so you have to go through the process again; hence getting an FAA ticket in the first place.

In the US you can even get a full FAA ticket passing the written and doing a flight test if you have >100 hrs (incl. relevant night experience) - hardly a burden.

I don't read what nigelh is saying as don't fly without a license, just that keeping up multiple licenses and type ratings across each jurisdiction is not particularly practical; it's a paperwork exercise and does not make you a better or safer pilot.

Law's and regs are fine, though it is important not to loose sight of the forest for the tree's, which is most often the case when broad sweeping regs are created without understanding or reviewing their real-life implications.

Do you feel safer standing on the apron next to your large helicopter on a bright sunny day just because you are wearing a hi-vis vest?

[HillerBee]

The new rules are EASA rules, and not specific CAA UK, so it applies to any European Country and citizen.

Many countries in Europe don't allow you to fly on an FAA ticket now, if you are a resident. Basically the UK and Ireland are the excemption.

I'm just stating facts not saying I agree.

[Ready2Fly]

This is an exempt from LASORS section F8
For single-engine turbine helicopters with a MTOM <3175 kg, the proficiency check in accordance with JAR-FCL 2.245 (b)(1) is only required on one of the applicable types held, provided that the applicant has:-

i. completed at least 300 hours as pilot in command of helicopters; and

ii. completed 15 hours as pilot on each of the type(s) to which that revalidation proficiency check shall carry across, and

iii. completed at least 2 hours as pilot-in-command flight time on each of the other type(s) during the validity period to which that revalidation proficiency
check shall carry across;

The proficiency check shall always be performed on the type least recently used for a proficiency check, unless an individual written permission has been given by the Authority.
To me this is a reasonable regulation at least for SET. I am sure if you have flown less than 2 hours on a type within a year, even on a FAA ticket you would get some familiarisation again before an operator lets you go on your own and not everybody on a FAA and/or JAA ticket has x thousand hours and y hundred on type.

[nigelh]

Hiller......that sounds v reasonable initially but what happens if you are current on some of these types but dont have type ratings on your CAA licence . For instance i have 206, 500, Gazelle on my UK licence but have many hrs and am current on 480, 206L and 109 . Can i do my check on one of these or do i need to do a full type rating on all of them even if i have 100,s of hrs already ?? what are you supposed to do for 5 hrs training ....this could mean 20-30 hrs training for pilots who are already current and would be prohibitively expensive .

[Epiphany]

There is a limit on the amount of current type rating for commercial operations for a very good reason - safety.

[birrddog]

Epiphany, a piece of paper is not going to make you any safer.

And before those who think the FAA system, or current UK ANO blanket validation is for unsafe cowboys...

Show me one operator or insurance co. that is going to allow you to just show up, take their expensive machine for a joyride, without getting to know you and do a check ride and possibly a minimum amount of dual.

This is the common sense reality.

[Epiphany]

Epiphany, a piece of paper is not going to make you any safer.

If the piece of paper says that you have been recently checked as proficient on a particular type of helicopter it will.

[Canros]

There is a limit on the amount of current type rating for commercial operations for a very good reason - safety.

Perhaps someone could provide a link to the reasoned safety case made to support this statement. The qualifications and authority of those making the case would help determine the validity of such a bold statement.

[Bravo73]

There is a limit on the amount of current type rating for commercial operations for a very good reason - safety.

Perhaps someone could provide a link to the reasoned safety case made to support this statement. The qualifications and authority of those making the case would help determine the validity of such a bold statement.


This is what OGP think about the matter: (my bold)

4.3.4 Pilots flying more than one aircraft type
Aircraft operator policy regarding how many types of aircraft their pilots may fly varies significantly from company to company. The advisability of pilots flying more than one type will vary with the types involved, the experience level and ability of the individual pilot. Nevertheless, because flying several types on a day-to-day basis inevitably increases the danger of incorrect responses in the case of emergency, and the likelihood of handling errors or errors of omission, a limit must be placed on the practice.

It is expected that aircraft operators have a written policy on the subject, which applies across their operations. While pilots are quite correctly endorsed on a number of aircraft types, it is recommended that only in exceptional circumstances would more than 2 types be flown on a day-to-day basis, with a preference to see a single type flown, or scheduling in blocks of days on a particular type. If more than one type is flown, recency flying and type training must be closely monitored both by individual pilots and by a nominated member of the flying, training or operations staff.

(From OGP Report No 390, Aircraft Management Guidelines)

[Epiphany]

Perhaps someone could provide a link to the reasoned safety case made to support this statement. The qualifications and authority of those making the case would help determine the validity of such a bold statement.

Bold statement? I would have thought that it was a statement of the bleeding obvious.

[JimL]

Canros,

... and your qualifications for making such a statement are?

Jim

[nigelh]

Epiphany ....did you really mean that ??!! You really believe that a piece of paper makes you a safer pilot ? I know that if i had to choose between flying as a pax with pilot A 200 hrs just got type rating and pilot B 2,000 hrs ( 1,000 on type but no type rating )....i would chose the 2,000 hr pilot . He may not be safer ...he may be equally safe but he will have a hell of a lot more experience to draw on in an emergency ...and thats what i would want ...good airmanship.
Bravo . I see the sense of this for commercial ops in complicated ME machines but honestly is there any difference between flying any of the singles ??? ( dont count robbos as they are a case all of their own ).
I guess the only people who will care about this is the ones who will get hit with more red tape and more cost of unnecessary hrs of flight tests /instruction .
ps what do you think will happen to the 1,000s of people who now fly around much safer with an FAA IMC ?

[Bravo73]

Bravo . I see the sense of this for commercial ops in complicated ME machines but honestly is there any difference between flying any of the singles ???

FYI but the OGP guidelines also cover single pilot, SE operations. The same recommendations and restrictions apply.

[JimL]

Nigel,

Surely the question should be whether you would choose a pilot who just 'stepped' into a new type without any rating or one who has just passed a rating exam.

It is questionable whether a licence should permit a pilot to fly any type below 5,700kg without undergoing some training and checks? Remember that below 5,700kg are the S76, the AS365, the BK117, the A109 (did you fly that without any training), the EC135, the AS355, the MD902, the BO105 etc.

Jim

[birrddog]

If the piece of paper says that you have been recently checked as proficient on a particular type of helicopter it will.

I've got this piece of paper see... sais I own a bridge in London... would you like to buy it?

[nigelh]

Jim..I have flown approx half of the types without any rating . I have always had some training before going solo and then always done a few hrs solo before taking pax . I have always felt totally up to speed on any single within an hour ...not due to any skill but just the fact that they all fly pretty much exactly the same !!! ( my last CFI check ride was in a 300c which i havent flown for 20 yrs and i had 45min famil flight before the test ...and past ). The 109 took a bit longer but just due to more complicated procedures etc Am i missing something or are FAA pilots jumping into machines without training and killing themselves ?? My example was of a pilot with many hrs experience in that type against a low hr pilot who had the piece of paper .

[coning angel]

So you're telling us you were up to speed in a 109 in little more than 45mins? Really? You must be a helicopter flying god. Ok, you could probably fly it, but to know all of the immediate actions in a multi eng helo in less than an hour? Total rubbish. One day we'll no doubt be reading your obituary.

[Epiphany]

Birddog,

I've got this piece of paper see... sais (sic) I own a bridge in London... would you like to buy it?

Not from someone who doesn't have a current type rating. I wouldn't trust you.

[birrddog]

Acshurely, I have 4 current type ratings on one of my licenses.

That mean I can sell you 4 bridges? ;)

[Epiphany]

No. Because if you have 4 current type ratings on a PPL(H) then you obviously do not need any more money. Just more sense.

[birrddog]

I guess I better not tell you then about the other 4 types and their variants I fly on my FAA ticket lest you have an implosion of paperwork envy. :p

[Epiphany]

Envy and FAA are not two terms that I would use together. I hold both UKJAR and FAA ATPL's are I know which one I take seriously. I also have 14 helicopter type ratings but one twin and one single are all that I am allowed to operate by my company - thankfully.

[paco]

Nigelh - sorry, but your statement:

Epiphany ....did you really mean that ??!! You really believe that a piece of paper makes you a safer pilot ? I know that if i had to choose between flying as a pax with pilot A 200 hrs just got type rating and pilot B 2,000 hrs ( 1,000 on type but no type rating )....i would chose the 2,000 hr pilot . He may not be safer ...he may be equally safe but he will have a hell of a lot more experience to draw on in an emergency ...and thats what i would want ...good airmanship.

needs taking up.

I have flown with pilots with 2-300 hours whom I would trust with anything. I have also flown with pilots that have 17,000 hours whom I wouldn't trust with a pram.

As for other comments about currency, as one who was once current on 6 reasonably different types (3 fixed wing and 3 helicopter) for more than a year, I can assure you it is hard work. There is a limit for a reason!

Phil

[nigelh]

Paco . I quite agree with you but was trying to make a point ( unsucessfully it seams ) . It appears that i am in a minority thinking it is unecessary to make pilots, with 30 yrs experience and thousands of hours , sit in a helicopter and fly it for x hrs with an instructor who in all probibility knows less about the type than he does .:ugh:

Epiphany . Birddog ( the one with too much money ...) seems to have found your achilles heel ....we now know you are insecure and dont take your FAA licences seriously as you have a "proper" licence ...

Coning .... say after me " i am a naughty boy as i didnt read the post properly " You really should not make smart arse remarks about obituaries on this site . It is in bad taste and poss too close to home for some unfortunate people . After 30 yrs i think it is fair to say that if i and my instructor feel happy that i am competent ...then possibly i am .:rolleyes:

[Camp Freddie]

As soon as people start to say "that requirement shouldn't apply to me as I have loads of experience" or even if chief pilots or management say some pilots are more experienced so therefore "that regulation shouldn't apply to him" the situation immediately becomes hopeless and inconsistent, and special cases and variations pop up all over the place.

Validations aside, If people are based here then to me clearly they should have a JAR/EASA licence, if they are based in an FAA territory then they should have an FAA licence. For someone to say themselves that "I don't need to do proper type rating training on this type because I have a foreign licence" to me sounds ridiculous, in that case they should go to that country if they want to operate like that.

Using an FAA licence is to me just a "device" to avoid being subject to the same regime as the rest of us, who would like to save money as well but have chosen to use the system that was designed for our area of operation rather than for another continent.

[HillerBee]

If you have more than 100 hours on type all you have to do is a LPC with an examiner to get a EASA/JAA typerating (<3150 kg) So if you're current no problem at all.

[paco]

Nige - It seems you are in a minority! I have examined people who have way more hours than I have, and vice versa. It's simply the luck of the draw, and we both had something to offer each other. In any case, if you have lots of similar types, you only need an lpc on one to make them all current.

cheers

Phil

[nigelh]

Paco . Are you saying then that one LPC will validate all the other types that i fly ...even if i dont have an original type rating in them ? I assumed i would now have to do a rating on all the types not on my CAA licence .
Also is it definitely correct that if you get 100 hrs pic in your log book on that type you can just do the LPC and will then get the rating ?
HillerBee not doubting you but this is news to me and would mean just an LPC on each type initially then one type each year . Which is far better than i was led to believe.

[paco]

It's a while since I did it, but if I remember right if you had, say R22 and R44, or 350 B2/3/4, you could do a rotating lpc and the types would all be covered. Best check with a TRE for current info.

phil

[Curtis E Carr]

From LASORS 2010, and with regard to the revalidation of the SEP and SET groups:

Revalidation of a helicopter type rating requires a
proficiency check in the relevant type of helicopter within
the 3 months immediately preceding the expiry date of
the rating, and at least 2 hours (including the proficiency
check) as pilot of the relevant helicopter within the validity
period of the rating.

For single-engine piston helicopters as listed
below (Appendix 1 to JAR-FCL 2.245 (b)(3) refers), an
applicant shall complete at least the proficiency check
in accordance with JAR-FCL 2.245(b)(1) on one of the
applicable types held provided that the applicant has
fulfilled at least 2 hours pilot-in-command flight time on
the other type(s) during the validity period which that
revalidation proficiency check shall carry across.

The proficiency check shall always be performed on the
type least recently used for a proficiency check. The type
ratings for this purpose are:-

Bell 47, Brantley B2, Hughes 269, Enstrom ENF28 and
Hiller UH12

For single-engine turbine helicopters with a MTOM
<3175 kg, the proficiency check in accordance with
JAR-FCL 2.245 (b)(1) is only required on one of the
applicable types held, provided that the applicant has:-

i. completed at least 300 hours as pilot in command of
helicopters; and

ii. completed 15 hours as pilot on each of the type(s) to
which that revalidation proficiency check shall carry
across, and

iii. completed at least 2 hours as pilot-in-command
flight time on each of the other type(s) during the
validity period to which that revalidation proficiency
check shall carry across;

The proficiency check shall always be performed on the
type least recently used for a proficiency check, unless
an individual written permission has been given by the
Authority.

Note that the SEP group does not include the R22 and R44.

And with regard to the transfer of type ratings:

A type rating endorsement on a licence issued by a
non-JAA State may be transferred to a UK issued pilot’s
licence, subject to:-

i. For a single-engine turbine and single-engine piston
helicopters with a MTOM < 3175kg, 100 hours flying
experience as pilot on type,operating as P1 or P2
appropriate to the rating required.

For all other helicopters, 350 hours flying experience as
pilot on type, operating as P1 or P2 appropriate to the
rating required.

ii. Operational experience as pilot on type within the
preceding 5 years.

iii. Pass a Proficiency Check on type with a JAA
Authorised Examiner.

iv. Have met the requirements of JAR-FCL 2.250, and
2.255 as applicable, including theoretical knowledge
requirements.

Applicants who hold a type rating but do not meet the
experience requirements above will be required to
complete a course of training at an approved TRTO. The
CAA may consider a reduction in the amount of training
required to take account of previous experience on type,
subject to a recommendation in writing by the Head of
Training. Applicants will be required to pass the written
theoretical knowledge examination and a Licensing Skill
Test (LST).

[Bravo73]

Gadzooks, C.E.C., you didn't expect nigelh to read LASORS, did you? ;)

[nigelh]

Bravo ... Good point , well made !! Think it best if I leave it until 2014 when Europe and EASA will probably be too broke to issue anything !!