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kenobee
9th Mar 2013, 13:33
I am an instructor with a small flying club in Ireland. We have to change from being a JAR RTF to an EASA ATO by April 2015. As I understand it we have to produce 3 documents, an Organisation Management Manual (OMM) an Operations Manual (OM) and a Training Manual (TRM). Does anyone have any guidance to offer? Are there any existing templates out there?

Whopity
10th Mar 2013, 09:18
Rumour has it that the UK CAA may be contracting out the provision of sample manuals, to act as a template, to meet the 2015 deadline.

A and C
10th Mar 2013, 09:40
I do hope that Whopity is correct, this industry is on its knees financially and more stupid over regulation is the last thing the industry needs, a little help to comply with these new rules from the UK CAA is welcome as well as being an indication that this is one regulatory step too far on the part of EASA.

I would have thought that following the complete fiasco that part M over regulation has become EASA would have realized that interfering with training system that has worked well for years was a stupid thing to do.

kenobee
10th Mar 2013, 14:32
It is interesting to hear this rumour regarding possible CAA template manuals. I thought the UK were further down the EASA road than we were in Ireland. Are you still working to the JAR system with small clubs operating as RTFs?

Whopity
10th Mar 2013, 17:33
Are you still working to the JAR system with small clubs operating as RTFs?Yes until April 2015 however; all new applicants must be in accordance with EASA.

hvogt
10th Mar 2013, 21:55
kenobee,

the following lines are based on a very brief look at the relevant regulations, so please take them for what they are, just some first thoughts.

The requirement to keep an Operations Manual (OM) and Training Manual (TRM) follows from point ORA.ATO.130 of Annex VII of the Amended Aircrew Regulation (Commission Regulation [EU] No 290/2012 of 30 March 2012) and from point ORA.ATO.230 for those ATOs providing training for professional licences. The content of the manuals, however, is only prescribed in rather general terms and thereby left open to further interpretation. The relevant AMCs (Annex to ED Decision 2012/007/R) give advice on the content of the manuals in more detail, but only with regard to ORA.ATO.230, i.e. for professional ATOs. A look at the draft version of EASA's User Guide for ATO Manuals (http://easa.europa.eu/approvals-and-standardisation/organisation-approvals/docs/FCL/UG.FCTOA.00004-000-UserGuideForATO_Manuals080612.pdf) (which is targeted at foreign ATOs) might give an impression of what will be required. It seems the breakdown of the OM's contents in this User Guide is more or less a copy and paste job from IEM No. 3 to JAR–FCL 1.055.

I think if I were to prepare an OM and TRM for a small flying club, I would use this IEM No. 3 to JAR–FCL 1.055 as a template. One mustn't forget, though, that IEM No. 3 to JAR–FCL 1.055 applies to professional training organisations, i.e. those that conduct 'approved integrated or modular flying training courses'. One should assume the requirements for small training organisations, like your flying club, must be less stringent. According to the above mentioned User Guide, EASA seem to be aware of this and ask for 'information [...] as applicable to the size, scope and complexity of the ATO'.

kenobee
11th Mar 2013, 16:16
HGOVT
Thanks you very much for the useful information. It took me about an hour to track down the references! So I will post the relevant links here for the assistance of others.
User Guide for ATO Manuals
http://www.easa.europa.eu/approvals-and-standardisation/organisation-approvals/docs/FCL/UG.FCTOA.00004-000-UserGuideForATO_Manuals080612.pdf


Interesting EASA Workshop held in Vienna 24th Jan. 22013
http://www.austrocontrol.at/jart/prj3/austro_control/data/uploads/PEL/Vienna%20workshop%20ARA%20+%20ORA%20clean.pdf

Annex to ED Decision 2012/007/R
European Aviation Safety Agency
Acceptable Means of Compliance
(AMC)
and Guidance Material (GM)
http://easa.europa.eu/agency-measures/docs/agency-decisions/2012/2012-007-R/Annex%20to%20ED%20Decision%202012-007-R.pdf

Pull what
13th Mar 2013, 12:16
I am hearing some very high figures for the CAA to read these manuals when completed, £4-5000. Anyone else know anything about this?

BillieBob
13th Mar 2013, 16:30
The application fee for an ATO providing training for the PPL and LAPL is £1000. This will buy you 5.8 hours of an inspector's time, which is what the Authority estimates is the time taken to process a fully compliant application. If the application is not fully compliant and, therefore, takes more than 5.8 hours to process, the extra time will be charged at £172 per hour up to a maximum total of £10,000 in any year or part thereof.

Each further course (e.g. LAPL to PPL upgrade, inclusion of TMG, Night Rating, Aerobatic Rating, etc.) will be charged at £500 per course and subject to the same £172 per hour surcharge if it takes more than 2.9 hours to process.

Depending upon the courses for which approval is sought, I would have thought £4-5000 quite possible as a final fee.

BigEndBob
21st Mar 2013, 23:22
If i have to pay £4-5000 for Lapl, PPL and night approval, then EASA and CAA will have achieved there ultimate aim of closing us down.
A one man operation with two aircraft cannot absorb those sort of costs.
I may as well go on the dole. Already 50% of turnover goes in tax. Why be underpaid tax collectors. Examiner renewal due soon circa £600 by the time i finish.

Whats the point of all this paperwork. Already someone as offered to do this for me and get it through for a £1000 fee, plus whatever the CAA want to charge.
Another job creation scheme for someone that doesn't live in the real world.

Example i have just printed off the paper work to renew an old CAA licence.
I think i have printed off about 23 sheets of paper!
Yet at the bottom of every CAA e-mail it asks is it really necessary to print this e-mail, think of the environment, thats obviously only for internal consumption.

Who thinks all this c**p up. I now see PPL turning up with all sorts of invalid licences, not realising it expired 2 years ago or flying with expired c of e.
In the old days 13 month c of e were stamped in logbook, where it was noticed every time the logbook was opened. Now PPLs only open their licence when a medical is due.

Cows getting bigger
23rd Mar 2013, 08:37
Yes, it is all thoroughly depressing and I've yet to see one bit that actually enhances safety. The lunatics are most definitely running the asylum.

turbine100
25th Mar 2013, 15:08
The new rules also affect AOC operators, they need to have their own ATO or have an association to an ATO. The costs for applications and hours for the inspection approval and mention of the templates, are all correct. With some schools struggling financially as is, not an idea situation for all.

Treadstone1
25th Mar 2013, 20:58
And don't forget the SMS......:ugh:

BillieBob
26th Mar 2013, 09:07
What SMS? There is no requirement for a separate Safety Management System, despite what the empire builders at the Belgrano would have you believe.