RTF to ATO

[justmaybe]

The latest brief from the CAA GA Unit is good news if it all comes to fruition in October. If it does, the possibility exists for a really simple transition (if at all) in the future (Update - RTF to ATO and Changes to Regulations)

[Whopity]

And if it doesn't, it will be a shambolic mess!

[BEagle]

Quite so, Whopity!

The CAA is already working on an AltMoC for vastly simpler RF-to-ATO conversion, which could be in place this Autumn, probably before the October EC session.

The last thing the training industry needs is 3 years of chaos and confusion whilst EASA re-invents the wheel yet again.

The 3 year delay is down to les grenouilles insisting that they continue doing things their way and nobody else's. It also suits those EASA member states which haven't done much to assist RFs with their conversion.

If there's a consultation, I hope that people will oppose the 3 year delay, 'dual training systems' and 'training outside an ATO' for the LAPL/PPL. The naïve few might think that such training would revitalise the UK training industry and bring down costs; the reality is that it would merely introduce non-standardised 'car boot' training and the unlucky punter would be put at risk as a result. And where would trainees sit their exams - at an ATO who would charge them £300 per exam, perhaps?

CAA GA Unit needs to listen to its own experts who've been around in the PPL training world for more than 12 months, realise the folly of this French-driven nonsense and firmly object.

As I've said before, appeasing EASA doesn't work; when dealing with €urocrats we need a Churchill, not a Chamberlain!

I trust you'll be objecting, Whopity?

[BigEndBob]

Reason way my template disc is sat gathering dust on a shelf!

[Whopity]

The latest missive from Brussels:
Information note for Member States and Industry on the proposal to amend Commission Regulation (EU) No 1178/2011 (Aircrew) relating to training organisations

1. General
The aim of this note is to provide further information regarding some of the details and the consequences related to the proposed changes to the Aircrew Regulation which have been developed by the European Commission (EC) and the European Aviation Safety Agency (EASA) and which were
presented to the EASA Committee on 9 July 2014. All Member States (MS) agreed in principle to the approach presented related to certain non-complex ATOs and the training for certain licences and ratings between 8 April 2015 and 8 April 2018. The proposal will be formally voted upon by the MS in October. As the proposed changes are supported by the MS it is reasonable to expect them to be in force early 2015.
It should be highlighted that the Agency has also presented a proposal to the EASA Committee which aims on developing a complimentary solution for conducting training towards an LAPL, PPL, BPL or SPL outside of ATOs. This task will be launched in the coming months and the Agency intends to
explore all the options given for future rule changes (not part of this proposal) in order to simplify the situation for training towards non-commercial pilot licences and associated ratings and certificates. The purpose of this note is however, only to inform all MS and the Industry about the amendments being currently proposed and their possible consequences in order to allow them to assess the impact on their planning and to better prepare for the proposed changes.
The current proposal for amending the Aircrew Regulation was initiated based on strong feedback from MS and General Aviation (GA) stakeholders stating that the requirements for transferring the former Registered Facilities (RFs) and other national training organisations (mainly for balloons and sailplanes) into non-complex ATO's according to Part-ORA by 8 April 2015 latest, seem to be disproportionate for the activity and the associated risks and places unnecessary burden on MS and stakeholders. Furthermore it might not be feasible for all these organisations and the MS approving them to conclude the certification process by that date. The proposed amendments therefore focus on this specific issue.

2. Proposed regulatory changes
The Commission and the Agency are proposing the following changes to Commission Regulation (EU) No 1178/2011:
- Article 10(a)(3) to be amended in order to allow JAR compliant registered facilities which have been registered before the application date of these rules to provide training towards the Light Aircraft Pilot Licence (LAPL) and the Private Pilot Licence (PPL) until 8 April 2018.
- Article 2 of Regulation (EU) No 290/2012 amending Regulation (EU) No 1178/2011 specifies so far that MS may decide not to apply the requirements of Annex VI and VII (Part-ARA and Part-ORA) to training organisations providing training only for the LAPL, PPL, SPL or BPL until April 2015. The amendment proposed will allow an additional derogation until 2018
unless otherwise requested by a training organisation.
- Article 12 will be amended to allow MS not to apply certain provisions of Annex I until April 2018. This includes the provisions related to balloon and sailplane licences and the requirements for some of the new ratings / certificates.

3. Consequences for training organisations
Introducing the changes indicated above will have the following consequences for the different type of
training organisations and for the MS approving them.

3.1. Former JAR-compliant training organisations certified as ATO towards Part-ORA
Former JAR-compliant training organisations (FTOs/TRTOs) are already grandfathered by Regulation (EU) No 1178/2011 as an Approved Training Organisation (ATO) according to Part-ORA. The privileges of these organisations are limited to the privileges included in the approval issued by the MS (Article 10a(2)). An additional transitional period until April 2014 was given to them for adapting their management systems, training programmes, procedures and manuals. These ATOs are not affected by the proposed rule changes.

3.2 Registered facilities and other training organisations certified as ATO towards Part-ORA
Former JAR-compliant registered facilities (for aeroplane and helicopter licences) or national training organisations (for sailplane and balloon licences) which have been certified or will be certified according to Part-ORA as an ATO under the new system will have the full privileges given by the certificate for providing training towards Part-FCL licences including courses for the new ratings (e.g. the en-route instrument rating, mountain rating, instructor courses, etc.) if these privileges have been given.

3.3. Registered facilities not certified as ATO towards Part-ORA
JAR-compliant training facilities registered in a MS before the regulation applied which have not been certified yet towards the new rules will receive the privilege to provide training towards the LAPL and the PPL in the respective aircraft category. The privilege will also include the associated ratings which were included in the registration before. This will include in most cases the associated class (Touring Motor Glider and Single Engine Piston) or type (Single-engine helicopter) ratings and should also cover the night rating for those registered facilities which provided training for the night qualification before. 8 April 2018 is proposed as the end date for this extension of privileges without complying with Part-ORA. As a consequence these JAR-compliant registered facilities will have until 2018 for adapting their management systems, training programmes, procedures and manuals in order to receive an ATO certificate according to Part-ORA.
Apart from training towards a LAPL, these JAR-compliant registered facilities will not be allowed to provide training for additional Part-FCL licences or ratings which had not been included in their privileges under the JAR registration. In order to extend the privileges and to provide training for additional Part-FCL courses for other licences or ratings, these training organisations have to be approved in accordance with Part-ORA.

3.4. Other national training organisations for sailplanes and balloons
Based on Article 2 of the Regulation (EU) No 290/2012, MS may decide not to apply the requirements of Part-ORA to training organisations providing training only for the LAPL, PPL, BPL and SPL until April 2015. The amended text proposes an extension of that period until 8 April 2018, and no longer as an opt out.
Consequently training organisations for sailplanes and balloons will only be allowed to provide training for national sailplane and balloon licences and associated ratings and certificates. The training will have to follow the national rules and procedures until the end of the transition period or until the training organisation is approved as an ATO under Part-ORA.
MS may in this case continue issuing national sailplane and balloon licences during this extended transition period. These licences can also be converted into Part-FCL licences based on the conversion reports established by the MS. The changes proposed for Article 12 of Regulation (EU) No 1178/2011 (new paragraph 2a) will allow MS not to apply the provisions for balloons and sailplanes contained in Annex I until April 2018.

Brussels, 18 July 2014

The shambles continues; ad infinitum!

[fireflybob]

Reason way my template disc is sat gathering dust on a shelf!

Mine also, BEB!

[jez d]

JAR-compliant training facilities registered in a MS before the regulation applied...

Was this the September 2012 transition date ?

Thanks

[Whopity]

It doesn't really matter, if you are an RTF you can continue, if not, you need to become an ATO. Another example of dual standards creating an unlevel playing field and unfair competition.

[Mickey Kaye]

Stupid question time.

Does this mean (if it gets voted in) that RTF will now be able to teach for the LAPL?

[jez d]

Apart from training towards a LAPL, these JAR-compliant registered facilities will not be allowed to provide training for additional Part-FCL licences or ratings which had not been included in their privileges under the JAR registration. In order to extend the privileges and to provide training for additional Part-FCL courses for other licences or ratings, these training organisations have to be approved in accordance with Part-ORA.

Appears so, although RFs wouldn't be permitted to conduct training for the IR(R) or CBM-IR without 'upgrade' to ATO status.

[Treadstone1]

Correct Whopity.. It all stinks

[BEagle]

jez d wrote: Appears so, although RFs wouldn't be permitted to conduct training for the IR(R) or CBM-IR without 'upgrade' to ATO status.

No approval is required to conduct training for the IR(R) - did you mean the EIR?

[dobbin1]

Will an RF be able to teach for the aerobatics rating, which did not exist before EASA? The wording above seems to suggest not, even if the RF currently does aerobatic training.

If the answer is no, then I hope the grandfathering arrangements will continue as is.

[BEagle]

dobbin1, I understand that if the RF is teaching the AOPA/BAeA syllabus, then that will 'grandfather' a right to teach the Aerobatic Rating. Which isn't surprising, given that the AOPA/BAeA Basic Syllabus was aligned with the Aerobatic Rating course a couple of years ago.

However, ad hoc aerobatic training to some other syllabus might not be recognised as qualifying.

[dobbin1]

Thanks Beagle. That is good news - we do the AOPA cert.

[fireflybob]

Anyone know what the latest is on this - is the CAA issuing a CD with new templates in October?

[BEagle]

fireflybob wrote:Anyone know what the latest is on this - is the CAA issuing a CD with new templates in October?

Work is ongoing; however, October might be a little optimistic.

[Whopity]

In a CAA letter dated 11 Jjuly 2014 it said:
Subject: Update - RTF to ATO and Changes to Regulations

There was very strong support for the deferment to allow RTFs to continue training for the PPL without ATO approval from 8 April 2015 to 8 April 2018 to permit time to do detailed work on alternative options for private pilot training outside of ATOs. Assuming the deferment is agreed, and alternative options are not subsequently agreed, RTFs would have to transition to ATOs by 8 April 2018 at the latest. The discussions on the alternative options have not yet started so we do not know what private training outside of ATOs may look like and what restrictions and conditions, if any, may be applied. I have tried to find the letter on the CAA website without success.

[justmaybe]

Does this help
http://www.caa.co.uk/docs/33/CAP%201192.pdf

[BEagle]

Whopity, the relevant paragraph states:

We have engaged with EASA and other Member States to propose deferring until April 2018 the requirement for Part-FCL flight crew training to be conducted at Approved Training Organisations and the mandatory date for holding any LAPL, SPL or BPL, and many associated ratings. An associated and strongly supported proposal seeks alternative options for private pilot training to continue outside of ATOs beyond April 2018. These proposals will be voted on at the October 2014 EASA committee. Assuming the deferment is agreed, but there is no agreement on alternative options, RTFs would have to transition to ATOs by 8 April 2018 at the latest. Discussions on alternative options have not yet started.

Rather an odd statement:

'Part-FCL flight crew training'? - I presume they meant 'for non-professional licences'?
'An associated and strongly supported proposal' - Supported by precisely whom? Presumably the French? And the German gliding organisations?
'private pilot training to continue outside ATOs'? - The EASA paper referred to LAPL, PPL, BPL and SPL training, but gave no clue as to whether this includes 'associated ratings and certificates'.... Does 'outside ATOs' also imply 'outside RFs'?


This is an unholy mess. I have yet to meet anyone who supports the idea of PPL/LAPL training outside an RF / non-complex ATO.

[Whopity]

This is an unholy mess.Agreed
I have yet to meet anyone who supports the idea of PPL/LAPL training outside an RF / non-complex ATO. It worked perfectly well up to 1999 and I have not noticed any improvement since then!

In 1995 PPL(A) issues were 3451 compared to 1657 in 2013 a reduction of over 50%! So you could say we have already destroyed half the industry.

[BEagle]

Whopity wrote: It worked perfectly well up to 1999 and I have not noticed any improvement since then!

Not really. As you and your erstwhile Gatwickian employers well knew, there were a lot of shady goings-on in those days....

[Whopity]

there were a lot of shady goings-on in those days.... So little has changed!

[Mach Jump]

...I have yet to meet anyone who supports the idea of PPL/LAPL training outside an RF / non-complex ATO.

Then you should get out more, BEagle.

I think that any qualified Instructor, with access to a suitable aeroplane should be able to give instruction without any further formality, and I know many other sensible people who think the same.

The rest is all just unnecessary baggage that will slowly, but inevitably, increase in weight until it drags the industry to a standstill.


MJ:ok:

[Esperanza]

So now that the requirement to become an ATO has been delayed until April 2018 I have one question. Do we still have to get ATO approval to teach LAPL? I'm guessing that the answer is yes.
Delay to flight training school transition deadline announced | CAA Newsroom | About the CAA (http://www.caa.co.uk/application.aspx?catid=14&pagetype=65&appid=7&newstype=n&mode=detail&nid=2389)

[BillieBob]

The original letter from the GAU stated clearly that, in the event of a positive vote, RFs would be able to instruct for the LAPL during the extended derogation. This will, of course, please those ex-RFs that have paid in excess of £1,000 each for an utterly worthless approval.

[Danny boy]

The BGA are saying on their website that the requirement to have a EASA LAPL or PPL has also been deferred until April 2018...

Don't think thats correct, the CAA website says nothing regarding any changes to Part FCL deadline of April 2015, just the deferment regarding the RTF to ATO...:ok:

http://old.gliding.co.uk/bgainfo/news.htm

[Whopity]

IN 2013/206 (http://www.caa.co.uk/docs/33/IN_Deferment%20of%20requirements%20for%20Validation_20122013 .pdf) confirms that the requirement to have an EASA licence for all aircraft is deferred to 8 April 2015.

[ifitaintboeing]

IN 2013/206 confirms that the requirement to have an EASA licence for all aircraft is deferred to 8 April 2015.

That will now be deferred until 08th April 2018. UK national licence holders, including NPPLs, will be able to continue to fly EASA aircraft within LAPL privileges until 08th April 2018.

ifitaint...

[Duchess_Driver]

That will now be deferred until 08th April 2018. UK national licence holders, including NPPLs, will be able to continue to fly EASA aircraft within LAPL privileges until 08th April 2018.


Any idea if/when there will be 'official' publication of this? (if it hasn't been issued already!)

Ta
DD

[BEagle]

I believe that the date of effect is on the 20th day following publication in the Official Journal of the European Union. However, the recent vote has yet to result in anything being published in the OJ.

Also, there was a proposal in the draft amendment to extend the derogation for 3rd country licence holders' conversion until Apr 2016 - but I don't know whether that was actually tabled at the Committee meeting.

[timprice]

Its on CAA's own website under frequently asked questions

The European Aviation Safety Agency (EASA) requirement for all Registered Training Facilities (RTF) providing private pilot training, to become Approved Training Organisations (ATO), will be postponed, the UK Civil Aviation Authority (CAA) has confirmed. The Aircrew Regulation requires all pilot training leading to an EASA flight crew licence, to take place from an ATO. Implementation of the requirement for RTFs will now be deferred to April 2018, following a decision made on 9 October 2014 by the European regulator.

Under the original timeframe, RTFs had to become ATOs by April 2015, as part of a package of Europe-wide changes to the flight crew training industry. Following representations from many in the general aviation community, the CAA has worked with EASA to extend the transition deadline in order to permit work to be carried out to produce a more proportionate alternative set of European rules for private pilot training.

This decision, which acknowledges the difficulties some training schools have faced in meeting the original deadline, will enable schools to continue instructing students for the award of EASA private pilot licences until April 2018, while a more proportionate system is developed and put in place. The CAA will continue to work with EASA and members of the UK and European GA communities to develop alternative options, with the ultimate aim of providing a high quality pilot training structure.

Tony Rapson Head of the CAA’s General Aviation Unit said “This postponement is not only important in itself, but is also clear evidence of EASA starting to deliver on its commitment for ‘Simpler, Lighter, Better Rules for General Aviation.”

The CAA said it supports EASA in its development work and remains committed to making sure the transition process from RTF to ATO contains the minimum of regulatory burden.
:ok:

[Mach Jump]

So, for the next three years, if you want to start a new school, you still have to become an ATO under the present rules, knowing that they will all be relaxed, or even disappear altogether in the future? Isn't it about time that this ridiculous shambles was abandoned, and PPL/ LAPL training allowed to continue using the RTF system? (Which was itself becoming far too onerous and expensive!)


MJ:ok:

[Whopity]

The CAA said it supports EASA in its development work and remains committed to making sure the transition process from RTF to ATO contains the minimum of regulatory burden.What a shame that in practical terms it does not support the EU objectives listed in Regulation 216/2012(c) to promote cost-efficiency in the regulatory and certification
processes and to avoid duplication at national and
European level; and

(f) to provide a level playing field for all actors in the internal
aviation market.

[172510]

(f) to provide a level playing field for all actors in the internal
aviation market
RTFs may provide training for PPL night etc. at a significantly lower cost than ATOs.
And yet if I wanted to provide training for PPL, night etc, I would have to set up an ATO, as it's not allowed to set up an RTF anymore.
What kind of level playing field is it?

[xrayalpha]

Level playing field - ha!

We thought about being an RTF just before the deadline but - looking three years down the line - didn't think it would be much use in that period.

So we should work towards becoming an ATO......

But now we could have had three more years of RTF!

So we won't be adding Gp A training at Strathaven.

(and there is a Red Tape challenge to find out why GA is shrinking?)

[S-Works]

Speaking from the other side of the fence. We did it with little problem. Biggest issue for us was the SMS which I still think is pointless but nonetheless we are compliant.

At times I think it's a lot of fuss about nothing and wonder if the reluctance to change is as much a problem as red tape?