NPA 2015-20 : a chance to get rid of dead wood

[B61]

Proposing to have BTOs (Basic Training Organisation) replacing Resitered Facilities.

I see that Option 3 is no training structure at all.

Let's go for this !

Training can be done by any suitably qualified instructor.

It gets us away from all this dealing with "corporate bodies" bu**sh1t , many of which are owned or run by people who do not have any instructor qualification at all.

Clubs can provide the aircraft, or an individual / group of owners can, but the responsibility for training can now be with the people with the expertise. They have, after all, taken the FIC course and passed a test.

What counts is licensed people, not some paper entity and a couple of manuals that no-one ever reads.

The NPA points out that costs to students would be lowered and make the PPL more accessible.

[Spunk]

:eek::eek::eek::mad:

[Mach Jump]

That would get my vote for sure, but I doubt if the powers that control these things will allow any relaxation of control they already exercise. Once the bureaucratic ratchet has clicked over a tooth, it can't, it seems, go back.

I just hope that the bureaucracy for 'Approval' can be kept to no more than that required for 'Registration', which had already been overdone, and that all additional PPL Ratings can be treated in the same way.


MJ:ok:

[BEagle]

NPA 2015-20 proposes only very light oversight requirements, but the scope of training isn't as comprehensive as that proposed by NPA 2014-28, which would have covered all associated ratings and certificates which could be included in a PPL - such as MEP and IR. However, the UK CAA is planning to release an AltMoC for noncomplex ATOs to meet that need.

A complete free-for-all such as B61 proposes will never be acceptable to most Member States. The EASA tactic is to include various options so that they can identify the most appropriate and reject those identified as having a negative impact on safety. Hence Option 3 is only included so that they can explain why it has been rejected.

B61 wrote: Clubs can provide the aircraft, or an individual / group of owners can, but the responsibility for training can now be with the people with the expertise. They have, after all, taken the FIC course and passed a test.

Oh I can just see that happening! Some wet-behind-the-ears hours-builder approaching a Club to hire one of its aeroplanes to teach some unknown student to fly....:rolleyes:

Option 2 seems a reasonable 'light touch' compromise and is achievable by the end of the opt-out period. If the on-going discussions between Member States and the Commission lead to an amendment of the Basic Regulation, Option 1 would also be achievable, but currently there's no guarantee of this.

The only real quibble I have with NPA 2015-20 is that it hasn't considered inclusion of training for the 'Basic IR' (being developed by the RMT.0677 Task Force) within the scope of a BTO.

[AdLib]

But B61 didn't propose a complete free-for-all. The training would be conducted by a 'suitably qualified instructor' who, by this circular definition, would be suitably qualified.

I totally agree with you on the wet behind the ears thing, but that says more about the suitability of the FI qualification when issued. Perhaps a half-way house of only operating under the auspices of an ATO until the (R) is lifted and then Option 3? Other then that, I'm with B61.

[Mach Jump]

NPA 2015-20 proposes only very light oversight requirements, but the scope of training isn't as comprehensive as that proposed by NPA 2014-28, which would have covered all associated ratings and certificates which could be included in a PPL - such as MEP and IR. However, the UK CAA is planning to release an AltMoC for noncomplex ATOs to meet that need.

Lets hope that it's the Facility that's 'Approved', rather than individual courses. For instance, it seems absurd that a facility approved to conduct PPLs, would have to apply for additional approval to conduct LAPLs, and LAPL-PPL 'upgrade' courses, in the same way that those who have approval to conduct IR training at present, have to apply for further approval to conduct CBIR training. Also, let's get rid of the need to list individual aircraft and individual instructors in the 'Approval'. This is just a pain in the ass, and serves no purpose. (And seems to be widely ignored anyway.)

BEagle: Is the target date for this when the present state of limbo expires in 2018, or could we possibly see the new rules introduced earlier? And are new applicants for 'Approval' going to be treated the same as existing RFs?


MJ:ok:

[B61]

Beagle,

The average club provides an FI with very little beyond aircraft and a supply of students. Certainly nothing of value in instructional terms.

Once you are up there with a student, just what can be provided by way of "supervision" ? If the FI course ain't up to scratch, which seems to be your inference, then it should be sorted so it is fit for purpose.

How many clubs are more than virtual outfits reliant on contract and zero hour staff (who actually hold the required qualifications to teach the course ) ?

Time to cut out the middlemen and keep them in the place as no more than aircraft rental agencies. If you are an instructor, and can teach up to what you have, sticking in an intermediate layer of bureaucracy achieves nothing.

It's about time some of the ex-CFS characters who trot out this tripe about "standardisation" etc woke up, smelled the coffee and faced the reality of the civilian instructional world.

Fact is, there are few real jobs, the pay is naff, and clubs rely on the FI who is at least doing a job in aviation prior to get something that actually pays a return on his investment.

So give them a break and go for option 3.

[BEagle]

Option 3 - Some negative impact on safety, as it will be more difficult to perform adequate oversight and standardisation of training.

Which is why it won't be accepted.

[Mach Jump]

Although I'm sure that it won't be accepted, I agree entirely with B61. The 'oversight and standardisation of training' is in reality, just an illusion, and no more than pointless bureaucracy.

Chasing this illusion has, over the last couple of decades, almost driven the flying training industry out of existence. :(


MJ:ok:

[markkal]

Fortunately, one national federation is actively involved in the process, the french one, backed by more than 600 aeroclubs, doing most if not all the Ppl training, 99% of them Registered Facilities (RF).

If nothing is done and RF's will need to convert to ATO's most of them will disappear.

Then there are the instructors, 99% of them coming from a peculiar selection within the system which has worked well over decades.

Instructors are mostly active club members who after decades of experience get the opportunity to share their knowledge.

For that there is a pre entry selection done in Paris, multiple choice questions exam from a PPL databank requiring 80% right answers to pass.

Successful applicants are then directed to the state academy SFACT for a 6 week full immersion training course. Applicant takes 60% of the training cost and french federation 40%. Upon completion they become FI's, the only limitation is that the cannot get paid, no big deal, small aeroclubs rely on volunteer staff, instructors or secretaries and they do a great job. Most of them work elsewhere and join the aeroclubs outside their working hours or on weekends.

The alternative is to go to a private flight school for the course but then there will be no financial subsidy.

Only big aeroclubs have the luxury of hiring few full fledged CPL or ATPL instructors.

If these aeroclubs have to become full fledged ATO's according to the existing system, the whole industry will be upset.

Aercoclubs cannot bear the expense, instructors will have to get a theoretical CPL or ATPL to carry on doing what they have done for years, often decades. And the requirements in terms of staff, paperwork, facilities for RF's to convert will be unbearable.

The result will be that surviving entities will have to rely on fresh 200 hr ATPL students willing to get an FI rating, getting a temporary underpaid job waiting for an airline to hire them.

Then, the existing system has allowed the french to excel in activities such as aerobatics and mountain flying, where experience is what counts, CPL or ATPL are of no use.

Let's hope that RF's will be allowed to become BTO's quickly as quickly as possible, or General Aviation will be wiped out, let's thank the french who are the driving force for this implementatiuon.

[Mickey Kaye]

Option 3 - Some negative impact on safety, as it will be more difficult to perform adequate oversight and standardisation of training.

Which is why it won't be accepted.

And where does the evidence for that come from Beagle?

[markkal]

The whole of EASA philosophy is geared towards "Safety" and "Standardisation".

The infinite bureaucratic legislation produced is in support of this philosophy, created to fit in our society based on litigation.

Protection against potential litigation issues is the primary objective of lawyers bureaucrats within EASA.

Operation outside corporate bodies, without structure and oversight is very unlikely.

[BEagle]

My quote came from the NPA - I was not an RMT.0657 Task Force member, so am not privy to the TF's discussions.

Have you read the NPA? If not, see http://www.easa.europa.eu/system/files/dfu/NPA%202015-20.pdf .

The CAA plan to release a notice in the near future, which will summarise the main points of the new proposal and the requirement for new BTOs to gain approval.

[Whopity]

The whole of EASA philosophy is geared towards "Safety" and "Standardisation".In the time that EASA has been in place Standardisation has largely gone out of the window and there has been no measurable improvement in Safety. The buracracy has served no purpose other than to make it easier for our "blame culture" to find someone to hold responsible for whatever goes wrong, thereby covering the backsides of those further up the line.

[TheOddOne]

What saddens me most is the negative impact that all this uncertainty has had on our morale and the wicked waste of thousands of hours of instructors' time attending seminars. We were given a CD with 'how to do an ATO application' which is now useless (I'm pleased to say). The one I attended at Exeter must have had well over 100 people there.

Thankfully most of us put off actually wasting more time writing manuals which it turns out we'll likely never need.

Standardisation. This time around, we invited our FI examiner to visit with us - he spent a whole day with 2 of us and I must say it was FAR more valuable than the 2-day seminar I went to 3 years ago. We each did a 90-minute flight test, long and short briefings and an extensive de-brief - a long day for us and the examiner (2 hour drive each way) but much appreciated.

Perhaps we could go back to having AOPA running PPL training???

TOO

[Whopity]

This time around, we invited our FI examiner to visit with us A few years ago following the disolution of the Examiner's Panel, the CAA ran Standardisation Seminars for such people, but the powers that be, deceided it was too expensive, so they were abandoned. Now, there is no standardisation of examiners, so they could all be doing different things! The regulation is so badly produced and worded it can be interpreted in a multitude of different ways and there is no medium for examiners to get together and discuss issues as they used to do.

I am told the CAA no longer has anyone to run the next Senior Examiner Seminar, which they had insisted in keeping in-house, as the last remaining attempt at standardisation!

[Arewerunning]

Freelance instructors that do this for a living are way better that any ATOs.

Let the market judge.

[huv]

Everything in the NPA is pointing to option 2: establishing the BTO concept. So I guess that is what we should expect?

"The only real quibble I have with NPA 2015-20 is that it hasn't considered inclusion of training for the 'Basic IR' (being developed by the RMT.0677 Task Force) within the scope of a BTO."

Exactly my thought, BEagle. Consultation time is now and until Feb 29th. I hope you are going to write EASA about that - I am definitely going to. Basic IR is part of the "easier access to instrument rating for GA pilots" Task Force in EASA, and what could be more "proportionate" than to allow the Basic Training Organisations to train for that too.

Common Response Tool for the consultation is here:
EASA CRT application (http://hub.easa.europa.eu/crt/)

[BEagle]

I've already spoken with the TF members who drafted NPA 2105-20 about including BIR training within the scope of a BTO.

The draft NPA for the BIR is being written on the assumption that BIR training will be permitted at a BTO.

[hooligan88b]

:ok: B61 Best post I've seen for a long time.
Yes rookie instructors can be a menace and should be monitored (which rarely happens in practise under the current system) but this standardisation rubbish comes straight from the CFS bible.. that and whizz wheels...don't get me started

[172510]

B61 is entirely right.
Nevertheless it seems to me that the BTO achieves almost the same thing.
Edit: According to the document called NPA 20,
The approval is automatic, it is in fact a registration process, not an approval process. The difference with RF is that the approval automatically granted may be withdrawn at a later date.

To set up a BTO you don't even have to have a fleet (according to NPA20). Any Instructor can setup a BTO, with two documents
- A training program which must be approved, but you may use one which has already been approved.
- A safety policy which should be easy to develop for a single instructor BTO.
It's probable that every instructor will soon use the same two documents.
A single instructor may be the legal representative of himself (he or she is anyway), there is no requirement to setup a company (although that may be advisable for legal protection).

The paperwork is minimal: keep some record of your training (I suppose you would do it anyway) and spend some time each year to self audit your operation (e.g. check that your ratings are current, that you paid your insurance bills etc.)

Unless I have missed something, this BTO thing will be my Chrismas gift.

A last question: what is Basic IR?

[BEagle]

The Basic IR Concept Paper is here: http://easa.europa.eu/system/files/dfu/ToR%20%28%2B%20Concept%20Paper%29%20RMT.0677%20Issue%202.pdf

The UK CAA issued an Information Notice concerning NPA 2015-20 yesterday: http://publicapps.caa.co.uk/docs/33/InformationNotice2015120.pdf

[B61]

I have had a look at the CAA Information notice.

They are trying to goldplate the BTO requeuirement with b/s like "head of training" and "safety representative" even when it only states "if applicable" in the NPA.

Looks like it is the usual CAA reaction to go for the more extreme end with maximum regulation of an EASA requirement which is actually quite flexible in intention.

172510 has the right idea in that any instructor should be able to set himself up as a BTO.

The important bit to me is that some corporate body should NOT be able to set themselves up as a BTO if they do not have anybody in place who can actually provide the training.

Having some unqualified Rsole set up as "accountable manager" of some corporate shell with approvals, and then use those with the qualification to do the job on some zero hours contract, is unacceptable.

When is someone at the CAA going to grasp that the PPL is a RECREAtIONAL licence, not the first rung of a ladder to a CPL, and does not require organisations to be set up to provide the civiliN equivalent of CFS, or playing at being a public transport operator ?

[Whopity]

Perhaps we should analyse what has been acheived in the 15 years that Registered Facilities have been in existance. There has been no measurable improvement in safety and no improvement in quality of the end product however; over the same period costs have soared and numbers reduced by around 50%. On top of that, the Authority totally lost control of the "Registration Process" and were forced to go out to Industry to find out who was and wasn't registered. Clearly registration was of little consequence.

Most instructors teach as they were taught to do on their FI Course, playing with the syllabus has little or no bearing on what or how they teach.

It was never the JAA's intention to include the PPL in their plan, consequently there was no plan to produce exam questions. The EASA PPL is a myth, it is nothing more than a comon label on a National licence which varies considerably from State to State and follows historical precident rather than any centralised European standard or concept.

FIs are probably better trained now than they ever were, so why are they not trusted to do their job without being subject to commercial pressures that exist in any RF or BTO? Such pressures can actually undermine their professionalism.

Policy statement for a one man BTO; Not to have an accident! If we had a check list for going to the toilet, we would all need twice as many pairs of trousers!

EASA has reduced the experience requirements for FIC instructors and Examiners by 80%, this cannot be compensated for by encasing training in a cocoon of bureauracy and manuals.

Option 2 has been tried and failed!

[BEagle]

BTO.GEN.200 and its associated AMC identify BTO personnel. The rule requires the appointment of a representative acting as focal point for the CA.

The BTO, through its legal representative, is responsible for the allocation of sufficient resources in order to ensure activities and essential functions.

In addition, the AMC identifies a head of training responsible for ensuring compliance with the Part-FCL training requirements.

The AMC also specifies that the legal representative is responsible for the safety awareness function and may be assisted by a designated safety adviser.

Finally, it should be noted that GM1 BTO.GEN.200 allows combinations of the above functions in order to offer the maximum flexibility to adapt the BTO concept to small entities (including one-man entities).

The expression 'legal representative' came at French insistence and was not supported by other Task Force members.

Option 2 is the only feasible way by which an RF can be freed from the more formal ATO requirements within the available timescale. Options 1 and 3 would require a Basic Regulation amendment - which would probably take 5 years under European legal processes....

[Mach Jump]

Seems to me we could save ourselves a lot of grief by just issuing BTO Approvals with every Full Instructor rating, automatically nominating that Instructor as 'Head of Training', 'Legal Representative', and 'Accountable Manager'.

If Individual Instructors then want to work together, as a group, and form a multi-instructor School, the onus would be on them to combine their BTOs, produce standard procedures, and nominate the roles amongst themselves, or they could choose to work as individual BTO's, from the same building!

New Instructors would then have to nominate a Full Instructor(BTO) under who's supervision he would operate, until upgraded.

Keeping things simple, and, at the same time, complying with Option 2 isn't rocket science. It just requires that the people who will implement the new rules, have the will to do so..


MJ:ok:

[172510]

I have edited my initial post above

[markkal]

Can we expect this to happen, latest 2018 or will it be postponed? Opts outs here, opts out there, this is a joke.......

Easa and its bureaucrats have failed royally, thanks to the British and the French who have fought this battle....OK for option 2, without delays, the industry is in a bad shape, the bureaucracy is wiping out everybody around...

Dernière option pour l?EASA? ? aeroVFR (http://www.aerovfr.com/2016/01/derniere-option-pour-leasa/)

http://www.easa.europa.eu/system/files/dfu/NPA%202015-20.pdf

[TheOddOne]

Thanks for the link to aeroVFR. Tres informatif!

Interesting to see what the French for GA Road Map and Basic Training Organisation are. Great selection of webcams.

TOO