DTO

[timprice]

Any one know any more, been looking for further information, about when they might start?:sad:

[Whopity]

They can start the minute it becomes EC Law however; that will not be until 6 months after the document is posted in the European Parliament. I am not sure if that has happened yet, but you can take the cue from whenever that happens.

A useful EASA presentation here (https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&ved=0ahUKEwiT87L6zKXaAhXD1RQKHXeZA80QFgg0MAA&url=https%3A%2F%2Fwww.easa.europa.eu%2Fsites%2Fdefault%2Ffil es%2Fdfu%2FCKUC_PPT_2017_AERO_Introduction%2Bto%2BDTO_genera l_v2.pdf&usg=AOvVaw0P40qQYLSn8SDIU5-SX-TZ)

The CAA has published CAP 1637 which looks much more complicated.

[timprice]

Thanks Whopity, I have already seen that.(EASA presentation)
Ah well will just have to wait.:rolleyes:

[BillieBob]

The intention was for the Regulation to be published in time for it to become effective on 8 April with a 12-month implementation period to allow all RFs to become DTOs by 8 April 2019. Predictably, however, this has not happened - the EC have screwed around with the Opinion from EASA and the UK CAA has gold-plated the result out of all recognition.

The consequence is that, instead of the light-touch regime we were promised, we will eventually get something that is not dissimilar in its requirements to the ATO but with a nominal 5 year oversight schedule to allow the CAA to manage with its current, inadequate bunch of inspectors.

[AllanA]

The intention was for the Regulation to be published in time for it to become effective on 8 April with a 12-month implementation period to allow all RFs to become DTOs by 8 April 2019. Predictably, however, this has not happened - the EC have screwed around with the Opinion from EASA and the UK CAA has gold-plated the result out of all recognition.

The consequence is that, instead of the light-touch regime we were promised, we will eventually get something that is not dissimilar in its requirements to the ATO but with a nominal 5 year oversight schedule to allow the CAA to manage with its current, inadequate bunch of inspectors.

Completely agree, the nonsense coming out of the UK CAA is simply astonishing!

[timprice]

If it makes it even slightly simpler at least that's something, plus hoping not as costly! Time wise.:sad:

[Mickey Kaye]

How can it possibly be cheaper than RTF's which for many years there was no charge and currently is 102 quid per year.

Having looked through CAP 1637 I have to agree with Whopity it appears an awful lot more complicated and I very much hope alot of the gold plating doesn't come to fruition.

[Whopity]

For those who haven't noticed:Part-DTO is now published and in force!



Related Content (https://www.easa.europa.eu/newsroom-and-events/news/part-dto-now-published-and-force#group-easa-related-content)

Commission Regulation 2018/1119 for Declared Training Organisations (DTO) (https://www.easa.europa.eu/document-library/regulations/commission-regulation-eu-20181119) has been published on 13 August and has entered into force on 2 September 2018.The new Part-DTO (Declared Training Organisations) grants significant alleviations for the GA training domain. Training providers for the Light Aircraft Pilot Licence (LAPL), the Private Pilot Licence (PPL), the Balloon Pilot Licence (BPL) and the Sailplane Pilot Licence (SPL) no longer need to seek prior approval of their training organisation. They just need to send a declaration to the competent authority instead.

[timprice]

Wow wonder if that allows type rating training on helicopters?

[Whopity]

Yes, as follows:
a single-engine type rating for helicopters referred to in point DTO.GEN.110(a)(2)(c) of Annex VIII (Part-DTO) may complete the training course at a DTO.

[justmaybe]

Cannot locate SRG 2143?

[Whopity]

The SRG2144 is available but not the 2143.
Could the CAA have been caught on the hop again, after all its only been law for a week!

[timprice]

Thanks Whopity, very interesting up to 5 seats for type rating training on DTO.

[Fl1ingfrog]

Sorry, I've missed something. Where is the limitation of "5 seats" for type rating training in the document?

[Whopity]

DTO.GEN.110Scope of the training
(a) A DTO shall be entitled to provide the following training, provided that the DTO has submitted a declaration in accordance with point DTO.GEN.115:
(2) for helicopters:
(c) single-engine type rating for helicopters for which the maximum certified seat configuration does not exceed five seats;

[Fl1ingfrog]

Whopity thanks, I skimmed over the helicopter bits. Sorry, I promise to do better next time.

[timprice]

5 seats makes it interesting for Bell 206 5 seats, but Longranger 7 seats? but would that be allowed under difference's as in same group?

[Whopity]

but would that be allowed under difference's as in same group? Anything that complires with the Regulation is allowed. The DTO would be limited to type ratings on the 5 seater. Differences training does not require a DTO or ATO so does not enter into the equation its a seperate issue.

[BillieBob]

No training is permitted on the Longranger within a DTO. Differences training is only a separate issue until the next change to Part-FCL when, with the exception of SEP and MEP aeroplanes, all differences training will have to be done in an ATO or DTO (and approved, leading to the inevitable fee).

[timprice]

The plot thickens? thanks to Whopity and Billie Bob for your assistance.
Tim:)

[justmaybe]

So the CAA tell me that the application form is SRG 2145, and not 2143 as published!!!!

[Whopity]

and not 2143 as published!!!! They have actually replaced the page (https://www.caa.co.uk/General-aviation/About-the-GA-unit/Declared-Training-Organisations/)since the weekend and amended it to say SRG2145. They have also made the page look as though it was there from before 2nd Sept!
Declared Training Organisations (DTOs) offering training towards basic licences and rating for private pilots will be available with effect from Sunday 2 September 2018. No declarations can be made before this date.

[chrisbl]

They struggle too to use the correct spelling for principle and principal.. All principals were principles in V3, they did a global change when the error was pointed out and now all principles are principals in V4. Lets see what V5 shows.

SRG 2145 is wrong as well where it refers to Principle Place of Business

Priceless.

[Whopity]

Firstly they drove out all those with knowledge; then they removed the more expensive clerical staff with experience; now they are left with nothing but tick box checkers.

[timprice]

Lets tick the boxes and keep going forward;)

[Mickey Kaye]

Flicking though SRG2145 and CAP1637 but it seems to be way more involved than what was required to be a RTF. And I thought everything was for a lighter more proportional touch.

There appears to be a huge amount of additional work and I mean masses. All of which I am sure will require auditing and for the life of me I can't see the bill only coming to 55 quid a year.

[Whopity]

but it seems to be way more involved than what was required to be a RTF.
Indeed, but just follow the EASA Brief (https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&ved=2ahUKEwjfkcK5qvHdAhWMCMAKHRxVB6EQFjAAegQICRAC&url=https%3A%2F%2Fwww.qcm.ch%2Fuploads%2Fmedia%2F1-dto-short-4-ga-roadshow-switzerland-2017-10.pdf&usg=AOvVaw3qEyL2ANvvZQOjYBbsaX3f)

[timprice]

Starts at £55 until they work out it will then require ravelling etc on top, unless it goes out to industry? you never know?:O

[Danny boy]

Has anyone applied for DTO yet?
Also do you think it may be delayed until Sept 2019 instead of April 2019 ?...

[Whopity]

Has anyone applied for DTO yet? There is no Application involved, you make a Declaration
Also do you think it may be delayed until Sept 2019 instead of April 2019 ?... No, it was implemented into EU Law on 2 Sept 2018 and from that date anyone can make a declaration.

[timprice]

I think Danny Boy, means has anyone made a declaration yet?:ok:

[Whopity]

has anyone made a declaration yet I believe so.

[BEagle]

13 so far - see https://www.caa.co.uk/General-aviation/About-the-GA-unit/Declared-Training-Organisations/

[BigEndBob]

Always someone keen to jump on the bus and take the back seat.
Me i will wait for the next bus, it won't be long.

New schools DTO or do they have to be ATO?

[MrAverage]

I'm waiting a little longer too B.E.B. Need to know if we'll still be able to add the IRR to EASA licences beyond April and/or the BIR. I've written to the APPG in the vain hope some common sense might result from their intervention................

I don't want to be an ATO but if they take away another income stream I may have to.

[BillieBob]

New schools DTO or do they have to be ATO?If you want to do anything more than LAPL/PPL, SEP, TMG, Night & Aerobatics Ratings then you need to be an ATO.

[Mickey Kaye]

I'm looking though AMC1 DTO.GEN.115(a)(5) Declaration and also trying to fill out SRG2145 of which section 8 "training aircraft" states you need to supply the aircraft type and registration. However DTO.GEN.115(a)(5) states

"The list on the declaration of aircraft used by the DTO should contain at least the models used for training (e.g. Cessna 152, Piper PA 28, Robinson R22 ,etc.). It is not necessary to list on the declaration each individual aircraft with its registration mark"

So does that mean in Section 8 of SRG2145 I simply put Not Applicable with respect to aircraft registration?

[Whopity]

The simple answer is to fill in the items required by the regulation and say nothing more. If the CAA raise an observation, then ask them for the reference.

[TheOddOne]

I guess quite a few people like us will be using this festive season to polish our Declarations, so there'll be a pile of them in January for the CAA to go through. I understand they've 60 days to accept a Declaration, which doesn't leave much time if they take the 60 days and then reject it - potentially we could be temporarily out of busines in April if there are snags.

Incidentally, we're still plugging away with IR(R) courses - got 2 on the go at the moment - as they aren't part of being a DTO. As far as I can tell, they'll still be a valid course after April.

TOO

[Kemble Pitts]

Whopity's approach is spot on. If CAA say 'what about this or that bit of gold plating that you've not provided?' ask them to clarify exactly where it is required in the Regulation. If its not in the Regulation then politly tell them where to get off.

[memories of px]

So after filling in the necessary DTO paperwork, will the CAA also issue me with a set of exam papers?, used to have a set with my BX rating, not so with an FE rating, they belong to the ATO ,perhaps i need a GR rating? more £££

[Whopity]

I understand they've 60 days to accept a Declaration, which doesn't leave much time if they take the 60 days and then reject it - potentially we could be temporarily out of busines in April if there are snags.
You can commence operation the minute you make your declaration. They have 10 working days to acknowledge receipt. They can make observations but there is no process for rejecting it so there is no 60 days.
perhaps i need a GR rating? more £££ If you hold a FE Certificate they do not charge extra for a GR Certificate.

[Mickey Kaye]

More questions.

Section 11.AERODROME PARTICULARS

"b) If aerodrome is unlicensed, confirmation that safety assessment required in Article 209, ANO 2016 has been conducted"

Now having read Article 209 of the ANO I have to say I can’t see where it says that a safety assessment has to be conducted. What it actually says is “satisfied on reasonable grounds that the aerodrome has adequate facilities for the safe conduct of such flights.”

Would anyone be kind enough to point me in the right direction of what I need to do to meet this requirement?

[Whopity]

State that the aerodrome is operated in accordance with the requirements and recomendations of CAP793.

[Duchess_Driver]

satisfied on reasonable grounds that the aerodrome has adequate facilities for the safe conduct of such flights.

that’s your safety assessment. Typically it’s easier if the arrodrome has once been licenced but I work through the same headings as for AIP - AD entries looking at runway size , obstacles in the approach, general state of the manoeuvring area and obstacles off the taxiways etc, signage, lighting, noise abatement and escape options in the climb out.

Bottom line is would you let your ‘most precious’ be trained there?

[deefer dog]

Could someone help me with getting an approved training programme reference for the LAPL to PPL.

Thanks.

[Whopity]

AFE; Pooleys; FFA

[deefer dog]

Thanks....somewhat belated!

[Mickey Kaye]

FFA?

Flying farmers association?

[memories of px]

thanks for the information whoppity, i applied for the GR certificate, and they say they want £249, have things changed?

[Whopity]

Certainly it was the case that if you applied for the FE(PPL) and GR concurrently, only one charge was levied. Perhaps its worth contacting GA Dept who sponsor Stds Doc 11 and ask them.

[memories of px]

Did i read somewhere that the CAA are meant to acknowledge receipt of your Declaration within 10 days?

[SkyCamMK]

Yes and after 20 days contact them if nothng heard

[timprice]

Never heard anything, they just put us on the approved list of training schools:ok:

[Whopity]

Regard that as contact. The regulation does not specify the method of contact.

[TheOddOne]

I see there are only 127 declarations on the list, so far. I'd heard the CAA were expecting around 250. With only a couple of weeks to go, is there a thinning out of some redundant RTFs?

We paid £55. For 127 declarations, that's an income of £6,985. I can't believe that the CAA can come and physically inspect us all in a 3-year cycle for that, or even actually just process our initial declarations. So the questions are:
Will there be some hefty fees down the road?
If not, who is subsidising us DTOs?

TOO

[memories of px]

I see the CAA has issued SWA2019/087 regarding Acceptance of Training at an RTF after the 8th april, ( training ceases to be valid) surely, the clubs concerned would merely have to submit the declaration and carry on as if nothing happened, or do they have to wait for their approval number before than can start trading as a DTO.

[TheOddOne]

We got our approval number by return of e-mail. I see there are currently 177 listed, against the CAA's expectation of about 250, so some must have fallen by the wayside. The whole thing was extensively advertised, so any RTF in current operation who hasn't registered has only themselves to blame.
The problem might come for students who are unaware of the requirement. We were careful to tell our students what was going on to assure them that their training remained valid and they weren't wasting money.
I'd be interested to hear if anyone has been inspected yet. The CAA are supposed to give 3 months notice and work to a 3-year cycle. That's just over 1 per week, not overly burdensome. I can't imagine it taking more than 1 day for a small outfit like ours.

TOO

[timprice]

You are also missing some others that went from ATO to DTO so I think more than that didn't bother.:)

[Hughes500]

Well Tim I included PPLH training in my ATO, given to The CAA after ATO inspection 7 weeks before the deadline, was told we will get round to looking at it !!! Just carrying on as normal.
So really not sure what is going on at The Belgrano

[timprice]

You are talking CAA here 7 weeks is not a lot of time, I think they are quite busy and short of staff, plus what else is going on, nothing will happen quickly:ugh: