Air Experience conducted by PPL holders

[shorehamite]

Can anyone please confirm, if a student can log the flight time carried out by a PPL holder?

[BEagle]

Not unless he/she wishes to record passenger time. It may not be logged for any flight crew licensing purpose unless the PIC was an FI (not a CRI).

[shorehamite]

Thanks, I was wondering why a local club was selling " Flying Lesson Vouchers" but using a PPL holder to conduct the flight.

[this is my username]

They are probably using this provision for "introductory flights":

https://www.caa.co.uk/General-aviation/Aircraft-ownership-and-maintenance/Introductory-flights/

[shorehamite]

Thanks, so they shouldnt be doing land aways according to the publication.

[Whopity]

From the CAA Guidance document on Introductory Flights:
The aim of the introductory flights is to attract new trainees or new members. They are not designed, and should not be sold, to replace EASA Part FCL Exercise 3: Air Experience flight, in which a qualified instructor would typically give a demonstration of the controls and some flight training exercises with the participant handling the aircraft. Flight time as a passenger on an introductory flight will not count as training towards the grant of a pilot’s licence.

A marginal activity should be understood as representing a very minor part of the overall activity of the organisation. An organisation intending to offer such flights as regular business activity is not considered to meet the condition of a marginal activity.

Flights organised with the sole intent to generate income for the organisation are not considered to be a marginal activity.

" Flying Lesson Vouchers" would not count as an Introductory Flight.

I wonder if their insurers are aware of what is going on.

[Edgington]

Companies are using introduction flights to do perform scenic flights and as said "trial lessons". They use PPL holders as they do it for free and the company keeps the pilots/instructors fee, more profit for them.

The CAA don't care about these flights, it's going to take an accident before something happens.

[Whopity]

I wonder which seat these PPL holders sit in!

[shorehamite]

the right, i dont think the customers are told the true facts

[Fl1ingfrog]

The CAA don't care about these flights, it's going to take an accident before something happens.

I do not know of any ATO/DTO sanctioning these flights, why would they? If anyone knows of any instance of such an organisation utilising unqualified PPLs to conduct air experience flights (outlined in the PPL syllabus) instead of a flight instructor then name them. Flying clubs charging the public for a training flight but using a PPL masquerading as an instructor: "so they can pocket the instructor fee" is a criminal offence and will result in a certain prison sentence. If you truly know of any such flights then report them.

As far as I can see these flights are advertised by the individual PPL and conducted independently of and without any reference to a flying school. The quote from the CAA that whopity has shared is a joke. The CAA team who wrote that must have been in the pub all afternoon to come up with such nonsense.

3.5 Article 6.(4a)(c) of EASA Air Ops applies to other-than complex motor powered aircraft conducting introductory flights as follows: ‘introductory flights, parachute dropping, sailplane towing or aerobatic flights performed either by a training organisation having its principal place of business in a Member State and approved in accordance with Regulation (EU) No 1178/2011, or by an organisation created with the aim of promoting aerial sport or leisure aviation, on the condition that the aircraft is operated by the organisation on the basis of ownership or dry lease, that the flight does not generate profits distributed outside of the organisation, and that whenever non-members of the organisation are involved, such flights represent only a marginal activity of the organisation.

Thanks, I was wondering why a local club was selling " Flying Lesson Vouchers" but using a PPL holder to conduct the flight.

If it is a flying lesson then the flight must be undertaken by a qualified Flight Instructor. They will be defrauding the customer if they have sold them a lesson but an unqualified PPL only holder is doing the flight.

[BDAttitude]

So what's a lesson and what is an introductory flight to a pedestrian?
Is showing them where the altimeter and the airspeed indicator is and what you do with rudder and what with aileron a lesson? It's not flight training for sure. Flight training starts only after the student has been notified to the aviation authority (at least in my country) . So it is clear that it may not be logged and a FI is not needed. Is a CPL needed? That's the question. If a club does it in order to aquire new members, it is covered by the exemption above. PPL sufficient. If a club does it to promote aviation and improve relationship with the locals ... already borderline, although most stay it's still Okay. Advertising them online as scenic flights or via event agencies (which is IMHO the root cause why we have this regulaoty mess - thank you Jochen Schweizer & Co) - NO GO!
Personally I can't be bothered doing this flights any more. Too risky for me as my club sells them as vouchers without people having pretend to be interested in a membership. Also made some not too good experience with middle aged men with cameras with telephoto lenses. So I leave it to the youngsters so save some charter fees and clean the vomit.

[Whopity]

Flight training starts only after the student has been notified to the aviation authority (at least in my country) Not a requirement of the EU Regulation.

As far as I can see these flights are advertised by the individual PPL and conducted independently of and without any reference to a flying school. There are plenty of these but they go under the heading of Cost Sharing, not to be confused with Intoductory flights carried out under the auspicies of an organisation. One pilot recently convicted is doing three and a half years behind bars!

[BDAttitude]

One pilot recently convicted is doing three and a half years behind bars!
Do you have some quality news outlet or official report link to that case?

[TheOddOne]

Could be this one...

https://www.manchestereveningnews.co.uk/news/greater-manchester-news/robert-murgatroyd-manchester-crown-court-17035215

TOO

[Fl1ingfrog]

The chap involved in the prosecution reported in the Manchester Evening News has spent his professional life embroiled in controversy. He is a very experienced Flight Instructor and a one time CAA PPL Examiner. He owned and operated his own flying school and also at one point a small airline. He's alway been indefensible and perhaps now enjoying his just deserts. The flight could just as well have been a "cost sharing flight" if managed differently.

For me its shameful how the CAA are impotent on all this or perhaps spineless. I've been looking at the 'wingley' website where there are mostly very low houred basic PPLs advertising themselves. They are able to advertise for total strangers to pay for flying with them. It matters little that the passengers pay less or at least no more than the pilot (?) Other than holding a PPL: there are no standards checks, no routine skill assessments, no area or route checks. They don not need to undertake a risk assessment nor have a go/no go equipment sheet, no ops standards sheet which include such things as weather and cloud base minimas and stipulating actions such as diversions.. Many of the flights land away and are away from the departure point all day.

The fact that the passengers are not paying the whole cost and that the pilot is flying at a loss should not be relevant. The passengers are strangers and may be the recipient of a voucher that has been bought for them by a third party. There is no relationship to the pilot. The expectation therefore that the flight takes place can be enormous. The pressure on the pilot to fly is obvious.The situation is not one of friends flying together and sharing the cost in goodwill.

[parkfell]

As has been mentioned, until an unfortunate accident occurs and the AAIB are involved, such ‘pleasure flying’ which really needs an AOC will continue to operate.

The unsuspecting punters are oblivious to the potential dangers.
Similar to what you come to expect operating in a banana republic.

[TheOddOne]

...or in the United States where a 'loophole' allows flights to take place with fare-paying passengers on sight-seeing trips operating to similar standards to private flights (Part 91). There have been a number of fatal accidents recently, one involving a wartime Boeing B17 and at least one with a DH Beaver on floats. For some reason, the Feds seen very slow to tidy this up.
With Wingly, there is some advice to the participants about the nature of the flight, although I do accept that there is little operational oversight,

When we do Trial Lessons, it is within a Club environment, with an Operations Manual giving clear restrictions on weather minima and with an instructor trained to fly with strangers, in an aircraft maintained to a standard. As a Club, we don't operate with a PPL doing 'air experience flights' though I do know of a Club that does. In their case, they have established a separate Ops Manual to cover the operation. In the beginning, they were charging the 'Trial Lesson' price, but they now quote 2 rates, depending upon whether or not you are flying with an instructor.
When we had our CAA inspection as a DTO, the inspector went through our Ops manual with a fine toothed comb and found it all very satisfactory. I think he felt some places were sailing close to the wind, but within the rules so the CAA are unable to take action.

As ever, it will be the insurance companies who will test the Law. Fortunately, there haven't been any cases as far as I am aware for a test to be applied.

TOO

[Whopity]

For me its shameful how the CAA are impotent on all this or perhaps spineless. The CAA was filleted by the former Chief Executive and his cohort Dame Edna leaving it with no backbone but they saved a lot of money. The Head of Enforcement resigned and was never replaced! At least the DGAC in France apply some sensible rules to these new activities.

[Edgington]

I do not know of any ATO/DTO sanctioning these flights, why would they? If you truly know of any such flights then report them.


I know of at least two ATO's who do, they need their planes to be flown to make money. When a lot of instructors went to the airlines, they didn't have the instructors to fly these lessons. So converted them to introductory flights, using PPL's to perform them some experienced some who only just qualified.

A few years ago I was working for a company that held an AOC to perform scenic flights on C172's. Because others where advertising and selling cheaper introductory flights business suffered. We reported it to the CAA all they said it illegal to sell through their website, but they did nothing so it continues. It seems the CAA prefer to deal with problems retrospectively and not take a pro-active stance on enforcement.

[Fl1ingfrog]

Whopity your so right in much of what you say. Sadly though the French DGAC have proved impotent as well but at least they have issued a view and encourage flying clubs not to facilitate, although they did so 5 years ago and since then nothing. Wingly and Airbnb are advertising, with impunity, these private flights in France. The faux pas from EASA is europe wide.

What we don't have is a definition of "direct flying cost. In my estimation a 160 hp aircraft owner will need to budget* £6-8000 per annum (Maintenance, Insurance and hangarage) before the average 4 seater aircraft ever leaves the ground. Shared over 100 hours this comes to £80 an hour. Such an aircraft will burn in the region of £45-50 an hour in fuel with engine depreciation of £6 per hour and a 50 hour inspection probably being £350 so another £6-7 per hour as a direct result of flying. This gives us £80 (annual charges) + £58 (direct) totalling £138 per hour which bears no relation to what is being charged as advertised on wingly. If you remove the annual costs as not being direct and therefore not recoverable the figure dives to £58 per hour. The charges advertised are normally per person and not on a simple division of the operating cost but as a discount depending on the number of passengers carried.

Now just to complicate things the law allows you to build into your direct operating costs the hourly charge an aircraft hirer/leaser will demand (doesn't have to be a flying club) which will be anywhere between an inclusive £150-200 per hour wet from a flying club. Nothing in the regulations bars the aeroplane supplier from making a profit. The aeroplane supplier and the private pilot could be the same person if things are structured so. I'm not sure how UK flying clubs are dealing with this, whether or not they are banning their members from using their aircraft for these flights or facilitating.

The profit bells ring loudly. EASA have made fools of europe's NAAs none of whom saw this coming. The FAA in the U.S. have simply banned these flights. In the UK we have some very sensible basic rules for charity flights, are these rules also redundant? I can't see how they can remain effective.

* obviously costs will vary and could be less or more.

[MrAverage]

I banned them as soon as I knew they were a threat. Had to amend the FOB. I believe Sky Uber was the first. Luckily, we're backed up by our airfield manager. He banned them too.

Oh, and I wish I could get a 50 hour for £350!