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FI Rating without CPL knowledge latest?

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Old 6th Nov 2007, 10:16
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FI Rating without CPL knowledge latest?

Wanted to know what the lastest news on any on the EASA/CAA/GAAC discussions, regarding the FI shortage?
A couple of months ago I heard there was going to be a high priority meeting with the CAA/GAAC on perhaps dropping the CPL/ATPL written exams requirement to obtaining a FI rating.
Would like to know as I'm looking to become a FI and would not fancy wasting time & money in the next year.
Was there anything in Novembers FTN paper? I only manage to get it from my club a couple months late (when it surfaces)
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Old 7th Nov 2007, 07:43
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EASA

Ive heard its 2009...
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Old 7th Nov 2007, 09:15
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FI Without CPL

The sooner the better. With the old self improver route to the airlines all but gone, the CAA/JAA must go back to the days of the FI rating being attached to a PPL. Even most pilots working for the airlines who had FI rating do not renew them (iam told that even 1 hours instructing invaladates a rest day). Most CPLs who had instructor ratings (not all) used it to help build hours toward an airline job, very few took there CPL/FI with the view of becoming a carreer instructor.
There are many good PPLs out there who would like to instruct, but are put off by the huge costs invovled. I myself have a PPL, IMC and a Class Rating Instructor (SE) Rating and just over 700 hours and would like to do and full FI rating, but now getting on the wrong side of 40 and not much hope of ever getting a commercial flying job (I know many CPL/IRs in their 20s finding it hard) I cannot afford or justify spending the best part of £26,000 on a CPL/FI.
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Old 7th Nov 2007, 15:41
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Wicker, you must be joking. £26,000 for an FI rating and CPL?
That sounds way off the mark. I did my FI for about 10,000 EUR and the ATPLs are about 4,000. You don't have to get the CPL rating although I fail to see the point of not having one if you want to instruct. You can't legally get paid and it really takes alot of time, so doing it for charity isn't an option me thinks. Besides if you're over 40 you could likely land a full time instructing job and make a living off it, most schools have an issue with FIs taking off for greener pastures as soon as someone mentions "jet"...
I'm nigh on 40 myself and just did my FI, with 700 hrs in the book, and I see it as my next career. It's alot of fun, but you need the money to keep it that way.
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Old 7th Nov 2007, 17:49
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FI Rating

Sorry Deice, slip of the finger there that should have read £16,000
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Old 19th Nov 2007, 10:51
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In my view it's a good thing that you do have to have the CPL exams behind you to be an instructor. In my experience, even with the exams completed most FI students need some "refresher" training - without that academic base they would struggle badly.
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Old 19th Nov 2007, 13:44
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CAA and JAA are going to be a moot point before long. Within the next few years EASA will assume full regulatory authority for Flight Crew Licensing. EASA rules are EU Regulations which, EASA being a higher EU executive authority, will supersede any national regulations.

I wouldn't worry too much about whether the CAA will initiate a PPL FI without CPL exams - it is what EASA do that will make the difference and whether the CAA can convince other member states that such a rating would be productive).

In any case, the proposal as I understand it is that the PPL FI will be for primary PPL instruction only, daytime VFR only, no night, no IF, and limited to aircraft with fixed u/c and prop with a given maximum weight but I would welcome some clarification of this.
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Old 19th Nov 2007, 14:53
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I really do not know on what your speculation is based. Anyway whatever EASA decides each state may for its own purposes act how it likes. Whatever it does decide I have heard nothing in regard to restrictions to night, imc or on the 'differences' classified type training that you mention.
ICAO is the overiding factor here and with regard to the Flight Instructor Qualification the UK is already complient in having a dedicated Flight Instructor Course, instead of the alternative need for extensive exams.
The problem with regard to a Flight Instructor being paid is wholey in the hands of the UK. Within the UK flight instruction is considered 'Arial Work' when the instructor is paid. Exemptions, granted from this restriction on payments, are already in place for microlites etc and could simply be extended to flight instruction on PPL A aircraft, particularly in the case of the NPPL.
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Old 19th Nov 2007, 16:00
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Homeguard,

I do not wish to get into an argument with you or anyone else over this but I do think you have your wires crossed re: EASA and its powers.

I do not speculate but base my comments on published CAA documents.

JAA was never a regulatory authority as such, hence the reason national aviation authorities (NAAs) could make their own rules should they so wish and of course they often did. Legal authority and responsibility laid with each individual NAA and each country occasionally made its own rules, however, in the main most stuck to the agreements outlined within JARs.

Similarly, ICAO is not a legal authority with regulatory powers over individual member states, however, membership of ICAO requires compliance with certain established procedures. Again though, deviations to ICAO rules were possible, subject to ICAO agreement, but legal authority rested with individual NAAs.

EASA is a different kettle of fish. It was recognised that, in order to obtain EU cross border compliance full legal regulatory authority within EU was required and as such EASA has been granted the status of a higher executive body within the EU, i.e. it has full legal clout across all member states. Individual states may have their own legislation, e.g. Air Navigation Order, but these would either endorse or ratify EASA regulations.

The new instructor rating under consideration by the UK National PPL Policy & Steering Committee is for a Simple Single Engine Aircraft (SSEA) rating and would only be related to the NPPL and not the JAA PPL, therefore, it is a daytime VFR licence only and restricted to the NPPL maximum weight for SSEA of 2,000 kg.

It is also expected that the UK NPPL will cease when EASA assumes full regulatory authority for FCL and it is presently unclear what EASA licence will replace it, probably something along the lines of a Recreational Pilot or Sports Pilot licence.

Saying that, EASA has formed a sub committee which is looking at the possibility of introducing a pan-EU Light Aircraft Pilots Licence with appropriate instructor ratings.

Hope this helps clarify things.

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Old 19th Nov 2007, 17:29
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Simple.....what?

To uncross wires a little bit, nothing is that simple.
With regards to the JAA. Yes it was a voluntary get together of enthusiastic NAA and some 30+ NAA signed up for it. Less than half that number ever reached compliance and probaly never would have (my opinion).
It would be impossible for EASA to legislate ignoring ICAO and act in isolation. Therefore a future overal standard licence to be imposed on all member states, who act in a world market and which conflicts with ICAO, will not happen.
As to your point that that member countries stuck closely to the JAR - they did not. France retained and also constructed individual standards of its own as have many other countries. The UK, ignoring JAR, devised a difference much more radical than anybody in establishing the NPPL and, although not intended as such, could be seen at the time as sticking one up em.
Would the EU through EASA dare to devise a detailed licence to be imposed on each state. If it did it will be a first. EASA will do no more than produce a framework, not in conflict with ICAO, which can and will be interpreted and applied in different ways in different states as now. Witness such in many other industries.
As to the different standards for the NPPL, they are in the main artificial. They were devised to satisfy any difficult questions from the Dept. of Transport who would quite reasonably ask; why, having just sponsored a new statute (ANO) at the request of the CAA to comply with the JAA agreement, were they (the CAA) coming back with a scheme just like the old one which had just been changed. The NPPL had to look different.
What could justify, in any future EASA debate, restrictiing a similarly trained pilot from flying an aircraft in excess of 2 tonnes when another pilot could fly an aircraft up to 5.7 tonnes without any real difference in skills training?
What could justify restricting one pilot from flying say a Sarotoga up to MAUW full of duty free wine but without more than 3 passengers while another could fill all seats with people but not take home so much wine?
What could justify the not allowing of the NPPL holder the ability to qualify to fly at night when the flying course to do so did not require a test or examination? Flying at night has never been seen as exceptionally different to flying during the day.
What is it in the training of the JAA PPL that allows them but prevents the NPPL achieving an IMCR?

Is there any real explanation of any of this close2 that you can give to me in my ignorance.
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Old 20th Nov 2007, 08:04
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It is clear, homeguard, that you do not fully understand either the status or the intentions of EASA. As an agency of the EU, the rules that it develops, once accepted by the Commission and rubber-stamped by the parliament, become EU law, to which all member states are subject. Neither the UK nor any other member state will be able to legislate other than in accordance with EU law.

The first draft of the EASA Implementing Rules for Licensing has recently been published internally and the implications, particularly for the UK, are reported to be significant - e.g. loss of the IMC rating, restricted BCPLs, the NPPL, national (lifetime) PPLs, etc. Holders of UK national ATPLs, who do not have the required MPA experience for issue of an EASA ATPL, will have to downgrade to a CPL.

However, EASA does intend to issue a 'Light Aircraft Pilot Licence' for both aeroplanes and helicopters, which will not not be compliant with ICAO. This is intended to be a two tier licence, the lower tier allowing A to A flights (with no intermediate landing) limited to a radius of 50km from the point of departure and the higher tier giving privileges similar to the UK NPPL but extended throughout Europe. There is intended to be an instructor rating allied to this licence, which will allow instruction without the requirement to have passed the CPL exams - to instruct for a full EASA PPL and above, CPL knowledge will still be required.

Currently, EASA still seems to be determined to require an instructor to hold an EASA licence and rating in order to instruct for EASA qualifications. This will have a significant effect on those training organisations operating outside Europe who currently employ, for example, FAA licenced instructors under the terms of Appendix 1 to JAR-FCL 1.300. It will have an even greater effect on bizjet training where over 90% of type rating instruction is currently given by instructors who do not hold JAA licences.

Oh yes - the rules also currently require an instrument rating to be held for flight under IFR, which includes all night flight in the UK!!

The Implementing Rules will be published for consultation sometime next spring, probably March and it is important that everyone has their say. However, in the usual EU fashion, they are likely to be well hidden in the tortuous EU website and the consultation period will be limited to only 3 months so everyone will need to be on their toes.

Last edited by BillieBob; 20th Nov 2007 at 11:10.
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Old 20th Nov 2007, 09:02
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Thanks, BillieBob, for that clear explanation.

Hopefully, that should now clarify things.
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Old 20th Nov 2007, 12:28
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Who, when and what?

Now, the two of you are quite correct in saying that I do not understand the inner workings of the EU and to many the processes are confusing to say the least.
However, the EU Commision has never made law and to my little knowledge (I conceed that) they issue guidlines/recommendations (both words mine) and it is for each state to interpret and apply those guidlines as they see fit. You both say that the UK Parliament rubber stamp. Do you think that your MP would agree to that statement - I doubt it! As you will be aware the very idea is a sensitive one.
You are both seeming to be bowing to an inevitable result. However, any proposals have yet to be consulted on and further a submission made to the commision and further on still a submittion to the Dept. of Transport and then onto parliament who will have to, I presume, go to consultation with industry. A long way to go it would seem to me. I believe that some countries such as Germany have great difficulty with the process. They are a federal state and national legislation has to pass through each state to become national law. Yet another hurdle. To use words such as 'intend' in qouting EASA are a premature claim.

Are you both saying that there is no resistance being made to the proposals from those representing us?
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Old 20th Nov 2007, 13:31
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Homeguard,

You are pretty much on the money regarding the normal process for legislative development within EU, however, it is somewhat different within EU aviation.

It was explained to me by my colleagues at a certain grey building in Gatwick, who are personally involved in the development of legislation (and having been so myself to a far lessser degree), that, in order to maintain cross border uniformity and compliance (and thus avoid the problems experienced under JAA, with, as you correctly state, each country going off and doing its own thing to one degree or another) EASA has been granted the status of a higher executive authority, which gives it the power to develop legislation which, when approved by the EU Parliament, becomes binding on all EU member states.

This is somewhat different to the normal process whereby EU Directives (your 'guidelines/recommendations') are issued by the EU Commission to EU member states for imlementation into national legislation. In this respect, it is common to find individual countries either adhering steadfastly to the EU Directive (as is commonly in the case with the UK), blatantly ignoring the Directive if they disagree with it (as is the case with F......) or somewhere in between.

Thus, whilst the UK DfT, CAA and industry are heavily involved with the legislative development process, the final regulations are implemented by EASA and not individual member states.

With a bit of luck that'll help clarify things a bit further.
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Old 20th Nov 2007, 14:38
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Who.................?

Well no it isn't clarified.
Who in the UK has the authority to write a blank cheque to EASA or the Commision? Directives are not mandatory. Two countries, Holland and France have had a referendom and through that have stated clearly that the EU will not rule them. Their governments have given no mandate to write 'blank cheques'. I do not believe that our parliament would allow legislation to be made in Brussels just to be rubber stamped. What ever EASA finally decides to recommend it will have to be acceptable to ALL states. A lot of wasted time otherwise should all their effort be rejected.
What then is the situation should our working party reps say to our government; the EASA resolve is wrong and harmful to our industry for reasons that are then well argued. You say that ATPLs who have not met the current or future elements will have to give it up and be downgraded to CPL - I don't believe that. I can envisage a reasoned arguement that saids unless certain requirements are met - so many flight hours of multi-crew etc. - the pilot can not exercise the privilege of the licence already held. A UK Plumber cannot now sign off a gas installation unless they are registered with CORGI and are approved to do so. They remain, just the same, a Plumber.
To mess around with too much detail with regard to each countries custom and practice will cause chaos. I would hope that our representatives at EASA are representing our best interest and should report to our government should our best interest not be served by any proposal. I certainly believe the their job is not to horse trade away our freedoms.
What is the stance of our reps? I ask again for you both appear to have ears at the keyhole.
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Old 20th Nov 2007, 15:10
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Do you realise that there are 13 (or so I was told by my GCH installer) different CORGI certificates and that you only require 5 of them to state that you are CORGI registered. But what that has got to do with aviation legislation is beyond me!!

Now, on to this stuff about aviation legislation, ALL member states are invited to play a part in the negotiation and development process in various sub-committees. Of course, each NAA is there to serve the best interests of its own state and it must (should?) have a reporting chain to central government (in our case the DfT) but there must come a point where compromise plays a part, otherwise the process could not work (that's not to suggest the French would ever compromise over anything).

That is the whole basis behind EASA, one centralised agency which regulates through standardisation all of the aviation legislation within the EU, so that everyone is singing from the same hymn sheet. As I understand it, central government of all member states have already agreed this as being the status quo and any further implementation of regulations does not require further agreement at national level, having entrusted the develoment of the regualtions to their respective NAAs. Once the sub-committees (with NAA representatives having reported back to their respective national central governments) have agreed the standards to be implemented it merely remains for EASA to put the regulations forward for ratification and implementation.

All of these issues go for consultation to the general public and this is where we have our chance to state our objections. As BillieBob said, 'Watch this space' for the consultation on the EASA LAPL and FI ratings, etc.

I know nothing of ATPL being downgraded to CPL - something I was unaware of. Grandfather rights is something I would expect the CAA to be very keen on.

Are you a FI now or is this something you are looking towards?
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Old 20th Nov 2007, 15:37
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No ...no and no!

To answer the first question I have been a full time FI for almost twenty years and a Flight Examiner for in excess of 17 years. I also owned and operated my own flying cub and school for 14 years or so. I have therefore some well grounded knowledge and a well honed experience of how ill-informed legislation causes considerable hardship to many.
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Old 20th Nov 2007, 16:31
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JAR-FCL has proved to be an expensive nonsense which hasn't furthered safety one iota.

We must ALL stand up and say "NO!!" to the EASA proposals. Write to your MP and explain that these Eurocrats wish to reduce safety, add cost and reruce your long-held privileges. For no justifiable reason.

The UK representatives have utterly failed to show sufficient interest in protecting the rights of GA pilots in the UK - and are selling us down the river.
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Old 20th Nov 2007, 16:31
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Homeguard, I'm sorry but you are wrong in almost every respect. European law, once processed through the European parliament (not Westminster) is binding on all member states and supersedes UK national law. This was confirmed by the UK courts in the case of the 'metric martyrs'. We are not talking about EU directives here, which are something quite different. Once adopted, the Implementing Rules for Licensing will be legally binding in the UK and there is nothing whatever that the UK parliament can do about it. Those are the unfortunate facts of membership of the EU, as so many other industries have discovered to their cost.

In answer to some of your specific questions and points.
Who in the UK has the authority to write a blank cheque to EASA or the Commision?
The UK parliament, which has done so in a number of treaties and continues to do so, despite the expressed will of the electorate.
Two countries, Holland and France have had a referendom and through that have stated clearly that the EU will not rule them.
No, they rejected the European Constitution, which is now being brought in anyway disguised as a 'Treaty'
What ever EASA finally decides to recommend it will have to be acceptable to ALL states.
Competence in this area has already been ceded to the EU. Member states may comment on the proposed Implementing Rules, just as you and I may, but the final decisions rest with the EU.
I would hope that our representatives at EASA are representing our best interest
Only 4 National Aviation Authorities are represented on the FCL.001 working group that is developing the Implementing Rules - the other representatives are from European representative bodies, each interested only in their own members' interests.
However, the EU Commision has never made law
The EU Commission is the only body that can frame EU law, which is then sent to the EU parliament for rubber-stamping. MEPs are expected to vote on new laws at the rate of dozens per hour and cannot be expected to consider them properly - they simply vote as directed by their parties/groupings. It is very unusual for laws sent to parliament by the EU Commission not to be passed.
....and then onto parliament who will have to, I presume, go to consultation with industry
No, industry gets its chance to comment at the same time as you, I and the National Aviation Authorities. EU law is never set before the UK parliament, that's what the EU parliament is there for.

What a worrying number of people fail to understand is that well in excess of half of the laws of this country are now made by the EU with no input from Westminster and the proportion is increasing inexorably.
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Old 20th Nov 2007, 18:57
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Sorry chaps to but-in (as the original poster)

Would you advise me starting the ATPL/CPL ground studies now, if all I want to do is instruct?


(says in a very small voice......and then takes cover)
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