CAA Set to abolish Registered Training Facilties

[BEagle]

DFC, part-FCL does not apply to the regulation of pilot licensing for aircraft of less than 450 kg. That was made quite clear at the Gatwick EASA meeting a few weeks ago.

The infernal LPL appears to have become some one-size-fits-nobody €urocratic farce intended to be attractive to pilots of aircraft which, in the case of single pistons, fall more or less into the SSEA category. But which offers far, far less than the UK NPPL currently does.

All that it will do is to polarise people either 'down' to Microlight level or 'up' to PPL level. The only real benefits to the Microlight world will be the numbers of people driven out of the SEP/SSEA world by pointless €urocracy.

[LH2]

Just one general question, if I may:

How come nobody else in Europe seems to have a problem with the changes related to EASA, which incidentally are not exactly new or surprising? I have asked this question many times in the past and none has offered any explanation at all, let alone a convincing one.

Incidentally, I find EASA's NPAs are eminently clear and legible for a legal document. It is bemusing how much opposition to the rules comes from people who freely and adamantly acknowledge they haven't read them ("because they are too difficult"). Also, often this point of view is presented with poor spelling and grammar, which clearly makes one wonder.

Anyhow, that old joke about a plane full of Brits comes to mind

[Whopity]

1. Pilots involved in the operation of aircraft referred to in
Article 4(1)(b) and (c), ....., shall comply with the relevant ‘essential requirements’ laid down in Annex III.

Article 4
Basic principles and applicability
4. Paragraph 1 shall not apply to aircraft referred to in
Annex II.

Annex II. Aircraft referred to in Article 4(4)
Article 4(1), (2) and (3) do not apply to aircraft falling in one or more of the categories set out below:
(e) aeroplanes, helicopters and powered parachutes having no more than two seats, a maximum take-off mass (MTOM), as recorded by the Member States, of no more than:
(i) 300 kg for a land plane/helicopter, single-seater; or
(ii) 450 kg for a land plane/helicopter, two-seater; or

As confirmed by Cologne a week ago.

[belowradar]

Great example of how not to write new aviation regulations

If I had time to go from one paragraph to another trying to piece together the meaning and intent that would be fine but I don't. Why can't EASA have a look at the American FAR's and then take a leaf out of that book ? the old acronym KISS should apply.

By the way does anybody know when we can train from unlicensed airfields ?- I have looked on CAA website, searched EASA PROPOSALS and called CAA they haven't got a clue

[chrisbl]

Belowradar, you are a waste of space.

[belowradar]

ChrisBL

What'sthe matter ? don't like a taste of your own medicine ?

Suggest you re-read the terms of PPRUNE, you certainly did not join this site to make unnecessary personal attacks on people you don't even know.

This is a forum for Professional Flying Instructors and Examiners.

If you don't have anything positive to add to this debate fair enough but no need to get upset when you started the negativity.

[Say again s l o w l y]

Children, can I make a suggestion?

Shut it.

[belowradar]

SAYAGAINSLOWLY


NO ! This is a thread for debate, views and information sharing. Too often the message is lost because of rude arrogant posts so I am sorry but you can shut up unless you have something constructive to add to this debate.

[DFC]

The problem is that firstly one has to read the complete set of proposals.

Secondly, when asked a question, Authorities (EASA / CAA etc) provide an answer that is correct in relation to the question as asked. They do not expand into areas that they do not want to even if it may be relevant to how such a question would be answered in the near future.

I have highlighted the relevant part of ther NPA below;

The BMAA and European Sport Aviation have spent quite a bit of money to ensure that the Basic LPL / LPL suits them when it comes and that the transition is fair to their members.

Grandfather rights are covered by the NPL if one reads the document. So too is

the principle of right of access to a profession

.

Please read all the documents.

47. In the case of licences or other certificates that were issued on the basis of national rules
noncompliant
with JARFCL

, similarly to the case of Part66

, national licences and
certificates could be converted into PartFCL
licences and certificates. In the case of
aeroplane and helicopter licences, this conversion would take place in accordance with
Annex IV to the Licensing Cover Regulation, which was drafted on the basis of Appendix
1 to JAR–FCL 1.005 and Appendix 1 to JARFCL
2.005. This Annex would also apply after
the end of the transition period for the conversion of pilot licences issued by Member
States in accordance with national rules for aircraft that are currently in Annex II to the
Basic Regulation. The Agency also considers the requirements in this Annex to be
adequate for application to holders of national pilot licences for Annex II aircraft used in

commercial air transport.

Don't forget that once this is over the CAA will not be issuing any national licenses so unless it removes the requirement for a microlight pilot to have a licence (which would be a breach of EU law anyway), then in the future, every pilot regardless of what they fly will be trained, tested and licensed under EASA.

Regards,

DFC

[belowradar]

Contrast the European approach to open and honest debate ? with the well established and proven FAA method Recently Published Rulemaking Documents

Here you get to make any comments you like regarding the proposed change, there is a named individual who "owns" the change and who you can contact, and lo and behold it is written in straightforward English that is easily understood. You also get to choose your preferred method of feedback.

Why do EASA even have to screw up their NPR process, could it be because they don't wan't open and honest comments but merely wish to bulldozer their new regulations onto the aviation community ?

[eddietcapt]

Getting back to the start of this thread!
Please note that consultation period for NPA-2008-22d "Authority and Organisation Requirements - Certification Specifications for Aeroplane Flight Simulation Training Devices "CS-FSTD(A)"" has been extended until 15 Apr 2009.

See: http://hub.easa.europa.eu/crt/docs/viewnpa/id_55

To place comments please logon at EASA CRT application

For further information please contact Rulemaking Process Support at [email protected]
If you have a PPL and you are instructing you should look at this and make your comments known. If these rules are passed training will be too expensive in the UK and we will all end up with US ratings or going to USA to get trained.

[theavionicsbloke]

Engineers Experience of EASA Implementation

An interesting debate.

Folks, you may or may not be aware that engineering has just (in the last five years) converted to EASA.

So now... well, I’m afraid ... it's the pilots turn !!

However, you may gain some comfort from my short story of changes that I have experienced as follows: (Sorry for the length !!)

As a CAA Licensed Engineer and having just started to settle into the JAA way of life I suddenly found my world turned upside down by this new, out of the blue EASA contraption ....

Overnight our work places went from JAR 145 approved maintenance organisations to Part 145. Our licences went from CAA BCARs A & C, X & R Category licences to EASA A,B1, B2 & C licences. C of A’s have now become ARC’s !

Although sceptical and anxious before the changes we have undergone, now we are somewhere on the other side I must confess that I rather like the EASA approach. EASA seem to be a little better organised, and once understood it appears that there is very little change in the actual requirements but things are split up, given new names, put into logical order and clarified.

Now free of the old CAA ambiguity! Legislation and procedures, have suddenly been bought clearly into focus.

One fall out from this, that has become very evident is that there is no longer any room for the individual to exercise discretion or judgement any more. It’s either In the Box or it’s Out the box. The grey areas and good old ‘room for interpretation’ have all but disappeared !

Although we were told that the CAA would be no more, this has now been halted. The National Authorities (CAA etc) are now referred to as the EASA ‘Competent Authority’ and assumes some EASA duties. Issuing Licences is one of them for example. So you may still be ringing up good old Gatwick for sometime to come yet.

When I have challenged the ‘Competent Authority (CAA)’ their final comments to me have been “The requirements have not changed. We are now just enforcing how things should have been done in the first place”

What we have learned is that If you are currently doing things free from convenient interpretation or through squints of the eye, using the paragraph that the CAA missed in your documentation submitted for approval, then you will have nothing to worry about. If you are not, as either an organisation or an individual then you will l have to make changes and tow the line.

[Mickey Kaye]

Have the CAA now stopped accepting applications to set up registered facilities? and gone over to ATO.

Does anyone know what the differences are in both set up and running costs and any extra administration thats involved.

[SkyCamMK]

The line

For clarity and interest:

Glider pilots "tow the line" the rest of us are supposed to "toe the line" A line that is a broadsword's length from the opposition in front of the Dispatch Boxes in the House of Commons and sewn into the green carpet as red stripes.

[S-Works]

I am not sure they have gone to an ATO at all. We had to re register our RTF recently and that just says certificate of registration and our OCP number.

God knows why we have to register as an RTF, FTO and TRTO when we use the same staff, same premises and same ops and training manuals........

[WestWind1950]

Just one general question, if I may:

How come nobody else in Europe seems to have a problem with the changes related to EASA, which incidentally are not exactly new or surprising? I have asked this question many times in the past and none has offered any explanation at all, let alone a convincing one.

.........

Anyhow, that old joke about a plane full of Brits comes to mind

no, you guys are NOT the only ones balking about the EASA stuff. Since I can only read in English and German, I have no idea how the French, Spanish, Italians, etc., look upon this.

Oh, and to add to OUR problems.... since most documents are only in English, most of the authority personal in other countries besides Great Britain have trouble reading and understanding them. Only the final drafts get translated. So that makes it quite difficult for people from other, non-English speaking countries to read proposed ammentments and comment.

In one of the above mentioned EASA documents... I believe it was this one... it mentions the requirment for aerodromes for trainign and one point mentions being a controlled airfield!

I wish the EASA homepage was easier to navigate.... the use too many abbreviations!

[BillieBob]

Have the CAA now stopped accepting applications to set up registered facilities? and gone over to ATO.

No. The EASA Implementing Rules do not come into force until 8 April 2012 and the UK CAA have declared a 3 year transition period to allow Registered Facilities to become fully compliant. Consequently, there is no obligation on a current RF to become an ATO until 8 April 2015. The CAA have recently had to require all current Registered Facilities to re-register (at a cost of £100 per year) because they failed to keep track of how many facilities were registered.

Does anyone know what the differences are in both set up and running costs and any extra administration thats involved.

Not precisely. The intended requirements have, until now, been detailed in Part-OR but this has not yet completed the Comment/Response process and so nothing is certain. In any case, EASA has now decided to do away with Part-OR and to include its ATO-related provisions in Part-FCL, which has completed CRD and is currently undergoing the comitology process.

On the basis of the Rules already published in Part-OR, it is likely that an ATO, even if only offering the PPL and LAPL, will have to produce (and obtain approval of) an Operations Manual, a Training Manual and a Safety Management and Quality System as well as complying with formal staff training requirements. Since the approval process will require CAA involvement, there willl clearly be a fee imposed over and above the costs of initially meeting the requirements and thereafter maintaining compliance.

God knows why we have to register as an RTF, FTO and TRTO

Because the UK CAA seems incapable of reading and understanding the requirements. Registration is required solely for organisations conducting only PPL training and nothing precludes an FTO from offering type rating training without also being a TRTO.

In one of the above mentioned EASA documents.... it mentions the requirment for aerodromes for trainign and one point mentions being a controlled airfield!

Your link leads to the Certification Standards for FSTDs, which is hardly relevant. The proposed rules for airfields to be used for flight training are, for the moment, detailed in Part-OR. The relevant hard law (OR.ATO.140) does not mention controlled airfields at all; it simply requires that an ATO shall use aerodromes or operating sites that have the appropriate facilities. An air traffic control service is, however, mentioned in the associated AMC, which currently reads "....an air traffic service except for uncontrolled airfields or operating sites where the training requirements may be satisfied safely by another acceptable means of air-to-ground communication" Interpretation of this is left to the 'competent' authority, as is the option to accept an alternative acceptable means of compliance, potentially removing the requirement for any form of air-to-ground communication.

Bear in mind also that, under EU law, an alternative AMC accepted by any competent authority becomes automatically acceptable in all member states (i.e. if an alternative AMC that does not include any requirement for air-to-ground communication is accepted by, say, the Bulgarian authority, the UK must accept it as well)

[WestWind1950]

sorry, I posted the wrong one... NPA 2008-22c is the one I meant. Under AMC to OR.ATO.135 AERODROMES (page 48) is says:

AMC to OR.ATO.135 Aerodromes
1. Except in the case of balloons, the base aerodrome and any alternative base
aerodromes at which flying training is being conducted should have at least the
following facilities:
a. at least one runway or takeoff
area that allows training aircraft to make a
normal takeoff
or landing at the maximum takeoff
or maximum landing
mass authorised, in the following conditions:
(i) under calm wind (not more than 4 knots) conditions and temperatures
equal to the mean high temperature for the hottest month of the year in
the operating area;
(ii) clearing all obstacles in the takeoff
flight path by at least 50 feet;
(iii) with the powerplant operation and the landing gear and flap operation
(if applicable) recommended by the manufacturer; and
(iv) with a smooth transition from liftoff
to the best rate of climb speed
without exceptional piloting skills or techniques.
b. a wind direction indicator that is visible at ground level from the ends of each
runway;
c. adequate runway electrical lighting if used for night training; and
d. an air traffic control service.
2. In addition to 1, for helicopter training sites should be available for:
a. confined area operation training;
b. simulated engine off autorotation;
c. sloping ground operation.
3. In the case of balloons, the take off sites used by the training organisation should
allow a normal takeoff
and clearing of all obstacles in the takeoff
flight path by at
least 50 feet.

In Germany ALL airfields are certified (it's a law) and usually have at least traffic advisory service, not necessarily controlled (which I would interpret at with ATC). So, how would you all interpret the above?

[BillieBob]

sorry, I posted the wrong one

You are still posting the wrong one although, to be fair, EASA, in line with its aversion to public scrutiny, seems to have suppressed the correct one.

You have linked to the original draft, dated 30 Oct 2008 while the quote above is from the draft Opinion, dated 4 Oct 2010. This later text was published for stakeholder reaction some months ago but has, as far as I can tell, now been removed from the EASA website (at least I can no longer find it), presumably because Part-OR no longer exists. Nevertheless, it is the text that will be included in Part-FCL.

In any case, as previously explained, anyone has the option of submitting an alternative AMC that does not include any requirement for air-to-ground communication and so the perceived requirement for ATC is, in practice, a red herring.

[WestWind1950]

Billie, that's exactly what I meant by the site being horrible to navigate. For me, if something is on the site, then it is the actual version being submitted, especially if another version can't be found (and yes, I tried their search function..... forget it). It's all quite frustrating... to put it mildly.

How are we to be prepared for the new rules getting incorperated in one years time if there's such a mess?