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EASA ATO changes are a good thing.

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EASA ATO changes are a good thing.

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Old 7th Dec 2010, 12:08
  #21 (permalink)  
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If someone is currently providing correct PPL training as an RTF then where will the changes be?

The approval of an ATO will be issued for an unlimited duration. (OR.GEN.035)

So please tell me what will change?

Ops Manual, Training Manual are only required if providing training beyond LPL / PPL.

Everyone should be already operating safely and competently so please can anyone give some specific examples referenced to the relevant documents where a safe and competent RTF currently established will have difficulty?

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mrmum,

You just need to take a look at what they did to light aircraft maintenance, huge increases in cost and paperwork,
What a perfect example.

Indeed it has been a great improvement on what went previous for the owners and operators who took (take) the time to do it properly.

Perhaps an owner who never bothered to check what AD's were applicable to their aircraft and never kept their maintenance manuals or other important documents up to date and who did nothing to ensure that their responsibilities as an owner were fulfilled had a bit of a shock. But for those that were doing it correctly all along there has been no significant change - just like the ATO's in afew years time.

So yes you are correct - it is a perfect example where people who were doing things properly in the first instance have the benefit of more choice and in many cases a more relaxed maintenance system.

Increase in cost - zero and in many cases a reduction due to cross-border competition. Increase in paperwork - zero.

But of course the loudest noises are from those that had to up their game in order to reach what for most was a basic minimum standard.
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Old 7th Dec 2010, 12:53
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Ops Manual, Training Manual are only required if providing training beyond LPL / PPL.
Not any more. In the revised text of the CRD, the requirement for an Operations and Training Manual now appears in Section I - General. i.e. it applies to all ATOs. Similarly the oversight requirements, which in the NPA to Part AR provided for a 'lighter touch' regime for ATOs providing instruction only for the LAPL and PPL are now the same for all organisations.
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Old 7th Dec 2010, 13:30
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With regard to engineering I'm just a customer, so maybe I've just been fortunate and always had a "good" maintenance organisation then, but in my admittedly limited experience, there's been no change in the standard of work done, just higher costs, which the maintenance organisation have blamed on extra "box-ticking" required by EASA. Can you please explain how cross-border competition will help reduce the cost of maintaining a Warrior north of Manchester?

I don't expect that becoming an ATO will be insurmountably difficult, if as suggested, the RF is doing things reasonably well in the first place, however it will be more burdensome the smaller you are. What I do strongly suspect is that the focus of any initial inspections and ongoing oversight will be on how well the paperwork is completed, rather than the quality and competency of the resulting pilots.

As to cost, I cannot see how it will not be significantly more. At the moment there is no fee to be a RF, however as the CAA are currently making everyone re-register by the end of the year, it appears that this is a precursor to sending out the bills. Also, they will no doubt be charging for inspection visits (at Gatwick rates), as well as taking up the CFIs/HoTs time.
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Old 7th Dec 2010, 14:02
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I have noticed over recent years that the CAA seem to be fairly happy to issue FE authorisations to anyone who meets the (low-ish) requirements and will pay the fees. Pre-JAA as some will remember, you had to have at least 1500 instructional hours before being considered for an "X" rating.
And under EASA they will have no choice other than to give them to anyone who meets the minimum experience requirement and has completed the required training course. Two ticked boxes = Examiner Authority! More Examiners, Lower Standards and less standardisation.
I've never been asked in 18 years.
FIEs are required to check examiner records as part of the FE revalidation process! If you don't have enough, you will need additional training.
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Old 7th Dec 2010, 15:04
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Whopity

Quite correct, what I really meant was that in relation to the standard of student training records, if the regulator thinks that FIs aren't doing a good enough job, then they already have the opportunity to monitor some at FI revalidations/renewals or get in introduced as a topic on seminars (if it isn't already)

Also, I couldn't agree more with your comments regarding the quantity/quality/experience of FEs.

Last edited by mrmum; 7th Dec 2010 at 15:07. Reason: Add FE comment
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Old 7th Dec 2010, 15:58
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it appears that this is a precursor to sending out the bills.
Correct. As of April Fools Day 2011, registration will cost £100 per year. The re-registration process is required because the CAA currently have no idea how many Registered Facilities are out there - how's that for adequate oversight?
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Old 8th Dec 2010, 10:20
  #27 (permalink)  
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OK. So how DO we improve standards?

The standard of instructors Ive seen on seminars is not good - and therefore think that the 'free-range' instructor theory and 'trust us to do a good job' is not adequate - especially in the instructor-come-hour-builder whose eye is NOT on instructing but his future heavy career. Also there is more than students cash at stake here...far more. We are talking a GREAT many lives - the lives of their passengers, other pilots and the HUGE number of people they will over-fly. I'm sorry but the responsibility on us instructors and examiners is far greater than many seem to realise.

I think many instructors don't teach all the things they should. I know things get missed out. I don't think some RFs care as long as the money rolls in...RFs spend almost all their time under the radar. RFs are not regulated currently by the CAA and therefore unsound practices have developed at some RFs. I have worked at (and was incredibly upset by) one RF in the past whose eye was on the balance sheet so much so such they worked on 1:15 slot times for a 1hr flight(!!). I use 2hr slot times as a minimum. Now this organisation the CFI was on a grandfather rights BCPL + instructor rating (not that this is inherently bad) and was an FE. Let us say modern practices and techniques did not 'infect' his world. Who would tell this person that the organisation doesn't come up to scratch? It wouldn't have been picked up on by an FIE or FEE. It seems in this case it is only through ATO status and inspection that this sort of thing would have been picked up..?

I most certainly do not believe that the student is as savvy as suggested. How do they know they shouldn't be in the circuit by lesson number 4?! I have just been involved in a student I picked up from another instructor - we have all seen it lesson 2 "4, 6, 7", lesson 3 "6, 7, 8". My heart sinks. [Action to address this drop in standards from someone who I understand is an examiner(!) is in progress]. The student had no idea - and thought he was progressing well. But didnt even know about keeping the a/c in balance - resulting in maintaining a climb using R-wing down instead of R-rudder. I can tell you I was shocked when I looked out at the wing tips. But the student thought he was progressing well - clearly here the instructional standard is not good enough and the student (who is actually very good, intelligent and a fast learner) simply didn't know that this wasn't normal. Just peruse the 'Private Flying' forum here on PPrune and you'll understand exactly what I mean...

As an examiner with limited time I cannot test everything in the syllabus. As instructors we should not be teaching to pass a test - yet clearly some clubs & schools are doing exactly this - if examiners were allowed to simulate any number of emergencies maybe we could get a handle on this - but examiner's hands are tied (and rightly so to ensure consistency). There again is the examiner the right person to be policing this (as suggested above)?

So I'm back to where I started. I still think the changes are a good thing...because I cannot see a better and practical way to improve standards - I mean actual positive recommendations that can (at least through reasoning) be expected to raise instructional standards.

Oh. And one good thing EASA (will) do. Non-expiring pilots licences. That will save me a hassle and hundreds of pounds every 5 years.
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Old 8th Dec 2010, 11:01
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Non-expiring pilots licences. That will save me a hassle and hundreds of pounds every 5 years.
I believe approvals may be no expiring too but you will still have to pay for them every year!
As an examiner with limited time I cannot test everything in the syllabus
And is not required to do so. The test is clearly laid down and allows the Examiner to determine if the candidate is "Safe" to be granted a licence to carry passengers. There is more than adequate scope to determine that without going into nuts and bolts detail.

RFs vary from good to bad but so do FTOs. We are quick to blame the new instructor but I have seen better flight tests from many new instructors than old timers who were probably badly taught 30 years ago. That shows at Seminars too.

We hear little about the stand of instruction in gliding schools or Microlight schools yet all instructors are doing the same thing: training a recreational pilot to be safe enough to carry passengers. I do not believe additional regulation will make one iota of difference to instructional standards.
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Old 8th Dec 2010, 16:14
  #29 (permalink)  
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I do not believe additional regulation will make one iota of difference to instructional standards.
Whopity, you are 100% correct. The new ATO requirements (and the transposition of FCL requirements) happening in 2012 has nothing to do with raising standards.

The reason why RTF standards can be low and for a large part go unnoticed by the CAA is because too few people are willing to stand up and say something.

I have to ask why the RTF described by FormationFlyer has not been reported to the CAA by Formation Flyer. It is the duty of every instructor and examiner to report such failings properly as to do otherwise could be takes as either not noticing the failings or assisting in covering them up.

RTF registration was always non-expiring provided that the training was being done correctly and safely

Unless the CAA is informed of places where the minimum standards are not being met then the posibility to commence an action to correct the situation is limited.

The same is going to apply to ATO's.

An examiner can not test everything and a good example is the use of the mixture. In this regard, it is unfortunate that while failing to properly use the mixture will cost money and has lots of secondary issues, a candidate flying an aircraft operated by a school that has clear rules which require "full rich mixture at all times" can not be failed for not leaning correctly in the cruise.

The test is also an opportunity for learning and so the use of the mixture can be questioned and one can check that the candidate has an understanding of how the mixture operates and what the POH / AFM / general procedures are for the use of mixture.


BillieBob,

We will have to wait for the next draft to see what will happen. However, even if they did require such documents from an ATO providing Basic LPL training I think that 1 sheet of A4 for both would be enough.

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If you want to change instruction standards then don't sit back and let the failing examples ruin your industry. This has always been the situation.

As for the seminars, with a few exceptions, I have to say that I found the standard of presentation and general ideas coming from the providers to be just as bad as those coming from the attendees.
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Old 10th Dec 2010, 00:38
  #30 (permalink)  
 
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Independent Examiners conduct check rides. It works.
Clearly you haven't flown with any recent FAA graduates recently then...

The standard varies immensely and when good is normally very good, however - unfortunately it is pretty piss poor on average.
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Old 10th Dec 2010, 07:21
  #31 (permalink)  
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DFC - agree wholeheartedly with everything you say there.

I have to ask why the RTF described by FormationFlyer has not been reported to the CAA by Formation Flyer. It is the duty of every instructor and examiner to report such failings properly as to do otherwise could be takes as either not noticing the failings or assisting in covering them up.
Absolutely.

This was quite a long time ago. I was a newbie instructor straight out of training operating as an JAR FI(R) - rather green but knowing that things weren't right. But as a newbie I didn't understand enough about how things work - I was just upset that standards were so low. I 'resigned' (as much as self-employed instructors as it was at the time 'resign') by expressing my concerns on a 6 page letter of resignation to the school in question. I didn't hold back. I expressed concerns that the school may well be liable should the unfortunate occur and that this wasn't good enough. I didn't know I could any more than that. But I stopped teaching there as I just could not put my hand on my heart and say I was doing an OK job - let alone striving for a good one. It was sub-standard on a number of fronts full stop. I suspect that many newbie instructors are still placed in such positions today. I also believe that the supervision of new FI(R)s is sadly lacking. The microlight world headed by the BMAA provide very clear guidance on what is expected for supervision. I wonder why this straight forward guidance from the BMAA instructors & examiners handbook is not taken up by the CAA? Perhaps because a good many flying clubs/schools could not comply?

Nowadays is a very much different story - especially as an examiner. These days I do speak up. I am actively participating in instructor standardisation and raising standards.
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Old 27th Dec 2010, 12:24
  #32 (permalink)  
 
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Would I be correct in thinking that if you own a BCPL you will now be shafted as to be an FTO you have to hold a CPL?
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Old 27th Dec 2010, 13:07
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Firstly, the BCPL will be invalid after April 2012. You have two choices, if its a full BCPL, ontain a JAA CPL Restricted before April 2011 or; if its a BCPL(Restricted) obtain a JAA PPL, so that you can continue exercising your existing Instructor and Examiner privileges after April 2012. After that date you will be able to be remunerated for Flight Instruction and Examining as a PPL holder

EASA Part OR does not specify that the HT of a PPL school has to have a CPL, so you should be able to apply for a approval as an ATO one you have written the required manuals and hold an acceptable licence. Your previous experience should meet all the HT requirements.

FF
I wonder why this straight forward guidance from the BMAA instructors & examiners handbook is not taken up by the CAA? Perhaps because a good many flying clubs/schools could not comply?
Because the CAA transposed the JAR-FCL requirement straight into the ANO even though it differed from the National requirement for an AFI that has remained there with the original wording. Those very same requirements apply to Microlight AFIs. Under EASA the CAA will have even less ability to make its own rules.
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