EASA ATO changes are a good thing.

[FormationFlyer]

Ive just been getting the info and catching up with the EASA proposals to make everyone be an ATO. (EASA Part-OR)

What cracking news this is. This is, without a doubt an excellent move. Finally maybe we can do something about the standard of instructing in the UK - and RFs will have to step up their game and the CAA will have more visibility.

I think this is a welcome step in improving standards. Roll on 8 April 2012. I'm looking forward to it!

[proudprivate]

Economics 101 for FF : barriers to entry

Dear FormationFlyer,

Whether the standards of instruction in the UK will go up through this remains very much to be seen. There is nothing that prevents the CAA from acting on its own behalf, if it believes the standard of instruction is faltering.

What is an absolute certainty is that instruction prices will go up, as competition gets stifled through the erection of additional costly barriers to entry into the flight instruction market.

What we really need is to take a step back, and reinstate the individual flight instructor as the authority in flight training, by getting rid of the RTF concept altogether. This would create a climate where flight instruction is encouraged and taken up by a lot more people.

In turn, it would lead to a bigger client base, and eventually, more pilots to join our community.

But I guess you work for Oxford Aviation or have a similar vested interest so this is going to be an empty discussion anyway...

[DFC]

What we really need is to take a step back, and reinstate the individual flight instructor as the authority in flight training, by getting rid of the RTF concept altogether.

Thats like saying that we need to get rid of the company registration concept and reinstate the sole trader as the mainstay of business.

There is nothing in the proposed system that prevents an individual from setting up business as a flight instructor or doing it for free if they choose.

All that it does is lay down minimum standards that any legal entity providing training etc has to meet. The requirements for providing say Groundschool is the same for an individual as for Big Airline Training Ltd.

You may feel that the individual is at a disadvantage in such a situation. However, as many sole traders will point out, being small has it's advantages.

The customer is entitled to receive the proper standard of training and care and that simply does not happen out of a car boot.

Perhaps you could take the time to read the proposals and then you will see that it is possible to teach (and be paid) with only a PPL. Therefore in the future, it will be possible for an individual with a PPL to set up a successful business. So costs from scratch to being in business are very small. provided that the individual has the required facilities they can teach people for B747 type ratings if they want.

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FormationFlyer,

You are 100% correct.

There is not going to be much change for most competent operators who are already providing training to a good standard be they individuals, companies or international corporations.

The proposals create 3 distinct camps;

1. The current providers who provide training to a good standard and will not notice any significant difference other than a few new market opportunities. As a customer you will not notice any significant difference

2. The current operators who are not providing training to the minimum standard required and who will have to put some work in to raise their game. Of course the work involved in bringing their training up to the minimum acceptable standards is going to cost money so watch them moan about extra regulation and pushing up their prices.

3. The last camp consists of operators who standards wise are solidly in 1 above but who recognise an opportunity to push up their prices with the good old excuse of extra regulation. They can mostly get away with this because they will only be doing the same with their price as those in 2. above.

If any current training provider complains about having to do work to acheive the minimum standards required post 2012 simply ask why their current standards are so poor.

[421C]

What we really need is to take a step back, and reinstate the individual flight instructor as the authority in flight training, by getting rid of the RTF concept altogether.

Thats like saying that we need to get rid of the company registration concept and reinstate the sole trader as the mainstay of business.

DFC,

The alternative is to have both the sole trader and the company, and give the customer the choice - ie. the Part 61/141 model of training in the US. It seems to me a legitimate question in abstract debate, although the European mindset on training and organisational approvals in general is such that Part 61 is inconceivable in practice.

I believe the Part 61 model is effective. Instructors are trained to instruct. The FAA publishes standards (and rather good books on ground and flight training) in Part 61 and the Practical Test Standards. Independent Examiners conduct check rides. It works.

I know how deep and absolute the conviction in the UK training community is about the necessity for organisational regulation to maintain "standards". That doesn't mean there is no other legitimate way.

brgds
421C

[DFC]

The alternative is to have both the sole trader and the company, and give the customer the choice

Absolutely and that is how it is going to be.

One has to remember that when you need your Gas Boiler repaired, you can either ring Big Plumbing company (Ltd) or you can ring Mr A Plumber (Sole Trader).

However, as far as you are concerned the only difference is in the name because they will both have everything they need to satisfy the requirements to be on the Gas safe register (formerly known as CORGI registered).

If as a customer you were aware that Mr A Plumber was not quite up to the minimum approval standard of Big Plumbing Comapny Ltd, would you trust your life and money to that individual (and purchase a lot of carbon monoxide detectors with what money you may have saved)?

Everyone has recognised that one can not provide effective flight training out of the boot of a car - where do you do the pre and post flight briefings, where are the strudent records stored and using random aircraft from various entities that may or may not meet the appropriate requirements.

It is good for the customer that no matter if they obtain their training from a stand alone instructor or a big training school, they can reasonably expect that they will receive the required training to the required standard at a suitable aerodrome in a suitable aircraft and that there will be the appropriate facilities for briefings, planning and study of relevant documents. They can also reasonably expect that their training records will be stored correctly for the appropriate time.

Are people trying to avoid any of these important points? No? Then where is the problem?

[FormationFlyer]

Whether the standards of instruction in the UK will go up through this remains very much to be seen. There is nothing that prevents the CAA from acting on its own behalf, if it believes the standard of instruction is faltering.

Er. They are acting. Its called EASA - the CAA and indeed all NAA are involved in the process - the overwhelming feeling is to NOT have RFs - AFAIK there was no objection from the UK CAA regarding the loss of RFs nor a proposal from the CAA to keep them. RFs are not a UK specific thing they are part of JAR FCL 1 (1.055). All of the EASA states are behind the EASA proposals - its not some bunch of admin guys in a darkened room doing this - the process is open - you can go to the EASA website and read all the comments that have been made on the proposed legislation. AOPA have been active in this as well.

What is an absolute certainty is that instruction prices will go up, as competition gets stifled through the erection of additional costly barriers to entry into the flight instruction market.

Or an alternative way of looking at it is that such regulation ensures that people take a responsible attitude to what they do and actually THINK and PLAN before doing it?

When doing my own training I flew a lesson with an RF and one with an FTO - this is way back before I even knew there was a difference between these places (I had only just finished my FW microlight rating - about as grass roots as you can get). The FTO offered more courses and was slightly more expensive - but professionalism was top notch - but they were not extremely expensive - just a bit more than the RF. The RF was way too laid back and the owner did my flight. I was not impressed. I chose the FTO (Aeros @ gloucester) because I felt that I was paying for quality training with people who cared about the standard I achieved. This is all some time ago but little has changed in 15 years. I am very pleased with the choices I made and Instructors I got to know who are incredibly professional and good (In particular Pete Hamlet who will always remain an inspiration - quality extraordinaire). Looking back - Im pleased I chose the FTO....but this is the crux of it.

Me? Im passionate about flying. I want everyone to have the highest quality of training. I dont want accidents, and I don't want to meet the idiot fiddling with his GPS because he wasnt taught properly a) how to navigate b) how to properly fly with a GPS - and Ive come close enough to being hit by other people and their pointy bits to be concerned.

What we really need is to take a step back, and reinstate the individual flight instructor as the authority in flight training, by getting rid of the RTF concept altogether. This would create a climate where flight instruction is encouraged and taken up by a lot more people.

So by removing any requirement to register and ensure even the most basic of facilities we could have anyone anywhere doing training for a PPL? I find this curious. Ill put money on the following...

In my experience many instructors:
- do not read GASIL
- do not use CAA website that often
- are not on the CAA publications subscription list
- do not read TrainingCom
- willingly operate aircraft overwieght (C152 in most schools with 2 up and full tanks).
- Fail to teach that which is already on the syllabus: namely
-- Ex4 Mixture leaning
-- Ex8 Sideslip
-- Ex9 compass turns (DI Failure - turning using the compass)
-- Ex9 timed turns (DI failure - turning using the compass)
-- Ex11 incipient spin recovery (In the AOPA Its 11B fully developed spins thats optional - 11A isnt and Ex11 specified by JAR is not optional - which covers incipient spin recovery)
-- Ex13 short field take-off and landing
-- Ex13 soft field take-off and landing
- Fail to teach emergencies: namely
-- Door open emergencies (PA28 in particular - checklist doesnt work and is IMO dangerous - try it).
-- ASI failure.
-- Alternator failure
-- Actually CALL practice PAN on 121.5 - the guys at D&D are fantastic and I run up a scenario on all my night courses where I get the student to practice pan with D&D - some nights have been a real hoot with D&D having us doing identifying turns etc. All good training and experience for us all - and leaves the student with one less thing to consider on the list of 'unknowns' should the worst happen.

I have also heard such rubbish in my time talked about crosswinds, carb heat (despite the CAA publishing 2 clear pieces of guidance - AIC and safety sense leaflet AND lycoming making use of carb heat clear in a service bulletin), use of flaps - "we dont use full flap", "we always use 10deg flap on take-off" (despite 1500m+ of runway and an aircraft that in a clean config is off in 550m). etc. etc.

I want to see the rubbish stopped and the gaps plugged. I believe that properly planning of courses, proper monitoring of students progress (and coverage of the syllabus) along with inspections ensuring that this happens and that instructor standardisation occurs will indeed do that.

In turn, it would lead to a bigger client base, and eventually, more pilots to join our community.

I disagree - it is actually cost that is more off-putting and fuel prices have the most major affect.

But I guess you work for Oxford Aviation or have a similar vested interest so this is going to be an empty discussion anyway...

Wrong. Nice try. Im just and instructor and examiner with a passion for flying from grass roots to commercial - and I believe we should strive for the highest standards in our roles as teachers. I do work with an RF and with DFCs scale I would place it in category 2. We are working on improving matters.

I think this is a very positive move - I believe we should all embrace these changes as a chance for us all to step our game up - it wont change the feeling the student will get doing tailwheel conversion at a grass airfield - But it will help ensure the training they receive will be well thought out and planned and that all the instructors at the same school are all teaching the same procedures. Surely thats a good thing?

[Mickey Kaye]

I’m a little sceptical as I believe it’s the professionalism of the instructor (and the boss) that determines the standard of instruction and that has nothing to do with it being a RF or an FTO.

Looking at the comments made on not teaching sort field take offs/leaning/alternator failure etc I can’t see for one second how the changes that are coming will address any of those points made.

What does concern me is history and when they forced MEP training to be conducted at FTOs it in my opinion did nothing for the standard of MEP training. All it did was increase costs and reduced availability.

[Whopity]

I chose the FTO (Aeros @ gloucester) because I felt that I was paying for quality training with people who cared about the standard I achieved.

For the purpose of PPL Training you will find that Aeros is a Registered Facility. The FTO covers the professional training that they do and uses different instructors. So what you are really saying is that all RFs are not the same, but then neither are FTOs!

All JAA PPL training conducted in the USA is at an approved FTO where the standard may be well below the standard at many RFs!

[FormationFlyer]

Whopity - you are quite correct.

Mickey - The current EASA proposal would mean that each exercise would need to be ticked off/signed as complete by an instructor. Additionally it is a requirement that the emergencies are listed separately and prominently and signed against when taught.

To sign to say an exercise was taught when it in fact was not becomes a matter for inspection of the organisation - for instance if I should see an exercise/emergency has been taught in the progress records you would to expect to find this mentioned in the student's record for a specific flight. So there would be a cross-reference. Additionally as these records are requirements to fill them in with the intent to deceive would be falsification - indeed one might suggest that during an inspection such falsification was intended to ensure continuation of the organisation's approval - a matter which I understand is illegal.

Perhaps I have mis-read something or misunderstand the way FTOs operate now. Perhaps I am just way too optimistic that the customer might just actually get what they paid for!

Judging by the quality of FIs 'presentations' at a recent seminar I would suggest we (as a body of professionals) are in dire straits. What else could be done to improve standards?

[Mickey Kaye]

Which i suppose is one of the things I'm skeptical about. As I can't see how a load of boxes being ticked makes standards any better.

Shouldn't the examiner ask the student to demonstrate side slipping, leaning etc and if the student meets a standard that the examiner is happy with they pass. If not then they fail.

Having also been to FI seminars I thought they are an utter waste of time and no way did it improve my standard of instruction or a very much suspect the standards of others.

[Whopity]

To sign to say an exercise was taught when it in fact was not becomes a matter for inspection of the organisation

A few years ago a microlight FI went to prison for 6 months when training records were investigated following a fatal crash. The dead pilot was not a student but a qualified pilot and it was deemed a safety record from his training was fraudulent.

[pembroke]

As we move to an ATO structure and the RF is history, how will the CAA/EASA audit these facilities? Most RFs seem to do a good job but the gap has always been the lack of an independent scrutiny to pick up bad practice and poor instruction. At present the CAA would struggle to look at more than a few training facilities each year, and under EASA it would be worse.

[belowradar]

As an independent RF FI and Examiner I see this whole debate as a cultural norm. FAA provides FI's with the qualifications and allows them the freedom to get on with the role that they have trained to do.

JAR/UK CAA Do not as no one individual is trusted with that authority. Individuals are not as trustworthy as Organisations and we don't want individuals to be successful (cultural fact in UK).

British Gas sent me around a chap to fix my boiler who didn't fix it but tried to get me to sign up for a contract that I didn't need, my local CORGI registered independent plumber fixed it quickly and cheaply and told me that no experienced plumber would work for British Gas because they pay peanuts. BIGGER IS NOT ALWAYS BETTER !

We will end up with the same old established monopolies calling the shots and screwing the students for the maximum possible (no cheaper across teh road oh what a surprise !).

EASA are trying to create a sterile standard when in fact what we need is well qualified and passionate instructors who have the confidence, skills, knowledge and authority to get on with the job of teaching. If there is some individuality as to how the required test standards and requirements are met then the marlet place will vote for who does it best and they are the best judges of that.

[proudprivate]

We need better enforcement and less regulation

I see this whole debate as a cultural norm

This is very much true. Bigger is certainly not always better. What I've witnessed thus far in the training scene is that bigger is more expensive. Quality-wise a bigger organisation is better equipped at eliminating buckaroo instructors. However, I think the participants in this debate underestimate the abilities of the flight student in assessing sub-standard teaching. Also, a CAA presently has wide authorities to curb sub-standard teaching.

Referring to DFC :

There is nothing in the proposed system that prevents an individual from setting up business as a flight instructor or doing it for free if they choose.

All that it does is lay down minimum standards that any legal entity providing training etc has to meet. The requirements for providing say Groundschool is the same for an individual as for Big Airline Training Ltd.

You may feel that the individual is at a disadvantage in such a situation. However, as many sole traders will point out, being small has it's advantages.

Please refer to the economic aspect of the matter : all this is creating a barrier of entry, discouraging competition in FI community. My premise is that the additional regulations mainly lead to increased administrative burdens, adding very little to safety or instruction quality.

All the safety concerns mentioned by FormationFlyer could easily be addressed at an FI renewal or recurrency check. Some of them (such as operating a training aircraft outside its W&B envelope) can be caught straight away. A simple rampcheck followed by an enforcement action by the CAA suspending flight priviledges for the FI for 3-6 months would suffice. No need for 300 pages of additional regulation.

Getting the syllabus done can be monitored by reviewing the student pilot's logbook and trusting the student pilot to be sufficiently proactive to get what she paid for.

By insisting on extensive record keeping, you are forcing students to pay for £ 40 - £ 100 / hour people to perform clerical duties without adding to safety or instruction quality.

As some community member remarked, it will just

...increase costs and reduce[d] availability

I think we are all passionate about our flying.

Me? Im passionate about flying. I want everyone to have the highest quality of training. I dont want accidents, and I don't want to meet the idiot fiddling with his GPS because he wasnt taught properly a) how to navigate b) how to properly fly with a GPS - and Ive come close enough to being hit by other people and their pointy bits to be concerned.

I don't think incident or accident avoidance is going to decrease by increasing administrative burdens, unless of course the aim of the EASA proposal is to reduce or remove general aviation altogether.

Perhaps you could take the time to read the proposals and then you will see that it is possible to teach (and be paid) with only a PPL.

Actually I'm concerned about this aspect of the proposal. Whilst I don't think administrative hurdles will help, I do think a flight instructor should be a very experienced pilot, holding at least commercial flight privileges. It is a simple matter of "being sufficiently ahead" of the student, who might have questions that go well beyond the issues needed to pass the flight test(s) and practice her hobby safely.

My bottom line is this :
Does the FI have to be very competent and do we have to weed out the cowboys ? Of course we do. But we shouldn't use this as an excuse to create oligopolies of flight instruction that harm the customer base and the general aviation community as a whole.

[BillieBob]

As we move to an ATO structure and the RF is history, how will the CAA/EASA audit these facilities?

The CAA will be forced to employ sufficient inspectors to audit every ATO at least every two years - the minimum required by EU law. Of course, the costs of this extra manpower will be passed on to the organisations in increased approval fees, which will be passed on, in turn, by the approved organisation in higher costs to its customers. As with everything else to do with EASA, you and I will pay.

[DFC]

belowradar,

I can't see anything the the changes that will change your situation - you can move from being a stand-alone RTF to an ATO.


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Please refer to the economic aspect of the matter : all this is creating a barrier of entry, discouraging competition in FI community.

Does the regulation of Airlines discourage competition in the Pilot community or act as a barrier of entry?

By insisting on extensive record keeping, you are forcing students to pay for £ 40 - £ 100 / hour people to perform clerical duties without adding to safety or instruction quality.

So are you proposing that;

You should be able to work as an FI and simply keep the student progress records in your head?

What if they decide to change schools?

How do you back-up your statement to the student that they need to perhaps think about making Sailing their hobby rather than flying?

How do you stand up in court and tell the Judge that you did train that dead student to the required standard and not only that, the student agreed with that every time they countersigned the training record - a record that you don't have?

As I have said many times before, good training providers be they individuals or large international companies will have no problem with this.

The standard of instruction will not change and nor is this process designed to change it. Seminars are not there to check competencies. They are there to provide a forum for information and collective learning.

What causes good instruction standards are good training providers providing good instructor courses and other training providers insisting on good standards of instruction from the instructors they employ - and not being afraid to show the under performers the door.

[mrmum]

Benefits of making RFs become ATOs

DFC

Whilst a large amount of what you've said in this thread sounds reasonable, I agree that we should provide a thorough, professional service to our customers (students). We should indeed do proper briefings, not chop bits out of the syllabus to keep the hours (cost) down and keep proper records. You are also correct, that these days we all have to have an eye on any potential future litigation and make sure we have ourselves covered.

However, I can't see why, if there is a perceived problem, this cannot or has not been achieved under the current system. The CAA has the ability to regulate what RFs (and FTOs) are doing now if they wish to, they just seem not to very much. Even if they choose not to inspect, all FIs are tested every 3 years (or 6 with seminar) and FEs every 3 years. How often have you seen anyone not pass a revalidation or renewal? This could also be a good opportunity to check what kind of records the FI/FE keeps, I've never been asked in 18 years.

There is also the skill test, if candidates are not being taught the syllabus properly, then this is where it should be picked up. However, from what I see, there are perhaps too many FEs doing too few tests each, to get much in the way of standardisation. 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.

The standard of instruction will not change and nor is this process designed to change it

Well what exactly is the point then? As with everything that has come from EASA, it is just an increase in administrative bureaucracy and cost for no safety benefit. You just need to take a look at what they did to light aircraft maintenance, huge increases in cost and paperwork, but do we get a better job done on our aircraft? No. In fact, I can't think of one single thing, that EASA has done that has been a positive or beneficial change.

[belowradar]

DFC You are correct I can register as an FTO however I will now have to pay an annual fee to be inspected and to register so these new and in my opinion unnecessary costs must be passed along.

I now also have an increased admin burden as well (above and beyond the normal maintenance of flight training records). This makes it harder to provide a straight forward, personal service at reasonable cost.

I did not need to do this previously and there have been no problems or issues so why should I pay some eurocrat money to come along and inspect my training records to see if I ticked the correct boxes ?

[BillieBob]

I will now have to pay an annual fee to be inspected and to register

You already have to pay an annual fee to register, it will just be a little bit bigger.

[proudprivate]

So are you proposing that;

You should be able to work as an FI and simply keep the student progress records in your head?

What if they decide to change schools?

You're starting from the premise that a "school" is a necessity. FAA Part 61 training doesn't necessitate a "school"-concept per se. In previous posts, you've referred to this dismissively as "training from the boot of a car". I have had an excellent experience with an individual flight instructor : as he took a limited amount of students at a time, a simple log book entry and the odd take home sheet largely sufficed as "record keeping".

I've received instruction from 6 different instructors throughout my aviation training thus far. Never a problem. You're telling the instructor where you are and what you still need to do. Each of the instructors was able to spots shortcomings that I hadn't realised and allowed me to improve on them, on top of the topics I explicitly mentioned. No filekeeping could have improved that. Was I taught out of the boot of a car ?

How do you back-up your statement to the student that they need to perhaps think about making Sailing their hobby rather than flying?

That must be a rare condition. A willing student, eager to take up skills, even if gifted with only moderate cognitive abilities should be able to complete the first stages of an aviation career succesfully.

Possible exceptions are : students unwilling to adhere to strict safety standards, or students too dumb to realise their own arse is on fire. Neither of them should be sent on a sailing course, btw. But surely a flight instructor is under no obligation to continue the flight training in these cases? Again, I doubt very much that an obligation to keep lengthy records is going to be of help here. Just a matter of curtiously stating the truth.

How do you stand up in court and tell the Judge that you did train that dead student to the required standard and not only that, the student agreed with that every time they countersigned the training record - a record that you don't have?

The logbook entries normally would show the student's progress. It would also show under which conditions the student is deemed to fly solo. I also doubt that excessive litigation needs to be curbed through compulsory administrative burdens.

As I have said many times before, good training providers be they individuals or large international companies will have no problem with this.

They will if the inspection fees and administrative burdens go up so much that an individual cannot afford to take on a couple of students per year, as many part-time instructors do.

Does the regulation of Airlines discourage competition in the Pilot community or act as a barrier of entry?

To a certain extent, it does. It makes it a lot harder for a small company to operate an air charter. That is why it is extremely important to weigh the necessity of each regulation as a barrier to entry against the benefits for the consumers.

In the case of flight instruction, it is clearly a barrier to entry that brings very little benefit to the consumer. That FAA part 61 instruction works well in the United States proves this fact. EASA, an organisation that is overlobbied both the maintenance industry and flight schools and pressured by individual member states with vested interests, clearly overlooks this matter.