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"Introductory Flights"

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Old 7th Apr 2018, 09:58
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"Introductory Flights"

Does anyone know if "introductory flights" carried out by (non-FI) PPLs as defined by CAA IN-2015/029 can be conducted by RFs / DTOs or are these only the province of full-fledged ATOs and / or non-commercial clubs?

I've seen some intro flights being done by a PPL holder at an RF - is that legal? The IN says ATO - is that interpreted literally by the authorities or do they mean "a legitimately established flying school"?
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Old 7th Apr 2018, 11:49
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I'm not sure but I've seen it carried out in the past illegally by a school who did trial flights as 50-60% of their total flying and at weekends 90% and had ppl's doing them which was clearly against the rules saying that it could only be done if it wasn't a major part of the business. Another nail in the coffin of the job of an FI..
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Old 7th Apr 2018, 17:53
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Article 2 of Regulation (EU) No. 965/2012, as amended by Regulation (EU) No. 379/2014, states that:
'Introductory flight' means any flight against remuneration or other valuable consideration consisting of an air tour of short duration, offered by an approved training organisation or an organisation created with the aim of promoting aerial sport or leisure aviation, for the purpose of attracting new trainees or new members.’
Approved Training Organisation = ATO or possibly TRTO
RFs are not approved under any current legislation and never have been.
DTOs don't exist yet.
An Organisation set up for the purpose of promoting sport or leisure aviation would need to be recognised as such.

Unfortunately, IN 2015-029 is a confusing muddle as it has combined Introductory Flights and Cost Sharing, which are two totally different concepts, in the same document.
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Old 7th Apr 2018, 23:11
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An introductory flight may be conducted by any organisation 'created with the aim of promoting aerial sport or leisure aviation'. How many Registered Facilities do not promote leisure aviation? Of course an RF may conduct introductory flights, which is more than can be said for a TRTO, whatever that is!

As for the 'marginal activity' clause and, for that matter, the 'no sharing of profits outside the organisation' requirement, I am told that the CAA are of the opinion that these are so badly drafted by EASA that they are unenforceable in law and that they are, therefore, forced to turn a blind eye. I'm aware of a couple of RFs (and voucher companies) that are making a small fortune as a result, along with some LAPL and PPL holders who are building loads of hours for free.
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Old 8th Apr 2018, 11:41
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RFs are not approved under any current legislation and never have been
As defined approved is used to refer to something that is generally or officially accepted as being correct or satisfactory. One was required to apply to become an RTF and those now registered had their applications accepted, or otherwise approved by an authority.

....offered by an approved training organisation or an organisation created with the aim of promoting aerial sport or leisure aviation, for the purpose of attracting new trainees or new members.
An Approved Training Organisation is a proper noun. An approved training organisation (without capitals) has the meaning of a training organisation that is approved. Had the author of the text meant an ATO he or she should have used a proper noun to make the distinction. Further, by highlighting other types of organisations that qualify, the writer endorses the view that the word organisation is being used in a general sense.


...that the CAA are of the opinion that these are so badly drafted by EASA that they are unenforceable in law...
Yep!
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Old 8th Apr 2018, 11:59
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One was required to apply to become an RTF and those now registered had their applications accepted, or otherwise approved by an authority.
There was no application involved, it was simply registration, a notification. There was no process of acceptance or approval, just a confirmation of registration, The CAA at one point didn't even know who was registered and had to write to those "responsible persons" who had originally registered, to see if they were still in existence.
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Old 8th Apr 2018, 12:17
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I stand corrected! Nevertheless I still hold the view that RTF's are in one way or another approved by the CAA. Why else would the CAA publish a list of such training facilities for the benefit of the general public.
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Old 8th Apr 2018, 13:11
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From the JAA Registration Requirements:
Upon receipt of the completed application form the Authority of the JAA Member State in which the
facility is located will register the facility to conduct PPL training within that State, without formal approval procedure,
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Old 9th Apr 2018, 16:51
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Thanks for your input everyone. Confusingly it appears that the EASA regulation refers to "approved training organisations", the CAA IN refers to "Approved Training Organisations".

A commercial RTF (ie one run with the intention of making a profit, as opposed to being a genuine members club) wouldn't meet the definition of an organisation "created with the aim of promoting aerial sport or leisure aviation".

Looks like a mess to me.

Last edited by this is my username; 9th Apr 2018 at 17:57.
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Old 11th Apr 2018, 13:47
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Another issue here is one of 'customer expectation' - it's one thing using hour-building PPL holders (who are not FIs) to conduct introductory flights - this to primarily to keep the costs down, let's be honest - but if the customer's expectation is that they will at least get some basic instruction and hands-on experience during the flight (as per Ex 3) and they get neither, they'll be sorely disappointed! This has happened in my experience - it's important to establish exactly what the customer wants before the flight and resource it accordingly.

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Old 11th Apr 2018, 19:05
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it's important to establish exactly what the customer wants before the flight and resource it accordingly
The purpose of an Introductory Flight is to allow an organisation to attract new members by giving a prospective new member a taste of the organisations activities. The person receiving the flight is not a customer as such and should have no expectations of being allowed to take control or to influence the content of the flight in any way.

The UK CAA has relinquished its duty of care detailed in GM1 ARO.OPS.300 to regulate such activity, wheras the DGAC in France has taken the matter seriously and laid down quite stringent requirements to ensure the safety of those carried.
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Old 11th Apr 2018, 19:50
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The originator of this thread provides a link in their first post for the CAA IN-2015/029 but no one seems to have read it fully.

There are no flying groups or organisations prescribed from taking advantage of the rule and this is made absolutely clear within the IN and including the FAQ and guidance section. The aircraft that may be used is also made simply very clear.

The flight must be non-profit making. Although the CAA seek to explain what this means this is not so straight forward as they wish it to be. On the one hand they say that the cost of renting an aircraft may be included in the basic cost and shared (no element of profit), but on the other hand they say the annual operating costs cannot be included; "keeping, maintaining and operating the aircraft over a period of one calendar year", all of which, it must be obvious, will be included in a rental charge

There are a number of non-profit groups and organisations that specialise in aerobatics, classic and vintage aircraft and other specialised activities that do not provide for licensing training but are always seeking new members to assist in all sorts of ways as well as flying. This rule change is of particular interest to them.

A flying club that normally conducts flying training should be very careful for two reasons. Flying training will normally amount to in excess of 50% of flying and costs will be very complex including annual costs not only of flying but also buildings, finance and administration.
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Old 12th Apr 2018, 07:47
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Fl1ingfrog

You're getting mixed up with the cost sharing rules.

For Introductory Flights the aircraft only has to be owned by the organisation or dry leased. There are no cost restraints.

Although we have never carried out these flights and will not do so without using an instructor, I'm sure this would be one example where the CAA would deem an RF to be an ATO for the purpose.
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Old 12th Apr 2018, 08:03
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There are no cost restraints.
No but there are proffit restraints:
‘An ‘organisation created with the aim of promoting aerial sport or leisure aviation’ means a non-profit organisation, established under applicable national law for the sole purpose of gathering persons sharing the same interest in general aviation to fly for pleasure or to conduct parachute jumping. The organisation should have aircraft available.’
and activity restraints:
‘The term ‘marginal activity’ should be understood as representing a very minor part of the overall activity of an organisation, mainly for the purpose of promoting itself or attracting new students or members. An organisation intending to offer such flights as regular business activity is not considered to meet the condition of marginal activity. Also, flights organised with the sole intent to generate income for the organisation are not considered to be a marginal activity.’
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Old 16th Apr 2018, 19:55
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Whopity,

That is simply a statement of the CAA's understanding, or what they may want it to mean. I doubt if their enforcement branch would want to test a prosecution on such poorly worded legislation.

‘An ‘organisation created with the aim of promoting aerial sport or leisure aviation’ means a non-profit organisation
No it doesn't....it means exactly what it stated. An organization created with the aim of promoting aerial sport or leisure aviation. There is no mention of the word profit!

Last edited by deefer dog; 16th Apr 2018 at 20:00. Reason: added text
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Old 16th Apr 2018, 20:01
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Their enforcement branch have no interest in it at all. One high profile accident and it will bite them in the bum! My quotes were direct from GM2 Article 6.4a(a);(b) of the Operations Regulation.
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Old 17th Apr 2018, 14:29
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Just in... Introductory flights | UK Civil Aviation Authority

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Old 20th Apr 2018, 19:32
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I love language, Introductory flight, Air experience flight (what's the difference?), Trial lesson.
So a Introductory flight is one where you trust the reputation of your company to use a PPL to fly a stranger and hope they might come back and learn.
Air experience, much the same thing but perhaps a term nicked from the RAF when cadets were taken up for ten minute ride and shown some basic aeros to try engendered some interest to join the air force, and fill a sick bag.
And Trial lesson, advertise a one hour lesson and only fly 20 minutes, to look competitive to the school down the road that gives a full hours flying, for twice the price and of course pay the instructor for the 20 minute flight.
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