Consultation on foreign aircraft

[IO540]

rustle

Maybe someone should ask the Europeans what they perceive the problem to be. It might not be the issue that fresh-minted FAA IRs are not acceptable to the Europeans but that 13 month old self-certified ones aren't. Or that 26 month old self-cert ones aren't. Or that 25 year old non ME tested ones aren't.

Who do you think is a better pilot?

a) One who does 100-200hrs/year IFR and runs on the FAA rolling currency regime, or

b) One who flies 20hrs/year IFR (like an awful lot of CAA/JAA IRs do) keeping to very good weather only, and has an IR checkride every year

A CAA employee would say b) is a better pilot but that is the "ivory tower" mentality, which is IMHO completely wrong.

The JAA IR is so hard to get (in the context of slotting the huge ground school into a normal working person's life) that very few noncommercial people are doing it. So, with the FAA route being preferred to most owners (and being an owner is the only real way to do decent hours) it follows that those that have a valid one are probably low time pilots, so they do need the annual checkride

Of course this kind of reasoning is a world away from the officialdom. The CAA man would just say that a pilot can forge his entire logbook and that an annual checkride is the only way to keep a lid on that. This doesn't seem to be a problem in the USA, however, where 75% of the world's GA lives (source: recent EASA report). Very very occassionally they uncover some logging irregularity but it is very rare to conclude that this was possibly a factor in some incident.

Most FAA IR pilots I know do loads of hours; more than I do. Some do 500hrs/year (in TB20s and such). This is not mirrored, by a long way, by JAA IR holders that I know of.

[slim_slag]

rustle,

I suppose my response would be that if there was a safety based case for regular reviews of IR holders then the FAA would mandate it. After all, they do this with a BFR, so they understand the concept, it's not just a CAA/JAA thing.

The significant departure from the CAA approach is that once you have got your IR the FAA consider you competent and responsible until proven otherwise, whereas the CAA don't,

[rustle]

IO, there's no point having a go at me - I don't make the rules up I just live with(in) them and all I am trying to do is broaden the discussion about this from the idiotic "747s into Heathrow" level to a slightly more realistic "well there must be something they [Europeans] don't like, so let's try and see what that might be"

I don't care who's more likely to be current, who's the better pilot, who has the most hours per annum etc.

I was attempting to have a discussion about why JAA/EASA might have taken the view they have. Jesus we've all heard a billion times why you think they've taken the line they have

You know why stupid sayings about "second engine takes you to the scene of the crash" come about? They come about through misinformation. They come about through the same tired, worn-out BS that gets trotted out every time someone says anything about twins/MEP.

It's the same with the tired BS about 747s into Heathrow. Every time someone wants to have a discussion about instrument ratings someone starts with the "well it's good enough to fly 747s into [JFK/HRW/LAX/WANK]" and I, personally, don't think that moves the discussion forwards very much.

But hey, what do I know. (Well I do know that if the rules said I need a Martian IR to fly on Mars I'd make time to get a Martian IR if I lived on Mars and wanted to fly on Mars; but that's just me)

If that is seen as an "attack on" or "devaluation of" or [insert paranoid view of life here against] FAA IRs or similar by people (as some moron on Flyer seems to keep harping on about) then that's more a reflection on them than me. IMHO of course.

[rustle]

Originally Posted by slim_slag

rustle,

I suppose my response would be that if there was a safety based case for regular reviews of IR holders then the FAA would mandate it. After all, they do this with a BFR, so they understand the concept, it's not just a CAA/JAA thing.

The significant departure from the CAA approach is that once you have got your IR the FAA consider you competent and responsible until proven otherwise, whereas the CAA don't,

In relation to MEP retesting I believe there is a safety case and I believe it can be found in the NTSB records. However I also believe that the lobbying against any such move (against private pilots) would be significant and ultimately successful, so the FAA don't pursue it. A bit like the lobbying by the NRA if someone threatened to take away guns.

As for the CAA/JAA/EASA attitude to retesting -vs- pilot self-certifying my own view is that both have inherent weaknesses (self-certifying can be practising bad habits without anyone to pull them up on it (no asymmetric esp.) -vs- retesting could be minimal hours p.a. etc.)

I do think though that the long-term difference between the two (FAA/JAA) are more pronounced than the immediate "on qualification" differences, especially in relation to MEP ops, and that the Europeans will stick to their guns [no pun intended ] unless it can be shown that isn't an issue.

If FAA IR holders were granted JAA IRs but then had to re-validate their JAA IRs in line with JAA requirements would that still be a huge problem? (Obviously to maintain your FAA validation you'd have to do whatever the FAA require, but apparently that already happens so the only addition would be the annual retest. In a MEP if you want MEP IR privs.)

[mm_flynn]

Originally Posted by rustle

"well there must be something they [Europeans] don't like, so let's try and see what that might be"

I think the candidates from the rumour mill are

1. The self certification of the FAA is a problem
2. FAA/IR flying requirements are not sufficient
3. The lack of NDB holding expertise in the FAA programme is a concern
4. There is a fundamental cultural difference in qualifications where Europe is based on Apprenticeship formal coursework and extensive examination and America is based on demonstrated competence
5. The weather is more difficult here (or maybe data is less readily available)
6. IR flying really needs to be done by people with 'Jet Type Rating' knowledge
7. The ATC infrastructure can't support a significant amount of GA getting enroute services
8. The fact that most PPL/IRs are probably in sub 2 tonnes means they aren't paying for the service so shouldn't be allowed
9. It is a club with an initiation process and we (club members) don't want to change it
10. The FAA way wasn't invented over here so isn't good enough

Some of these are clearly , some would never be admitted to, some might be true. Anyone with contacts, knowledge, or ideas of how to move from idle speculation to some knowledge?

[IO540]

rustle

I was attempting to have a discussion about why JAA/EASA might have taken the view they have

I agree with your objective.

The basic problem is that we have no idea where this "view" comes from, or even whether it is anybody's view at all. We don't know that JAA or EASA has actually taken any view whatsoever.

These organisations have various spokespersons which emit press statements fairly randomly. Some more credible than others, according to who it is. But by the time we get to hear about it, the credibility (in the sense of whether it is official policy, or any policy at all) cannot be established.

Example: an EASA man went public a few months ago, saying their long term objective was to accept FAA IRs as a straight swap for JAA IRs. Very sensible and amazingly progressive (without details, hard to say more) but sure to make any old-style Brit or German revolve in his grave at 2400RPM. I mean, if they accepted FAA certification as well, and there were no silly details (like charging £5000 for a new G-reg CofA, and CAA-style placarding of an IFR GPS with an "enroute only" sticker) the N-reg scene would dry up very fast indeed.

There are loads of silly statements going around. I went to a NATS presentation a while ago, and they announced that the CAA is going to ban all single-pilot jet flights in UK airspace. The ATCO clearly thought this was a good idea. Presumably this originated inside the CAA, but which bit? It may have been a private CAA view, or something said at a CAA briefing to NATS. Anybody with a brain (and most CAA people are individually quite competent) knows this is plain silly. It would exclude most Cessna Citations from UK airspace, for starters. (It was made in the context of scare stories about "hundreds" of these new fangled "light jets" clogging up UK airspace). In the same context, Germany made a similar "proposal" this year to require an ATPL for all jets in German airspace

Blatent anti-FAA prejudices are everywhere. Get almost any CAA or NATS or DfT man talking and you'll get enough to fill your bag. Thankfully, they never get very far because at some stage somebody who knows the international picture, and the politics of doing it, looks at them and quietly chucks them out. Like has happened with the latest DfT kick-out-N-reg proposal. On the face of it that was totally barmy from day 1, but it travelled a suprisingly long way.

If FAA IR holders were granted JAA IRs but then had to re-validate their JAA IRs in line with JAA requirements would that still be a huge problem?

Probably not.

But this kind of stuff (basically, EASA taking over FCL totally) is so far down the road that this sort of discussion is IMHO pointless.

[Fuji Abound]

Rustle

I don’t know the FAA position on multi renewals. I assume form your post they are something other than our annual revalidation?

If this is so, then it would be interesting to know the regime in which this works. In the UK asy currency is discouraged (strongly) without an instructor. The annual revalidation provides a good opportunity for some refresher training, and is probably about the right length of time to ensure all pilots have a reasonable chance of surviving an engine out. Self certification would clearly not work because pilots are not self reviewing asy procedures, and two years is almost certainly too long.

The analogy is instrument ops. Self certification is all very well but for those pilots that only just meet the minimum requirements the number of approaches flown are pitifully few, and there is no requirement on their part to self certify abnormal ops. even if it were safe, sensible or possible for them to do so without an instructor on board. How many accidents could be avoided by insisting on an annual revalidation I wonder? Reading the FAA reports there would seem to be little doubt there are a fair few accidents in IMC that are almost certainly only attributable to the skill failure of the pilot, in circumstances that you would expect an average instrument rated pilot to have avoided the problem. Would his chances have improved if the State had insisted on an annual check of competence?

Cynically, I suppose it boils down to the States right to impose itself on your right to kill yourself! I know one could argue that the State also has a right to protect the GP and any passengers the pilot might have with him. I cant remember the last time I read an incident report in the States where a pilot came down in instrument conditions and killed anyone, however there are a fair few cases where the passengers didn’t do too well.

Of course in the States the other factor has increasingly become the influence insurers are having.
Here, a ticket from the regulatory authority is almost always enough to get insured to do what it says on the pack, and moreover additional training doesn’t have much effect on the premiums. In the States insurers are increasingly requiring pilots to undertake ongoing currency reviews in order to obtain insurance (or obtain insurance at a sensible cost) on anything more complex or with two engines. This framework presumably does not exist in Europe because insurers do not load FAA IR premiums because they assume an FAA IR pilot is every bit as competent as his UK counterpart even though he might be self certifying his competency.

I would agree that comparing any of this with commercial pilots operating on an FAA ticket or any other ticket for that matter is totally irrelevant. There are very few similarities between the highly controlled environment in which commercial pilots operate and the average “amateur”.

I would have thought there might be one other vital difference between Europe and the States. IR tickets in the States are common, and so are the aircraft in which to use them in earnest. This obviously can result in some IR ticketed pilots meeting the minimium requirements (or certainly before the insurers got more involved) and flying in conditions in which they had no business to be. On the other hand most IR pilots in Europe of whatever complexion have made a serious committment to operate in these conditions because of the additional cost involved. Once again other factors may be operating which might just mean European FAA IR pilots are doing a better job that American FAA IR holders?

[IO540]

Fuji

a fair few accidents in IMC that are almost certainly only attributable to the skill failure of the pilot, in circumstances that you would expect an average instrument rated pilot to have avoided the problem

Isn't that true for 99% of crashes (mechanical failure excluded)?

One could make a very long list of airliner crashes which were caused by mistakes so stupid that nobody should have made them.

Like that Boeing 757 which ditched (drowning everybody) because somebody taped over the static vents, and in which neither pilot seemed to know the most basic things about the pitot static system. Two very current ATPs flying that one.

[Fuji Abound]

Isn't that true for 99% of crashes (mechanical failure excluded)?

It is, but as you know what I was trying to get at is at what point does recurrency training avoid one or two or more of these accidents?

I dont profess to know the answer. Nor have I ever been convinced the periods chosen here or there are based on any hard evidence.

What I do know from flying with other pilots is many are poor at practising abnormal ops. In my opinion the right balance of recurrency training should help avoid some of these accidents.

[rustle]

Originally Posted by Fuji Abound

Rustle

I don’t know the FAA position on multi renewals. I assume form your post they are something other than our annual revalidation?

If this is so, then it would be interesting to know the regime in which this works. In the UK asy currency is discouraged (strongly) without an instructor. The annual revalidation provides a good opportunity for some refresher training, and is probably about the right length of time to ensure all pilots have a reasonable chance of surviving an engine out. Self certification would clearly not work because pilots are not self reviewing asy procedures, and two years is almost certainly too long.

For the avoidance of any doubt, if you gain an FAA multi rating (or whatever it is called) you might never ever be re-tested in asymmetric flight ever again; even if you were tested on asymmetric for initial issue.

Ditto an FAA IR on a multi (I don't believe there is actually such a beast, AFAIK the IR applies to whatever you are allowed to fly) - through self-cert you will never be re-tested asymmetric, and even if you forget to self-cert and need a flight test to regain IR rights you could do that in a SEP (cheaper) then jump back in a MEP as an IR. (Obviously a JAA IR doesn't work like that as if you want MEP IR rights you have to be examined in a MEP. ME-IR is valid in a SEP in JAA land)

Ironic that the "second engine takes you to the scene of the crash" tag-line started in the US.

[421C]

Originally Posted by rustle

Maybe someone should ask the Europeans what they perceive the problem to be.

It might not be the issue that fresh-minted FAA IRs are not acceptable to the Europeans but that 13 month old self-certified ones aren't. Or that 26 month old self-cert ones aren't. Or that 25 year old non ME tested ones aren't.

That's a significant departure from the CAA/JAA requirements of annual retests (including asymmetric in the case of ME). A far more significant departure than the flying standard required in the IRT...

In that case, why don't they accept the FAA IR training regime or convert FAA IRs to JAA IRs and then impose the recurrent training standards?

The GA objections to JAR-FCL are little to do with either the IRT standard or the renewal requirements. It's all the bureaucracy and micro-regulation of the training process and FTOs that imposes cost and makes it impractical for people who aren't full-time airline cadets.

Personally, I don't believe it's anything to do with GA safety. Developing JAR-FCL was a time, resource and politically constrained process with one overriding priority - creating a 250hr Frozen ATPL training regime acceptable to both the airlines and the regulators. The advanced training needs of GA didn't get a look in.

[youngskywalker]

What an enormous amount of 'bs' is spouted on this web site and around flying schools in the UK regarding the ongoing JAA is better than FAA crap...those who critisize the FAA system the most seem to be those who have no knowledge whatsover of how things are done in FAA land. Neither JAA or FAA systems are perfect, perhaps a new one that took the best of both and combined them would be the answer?! Incidentaly there is such a thing as an FAA multi IR, I did both my CPL and IR on a twin and consequently I have no single engine licence whatsoever. (If an FAA pilot passes the IR on a single then they must do another IR flight test on a multi, albeit all you have to demonstrate is a single engine approach.) Also I am made to demonstrate my ability to handle and engine out on every BFR and IPC. So far I havn't yet managed to kill myself, although I admit now that I'm flying in Britain the weather is so much more difficult and of course tracking VOR's/NDB's is almost beyond my IR and god forbid I try and fly an ILS!!
For me gentlemen, time is running out

Edited to agree with the next post, I would have no problem accepting the same revalidation as the JAA IR. Like I said neither system is without flaws. We all share one thing in common and that is we love to fly, perhaps we could all work together and respect each others licences and ratings for the personal achievements they are. It's hard sometimes stay quiet when you perceive that some people de-value the licence you worked so hard to achieve.

[Fuji Abound]

I think some may be missing the point.

I dont think this thread has become is FAA anything better than JAA anything.

I would hope it is a more mature expression of opinion by those on both sides of the fence (or even those with a foot in both sides) about the pros and cons of each system and whether given these pros and cons there is any justification what so ever for the comments made at the start of this thread.

In short (and leaving completely aside whether or not the initial FAA or JAA IR training is better or more relevant)

1. Is it a good thing or a bad thing that IR pilots can self certify?

2. Are there features of the way FAA IR pilots operate in Europe or America (such as perhaps the requirment of insurance companies that I mentioned or the type of pilot that we see with an FAA IR in Europe) that makes one different from the other?

3. Is it satisfactory that an IR pilot should never have to revalidate his rating or is the instrument review every two years sufficient?

I think it is the answer to these questions which would give an insight into whether or not the greater revalidation that goes on in Europe is justified or as some would say complete BS! I think unless these questions can be answered the regulator may have an arguement that whilst both are ICAO compliant ratings, the recurrent training of each is sufficient to justify the opinion expressed. (and I suspect the vast majority would accept that the easy solution would be to recognise the FAA IR but require the same re-current training as that required for a European IR).

I think that was the issue Rustle may have had in mind.

[421C]

1. Is it a good thing or a bad thing that IR pilots can self certify?

Yes it is a good thing on 2 grounds (although I would not call it self-certification. It is an absence of a renewal requirement for pilots who maintain IFR currency).
Firstly, because it is part of a safety philosophy in which pilots are personally accountable, rather than a philosphy of forms, processes, rules and micro-managing regulators being accountable. It is a philosophy that does not automatically equate more rules and requirements with more safety. I can't find a way of not making this sound patronising, please forgive me, but I sometimes think that in Europe we are so indoctrinated with the idea that safety must be imposed by regulations that the idea of "self-certification" sounds intrisically dangerous. Secondly, it is a good thing (which we don't have to debate from first principles) because a giant controlled experiment which has been running for 10 years (since the start of JAR-FCL) on either side of the atlantic suggests it is. The US GA accident rate is as good as the best European countries. Owner-flown business GA (mainly by self-certifying IFR pilots) has an accident rate 4 times better than Personal/Recreational GA and thus, approx, 4 times better than the best European GA.

2. Are there features of the way FAA IR pilots operate in Europe or America (such as perhaps the requirment of insurance companies that I mentioned or the type of pilot that we see with an FAA IR in Europe) that makes one different from the other?

I don't think so. Firstly, AOPA US will tell you that the majority of US PPL-IRs are not current - they do the rating and then lapse. The typical active PPL-IR in the US is probably not very different from the European based FAA PPL-IRs, especially in recent years when it has become more common in the UK for lower time, "lighter" aircraft PPLs to go the FAA route.

On the insurance point, the FAA IR actually gets you a discount in the US. It's aircraft types (retractables, advanced twins) that have more onerous insurance requirements.

3. Is it satisfactory that an IR pilot should never have to revalidate his rating or is the instrument review every two years sufficient?

I stand by my earlier comment that the safety record of the US, in which a single county in Florida or California probably has more PPL-IRs than the whole of the UK, speaks for itself.

the recurrent training of each is sufficient to justify the opinion expressed. (and I suspect the vast majority would accept that the easy solution would be to recognise the FAA IR but require the same re-current training as that required for a European IR).

I think that was the issue Rustle may have had in mind

I am not sure why the debate has got so focused on the recurrent stuff when the entire GA history of opposition to the JAA IR, and every reason I have heard for a European pilot to go the FAA route, is based on the excessive initial training requirements, in particular for theoretical knowledge. Equally, it is these initial training requirements that the JAA refuses to relent on, including recent occassions when the whole topic was reviewed with representatives from flight training organisations. Despite Rustle's concern of "misinformation" on the comparison with FAA Airline captains flying into Heathrow, the fact is that the major, substantive points (eg. how training is conducted and the requirements to take a theory or flight test) that lead Europeans to use the FAA system are common to FAA PPL IRs and ATPLs.

[englishal]

Everybody has, and is entitled to their own views. What worries me is that some of the people in charge of making legislation are not educated very well in the matters they are legislating against.

There is not one iota of evidence which suggests that an annual review makes things safer.......

For the record, I do an FAA IPC every two years, despite being legally current, primarily to get my IMC revalidated as the CAA recognise this as a "TEST", and also becasue I don't want to kill myself. My choice you see, I am old enough and have enough common sense to make these critical decisions myself. I'm going to do one in a few week, in a MEP.

Also, regarding the MEP rating in the USA, it is very doubtful that you will be able to rent a twin unless you have 100's of hours ME time (unlike the UK), so this is a form of self regulation. If you are well off enough to own a twin, it is likely you will actually fly it 100's of hours per year anyway (or route sectors or whatever the JAR terminology is).

[slim_slag]

Originally Posted by rustle

In relation to MEP retesting I believe there is a safety case and I believe it can be found in the NTSB records.

Can you provide a link to your specific claim relating to MEP operations?

I've found a NTSB Letter which might be of interest to you.

Given the caveat

The Safety Board emphasizes that the conclusions reached in this study are not based on a summary of accident cases, although the merits of such Board studies have proven valuable in the past. Rather, the results are based on a statistical comparison of accident and nonaccident flights that allows for the generalization of findings from this study to the wider population of GA pilots and flights that may be at risk for a weather related accident.

it does go on to recommend some IR related training be carried out in the BFR.

Add a specific requirement for all pilots who do not receive weatherrelated recurrent training, that the biennial flight review include the following: recognition of critical weather situations from the ground and in flight, procurement and use of aeronautical weather reports and forecasts, determination of fuel requirements, and planning for alternatives if the intended flight cannot be completed or delays are encountered. (A-05-024)

For pilots holding a private, commercial, or airline transport pilot certificate in the airplane category who do not receive recurrent instrument training, add a specific requirement that the biennial flight review include a demonstration of control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, and recovery from unusual flight attitudes. (A-05-025)

So looks like the NTSB are indeed thinking along the lines of requiring a recurrent review of instrument skills. Note they haven't suggested a complete re-test attitude like what might exist elsewhere. As they haven't done so I would assume that the NTSB consider that to be unnecessary. So what you should really be doing is lobbying the CAA/JAA/EASA to remove unneccesarily expensive requirements to your ability to fly IFR.

If you read all the NTSB recommendations through the years then a large number relate to provdiing proper weather briefing and ATC services to GA IFR. It appears that Europe is light years behind the States in this regard, so perhaps the European regulators should prioritise their resources on fixing that.

Originally Posted by rustle

However I also believe that the lobbying against any such move (against private pilots) would be significant and ultimately successful, so the FAA don't pursue it.

That is just showing your prejudices against an extremely well respected and safe regulatory system. AOPA may agressively counter a lot of changes the regulators want to foist on GA, but when it comes to safety they tend to be proactive. What evidence do you have that AOPA would block mandatory instrument flying and weather training in a BFR?

And of course the contents of a BFR is up to the instructor and pilot and supposed to be tailored to the flying the pilot does. There is nothing to prevent flying under the hood in a BFR, and I know it happens.

[IO540]

The CAA could also learn some pretty basic statistical methods from the NTSB - quote:

This study employed the case control methodology, which compared a group of accident flights to a matching group of nonaccident flights to identify patterns of variables that distinguished the two groups from each other. Safety Board air safety investigators (ASI) collected data from 72 GA accidents that occurred in IMC or marginal visual conditions between August 2003 and April 2004.When accidents occurred, study managers also contacted pilots of flights that were operating in the vicinity at the time of those accidents for information about their flight activity. A total of 135 nonaccident flights were included in the study.

[my bold]

[Fuji Abound]

"There is not one iota of evidence which suggests that an annual review makes things safer......."

That has always been my impression.

421C - thank you for a very interesting analysis of the facts.

On one minor point it still seems to me that in the States the insurance companies are having an impact on the job pilots do. On the basis that many of the pilots who fly IFR in the States regularly will do so on more advanced types the recurrence training on which I gather many insurers are insisting is presumably helping pilots to deal with unexpected problems. Moreover does this suggest that on more complex types the insurance companies consider they have evidence to support that pilots who undergo recurrence training are likely to have few accidents or is their some other motivation at work?

Is this considered to be a good thing?

[rustle]

The interesting thing about self regulating through insurance is that whilst that may be the case within the US, it is not the case for an FAA ME pilot outside the US (in the UK for example).

In those cases there is neither the statutory blunt instrument of annual check flights, nor monetary incentive through insurance only being available if current and with 100s of hours on type.

[IO540]

It's changing in the UK.

4 years ago my insurer (Haywards) didn't care whether I had 10hrs+PPL or 1000hrs+CPL/IR. Today they certainly do. At my next renewal I will have 700hrs+CPL/IR and expect to get a nice discount.

It pays to ask your broker; if you don't tell him about your current hours, etc, he will never know.

There is a big story in the USA that fixed gear planes are cheaper to insure, and this has been a big plank in Cirrus/Lancair marketing, but this sure as hell doesn't show up on SR22 premiums versus say TB20 premiums; for the same pilot. One example I saw was 3x less for the TB20.