Commenting on EASA proposals

[chrisN]

Robin, that’s interesting. I was responding about how CAA used to do it (because EASA wasn’t there then), and how they also do it now, of which Mode S is a prime example. And they quote UK government guidelines as the reason for ignoring numbers unless they make different points (not just different “in your own words”).

I wonder if UK will have to follow Europe eventually?

Regards – Chris.

[IO540]

I read somewhere that EASA had not had a great deal of response / comments on these NPA proposals

The other point about the above is that most people will comment only on what directl affects them.

For example, I fly on an FAA CPL/IR and own an N-reg plane. I will therefore comment on the foreign proposal (pages 159-161) and the rest doesn't matter. I never commented on the NPPL because it was never relevant, and since I can renew my old JAA PPL (with a checkride I think) the EASA LPL will be of no relevance to me.

To me, what matters is that pilots are taught what they actually need to know to fly safely and confidently from A to B, and this doesn't happen under the present system, isn't going to happen under the new system, and I don't see any way it will happen short of a drastic overhaul / modernisation of the syllabus (which would be fiercely resisted by the training industry).

The vast majority of people coming into contact with this proposal already hold JAA PPLs (or some other JAA-land ICAO PPL) and they just rent, so it doesn't affect them either.

Which leaves only a few to wade through the 600 pages...

[trevs99uk]

Somebody was asking where the UK IMC was mentioned in the EASA documents see:-
http://www.easa.europa.eu/ws_prod/r/...202008-17a.pdf

Page 29 Subpart I section 48.

[IO540]

Finally, the Agency considers it necessary to refer here to the more general issue of the qualifications required for flying an aircraft in instrument meteorological conditions (IMC).
This issue was raised several times during the development of the implementing rules, both by members of the FCL.001 rulemaking group and by stakeholders contacting the Agency independently. In this context, the most controversial issue was the future of the UK IMC rating, which allows the holder of such a rating to fly in IMC in certain UK airspace categories without having an instrument rating. After discussions with the FCL.001 rulemaking group, the Agency has decided to initiate a new rulemaking task on this issue, which has already been included in the Agency’s Advance Planning 68 and will
be started after the summer. The working group for this task will review the existing instrument rating requirements and the training syllabus of the UK IMC rating.

Yes, this new rulemaking task is what I referred to earlier.

[David Roberts]

This working group is FCL.008 and held its first meeting in Cologne on Friday 12th December. The members of the group are in the pdf document on the EASA website at:
http://easa.europa.eu/ws_prod/r/doc/...omposition.pdf

Feedback I have had from the first meeting, which is really a scoping meeting and first overview of the issues, is 'so far so good'.