EASA threat to operation of N Reg Aircraft
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This does not suprise me.
I never expected the EU Parliament to vote down Part-FCL simply because 90%+ of the MEPs have no idea what it is about, and most of them are a bunch of brown-nosers who represent countries which need wide ranging EU co-operation.
The "interesting" part will be the detail of what happens over the next 2 years.
I posted a link yesterday to another bunch of EASA documents which mentions the 2 year derogation but on a very quick reading it was not clear what this means. Maybe the derogation is EU-wide?
I never expected the EU Parliament to vote down Part-FCL simply because 90%+ of the MEPs have no idea what it is about, and most of them are a bunch of brown-nosers who represent countries which need wide ranging EU co-operation.
The "interesting" part will be the detail of what happens over the next 2 years.
I posted a link yesterday to another bunch of EASA documents which mentions the 2 year derogation but on a very quick reading it was not clear what this means. Maybe the derogation is EU-wide?
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It is not a complete surprise to me either, albeit for different reasons.
I've had a quick look at the video, the actual vote on Comitology is starting at 09:38.
From what I can see, Said El Khadraoui (labour, BEL) and Mathieu Grosch (christian democrats, BEL) were urging their fractions to vote against the Van Dalen / Bradbourn resolution, and combined they have almost a majority.
Conservatives and Liberals voted in favour (I think I saw Gesine Meissner (liberals, GER) with a thumbs up and being a bit disappointed at the end of the vote).
I also noticed the presence of quite a few members showing up just for the vote (budget and comitology stuff). Among which was Laurence Stassen (NI, NED) substituting (I think) for Mike Nattrass (NI, UK).
Hard to tell, but I don't think it is a matter of "brown nosers representing countries that need wide ranging EU-cooperation". In combination with the budget increase and the 50 extra posts at EASA (which also got approval at the meeting today), I suspect more a classical case of political appointments at middle management level.
That is certainly the case. I assume a lot of people with go for plan B now, but it is certainly a black day for General Aviation and we are left with inadequate legislation. Then again, a lot of the blanks still have to be filled out, including the "BASA negotiation with the US", which, according to Mr. Baldwin, can surely be completed succesfully before 2014. 
What surprised me was that the vote happened today. I suspect that the private pilot lobbying was gaining a bit too much momentum in the EP, so that the EASA "advisors" insisted with Brian Simpson to have the resolution voted upon immediately (i.e. without time to brief the MEP's fully what was being voted upon) after the coordinators' meeting.
At least it came to a (close) vote, which I think is good for democracy. It is also good that EASA, which usually avoids daylight like a vampire, got some exposure so that everyone got a good look as to how they operate and what havoc they create.
Derogation is always the right for member states not to adopt (in this case delaying adoption untill April 2014/2015 as opposed to April 2012). In practice, unless a member state has a particular incentive to adopt legislation in advance, the Member States will invoke their derogation right. The UK (through the CAA) has already signalled its intention to use this right.
I've had a quick look at the video, the actual vote on Comitology is starting at 09:38.
From what I can see, Said El Khadraoui (labour, BEL) and Mathieu Grosch (christian democrats, BEL) were urging their fractions to vote against the Van Dalen / Bradbourn resolution, and combined they have almost a majority.
Conservatives and Liberals voted in favour (I think I saw Gesine Meissner (liberals, GER) with a thumbs up and being a bit disappointed at the end of the vote).
I also noticed the presence of quite a few members showing up just for the vote (budget and comitology stuff). Among which was Laurence Stassen (NI, NED) substituting (I think) for Mike Nattrass (NI, UK).
Hard to tell, but I don't think it is a matter of "brown nosers representing countries that need wide ranging EU-cooperation". In combination with the budget increase and the 50 extra posts at EASA (which also got approval at the meeting today), I suspect more a classical case of political appointments at middle management level.
The "interesting" part will be the detail of what happens over the next 2 years.
What surprised me was that the vote happened today. I suspect that the private pilot lobbying was gaining a bit too much momentum in the EP, so that the EASA "advisors" insisted with Brian Simpson to have the resolution voted upon immediately (i.e. without time to brief the MEP's fully what was being voted upon) after the coordinators' meeting.
At least it came to a (close) vote, which I think is good for democracy. It is also good that EASA, which usually avoids daylight like a vampire, got some exposure so that everyone got a good look as to how they operate and what havoc they create.
Maybe the derogation is EU-wide?
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No wonder the French are doing their own IR, bypassing EASA completely 
Obviously they have the inside track on happenings inside EASA. And if Goudot screws them around, his post-EASA career back home will mirror that of Dubcek.
I suspect we will see a lot more of similar national IRs appearing, because most of the civilised European countries do not want to trash their IFR community.
I've started on the JAA IR anyway, on the basis that it is an insurance policy whose actual cost is the difference between it, and the cost of whatever option may finally emerge. And the latter is bound to involve some exams and some flying time anyway, and I can take advantage of the 15hr ICAO IR to JAA IR conversion whose flying cost, on the basis that I fly a lot for currency anyway, is not a lot more than the cost of the FTO instructor (£80/hr).
Nothwithstanding this insurance policy, my belief is that an alternative will emerge before 2014, and it won't be any bilateral treaty. It will most likely be a de facto collapse of the EASA anti-N-reg initiative, caused by parallel initiatives, conversion options, etc.
Obviously they have the inside track on happenings inside EASA. And if Goudot screws them around, his post-EASA career back home will mirror that of Dubcek.
I suspect we will see a lot more of similar national IRs appearing, because most of the civilised European countries do not want to trash their IFR community.
I've started on the JAA IR anyway, on the basis that it is an insurance policy whose actual cost is the difference between it, and the cost of whatever option may finally emerge. And the latter is bound to involve some exams and some flying time anyway, and I can take advantage of the 15hr ICAO IR to JAA IR conversion whose flying cost, on the basis that I fly a lot for currency anyway, is not a lot more than the cost of the FTO instructor (£80/hr).
Nothwithstanding this insurance policy, my belief is that an alternative will emerge before 2014, and it won't be any bilateral treaty. It will most likely be a de facto collapse of the EASA anti-N-reg initiative, caused by parallel initiatives, conversion options, etc.
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This has just come out:
*Welcome to the September 2011 enews of IAOPA Europe, which goes out to
23,000 aircraft owners and pilots in 27 countries across the continent*
EASA railroads its N-reg attack through Parliament
The European Parliament yesterday approved EASA-FCL despite a last-minute
attempt to have it sent back to EASA for redrafting because of unresolved
issues surrounding third-country licences. The vote was very close – 16
against approval, 22 for – and a surprise for IAOPA was the fact that the
Parliament's Transport Committee chairman Brian Simpson and his socialist
group voted in EASA's favour. Mr Simpson had expressed support for IAOPA's
position on the N-register in the past and it had been hoped he would vote
accordingly.
The passage of EASA-FCL despite the deleterious effect it will have on the
general aviation industry illustrates not only the absence of any real
democratic control over EASA but the failings of the whole European
governmental structure. EASA-FCL was born out of a Basic Regulation written
by European Commissioners with no electoral mandate; the details were added
by bureaucrats at EASA who paid lip service to the idea of consultation with
industry. When the time came to vote, the elected members of the European
Parliament were denied the opportunity to pass judgement on the components
of this long and complex document – they only had the power to accept all of
EASA's proposals, or reject them entirely. Because the Commission's
deadlines (themselves entirely arbitrary) are bearing down on us, MEPs are
under enormous pressure to pass the legislation; failure to do so would have
caused chaos and confusion among the national aviation authorities who are
expected to begin implementing EASA-FCL by April next year, and it is a
measure of the extreme level of concern MEPs have over the N-registration
issue that many of them were prepared to 'throw the baby out with the
bathwater'.
The decision was effectively taken on August 31st by the Transport and
Tourism Committee, which speaks for the whole Parliament on this issue.
Thanks in part to the work of Herbert Habnit, founder of AOPA Netherlands,
two MEPs, Peter van Dalen and Philip Bradbourne, had sought a resolution
saying that EASA's third-country licensing proposals meant that many pilots
would be severely disadvantaged, subject to additional training, examination
and 'notable costs', and that the requirements were 'disproportionate'. EASA
claims the shortcomings in its regulation can be overcome by a bilateral
agreement between Europe and the US, but the van Dalen/Bradbourne motion
points out that 'there is absolutely no evidence nor clear future prospects
for the potential bilateral Aviation Safety Agreements being drafted and to
be concluded before April 2014'(by which time the third-country provision of
EASA-FCL must be fully implemented) that would solve these problems. It goes
on to say there are no safety issues behind EASA's regulation, and adds that
the draft regulation does not even conform to the requirements of the
Commission's own Basic Regulation.
Four more votes would have tipped the matter in general aviation's favour.
Mr Habnit was particularly disappointed at the failure of Mr Simpson and
those in his sphere of influence to support the resolution. Mr Simpson had,
says Mr Habnit, abrogated the provisions of the European Parliament's own
'Agenda for a Sustainable Future for General Aviation', adopted in 2009.
There has, he adds, been no real attempt to quantify the cost of this
politically-motivated attack on the GA industry. 'Even EASA does not
understand the consequences of its actions.'
IAOPA Senior Vice President Martin Robinson said afterwards: 'It's a sad
day. The MEPs were put under enormous pressure to push this through and were
denied the ability to address the huge flaws in it. This could not have been
railroaded through in a truly democratic process. Economically, the vote is
seriously bad news for our industry. Many of those who have been flying
perfectly safely for decades on FAA licences are not going to make the
extraordinary investment of time, effort and money needed to get European
IRs or other qualifications – they will simply give up. The European
Parliament has blown a great hole in our industry with this vote, and
because it has been bamboozled by EASA, it doesn't even know it.
'We now have to focus on the detail of the FCL annexe to the Bilateral
Agreement to make sure that EASA and the FAA reach sensible agreements on
what credits they will give to each other's training systems. It is unlikely
that the 2014 deadline will be achieved given the amount of work that needs
to be done, and the Commission has accepted that the deadline may need to be
extended. Retrospective legislation like this is damaging and the Commission
should now work hard with the industry to reduce as far a possible the
negative impact of these decisions.'
EASA-Ops – some amelioration, but not enough
EASA's final proposals on Ops were published yesterday (August 31st), and
while they have matured considerably since the original poor-quality
document was first made public, there are still areas with which IAOPA is
not satisfied. It is important that members look at Notice of Proposed
Amendment and make their observations clear to EASA. Failure to do so may
mean we are saddled with the undesirable, pointless and in some cases
expensive requirements which remain in the proposals, despite the best
efforts of Working Groups to have them removed.
IAOPA's representatives on the two Working Groups were Jeremy James
(non-complex ops) and Jacob Pedersen (complex ops). Both are happy that the
most onerous requirements have been cut out of the regulations. In complex
ops, the absurd requirement that a single-engined aircraft be capable of
continuing its take-off after an engine failure has gone, as has a
requirement that would effectively have prevented a single engined aircraft
from taking off at all in IMC conditions. In non-complex ops, a requirement
that all helicopters be fitted with floats when flying over water has been
modified to exempt aircraft flying within 50 miles of land, and the demand
for steerable landing lights has been finessed. The contentious demand that
all aircraft be equipped with a fixed ELT has been replaced with a more
sensible requirement for a PLB to be carried on an aircraft with six or
fewer seats. Proposals to require two horizons for night flight have gone.
However, a demand for heated pitot heads for night flying has been
re-introduced at the last moment after having been cut out at the Working
Group stage. This is a particular blow in the helicopter world, where heated
pitots are generally fitted only to aircraft which will operate in IMC and
where retrofitting costs will be enormous. The requirement is all the more
baffling because it was not contained in the last draft regulation, produced
only three weeks earlier, and there has been no explanation for its
reintroduction.
Other issues are:
1. Oxygen requirements – mandatory above FL130 and if you fly between FL100
and FL130 for more than 30 minutes.
2. Mandatory fire extinguisher, with no exemption for aerobatic flights as
requested.
3. Poor dangerous goods regulation, not adapted to non-commercial
operations.
4. More than doubled minimum visibility for an IFR take-off without a
special approval – now 400 meters RVR, as opposed to the existing 150 meters
RVR, with no justification for the change.
Jacob Pedersen says: "Items 1 and 2 prevent the pilot from taking
responsibility and selecting the safest course of action in a given
situation. It should never be the case that a safety regulation forces a
pilot to choose a less safe option, and in both situations EASA goes
directly against the recommendation of EASA's own review group. Consider the
pilot who is crossing the Alps at FL110 and finds himself on top of a cloud
layer after 30 minutes. Should he be forced to leave FL110, with smooth air
and blue sky, to descend 1000 ft, bringing him closer to high terrain and
into the clouds that might contain severe turbulence, rain, hail or worse?
EASA may make it the only legal option, but is it also the safest? Germany
has had good results with allowing operations between FL100 and FL120
without extra oxygen, and it is exactly these altitudes which are so
important, particularly for the Alpine regions."
The dangerous goods rules will cover EASA's back but add to cost and do
nothing for safety. Few non-commercial pilots will ever apply for dangerous
goods approval, nor will they intentionally fly with dangerous goods. Yet
EASA's rules will require all pilots to buy an ICAO document costing €100,
plus an update charge. In practice what will happen is that most pilots will
never know that they are violating ICAO recommendations on dangerous goods
since they will never obtain what is in fact a document produced for the
commercial world.
Jacob says: "The first three cases above are clear examples of the fact that
EASA is not writing safety regulation to promote safety but to absolve EASA
from liability if something goes wrong. If a pilot wants to take what he
considers to be the safest course of action, he could be forced to break the
rules, which is absurd. Item 4 is an example of EASA changing regulation to
prevent operations that have been conducted safely for decades, without
providing any evidence as to why this change is necessary."
*Welcome to the September 2011 enews of IAOPA Europe, which goes out to
23,000 aircraft owners and pilots in 27 countries across the continent*
EASA railroads its N-reg attack through Parliament
The European Parliament yesterday approved EASA-FCL despite a last-minute
attempt to have it sent back to EASA for redrafting because of unresolved
issues surrounding third-country licences. The vote was very close – 16
against approval, 22 for – and a surprise for IAOPA was the fact that the
Parliament's Transport Committee chairman Brian Simpson and his socialist
group voted in EASA's favour. Mr Simpson had expressed support for IAOPA's
position on the N-register in the past and it had been hoped he would vote
accordingly.
The passage of EASA-FCL despite the deleterious effect it will have on the
general aviation industry illustrates not only the absence of any real
democratic control over EASA but the failings of the whole European
governmental structure. EASA-FCL was born out of a Basic Regulation written
by European Commissioners with no electoral mandate; the details were added
by bureaucrats at EASA who paid lip service to the idea of consultation with
industry. When the time came to vote, the elected members of the European
Parliament were denied the opportunity to pass judgement on the components
of this long and complex document – they only had the power to accept all of
EASA's proposals, or reject them entirely. Because the Commission's
deadlines (themselves entirely arbitrary) are bearing down on us, MEPs are
under enormous pressure to pass the legislation; failure to do so would have
caused chaos and confusion among the national aviation authorities who are
expected to begin implementing EASA-FCL by April next year, and it is a
measure of the extreme level of concern MEPs have over the N-registration
issue that many of them were prepared to 'throw the baby out with the
bathwater'.
The decision was effectively taken on August 31st by the Transport and
Tourism Committee, which speaks for the whole Parliament on this issue.
Thanks in part to the work of Herbert Habnit, founder of AOPA Netherlands,
two MEPs, Peter van Dalen and Philip Bradbourne, had sought a resolution
saying that EASA's third-country licensing proposals meant that many pilots
would be severely disadvantaged, subject to additional training, examination
and 'notable costs', and that the requirements were 'disproportionate'. EASA
claims the shortcomings in its regulation can be overcome by a bilateral
agreement between Europe and the US, but the van Dalen/Bradbourne motion
points out that 'there is absolutely no evidence nor clear future prospects
for the potential bilateral Aviation Safety Agreements being drafted and to
be concluded before April 2014'(by which time the third-country provision of
EASA-FCL must be fully implemented) that would solve these problems. It goes
on to say there are no safety issues behind EASA's regulation, and adds that
the draft regulation does not even conform to the requirements of the
Commission's own Basic Regulation.
Four more votes would have tipped the matter in general aviation's favour.
Mr Habnit was particularly disappointed at the failure of Mr Simpson and
those in his sphere of influence to support the resolution. Mr Simpson had,
says Mr Habnit, abrogated the provisions of the European Parliament's own
'Agenda for a Sustainable Future for General Aviation', adopted in 2009.
There has, he adds, been no real attempt to quantify the cost of this
politically-motivated attack on the GA industry. 'Even EASA does not
understand the consequences of its actions.'
IAOPA Senior Vice President Martin Robinson said afterwards: 'It's a sad
day. The MEPs were put under enormous pressure to push this through and were
denied the ability to address the huge flaws in it. This could not have been
railroaded through in a truly democratic process. Economically, the vote is
seriously bad news for our industry. Many of those who have been flying
perfectly safely for decades on FAA licences are not going to make the
extraordinary investment of time, effort and money needed to get European
IRs or other qualifications – they will simply give up. The European
Parliament has blown a great hole in our industry with this vote, and
because it has been bamboozled by EASA, it doesn't even know it.
'We now have to focus on the detail of the FCL annexe to the Bilateral
Agreement to make sure that EASA and the FAA reach sensible agreements on
what credits they will give to each other's training systems. It is unlikely
that the 2014 deadline will be achieved given the amount of work that needs
to be done, and the Commission has accepted that the deadline may need to be
extended. Retrospective legislation like this is damaging and the Commission
should now work hard with the industry to reduce as far a possible the
negative impact of these decisions.'
EASA-Ops – some amelioration, but not enough
EASA's final proposals on Ops were published yesterday (August 31st), and
while they have matured considerably since the original poor-quality
document was first made public, there are still areas with which IAOPA is
not satisfied. It is important that members look at Notice of Proposed
Amendment and make their observations clear to EASA. Failure to do so may
mean we are saddled with the undesirable, pointless and in some cases
expensive requirements which remain in the proposals, despite the best
efforts of Working Groups to have them removed.
IAOPA's representatives on the two Working Groups were Jeremy James
(non-complex ops) and Jacob Pedersen (complex ops). Both are happy that the
most onerous requirements have been cut out of the regulations. In complex
ops, the absurd requirement that a single-engined aircraft be capable of
continuing its take-off after an engine failure has gone, as has a
requirement that would effectively have prevented a single engined aircraft
from taking off at all in IMC conditions. In non-complex ops, a requirement
that all helicopters be fitted with floats when flying over water has been
modified to exempt aircraft flying within 50 miles of land, and the demand
for steerable landing lights has been finessed. The contentious demand that
all aircraft be equipped with a fixed ELT has been replaced with a more
sensible requirement for a PLB to be carried on an aircraft with six or
fewer seats. Proposals to require two horizons for night flight have gone.
However, a demand for heated pitot heads for night flying has been
re-introduced at the last moment after having been cut out at the Working
Group stage. This is a particular blow in the helicopter world, where heated
pitots are generally fitted only to aircraft which will operate in IMC and
where retrofitting costs will be enormous. The requirement is all the more
baffling because it was not contained in the last draft regulation, produced
only three weeks earlier, and there has been no explanation for its
reintroduction.
Other issues are:
1. Oxygen requirements – mandatory above FL130 and if you fly between FL100
and FL130 for more than 30 minutes.
2. Mandatory fire extinguisher, with no exemption for aerobatic flights as
requested.
3. Poor dangerous goods regulation, not adapted to non-commercial
operations.
4. More than doubled minimum visibility for an IFR take-off without a
special approval – now 400 meters RVR, as opposed to the existing 150 meters
RVR, with no justification for the change.
Jacob Pedersen says: "Items 1 and 2 prevent the pilot from taking
responsibility and selecting the safest course of action in a given
situation. It should never be the case that a safety regulation forces a
pilot to choose a less safe option, and in both situations EASA goes
directly against the recommendation of EASA's own review group. Consider the
pilot who is crossing the Alps at FL110 and finds himself on top of a cloud
layer after 30 minutes. Should he be forced to leave FL110, with smooth air
and blue sky, to descend 1000 ft, bringing him closer to high terrain and
into the clouds that might contain severe turbulence, rain, hail or worse?
EASA may make it the only legal option, but is it also the safest? Germany
has had good results with allowing operations between FL100 and FL120
without extra oxygen, and it is exactly these altitudes which are so
important, particularly for the Alpine regions."
The dangerous goods rules will cover EASA's back but add to cost and do
nothing for safety. Few non-commercial pilots will ever apply for dangerous
goods approval, nor will they intentionally fly with dangerous goods. Yet
EASA's rules will require all pilots to buy an ICAO document costing €100,
plus an update charge. In practice what will happen is that most pilots will
never know that they are violating ICAO recommendations on dangerous goods
since they will never obtain what is in fact a document produced for the
commercial world.
Jacob says: "The first three cases above are clear examples of the fact that
EASA is not writing safety regulation to promote safety but to absolve EASA
from liability if something goes wrong. If a pilot wants to take what he
considers to be the safest course of action, he could be forced to break the
rules, which is absurd. Item 4 is an example of EASA changing regulation to
prevent operations that have been conducted safely for decades, without
providing any evidence as to why this change is necessary."
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EASA FCL.008 draft coming out Friday Sept. 30th, 2011 for discussion before NPA procedure, schould include a third country IR conversion (for PPL) in such terms:
- Minimum 100 Flight Hours under IFR-flight plan
- Short Theory Exam (around two weekends learning)
- IFR-Checkflight
- Minimum 100 Flight Hours under IFR-flight plan
- Short Theory Exam (around two weekends learning)
- IFR-Checkflight
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I don't log "under IFR flight plan" (not that it matters as I have >100 sim or actual ) but it always seems stupid to me to log "under IFR" because you could log every flight "under IFR" if you wanted to.
Also in the UK you are rarely "under IFR flight plan" if flying OCAS even though you might be IFR....
Anyway glad I didn't start the IR theory if that is true
Also in the UK you are rarely "under IFR flight plan" if flying OCAS even though you might be IFR....
Anyway glad I didn't start the IR theory if that is true
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Depends on what is meant by "two weekends learning".
I can think of at least 2 individuals who claimed to have swatted up the JAA IR theory in 4 days
It can be done if you have extremely good memory.
So I suggest caution. The devil as always is in the details. Interesting though...
But, finally, remember all this hangs on the "FCL008 IR" making it through the various stages. Currently it is no more than an unpublished committee proposal, seen by very few people outside that committee.
And there is no solution to the private+corporate jet pilots who, on one interpretation of the rules anyway, will need to get themselves the full 14-exam JAA CPL/IR.
I can think of at least 2 individuals who claimed to have swatted up the JAA IR theory in 4 days
It can be done if you have extremely good memory.So I suggest caution. The devil as always is in the details. Interesting though...
But, finally, remember all this hangs on the "FCL008 IR" making it through the various stages. Currently it is no more than an unpublished committee proposal, seen by very few people outside that committee.
And there is no solution to the private+corporate jet pilots who, on one interpretation of the rules anyway, will need to get themselves the full 14-exam JAA CPL/IR.
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10540
The fact that 4 MEPs who changed camp at the last minute in the Vote made me suspicious that promises were made behind closed doors which alleviated their fears.
My feeling will be that it will be a restricted IR. How restricted who knows.
The biggest problem is the fact that there is already an IR under the Eurpean system is this saying that with an FAA IR and 100 hours recorded airways you can change the FAA IR for a European IR or a European restricted IR?
Still not sure.
I would still do nothing at present in changing to EASA IRs
Pace
The fact that 4 MEPs who changed camp at the last minute in the Vote made me suspicious that promises were made behind closed doors which alleviated their fears.
My feeling will be that it will be a restricted IR. How restricted who knows.
The biggest problem is the fact that there is already an IR under the Eurpean system is this saying that with an FAA IR and 100 hours recorded airways you can change the FAA IR for a European IR or a European restricted IR?
Still not sure.
I would still do nothing at present in changing to EASA IRs
Pace
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Obviously nobody (that I know) knows.
I am not aware of any proposals which would result in anything less than a full ICAO IR.
There is an argument, which I agree with, that one needs to avoid any kind of "lower grade IR" because it could be used as a thin end of a wedge to restrict its holders to certain airspaces or certain airspace classes, altitudes, or aircraft types - even if the IR was an ICAO IR.. There is quite a lot of anti-GA prejudice in the "professional pilot/ATC" system already (almost wholly among individuals who have no experience of IFR GA or indeed any modern GA operations) in Europe. The ability to thus segregate the holders of a "GA IR" into some kind of ghetto would be undesirable.
Of course the MPs were offered something under the table. This is what EASA do all the time. You meet one official (e.g. Sivel) and he feeds you a little biscuit. You meet another official and he feeds you a different biscuit. They are a bunch of dishonourable people, but this is how politics works everywhere. I am sure the 4000BC Egyptian dynasties were up to speed on it
Re doing the JAA IR now, I have some notes which show a route of doing it reasonably efficiently. IF one assumes that "something" will have to be done "someday", then the real effort required is the incremental one.
So, what is the difference between the current JAA IR theory, and this "two weekends"? I bet it is less than you are supposed to think. It's probably a "few weekends"
As another example, I decided to do the current IR exams rather than wait for the "new" (commencing ~July 2011) ones which are claimed to be about 20% reduced. Firstly, nobody I know has done them and there is no sign of a question bank for them, and without a QB the revision workload is a good 5x higher. Anybody doing this without a QB needs their head examined.
But like I say above, it all depends on IF you assume "something" has to be done. Currently nothing has to be done before April 2014 and the reasons for this 2 year postponement are not magically going to disappear in 2014 - unless something else happens which makes it all irrelevant.
I am not aware of any proposals which would result in anything less than a full ICAO IR.
There is an argument, which I agree with, that one needs to avoid any kind of "lower grade IR" because it could be used as a thin end of a wedge to restrict its holders to certain airspaces or certain airspace classes, altitudes, or aircraft types - even if the IR was an ICAO IR.. There is quite a lot of anti-GA prejudice in the "professional pilot/ATC" system already (almost wholly among individuals who have no experience of IFR GA or indeed any modern GA operations) in Europe. The ability to thus segregate the holders of a "GA IR" into some kind of ghetto would be undesirable.
Of course the MPs were offered something under the table. This is what EASA do all the time. You meet one official (e.g. Sivel) and he feeds you a little biscuit. You meet another official and he feeds you a different biscuit. They are a bunch of dishonourable people, but this is how politics works everywhere. I am sure the 4000BC Egyptian dynasties were up to speed on it
Re doing the JAA IR now, I have some notes which show a route of doing it reasonably efficiently. IF one assumes that "something" will have to be done "someday", then the real effort required is the incremental one.
So, what is the difference between the current JAA IR theory, and this "two weekends"? I bet it is less than you are supposed to think. It's probably a "few weekends"
As another example, I decided to do the current IR exams rather than wait for the "new" (commencing ~July 2011) ones which are claimed to be about 20% reduced. Firstly, nobody I know has done them and there is no sign of a question bank for them, and without a QB the revision workload is a good 5x higher. Anybody doing this without a QB needs their head examined.
But like I say above, it all depends on IF you assume "something" has to be done. Currently nothing has to be done before April 2014 and the reasons for this 2 year postponement are not magically going to disappear in 2014 - unless something else happens which makes it all irrelevant.
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10540
Sorry I have misread this completely. This is not a proposal for a new PPL IR but a proposal to convert 3rd country IRs to EASA IRs!
The fact that you must hold a third country IR have a minimum of 100 hours under IFR flight plan, sit a differences exam and have an IFR checkflight comes clear.
This is to convert to a full EASA IR from an FAA IR and I would imagine a proposal for adding to the Bi Lateral already in place and is perfectly reasonable.
Pace
EASA FCL.008 draft coming out Friday Sept. 30th, 2011 for discussion before NPA procedure, schould include a third country IR conversion (for PPL) in such terms:
- Minimum 100 Flight Hours under IFR-flight plan
- Short Theory Exam (around two weekends learning)
- IFR-Checkflight
- Minimum 100 Flight Hours under IFR-flight plan
- Short Theory Exam (around two weekends learning)
- IFR-Checkflight
The fact that you must hold a third country IR have a minimum of 100 hours under IFR flight plan, sit a differences exam and have an IFR checkflight comes clear.
This is to convert to a full EASA IR from an FAA IR and I would imagine a proposal for adding to the Bi Lateral already in place and is perfectly reasonable.
Pace
Last edited by Pace; 14th Sep 2011 at 14:36.
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Sure, but you (I mean you Pace) will still need to sort out a JAA CPL and (taking the worst case scenario) the other bits of paper which would be needed to fly the aircraft if it was an EASA reg one.
There is a lot of detail to come out yet. It will be a year or two before this is all washed out, one way or the other.
Do you think the European FTO industry is going to sit there and allow all the ATPL candidates to pop over to Arizona for a few months and, in their copious time (most of them are "unemployed youths" ) get themselves an FAA CPL/IR, and then come over and knock off some easy conversion, instead of depositing a large 5-figure amount of money at a European FTO? BASA or no BASA, this just isn't going to happen.
There is a lot of detail to come out yet. It will be a year or two before this is all washed out, one way or the other.
Do you think the European FTO industry is going to sit there and allow all the ATPL candidates to pop over to Arizona for a few months and, in their copious time (most of them are "unemployed youths"
) get themselves an FAA CPL/IR, and then come over and knock off some easy conversion, instead of depositing a large 5-figure amount of money at a European FTO? BASA or no BASA, this just isn't going to happen.
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For flying a jet which is private as long as the pilot is not paid directly for flying services a PPL IR would suffice.
On the Question of older pilots holding FAA ATP working N reg in Europe there is already a discrimination problem with the current framework which EASA will have to address.
But good news is that maybe we will have a reasonable conversion offered with a differences course and flight test which is what should have been the case.
The other point regarding 14 exams for ATPs surely it would be the differences course plus some of the 14 exams or there would be a conversion for ATPs as well? Ie experience as an ATP, a differences exam and flight test at next type rating with someone like FS?
Pace
On the Question of older pilots holding FAA ATP working N reg in Europe there is already a discrimination problem with the current framework which EASA will have to address.
But good news is that maybe we will have a reasonable conversion offered with a differences course and flight test which is what should have been the case.
The other point regarding 14 exams for ATPs surely it would be the differences course plus some of the 14 exams or there would be a conversion for ATPs as well? Ie experience as an ATP, a differences exam and flight test at next type rating with someone like FS?
Pace
Last edited by Pace; 14th Sep 2011 at 15:34.
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The whole EASA vs FAA debate makes me very uncomfortable and despite reading countless topics and discussions I still fail to make proper sense of the situation.
I hold FAA tickets and these allow me to (safely) work in the corporate sector around Europe on a fantastic job flying jets. Aviation forms a large part of my existence and the FAA route was not planned. It was the UK's own CAA who put a barrier in place (eye sight) which stopped me going down the JAA route. None the less I stuck at it and obtained my FAA tickets and got a great job on jets.
So if / when / should / EASA railroad though what (in my eyes) looks like a bodged attempt at unification I will be out on my backside with no job. The CAA have made it clear they can't budge on their own requirements so it puts me in a very hard position.
I'm confident I'm not the only person in this bad position.
I sent an email to Mr Brian Simpson MEP - he very kindly responded a week later surprisingly in simple english with no references to legislation to dilute his response. He has stated that it is infact the FAA who at fault and EASA is merely fighting its own corner to have its own ratings recognised. He went further to say that we have it all wrong and rather than give EASA a hard time, we should lobby the FAA instead. I hate to admit, but he could have a valid point there?
No matter what the outcome while this political pi$$ing contest rages on - there are some of us perched very nervously wondering when the end will come and how we can pay our bills after it all caves in????
I hold FAA tickets and these allow me to (safely) work in the corporate sector around Europe on a fantastic job flying jets. Aviation forms a large part of my existence and the FAA route was not planned. It was the UK's own CAA who put a barrier in place (eye sight) which stopped me going down the JAA route. None the less I stuck at it and obtained my FAA tickets and got a great job on jets.
So if / when / should / EASA railroad though what (in my eyes) looks like a bodged attempt at unification I will be out on my backside with no job. The CAA have made it clear they can't budge on their own requirements so it puts me in a very hard position.
I'm confident I'm not the only person in this bad position.
I sent an email to Mr Brian Simpson MEP - he very kindly responded a week later surprisingly in simple english with no references to legislation to dilute his response. He has stated that it is infact the FAA who at fault and EASA is merely fighting its own corner to have its own ratings recognised. He went further to say that we have it all wrong and rather than give EASA a hard time, we should lobby the FAA instead. I hate to admit, but he could have a valid point there?
No matter what the outcome while this political pi$$ing contest rages on - there are some of us perched very nervously wondering when the end will come and how we can pay our bills after it all caves in????
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I sent an email to Mr Brian Simpson MEP
He has stated that it is infact the FAA who at fault and EASA is merely fighting its own corner to have its own ratings recognised.
Having had a clear look in the FARs about conversion at PPL level, I believe its EASA / JAA who have been the difficult ones. Also, the Americans don't require dual licensing for their residents. If I were a US resident, owning a Dutch company, I could fly my Dutch registered company plane in the US with Dutch paperwork, right ?
If any of the classical axe grinders (billiebob, bookworm, ...) could shed some light on Mr Simpson's position, we would be much obliged.
there are some of us perched very nervously wondering when the end will come and how we can pay our bills after it all caves in????
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Moonym20,
My sympathies, I ony fly on an FAA license as a hobby (occasionally on business), but it is not my livelihood.
In my opinion Brian Simpson is lying outright - it has nothing to do with the FAA. The fact is that
(a) for decades. there has been no problem with pilots domiciled in Europe with FAA licenses and FAA IR flying N-reg in Europe - there have been no legality issues (or safety issues for that matter - EASA never argued there was)
(b) Brian Simpson then voted in favour of a brand new EASA regulation which will make IFR flight illegal without a JAA IR in addtion to the FAA IRl for EU domiciled operators, from April 2012 (with it appears delays implemented to 2014)
So Brian Simpson and others have voted for a NEW European regulation that is wholly European inspired, wholly European controlled and only affects European citizens.
The FAA have changed absolutely nothing.
And with regard to agreements with the FAA, Brian Simpson is being wholly disingenuous - recognition of licenses FAA to JAA/EASA is currently more or less the same in either direction.
Effectively Brian Simpson is saying "we haven't got an agreement with the FAA about mutual recognition of all licenses so we [EASA and European MPs] will discriminate against our European citizens" - there is no logical connection between the two issues.
Plus, there is no definite date for any such negotiations / agreements, nor any guarantee that even if there were mutual recognition of some licenses that EASA would then relent. (Nor any timetable.)
The fact is that this is being used just for some perceived political expediency [e.g. for those in Europe that hate everything American and want to get N-reg out] - it's playground politics, and I'm afraid to say it is unfortunate folks such as yourselves who are the cannon fodder - it seems that Brian Simpson and others are entirely happy for you to pay the very high price of their political actions.
My sympathies, I ony fly on an FAA license as a hobby (occasionally on business), but it is not my livelihood.
In my opinion Brian Simpson is lying outright - it has nothing to do with the FAA. The fact is that
(a) for decades. there has been no problem with pilots domiciled in Europe with FAA licenses and FAA IR flying N-reg in Europe - there have been no legality issues (or safety issues for that matter - EASA never argued there was)
(b) Brian Simpson then voted in favour of a brand new EASA regulation which will make IFR flight illegal without a JAA IR in addtion to the FAA IRl for EU domiciled operators, from April 2012 (with it appears delays implemented to 2014)
So Brian Simpson and others have voted for a NEW European regulation that is wholly European inspired, wholly European controlled and only affects European citizens.
The FAA have changed absolutely nothing.
And with regard to agreements with the FAA, Brian Simpson is being wholly disingenuous - recognition of licenses FAA to JAA/EASA is currently more or less the same in either direction.
Effectively Brian Simpson is saying "we haven't got an agreement with the FAA about mutual recognition of all licenses so we [EASA and European MPs] will discriminate against our European citizens" - there is no logical connection between the two issues.
Plus, there is no definite date for any such negotiations / agreements, nor any guarantee that even if there were mutual recognition of some licenses that EASA would then relent. (Nor any timetable.)
The fact is that this is being used just for some perceived political expediency [e.g. for those in Europe that hate everything American and want to get N-reg out] - it's playground politics, and I'm afraid to say it is unfortunate folks such as yourselves who are the cannon fodder - it seems that Brian Simpson and others are entirely happy for you to pay the very high price of their political actions.
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Simpson sent the same email to a number of people by the looks of it...
Yes it is disingenuous.
If you take the typical "Euro N-reg" scene, you have a pilot who is flying a plane registered outside the EU, on papers issued by the State of Registry. All is ICAO compliant. (Currently this is allowed in Europe, except Denmark which uses a vague rule to harrass N-reg pilots based there.)
The equivalent situation from the FAA end would be a pilot flying say a G-reg in US airspace, on papers issued by the State of Registry. All is ICAO compliant. THIS IS NOT BANNED IN THE USA. (the fact that almost nobody does it, because only a rather strange person with money to burn for a laugh is going to keep a G-reg in the USA long term, and scraping around for a CAA approved MO to look after it, is irrelevant)
So, all this stuff about "we cannot do this here because the USA does not allow it over there, and if we get a BASA then all will be fine" is just a load of bollox, which at best is a lack of understanding, or at worst outright dishonesty.
What you cannot do is fly an N-reg on a non-FAA license in US airspace. Hence the 61.75 validation option, and the Foreign Pilot IR exam option if you want IFR. This is for noncommercial use only, and there is no (commercially useful, beyond ferry flying and crop spraying) CPL version of the 61.75. Lots of people thus fly in the USA, and outside the USA, on the 61.75 "piggyback" papers.
The above paragraph would be equivalent to flying a D-reg in German airspace, on an FAA license, which you cannot do. (It is probable that Germany offers a local validation of FAA papers, through various hoops. I know France offers one but only (AFAICS) to non EU residents as per this possibly badly translated letter. The only EU country AFAIK which allows this directly, VFR only, and IFR OCAS i.e. Class F&G, is the UK via an ANO concession which is due to be squashed by EASA in April 2012)
So, to repeat myself, all this stuff about "we cannot do this here because the USA does not allow it over there, and if we get a BASA then all will be fine" is just a load of bollox, which at best is a lack of understanding, or at worst outright dishonesty.
In a nutshell, the USA allows a lot more, both in the USA and outside the USA, than Europe allows both in Europe and outside.
I really don't know about Simpson. He seems fairly bright and it is possible he has been wrongly briefed. After all, these bizzare combinations of registries and pilot papers are not easy to get one's head round for the best of us. But he is totally reckless to be voting on stuff he clearly doesn't understand. One if the recipients of his letters ought to write back to him with a dose of reality.
Yes it is disingenuous.
If you take the typical "Euro N-reg" scene, you have a pilot who is flying a plane registered outside the EU, on papers issued by the State of Registry. All is ICAO compliant. (Currently this is allowed in Europe, except Denmark which uses a vague rule to harrass N-reg pilots based there.)
The equivalent situation from the FAA end would be a pilot flying say a G-reg in US airspace, on papers issued by the State of Registry. All is ICAO compliant. THIS IS NOT BANNED IN THE USA. (the fact that almost nobody does it, because only a rather strange person with money to burn for a laugh is going to keep a G-reg in the USA long term, and scraping around for a CAA approved MO to look after it, is irrelevant)
So, all this stuff about "we cannot do this here because the USA does not allow it over there, and if we get a BASA then all will be fine" is just a load of bollox, which at best is a lack of understanding, or at worst outright dishonesty.
What you cannot do is fly an N-reg on a non-FAA license in US airspace. Hence the 61.75 validation option, and the Foreign Pilot IR exam option if you want IFR. This is for noncommercial use only, and there is no (commercially useful, beyond ferry flying and crop spraying) CPL version of the 61.75. Lots of people thus fly in the USA, and outside the USA, on the 61.75 "piggyback" papers.
The above paragraph would be equivalent to flying a D-reg in German airspace, on an FAA license, which you cannot do. (It is probable that Germany offers a local validation of FAA papers, through various hoops. I know France offers one but only (AFAICS) to non EU residents as per this possibly badly translated letter. The only EU country AFAIK which allows this directly, VFR only, and IFR OCAS i.e. Class F&G, is the UK via an ANO concession which is due to be squashed by EASA in April 2012)
So, to repeat myself, all this stuff about "we cannot do this here because the USA does not allow it over there, and if we get a BASA then all will be fine" is just a load of bollox, which at best is a lack of understanding, or at worst outright dishonesty.
In a nutshell, the USA allows a lot more, both in the USA and outside the USA, than Europe allows both in Europe and outside.
I really don't know about Simpson. He seems fairly bright and it is possible he has been wrongly briefed. After all, these bizzare combinations of registries and pilot papers are not easy to get one's head round for the best of us. But he is totally reckless to be voting on stuff he clearly doesn't understand. One if the recipients of his letters ought to write back to him with a dose of reality.
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To reiterate what Mr Simpson said here's a paste of final paragraph on his email to me... maybe it's identical to other replies received...
"My final point is that no problem would exist if the United States recognised EU licences. Reciprocity would follow from the EU and the problem would be solved. It may be that IAOPA would do well to lobby the Government of the USA to seek such reciprocity and you may wish to do this on a personal basis also"
Being cannon fodder to a political argument really does suck..
He even hinted that if no BSA could be agreed then there may be a postponement of the 2014 deadline:
"While every effort has to be put into ensuring a mutual recognition agreement with the US, I am also aware that there needs to be a certain degree of flexibility if no agreement is reached before the set deadline. It is for this reason that the possibility to postpone the 2014 date for the validation or conversion of third country licences, should negotiations with the US fail, has been left open"
"My final point is that no problem would exist if the United States recognised EU licences. Reciprocity would follow from the EU and the problem would be solved. It may be that IAOPA would do well to lobby the Government of the USA to seek such reciprocity and you may wish to do this on a personal basis also"
Being cannon fodder to a political argument really does suck..
He even hinted that if no BSA could be agreed then there may be a postponement of the 2014 deadline:
"While every effort has to be put into ensuring a mutual recognition agreement with the US, I am also aware that there needs to be a certain degree of flexibility if no agreement is reached before the set deadline. It is for this reason that the possibility to postpone the 2014 date for the validation or conversion of third country licences, should negotiations with the US fail, has been left open"
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Yes "reciprocity" sounds warm and fuzzy, but what is he talking about?
The current lack of reciprocity is in the direction opposite to his argument.
The USA is easier than Europe for validating papers from the other one.
There is an apparent mental block in the EU machine on the present very easy FAA validations of ICAO papers.
Actually I think it is plain in-your-face dishonesty because everybody who can start up a C150 knows about the 61.75 route
But this mental block results in people like Simpson pretending that there is no US give on anything at present and that a reciprocal treaty is the only way for the EU to give something likewise.
The current lack of reciprocity is in the direction opposite to his argument.
The USA is easier than Europe for validating papers from the other one.
There is an apparent mental block in the EU machine on the present very easy FAA validations of ICAO papers.
Actually I think it is plain in-your-face dishonesty because everybody who can start up a C150 knows about the 61.75 route
But this mental block results in people like Simpson pretending that there is no US give on anything at present and that a reciprocal treaty is the only way for the EU to give something likewise.
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New labour...
My money is now on Brian Simpson's dishonesty, to be frank, knowing that quite a few people have briefed him in detail on the subject.
However, is there a remote possibility that we are talking about reciprocity of ICAO license recognition for 1500 hours+ ATPL's with x00 hours of Multi time ? And that JAA would recognize FAA papers for those but not vice versa ?
I cannot imagine that that would be a credible driver, but would he have a point referring to those ?
However, is there a remote possibility that we are talking about reciprocity of ICAO license recognition for 1500 hours+ ATPL's with x00 hours of Multi time ? And that JAA would recognize FAA papers for those but not vice versa ?
I cannot imagine that that would be a credible driver, but would he have a point referring to those ?
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This is not my speciality but I believe that both present JAA and EASA will accept any ICAO ATPL for a direct conversion, possibly with a check flight (but certainly exempting all exams) if the pilot has 2000+ hrs on a Part 25 aircraft.
Otherwise, there is no direct conversion of a fully commercial CPL/IR at present, in either direction.
(The FAA will give you a "61.75 CPL" and a Foreign Pilot Exam based IR, but while the IR is a full IR, the resulting CPL excludes paying passengers, hence my earlier crop spraying / ferrying usage limitation).
If you have a JAA ATPL and you want an FAA ATPL, you AFAIK already meet all FAA logbook stuffing requirements (1500hrs TT of which 100 is at night, etc) and you need to pass the ATPL exam, get an FAA Class 1 medical, and pass the FAA ATP checkride. Assuming you are a "real" ATPL, this is hardly onerous! You don't even need an FAA CFI signoff to sit the one exam; you can just turn up
Whereas an FAA ATP, with less than the above 2k Part 25 hours, gets zero rights to any conversion to a JAA ATPL, AFAIK. He has to do all 14 exams, do the full CPL/IR mandatory FTO logbook stuffing hours, get a JAA Class 1 medical, and pass the two test flights.
So I still don't get it. Europe is harder in every department here, again.
Otherwise, there is no direct conversion of a fully commercial CPL/IR at present, in either direction.
(The FAA will give you a "61.75 CPL" and a Foreign Pilot Exam based IR, but while the IR is a full IR, the resulting CPL excludes paying passengers, hence my earlier crop spraying / ferrying usage limitation).
If you have a JAA ATPL and you want an FAA ATPL, you AFAIK already meet all FAA logbook stuffing requirements (1500hrs TT of which 100 is at night, etc) and you need to pass the ATPL exam, get an FAA Class 1 medical, and pass the FAA ATP checkride. Assuming you are a "real" ATPL, this is hardly onerous! You don't even need an FAA CFI signoff to sit the one exam; you can just turn up
Whereas an FAA ATP, with less than the above 2k Part 25 hours, gets zero rights to any conversion to a JAA ATPL, AFAIK. He has to do all 14 exams, do the full CPL/IR mandatory FTO logbook stuffing hours, get a JAA Class 1 medical, and pass the two test flights.
So I still don't get it. Europe is harder in every department here, again.