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EASA threat to operation of N Reg Aircraft

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EASA threat to operation of N Reg Aircraft

Old 5th Oct 2010, 16:30
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EASA threat to operation of N Reg Aircraft

Info here.

Last edited by Mike Cross; 7th Oct 2010 at 22:02.
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Old 5th Oct 2010, 17:01
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EASA are the worst sort of eurocrats they sit in Cologne inventing new rules but they are not able to properly administer the rules that they have in place at the moment.

They have made MEP flying too expensive, they are about to make SEP training more expensive, part M maintenance costs IRO £ 1000 per year more for no increase in safety.

The attack on the American registered aircraft is pure spite because EASA seem unable to put an affordable IR in place for GA pilots so their answer is to try to stop GA pilots flying with the FAA IR. This move high lights how totaly unfit EASA is to run aviation within Europe, after all if EASA administered European Aviation properly Pilots would be more than happy to get an EASA IR.
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Old 5th Oct 2010, 17:03
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Mike this is the most disgusting Manner for EASA to behave and the most direct view to show that this organisation known as EASA have not got aviation interests at heart a must read

Latest Received from IAOPA

--------------------------------------------------------------------------------
IAOPA presses the EC to delay EASA's N-register attack

EASA’s eleventh-hour attempt to bounce the industry into accepting disastrous regulations aimed at killing off the N-register in Europe have shocked the aviation world and led to frantic last-minute moves to stop the Agency bulldozing new rules through the European Commission.
When the Agency finally showed its hand on the N-register it was through proposals on Flight Crew Licensing which will make it impossible for European citizens to fly in Europe on American licences, render worthless the FAA Instrument Rating and blow the bottom out of the market in N-registered aircraft. If they are adopted, the plans will force thousands of pilots to undertake new training courses costing millions of euros and slide the already-depressed used aircraft market into the mire. The safety benefit will be zero.

After years of discussion, the details became clear just two weeks before the EC was due to make a final decision on EASA’s proposals. IAOPA is asking the Commission to set the issue aside to allow time for its impact to be properly assessed.

The plans fly in the face of every assurance given by EASA’s principals that while they wanted European pilots to fly on European registers, they would properly address the reasons why they did not. EASA’s Executive Director Patrick Goudou promised in 2005: “We will ensure there are no special advantages to being on the N-register.” He has not kept his side of the bargain. Few of the compelling reasons why European pilots are driven into the arms of the FAA have been addressed, and those that have been looked at have been skimmed over in a desultory and unsatisfactory way.
EASA’s claimed motivation for attacking the N-register is safety, but that is a smoke-screen for political chauvinism. Aviation is a trade battleground between Europe and America, and pilots and owners are caught between the trenches. There has never been any evidence, or even any credible claim, that the N-register is unsafe. With this move, EASA has gone far beyond its safety remit and stepped completely into the realms of political protectionism.

IAOPA-Europe met in Amsterdam at the weekend to plan a response. Delegates from 17 European countries debated emergency tactics, and Craig Spence, Vice President of Regulatory Affairs for AOPA US, flew in from Washington. He left with a full understanding of the gravity and urgency of the matter.

AOPA UK’s Pam Campbell outlined the issue which, she said, had come as “something of a bombshell”. To fly an aircraft in Europe, no matter what the country of register, would require an EASA licence and if applicable an EASA Instrument Rating, if you were domiciled in Europe. A stop-gap validation on a non-European licence would be available from national aviation authorities, valid for one year. The pilot would have to apply to the authority of the nation in which he or she resided. There would be a test for the validation, and no repeat validation would be possible, although an extension would be granted for a maximum of one year if the pilot could prove that training to convert the licence or rating has been commenced.

The minimum requirements to convert a third country PPL would be to pass an examination in Air Law and Human Performance, a PPL Skills Test and a Class 2 medical. It would also be necessary to demonstrate English language proficiency, and to have a minimum of 100 hours. That would convert the licence to a PPL with an SEP rating. Higher qualifications would be granted subject to additional training at the discretion of the service provider. The holder of an FAA Instrument Rating would have to study for and sit seven theoretical knowledge exams, which are currently the greatest barrier to the IR for private pilots. EASA is tinkering with theoretical knowledge requirements but there will be few game-changing amendments. It is unclear whether there would be any credit for American training or hours flown.
Emmanuel Davidson of AOPA France said there were more than 10,000 European pilots holding FAA licences flying in Europe. “We have to bear in mind that if your American licence is made illegal and you have an N-registered plane, when you fly it on a European licence you will have to apply both European and FAA regulations, which would mean you can only fly in the country that has issued your licence. It will be illegal to fly, say, from France to Germany or England to Belgium. Those aircraft which have been modified to FAA STCs may not be able to go on the European register and will have to be sold, but to whom? A glut of aircraft will come onto the market, and the only place you’d be able to sell them would be America. There will be massive compensation claims against EASA and the EC.”

IAOPA Senior Vice President Martin Robinson said this had been sprung on the industry at the eleventh minute of the eleventh hour, and that all assurances given by EASA and EC figures that the situation was not as dire as it seemed had proved valueless. “We are facing a firing squad which has its rifles cocked,” he said. “EASA has consulted on Part FCL, and in response to IAOPA’s specific comments on third country licences it responded with one word – ‘Noted.’ That is all. EASA sends its work as an opinion to the European Commission, which has a time frame in which to accept or reject, and the hearing for that is on the 13th and 14th October.”

IAOPA has already met with MEPs and European Commission figures and more meetings are scheduled with the aim of getting the Commission to allow more time to discuss the issue. “Our first objective is to get the EC wound up to ‘park’ the issue so the ramifications can be looked at,” Robinson said. “In the short time we have available, there is no other option. Then we have to work on how we modify the text to get a proper resolution.
“There is no guarantee that the EC will listen. They could say we’ve had our chance, but we can demonstrate that our comments simply haven’t been listened to. The regulatory impact of this will be enormous, and I believe they are poorly understood, even at EASA. I cannot believe they have done a proper Regulatory Impact Assessment on FCL. If they even begin to work out how many people would be driven out of aviation by this, EASA and the EC would recoil from it.”

There is little individual AOPA members can do at this late stage to influence events. Martin Robinson said: “If you feel strongly about this you can write to Mike Smethers, Chairman of the EASA Board of Management, at the CAA in Kingsway, with a copy to your local MEP. But time is so short that we can only take emergency measures at this stage."

IAOPA will keep members informed of progress as it happens
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Old 5th Oct 2010, 17:09
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EASA also appear dishonest, with their well known top official telling people privately face to face that N-regs will be OK, etc.

Anyway, at least somebody is getting into gear.
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Old 5th Oct 2010, 17:32
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Like many here I am totally disgusted by this incompetent organization.
And I am totally disgusted by the incompetent, ill-informed politicians who have put them there.

Do these idiots think we should burn more THOUSANDS of pounds more on Part-M maintenance requirements and THOUSANDS of pounds more on forced conversion to EASA-IR, WITH NO SAFETY BENEFITS?

Just fly illegally. There's no point paying and giving them this money. It will only feed more incompetence.

I vow to make sure these idiots will never sleep until they are kicked out of office!

Anyone thought of staging a mass protest outside their offices?
I can see tens of thousands show up.
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Old 5th Oct 2010, 22:26
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Just fly illegally. There's no point paying and giving them this money. It will only feed more incompetence.
DP

I didnt think I would say this but this but flying illegally is a viable option??? But many would have to ignore the regs for that approach to succeed.

The French are masters at ignoring EEC regs that they dont agree with!!! Maybe we should learn the French approach? We should be more proactive in matters which affect us unfairly because only those who shout loudest get heard.

Apathy and acceptance is not the way "act as a doormat and dont be surprised if someone wipes their dirty feet all over you!"

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Old 5th Oct 2010, 23:55
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I agree, there is already widespread panic from PPLs scurrying to heed the CAA's advice to convert lifetime CAA PPLs to JAA ones as soon as possible in order to ease the transition to EASA licences at a later date. If 15000 pilots with fully valid national ICAO licences refuse to budge ( and the CAA admit it would take years to make the transition even with willing participants) , they are not going to be able to ground them all en masse overnight.
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Old 6th Oct 2010, 06:19
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they are not going to be able to ground them all en masse overnight.
You wanna watch them? They are doing it to the N-registers.

This thing is a step in a war to eradicate GA from Europe. First take away the escape possibilities then impose rulework on the homefleet to ground it. So far, it was a half baked idea, now it's turning into a direct threat.

These people need to be stopped NOW. If they don't I reckon there will be a disaster on our hands like never before. I also hope the US will react massively to this attack.

From the IAOPA Statement:

f they even begin to work out how many people would be driven out of aviation by this, EASA and the EC would recoil from it.
That is where IAOPA gets it wrong. This is the objective.
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Old 6th Oct 2010, 07:35
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There will be massive compensation claims against EASA and the EC.”
That is a route which does have mileage.

If pilots have been flying N reg in Europe for decades the practice has been firmly established and accepted within the EEC.

Should a body such as EASA regulate which stops people from going about their rightful business and through that those people are faced with massive costs and financial loss then they can indeed sue EASA and the EC who through their regulating have caused it.

Unless EASA can show solid grounds (ie emergency safety basis)for such damaging regulating on a practice which is so established they would indeed be liable.

I refer to our strong human rights and discrimination laws which overide such bodies as EASA

Again it would be interesting to have legal opinion on compensation claims?

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Old 6th Oct 2010, 07:53
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Pace - I wish you were right but there is nothing in human rights legislation which would be helpful.

I believe pilots as a community should do everything they legally can to prevent the legislation being adopted.

I rightly see a lot of strong views expressed here - but I dont see anyone mounting a creditable campaign.

I dont even see a good old fashion petition.
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Old 6th Oct 2010, 07:56
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I am no lawyer but within the UK (no EU angle) you would have no case, due to Crown Immunity (or whatever it is called).

There is a pile of EU laws, but I would be a little suprised of EASA had not obtained some legal input on this, as it appears fairly obvious. But maybe they haven't...

The best thing is to spread the news in the USA. Airbus business (to airlines or the Pentagon) could be affected if this gets the right publicity. There are many ex pilots running these shows out there and pilots generally don't like this kind of screwing around with pilots' privileges.

I don't see what sort of campaign could be mounted. EASA is more or less done with it anyway. The only avenue open now is lobbying within the EU, but that will be wholly the dirty kind of under the table stuff, with necessary national-interest angles. The big interested parties employ professional lobbyists for that work. European GA cannot afford this; only AOPA USA can.
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Old 6th Oct 2010, 09:21
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There will be massive compensation claims against EASA and the EC

Fuji 10540

The above snippet was taken from the AOPA announcement maybe they have it wrong?

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Old 6th Oct 2010, 09:22
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US backlash...?

Just got this from AvWeb Biz which is widely distributed in the USA:

AOPA says a new regime of rules proposed by the European Aviation
Safety Agency (EASA) "has potentially devastating implications for the
U.S. general aviation manufacturers and for the U.S. flight training
industry." EASA intends to adopt a wide-ranging series of amendments
to rules that appear to particularly affect those holding U.S. pilot
certificates and aircraft registered in the U.S. but resident in
Europe. "It would render FAA pilot certificates and instrument ratings
issued to pilots living and operating in Europe (including U.S.
citizens based in and flying in Europe)
effectively worthless,
requiring them to essentially start over and retrain and recertify,"
AOPA spokesman Chris Dancy told AVweb. "It would also eliminate any
advantage to owning and operating an N-number-registered aircraft in
Europe."
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Old 6th Oct 2010, 11:03
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Hum

You missed a bit out on the Avweb feature

AOPA says a new regime of rules proposed by the European Aviation Safety Agency (EASA) "has potentially devastating implications for the U.S. general aviation manufacturers and for the U.S. flight training industry." EASA intends to adopt a wide-ranging series of amendments to rules that appear to particularly affect those holding U.S. pilot certificates and aircraft registered in the U.S. but resident in Europe. "It would render FAA pilot certificates and instrument ratings issued to pilots living and operating in Europe (including U.S. citizens based in and flying in Europe) effectively worthless, requiring them to essentially start over and retrain and recertify," AOPA spokesman Chris Dancy told AVweb. "It would also eliminate any advantage to owning and operating an N-number-registered aircraft in Europe."



There are an estimated 10,000 pilots in Europe flying under U.S. certificates. Many of them got their training in the U.S. and a lot of flight schools cater specifically to European students. U.S. manufacturers will be hit from two directions. The rules will make U.S.-built aircraft "more difficult and expensive to own and operate," and therefore less attractive in Europe, a key market for most U.S. manufacturers, Dancy said. "And on that side of the Atlantic, it could mean a glut of N-number-registered aircraft being dumped on the market, further depressing used aircraft sales." AOPA has contacted members of Congress, the FAA and Department of Transportation to make sure they're aware of the issue. It's also supporting European aviation groups in their attempts to stop the action.
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Old 6th Oct 2010, 11:48
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I reckon the **** is really going to hit the fan over all this stuff. The commission has already bollocked EASA for "reinventing the wheel" and pressure from the US will have all manner of political repercussions. I can see the whole EASA shambles being wound up and having to start again from Scratch.
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Old 6th Oct 2010, 12:01
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This whole " for life" thing for the PPL is , I believe on dodgy grounds. I am as disgusted as anyone else but correct me if I am wrong, I am sure the small print says something like " for life subjuct to the laws in force at any time in the future"
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Old 6th Oct 2010, 12:01
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I can't see easa doing much about it now, everyone had the chance over the last 2years or so to get it all amended ,to change it the last 2weeks after it is all agreed will take some doing and will cause a major presendence to future rule making if allowed

The licensing system has been long overdue a standardisation for all eu ,at least we hopefully will have a level playing field for the future

At the moment we all look to the licensing body of our choice,the one that suits us best, whether medically or For technical reasons ,which means not always our own countries aviation authority

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Old 6th Oct 2010, 12:17
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Sadly I have to agree with you.

The problem is the time and effort by (mainly) volunteers on the working groups and within our representative organisations over many months and years results (usually) in what was originally planned. Then we get a mad panic at the last minute when what is presented as the opinion is finally published. All the nastiness is back in it, despite the hard work and effort that has gone before.

I'm still not sure in my own mind whether or not they are doing this deliberately or this happens through incompetence or accident.

Unfortunately, there are too many examples of bad faith from EASA over the years. We keep hearing about there being a lot of good guys there who want to make aviation work. I don't see much evidence of this myself
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Old 6th Oct 2010, 12:29
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People have been working extensively over the last years to have the more onerous aspects changed. However, at this point, it seems the drafters have ignored quite a lot of the input.

If you take the emotion out of it (which may be a bit of an ask if you are going to be off work for 6 months paying thousands to retrain) there are some very annoying aspects that are worth lobbying at the next level.
  1. The transition arrangements are unclear and to the extent they are clear seem unreasonably onerous
  2. There is a surprising bias against non-JAA ICAO certificates. Most countries outside the EASA environment validate or issue local certificates on the basis of an ICAO certificate with minimal additional overhead (for example in the US effectively passing an IFR procedures test for differences from ICAO standard and a BFR). Even EU national certificates have significant retesting or minimum hours requirements.
  3. There appears to be no empirical evidence to support the need for this overhead in accepting other licences around the world. In particular, the overhead appears to support a political agenda to drive bilateral agreements rather than any safety requirement.
  4. The key issues around IFR, which were referred to a separate committee due to their complexity, have not been included in the proposal - so in many ways it is incomplete
  5. There appears to be a great deal of cost and conflict/overlap with the local NAAs being driven without any indication of a safety or broader community benefit.


So overall, this seems like a massive piece of work (and cost) to implement with no safety benefit. So there is a good political case to look carefully at the implementation to reduce the impact and simplify the changeover processes.
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Old 6th Oct 2010, 13:50
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MM

We do have to look at the different systems and the historical reasons for them being what they are.
FAA land has always embraced GA. Being such a large continent private aircraft have always been a much needed mode of transport.

EASA land has been a mass of seperate countries with their own laws and GA didnt figure in a lot of them.

Politically aviation has been regarded as people carriers and their pilots as professionals. The training structures based more on a mini aviation degree.
EASA will not allow pilots to back door an EASA licence by finding an easy route through the FAA system.

So while a differences exam and IR flight test should be all that is required dictated by sense I doubt it will happen.

More likely IMO is that N reg will be retained although under more control by EASA

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