IAOPA sets out its stall on PPL licensing to the US and Europe
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Your instructor knows you well, knows your flying good and bad habits and is more likely to turn a blind eye. You dont go for a driving test and do it with the guy who taught you to drive you need an unbiased outside view of your abilities!
If we are expecting IR privalages in Europe rather than actually attaining and holding equiavalent licences is it not better to satisfy a European examiner representing EASA that we are up to the standards expected and save a fortune in the process.
- my aviation authority to respect ICAO papers
- instrument privileges to be maintained through verifiable currency requirements
I cannot see EASA letting an 18 year old with 200 hrs total give that approval!
- EASA is costing the taxpayer (you and me) € 105 Million a year. I think we deserve EASA to accurately weigh cost / benefit effects in the regulatory drafting process. And the weighing should be based on a real analysis, not some "sentiment" like in the preamble of the Basic Regulation.
...partly for job protection reasons and partly because it is American.
Last edited by proudprivate; 4th Jul 2012 at 15:52.
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I wonder what the pass rate is for renewals in Europe.
Even commercially there is some failures of pilots that are weekly doing 6 IFR approaches.
Even commercially there is some failures of pilots that are weekly doing 6 IFR approaches.
Last edited by mad_jock; 4th Jul 2012 at 15:54.
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What is the point of conjecturing why the FAA system might not work in principle (200hr 18year old CFIs, rolling currency etc) when it so self-evidently works in practice, and, to my knowledge, there is no evidence that the various conjectured problems actually manifest themselves? It's not as if the "sample size" is inadequate, since the US has probably 100x the volume of private IFR in Europe.
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Try 1000x if not 10 000x in GA aircraft.
And even the much touted 65000 FAA pilots in europe. I suspect that there in less than 1500 flying IFR on there FAA tickets including commercial.
And even the much touted 65000 FAA pilots in europe. I suspect that there in less than 1500 flying IFR on there FAA tickets including commercial.
Last edited by mad_jock; 4th Jul 2012 at 17:23. Reason: missed a 1
If I don't agree with you, proudprivate, the only conceivable explanation is that I'm corrupt and self-serving, right?
I notice that your assertions trivialise the debate. Some of your previous interventions do not mark you as particularly stupid. It's therefore only logical to question your motives.
Now tell me, are you or are you not making money from Aviation Regulation in Europe, be it as a consultant to the UK CAA on regulatory matters, a temporary agent at EASA, or a similar occupation ?
You keep trotting out the statistics thing:
First, notice the absence of any safety statistic in your argument.
The UK for example has a much more flexible approach to fuel planning than the FAA's 91.151 etc., and you'll find that the incidence of fuel exhaustion accidents is no higher in the UK than in the US. Will you petition the FAA for repeal of 91.151 then?
By contrast, FAA studies show deteriorating pilot skills with inexperienced PPLs, which is their main motivator for a BFR. I would guess that, based on the skills affected (some are affected more than others, and some are more safety related than others), an impact study would reveal a statistically significant accident increase in the absence of a BFR. This should then be weighed against the alternative of having pilots log particular exercises in lieu of a BFR. The conclusion would probably be that, systematically logging a bunch of unverifiable items would not outweigh a one off cost of a BFR.
The whole point of the debate lies in a cost/benefit balance, where the benefit is safety. It is certainly worthwile doing an impact study (a real one, not an EASA one where you twist assumptions to suit your needs) about the need of a medical for private flight, but that is not the issue here.
Last edited by bookworm; 4th Jul 2012 at 17:37.
The position I think we should be debating is the EASA/JAA vs FAA/ICAO one of the role of instructors vs examiners and the requirements for currency. I am qualified under both, although I have only a little ad-hoc instructing experience.
Provided needless bureaucracy is eliminated, I see no reason why the examiner system should not be cost effective. I pay mine about £60/hour, which given the differences in other aviation prices between the US and the UK doesn't seem unreasonable.
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the incidence of fuel exhaustion accidents is no higher in the UK than in the US.
One only has to briefly dive into any US pilot forum and see the discussion topics there, versus the UK ones
It's a different universe.
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The UK for example has a much more flexible approach to fuel planning than the FAA's 91.151 etc., and you'll find that the incidence of fuel exhaustion accidents is no higher in the UK than in the US. Will you petition the FAA for repeal of 91.151 then?
I enjoy your posts which are very detailed and informative especially on legal matters
Peter has a very valid point re fuel as the mission profiles tend to be very different in the USA to Europe with larger distance spreads.
This usually means that fuel considerations are more critical than the majority (not all flights) Over here.
You would expect the incidence of fuel shortage would be higher in the USA! If it is the same that would infact give the USA a better record.
Pace
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Aviation accidents are fortunately sufficiently rare that it's almost impossible to find any statistically significant result, particularly when comparing systems with many other differences. Your default seems to be to suggest that in the absence of statistical significance, everyone must do it your way. I'm afraid that doesn't wash.
I give what feel like copious amounts of my own time to attempt to protect the interests of pilots like you.
The UK for example has a much more flexible approach to fuel planning than the FAA's 91.151 etc., and you'll find that the incidence of fuel exhaustion accidents is no higher in the UK than in the US. Will you petition the FAA for repeal of 91.151 then?
I'm sure you can find other differences where 14 CFR is more restrictive than LARS. They're just not very relevant to the discussion here.
Yet you seem to be content with the idea of a BFR as being a reasonable and cost-effective safety measure taken by the FAA, and you "guess" it has an impact. I think you "guess" wrong.
- some FAA statistics on accident rates vs pilot hours
- an FAA study about deteriorating skill sets in low hour PPLs (but admittedly, that study was more qualitative and certainly not normalized for minimum logged hours)
But if the BFR isn't even necessary, why are you then advocating annual sessions with an examiner ? I would be in favour of a minimum logged hours regulation in lieu of a BFR or an annual check ride.
The cost of a medical affects vastly more pilots in the EU than an IR prof check. There is precious little evidence of its efficacy as a safety measure in private aviation. Why don't you focus some effort there?
But in absolute money terms, the annual IR proficiency check is much more expensive than even an annual medical. We're talking a factor 3-4 here. The fact that there are so few IR rated JAA private pilots in Europe (why would that be ?) shouldn't distract us from the fact that the maintenance cost of this privelege, which is essential if you want to go places by plane, is simply much to high.
Last edited by proudprivate; 4th Jul 2012 at 21:00.
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Bookworm
EASA are dealing with the private pilot part first. I have it on good authority that while 2014 is the official deadline, That EASA already have accepted that 2014 will be extended to 2016!
Commercial licences will be addressed after the private Pilot FCL aspect.
Yet from what i have also heard Commercial FCL is a bigger headache for EASA as far as legality regarding dual licence requirements.
It would be interesting to have your take on how you think the commercial CPL and ATP on FAA in Europe would be treated in a Bi lateral agreement? as well as the enforcement of the existing structure on employed pilots flying FAA aircraft within Europe?
Should an agreement occur regarding private licences how would that effect the legality of enforcing dual licences on commercial pilots??
Pace
EASA are dealing with the private pilot part first. I have it on good authority that while 2014 is the official deadline, That EASA already have accepted that 2014 will be extended to 2016!
Commercial licences will be addressed after the private Pilot FCL aspect.
Yet from what i have also heard Commercial FCL is a bigger headache for EASA as far as legality regarding dual licence requirements.
It would be interesting to have your take on how you think the commercial CPL and ATP on FAA in Europe would be treated in a Bi lateral agreement? as well as the enforcement of the existing structure on employed pilots flying FAA aircraft within Europe?
Should an agreement occur regarding private licences how would that effect the legality of enforcing dual licences on commercial pilots??
Pace
Last edited by Pace; 4th Jul 2012 at 22:01.
Peter has a very valid point re fuel as the mission profiles tend to be very different in the USA to Europe with larger distance spreads.
This usually means that fuel considerations are more critical than the majority (not all flights) Over here.
You would expect the incidence of fuel shortage would be higher in the USA! If it is the same that would infact give the USA a better record.
This usually means that fuel considerations are more critical than the majority (not all flights) Over here.
You would expect the incidence of fuel shortage would be higher in the USA! If it is the same that would infact give the USA a better record.
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Bookworm
I take your point to a point
But still think we have a cancer of state created jobs in Europe where their own interests are priority rather than the interests of the industry they serve.
Ie they regulate for regulation sake which all turns out as needless expense both to the tax payer and industry.
EASA could have copied the tried and tested FAA system obviously with European needed adjustments.
They would have saved a fortune, freed up the industry and made a bi lateral a simple affair as was the case with the FAA and Canada.
Rather than that they took the route that suited their own and political interests rather than that of the industry and their mandate of safety.
Pace
I take your point to a point
But still think we have a cancer of state created jobs in Europe where their own interests are priority rather than the interests of the industry they serve.Ie they regulate for regulation sake which all turns out as needless expense both to the tax payer and industry.
EASA could have copied the tried and tested FAA system obviously with European needed adjustments.
They would have saved a fortune, freed up the industry and made a bi lateral a simple affair as was the case with the FAA and Canada.
Rather than that they took the route that suited their own and political interests rather than that of the industry and their mandate of safety.
Pace
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And demanding that we do something the FAA way just because there is no statistically significant evidence that a different way is better is not a reasonable position to take.
(1) Trying to minimize regulatory burdens in the absence of valid documented anecdotal evidence or statistically verified evidence that significantly impact safety.
(2) Trying to harmonize Aviation Regulation worldwide (which is both an ICAO and an EASA concern).
Now you have just given us two good examples that it doesn't have to be the FAA way (fuel considerations and the necessity of a BFR).
But the way you formulate it reeks of an unhealthy anti-American sentiment. And the fact that certain elements complicate an interpretation of statistical data shouldn't be used as an excuse to impose a more burdensome regulation.
Recall the Seebohm quote :"We need this regulation because at present there isn't one". Now that is what I would call not a reasonable position to take !
A lot of the Euroland regulatory stuff is there not because of a specific safety consideration, but because "we can do it differently". It is this European Identity Crisis fueled regulatory drive that we should stop.
Last edited by proudprivate; 5th Jul 2012 at 11:19.
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The UK for example has a much more flexible approach to fuel planning than the FAA's 91.151 etc., and you'll find that the incidence of fuel exhaustion accidents is no higher in the UK than in the US. Will you petition the FAA for repeal of 91.151 then?
No. Because I make it my personal rule to always land with an hour of fuel on board, even when VFR.
The UK for example has a much more flexible approach to fuel planning than the FAA's 91.151 etc., and you'll find that the incidence of fuel exhaustion accidents is no higher in the UK than in the US. Will you petition the FAA for repeal of 91.151 then?
No. Because I make it my personal rule to always land with an hour of fuel on board, even when VFR.
I'm not quite sure where you get your impression of costs from. My annual MEP/IR renewal costs me about £180, for which I tend to get about 3 hours of the examiner's time, and I almost always derive useful insights. If I didn't have to do the exam, I'm be doing equivalent time in the air practising anyway. And the requirement for an annual IR prof check affects a tiny proportion of the private flying population. And you'd have to offset the cost of the BFR that you're proposing in its place.
My medical costs me £120, just like the other hundred thousand EU pilots (not to mention US pilots) who have to go through the process. For that I get about 30 minutes, and my AME has never found a problem. It's not that I'm ungrateful, but that's a much lower value-cost ratio than I get from the checkride.
Your habit of loading an extra 30 mins of fuel costs you too. CAT burnoffs are of the order of 5% per hour, SEP/MEP probably a bit less as we fly faster relative to best L/D. But if you call it 3%, then carrying an extra 30 mins of fuel than you need will cost you of order 1 minute of fuel per hour you fly. That's of the same order of magnitude of annual spend as a medical or a prof check. But I'm sure the value you get from it is in peace of mind and the time you save not having to do the math...
proudprivate, I'm a firm believer in the idea that regulation should bring a positive benefit-cost in terms of safety. The principle is worth repeating to EASA, and we do, again and again. But you're fixating on a single issue, which doesn't deserve the priority that you want IAOPA to give it. Is it possible that you're as nervous of "demonstrating your competence" to an EU examiner as I would be of demonstrating mine to 421C?
But the way you formulate it reeks of an unhealthy anti-American sentiment.
Originally Posted by peterh337
One only has to briefly dive into any US pilot forum and see the discussion topics there, versus the UK ones It's a different universe.
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BookWorm
You should not be nervous of 421C very nice informed guy I have not done a Bi Annual for years as keeping a current annual type rating negates the need for the Bi Annual.
But I do renew my JAA multi and its always good to go into any flight test with the thought of getting the max out of it.
The better the instructor/examiner the better and more you learn from the experience. We need to be pushed and challenged.
I always remember being checked out for a Citation position as then a co pilot.
The check pilot on the trip was an ex squadron leader. On meeting him he appeared to be a total pussycat and I got into the aircraft with absolute confidence.
My God what a change! The Guy was a total Rottweiller, very precise very demanding and by the end of the flight I felt I knew nothing.
I was about to thank him for the experience and slink off tail between my legs when he commented no you were fine.
So dont go by appearances only attitude! Yours
Surely 421C is not that fear invoking? Is he?
Pace
You should not be nervous of 421C very nice informed guy
I have not done a Bi Annual for years as keeping a current annual type rating negates the need for the Bi Annual.But I do renew my JAA multi and its always good to go into any flight test with the thought of getting the max out of it.
The better the instructor/examiner the better and more you learn from the experience. We need to be pushed and challenged.
I always remember being checked out for a Citation position as then a co pilot.
The check pilot on the trip was an ex squadron leader. On meeting him he appeared to be a total pussycat and I got into the aircraft with absolute confidence.
My God what a change! The Guy was a total Rottweiller, very precise very demanding and by the end of the flight I felt I knew nothing.
I was about to thank him for the experience and slink off tail between my legs when he commented no you were fine.
So dont go by appearances only attitude! Yours
Surely 421C is not that fear invoking? Is he?
Pace
Last edited by Pace; 5th Jul 2012 at 12:03.
Commercial licences will be addressed after the private Pilot FCL aspect.
Yet from what i have also heard Commercial FCL is a bigger headache for EASA as far as legality regarding dual licence requirements.
It would be interesting to have your take on how you think the commercial CPL and ATP on FAA in Europe would be treated in a Bi lateral agreement? as well as the enforcement of the existing structure on employed pilots flying FAA aircraft within Europe?
Should an agreement occur regarding private licences how would that effect the legality of enforcing dual licences on commercial pilots??
Yet from what i have also heard Commercial FCL is a bigger headache for EASA as far as legality regarding dual licence requirements.
It would be interesting to have your take on how you think the commercial CPL and ATP on FAA in Europe would be treated in a Bi lateral agreement? as well as the enforcement of the existing structure on employed pilots flying FAA aircraft within Europe?
Should an agreement occur regarding private licences how would that effect the legality of enforcing dual licences on commercial pilots??
I've always hoped that the FAA-TC bilateral would be the model for an FAA-EASA bilateral on licensing. Rumour has it that progress is slow, and I'm awaiting further reports from the Cleveland get-together.
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I've always hoped that the FAA-TC bilateral would be the model for an FAA-EASA bilateral on licensing. Rumour has it that progress is slow, and I'm awaiting further reports from the Cleveland get-together.
I have also heard that due to some previous agreement that EASA can not go ahead with the existing structure without FAA blessing ????
Something which they totally missed
Pace
Last edited by Pace; 5th Jul 2012 at 13:30.