IAOPA sets out its stall on PPL licensing to the US and Europe

[bookworm]

But you're happy with me saying "bilateral", or does that mean something different too?

[flybymike]

No (am)biguity there at all...

[Pace]

You ry wirting on an e pun : )

[peterh337]

Indeed, I think you missed the glory days of rec.aviation, but I learned more from rec.aviation.ifr than I ever have from PPRuNe

Maybe I missed the glory days but I remember it well. Quality discussion has moved to web forums but there has been a huge drop in quality over the years - I think partly (initially) due to the old hands having got bored with going over the same old stuff, and more recently because so many people post with Iphones which reduce postings to banal one-liners because (even assuming the user can actually write) writing anything meaningful is too much bother.

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,

As I have always said, any bilateral treaty on FCL cannot possibly deliver anything substantially better than the "standard European way" of converting FCL papers.

There will always be some exams, and there will always be a flight test. There may be acceptance of foreign training (like in the CBM IR proposal, but FTO pressure all but killed that route by demanding 100hrs instrument time, which probably equates to 1000+hrs TT, and ensures FTOs don't lose revenue by ATPL cadets doing FAA CPL/IRs in the USA first) but the fact that you have to pass the UK IRT, with its NDB work, means that such a concession is moot since practically nobody will pass the IRT without being in the clutches of an FTO (or fly with a freelance CRE/IRR) for many hours....

So you may get the treaty but it won't mean much in practice, to the actual process.

[Fuji Abound]

flybymike
*
Join Date: May 2001
Posts: 1,466
Biennial Biennial Biennial BIENNIAL GODDAMMIT!


I think you will find it is God dammit.

[flybymike]

I forsaw the possibility of some pedant like me raising the spelling of that expletive, and therefore Googled the most popular spelling before I posted. At that time it seemed to be the way wot a rote it! However, latest Google shows approx 50/50 split with two separate words! or even three (God damn it!)

[proudprivate]

Ah the rationalisation (sorry, I mean "rationalization") of my motives continues. Not self-interest, not corruption, not stupidity, what's left? Ah, must be xenophobia.

No. The impression comes in part from your trivialising the debate on cost benefit with making dismissive remarks style "So it has to be the FAA way, huh, well that just doesn't wash" that convey an impression of anti-americanism. The impression was fuelled many months ago with your rants about US congressional protectionism.

I don't think xenophobia would a motivator for your stance. There are plenty of both stupid and xenophobic people on PPrune, but I at least think you are neither.

But I do know some people in this debate (at the European Commission for instance) that are so frustrated with some parts of US diplomacy that their emotions get in the way of common sense during a negotiation. If it were just Seebohm, that wouldn't be problematic, but the number of people at key positions who are keen on "getting even with the US" has risen too much.

A true advocate of positive cost benefit in general aviation would still support burden relief, even if it meant losing an opportunity to get even.


The topic of this discussion is IAOPA seemingly accepting a need for annual re-examination, which I find difficult to understand, let alone underwrite.

You say

I'm not quite sure where you get your impression of costs from.

Well, a private pilot needs a medical every 2 years (or every 5 years for an FAA pilot under 40). That takes an appointment, a 30 minute drive, a 15 minute wait, a 30 minute examination (including the typing up) and another 30 minute drive home, for a cost of € 90 (£ 80), or € 45 per annum.

A check ride with my favourite JAA examiner costs me € 200. That is for a 1.5 hour flight and another 1.5 hours of preflighting, taking the plane out of the hangar, answering a few oral questions and the debrief. The 1.5 hour flight time cost me, depending on the plane I'm renting, about € 200 wet.
That adds up to € 400 per annum, or a factor 8-9.

As I fly regularly and almost systematically fly a variety of instrument approaches, I normally retain currency just by traveling, because one of the regular ones includes a hold. Admittedly, at times I could have saved money and time by requesting a visual, and it is indeed the currency regulations that make me do this, so in all honesty I have to concede that I'm adding about € 150 in extra costs flying vectored VOR approaches for the sake of regulation. That would make it a factor 2. But it is a lot more convenient than having to schedule and maybe reschedule an appointment with an examiner to get the obligatory annual check ride out the way.


Then you go on a tangent again as regard fuel costs and carbon constraints in relation to 14 CFR 91.151 (VFR fuel requirements), which frankly make me wonder whether you weren't reading rec.humor as opposed to rec.aviation.

I'm flying regularly relatively long stretches with small aircraft, so that wind actually becomes a factor in the range and the actual time recorded at progressive waypoints in the flight log becomes a meaningful contribution to flight safety. (If the 5 knot tailwind that I currently have were to turn into a 35 knot headwind, I would run into trouble 4 hours from now).

During the few "emergencies" that I've encountered (airport closed after a 3 1/2 hour flight because I had read the wrong notam source; a vacuum pump failure at night; a landing gear problem that required manual extension) I was really glad to having adhered to that principle of flying around with 4 -12 gallons "too much". I'm a big fan of Rod Machado, and he is also advocating "landing with one hour of fuel".

If someone were to propose a regulation change that would lower the minimum fuel requirements, I for one wouldn't object. But I don't feel the urge to petition it myself. I wouldn't think Rod is sponsored by the oil companies either.

Is it possible that you're as nervous of "demonstrating your competence" to an EU examiner

I hope you're not questioning my competence here. Having demonstrated my competence to a JAA examiner in the past, I didn't find the experience particularly nerve racking. And it shouldn't, unless of course you're referring to that C170 chip on the shoulder nutter that Peter was talking about the other day.

And the requirement for an annual IR prof check affects a tiny proportion of the private flying population.

This is, as I've already told you, a bogus argument. Why do you think there are so few JAA IR private pilots ? Because the theoretical part of the training is expensive and to a large extent irrelevant. And because the maintenance is such a bother. In fact, if it weren't for the 700 hour conversion in the old days, the proportion of the private flying population affected would even be tinier.


In conclusion, I continue to find it strange that IAOPA, which would have more members if it took a more principled stance on trying to minimize regulatory burdens in the absence of valid evidence of a regulation requirement and on trying to harmonize Aviation Regulation worldwide, seems to accept annual examinations and air law exams as if it were the normallest thing in the world.

[mad_jock]

You lot are making the mistake yet again thinking any of this is to do with safety.

Its purely to get european residents flying with european licenses.

You can argue up down left right and even if you are right it won't matter a bollocks.

[Fuji Abound]

Mad Jock

That strikes a cord.

The older and more stupid I get the more I find myself finding we have these discussions here (and they are interesting) but do our discussions make any difference? Does anyone of note read them, and if they did do they have any influence what so ever on the process? I suspect they don't, so as interesting as it maybe, its all rather academic.

I think in so many walks of life people feel they are disconnected from the political process and to make matters worse I am not even sure this is a political process.

I hate to say it because I am a passionate believer in discussing and "fighting" to preserve our rights but I suspect all the debate on here will come to nowt. I campaigned fervently with regards the IMCr including using the good services of this forum and I think it kicked up enough discussion to be worthwhile but it takes a great of effort and has to go well beyond the type of discussions we usually have here.

So Proudprivate as interesting as it is I would caution you not to spend to many hours over the keyboard or expect much to come of the views you and others have expressed however sensible some of them may seem. If you want to achieve anything your time would be better spent in other ways (but expect to devote a great deal of it), but if you just enjoy the debate then all well and food. Whatever you do don't get wound up over it because most of it is for fun's sake, albeit some on here may get there fun from debating in different ways. So whatever you do don't take it too much too heart and don't expect it to achieve very much if anything in the real Euro world

Sad to say but there it is.

[mad_jock]

Tis true Fuji.

The other thing thats laughable is that the pilots of europe are going to unite to save the rights of N reg pilots. When really most of us really don't give a toss if they get to fly or not.

We can disgagree or agree about the requirement of a nations right to oversee its own residents.

But the idea that pilots across europe are going to take a united front against EASA is in the planet Zanussi FIR.

You can't get 2 pilots to put a united front up against a urinal never mind bring a legal action. 3 pilots and then one of them will start pissing on the others shoes.

[peterh337]

I don't think discussing anything on any forum ever changes the political process, but it does raise awareness of an issue in the wider community.

There are plenty of people who are in positions to apply pressure in the right places, who would not have heard of it otherwise. Most of them don't post on forums. The countless emails I receive from other pilots are a witness to that.

Business jet pilots in particular are notorious for having their heads stuck in the sand.

When really most of us really don't give a toss if they get to fly or not.

You mean YOU don't give a toss if anybody else gets to fly or not. That much is self evident. Fortunately not everybody holds that position.

[Fuji Abound]

peterh337

Yes, you are right, I receive similar messages (particularly in the past in relation to the IMCr); there is no doubt some of our discussions do raise awareness. Having said that I think it does tend to be on the more subtle elements of legislation that are often intended to have far wider implications that at first blush might appear the case (lets see if we can slip this one through). The more obvious stuff is usually quite well picked up by AOPA and the other representative organisations.

Unfortunately Mad Jock is right for whatever reason pilots seem to be the most disconnected fraternity when it comes to mounting any sort of front as you and I well now with regards the IMCr. I have never understood entirely why, may be it is something to do with the mentality of too many pilots. Whatever the reason the community is a very easy target for the technocrats and in Europe despite some of the huffing and puffing quickly roll over. It is as you know a very different story in the States.

Sorry to be despondent.

[mad_jock]

Nope pretty much all of the 450,000 pilots in the EU don't give a toss because basically it doesn't effect them one little bit if the FAA pilots get shafted. For a very small percentage of Biz jet pilots it may allow them to either get a foot in the door if they are quick

I do give a toss though for

Permit aircraft
Microlights
Gliding
IMCr (and its replacement)

And the instruction of exercises 1-13 done properly for the PPL students in Europe.

[peterh337]

pilots seem to be the most disconnected fraternity when it comes to mounting any sort of front as you and I well now with regards the IMCr. I have never understood entirely why, may be it is something to do with the mentality of too many pilots.

It's indeed an interesting social phenomenon...

I think the explanation starts with anybody who wants to fly having to be a pretty obscessed individual - due to the grotesque over-regulation one has to put up with.

My son (16) more or less gave up getting on with the PPL, once he saw the contents of the books. I would say 90% of the stuff is not relevant to any form of aviation.

So only the most determined individuals make it through and hang in there long term.

The pressure continues through one's flying life. There are license renewals, medicals (every time you visit the AME you have no idea whether your aviation days will be over that day), and more fun for aircraft owners

Then you get the standard "volunteer organisation nightmare" whereby often the most obnoxious tend to rise to the top, because nobody else wants to (or is able to find the time to) do the job.

That's why there is so little social cohesion in GA.

You see (saw) the same thing in the communist regimes. Because everybody was under constant pressure (in the form of surveillance, even in the office, and general hassle through one's life, just making ends meet, etc) most people were quite ready to stab each other in the back to get any advantage. People in e.g. East Germany and Czechoslovakia were horrid towards each other.

[proudprivate]

As a quick reminder about what this thread is about...

Its about

- IAOPA representing a specific point of view as regards ICAO conversion and annual re-examination, which I could understand if it came from the "National Association of Examiners" but not from them.

- The need for regulatory burden relief for pilots and the overarching necessity to consider cost vs benefit (Mode S, 8.333 kHz, Part M etc in Europe, but also semi-annual medicals for FAA ATPs (although that is not related to private flying) and medicals "tout court" for private flight)

and to a lesser extent

- the ICAO wide regulatory harmonization effort.

It is not about

- the effects of the implementation of part FCL on EU resident operators.

[mad_jock]

It is not about

- the effects of the implementation of part FCL on EU resident operators.

But it is, its all part and parcel of the grand plan.

Get the legislation through on a promise then ensure that the condition can never be met.

To get what you want would then allow the critiria to be met for a one to one transfer which will never happen come hell or high water.

Give it 10-15 years and the numbers of N reg based in europe reduced to a small fraction of what it is just now there maybe some agreement. But I doudt it because the yearly check is pretty enshrined in the way things are done in Europe. Just like doing a high content of theory.

[Fuji Abound]

I thought it was about the four pages of discussion as to why we should or shouldn't have check rides or hop through other regulatory hoops because you (and others) consider the hoops have no safety benefits nor any other good reason for the hoops to be there in the first place.

I was simply pointing out that you shouldn't spend too much time on the discussion in the expectation of changing anything because it is already very well rehearsed and very unlikely to change any time soon. Aviation is full of hoops and guess what the regulators will probably go on creating a few more, because if they don't they wont have a job!

So as I said earlier enjoy the discussion for discussion sake but don't fall out with anyone over it or get upset. If you really want to achieve anything you will need to go about it another way. If you do (go about it another way) I wish you the best of luck.

[bookworm]

The impression comes in part from your trivialising the debate on cost benefit with making dismissive remarks style "So it has to be the FAA way, huh, well that just doesn't wash" that convey an impression of anti-americanism. The impression was fuelled many months ago with your rants about US congressional protectionism.

For what it's worth, I remain convinced that the EU needs an independent regulatory system, because the FAA has the dual mission of both regulation and promotion of US aviation interests. To allow the FAA to dictate regulation globally would be akin to allowing the Yankees to write the MLB rulebook (Home runs now count double -- because the fans want it, of course, not because it favors the Yankee lineup, no sir )

That doesn't mean that we shouldn't learn the lessons of a much larger aviation market, particularly for GA. But there are social, political, economic and structural factors that affect the insights gleaned.

The topic of this discussion is IAOPA seemingly accepting a need for annual re-examination, which I find difficult to understand, let alone underwrite.

Cost-benefit rears its head not just in optimal regulation, but also in optimal lobbying. There's an element of realpolitik, and it might be better to strive to drive down the cost of examination rather than try to change the examiner/instructor roles. I also remain convinced that there is merit in separation, but not at the expense of creating, as you put it, an oligopoly.

I hope you're not questioning my competence here. Having demonstrated my competence to a JAA examiner in the past, I didn't find the experience particularly nerve racking.

I was questioning your confidence, not your competence. I think you make too much of the difference between a prof check and a flight review.

This is, as I've already told you, a bogus argument. Why do you think there are so few JAA IR private pilots ? Because the theoretical part of the training is expensive and to a large extent irrelevant. And because the maintenance is such a bother. In fact, if it weren't for the 700 hour conversion in the old days, the proportion of the private flying population affected would even be tinier.

The disincentives are the TK and the very long flight training course for those who may already have good skills. Maintenance costs (beyond the sensible requirement to stay current) are minimal in the context of most EU-based IR pilot's flying spend.

In conclusion, I continue to find it strange that IAOPA, which would have more members if it took a more principled stance on trying to minimize regulatory burdens in the absence of valid evidence of a regulation requirement and on trying to harmonize Aviation Regulation worldwide, seems to accept annual examinations and air law exams as if it were the normallest thing in the world.

I don't think you'd say that if you'd read the joint EAS/IAOPA submission on regulation of GA and the corresponding working group paper for the EASA Management Board (which is being finalised today I think). But if I were running such an organisation, I'd be thinking about the value to my members of a principled loss compared to a compromised win based on the art of the possible.

[peterh337]

I remain convinced that the EU needs an independent regulatory system, because the FAA has the dual mission of both regulation and promotion of US aviation interests. To allow the FAA to dictate regulation globally would be akin to allowing the Yankees to write the MLB rulebook

Yet, that argument is totally spurious because the fact is that the FAA does not abuse the system.

The FAA provides US-taxpayer-subsidised "more or less everything"... pilot licensing, aircraft and equipment certification, certification of modifications, you name it.

Nearly all of it is totally free. I have just got an FAA FSDO to approve a custom AFMS for my GPS, allowing me to fly GPS approaches. (The aircraft was always OK; it was just a paperwork exercise, which 3 or 4 UK avionics shops failed to achieve in past years). Cost to me? Zilch. Well, I had to pay the UPS document return cost because a got a friend out there to present it on my behalf. Before that, I got a fairly nontrivial EHSI installation approved, also free. In EASA-land, that would have been into 4 digits, as a starting point. With certain negatives (hassle, in essence, unless you have "contacts" out there) this great system is accessible to FAA pilots worldwide.

If you were to call that "promotion of US aviation interests" then please can I have some more! Let's shut down EASA while we are at it; it doesn't do anything useful, despite pretending to preserve "safety" in this little corner of the globe.

Instead, EASA abuses the ICAO licensing/certification system. It is staffed by people who ostensibly do their best, and this may be true for the most part at the individual level where I dare say they believe in their mission, but the organisation as a whole is set up to deliver a gold plated system which is for the most part not based on safety data or any other evidence, and is particularly set up to channel business to a small number of EASA Part 21 approved companies, who are able to make nice money out of certification, and out of developing EASA STCs which are their "intellectual property" even though they are almost totally based on stuff immediately found in the FAA approved installation manuals...

EASA also runs some heavily and completely unashamedly politically motivated agendas... discussed here already.

[mm_flynn]

Originally Posted by mad_jock

... But I doudt it because the yearly check is pretty enshrined in the way things are done in Europe. Just like doing a high content of theory.

And I think that is the nub of the issue. An important fraction of the European aviation community likes the 'high touch, high cost' approach to aviation in Europe and are not at all fussed that it results in a system with higher intrinsic cost, lower utility, and generally worse safety records. But, it has rigour!

I think that despite the protestations by many as to the lack of objective basis the European position, poor cost benefit, comparable alternative approaches, etc. Some aspects of this are so deeply entrenched in the regulatory mind set that it would be reasonable for an organisation such as IAOPA to conclude they can not be shifted for any feasible amount of money are effort. As such, you conclude that any attempt to achieve a bi-lateral agreement that exempts certain pilots based in Europe from one of these touchstones (the annual revalidation) is going to sink the greater project.

I am only an observer, but in all my time in Europe, I have seen almost no evidence of European organisations rolling back the level of cost/intrusion of regulation and as such, agree IAOPA's approach is pragmatic. The list of onerous regulations is long and an annual flight review is not that high up the list in my book.