First of all, I dispute the need for a test. As Silvaire is pointing out repeatedly, the BFR is not a test. It is an opportunity to iron out potential deficiencies, and your trusted instructor is the perfect person to help you with that.

No. I would expect
- my aviation authority to respect ICAO papers
- instrument privileges to be maintained through verifiable currency requirements

- Who needs the approval of an 18 year old ?

- 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.

disgraceful ! If they did their job properly, no private pilot in Europe would want an FAA certificate.

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.

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.

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.

So if I don't agree with you, proudprivate, the only conceivable explanation is that I'm either stupid or corrupt and self-serving, right? Sorry I got that wrong first time.

I am not. I give what feel like copious amounts of my own time to attempt to protect the interests of pilots like you. I have to confess that occasionally I wonder why.

You keep trotting out the statistics thing:

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.

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?

In pre-JAA days, there was no "BFR" in the UK for PPLs, just a bi-annual requirement for a few logged hours. The CAA has analysed the "statistics", and of course demonstrate that there is no significant difference in safety since the introduction of the requirement for a bi-annual instructional flight. 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.

Let me end by agreeing with you. 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?

Indeed, and it is the blurring of the instructor and examiner roles that I find difficult to accept (though not as difficult as EASA's insistence that the examiner can not have given the student a single lesson). I salute you as an instructor 421C, as I've seen your teaching skills. I'd fear you as an examiner, but I suspect that's more about me than about you. ;)

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.

Fuji
Thank your for your very decent reply #41 above, following my rather blunt words.
brgds
421C

That could be simply due to the typical UK GA mission profile, which due to the severely crippled utility value in UK GA (airports closing ~6pm, lack of IAPs, etc etc etc) comprises mostly of short local burger runs, on which fuel doesn't matter unless you depart with practically empty tanks.

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.

Bookworm

I enjoy your posts which are very detailed and informative especially on legal matters :ok:
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

No. In the absence of statistical evidence or relevant anecdotal evidence (such as documented accidents or incidents), you choose the most cost effective way. I don't care whether that is my way, or Whopity's way, or 421C's way or Goudot's way, or even Seebohm's way.

Sorry I got that wrong. I must say you have a great cover.

No. Because I make it my personal rule to always land with an hour of fuel on board, even when VFR.

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.

I haven't done the impact study. If there isn't a significant impact, there is a case for getting it scrapped. My guess was based on
- 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.

Because that is an ICAO requirement, with a powerful medical lobby; much more powerful than the flight school lobby at EASA. Why don't you suggest your contacts at EASA to table it ? I'm sure the GA community would welcome it.

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.

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

But that, Pace, is the point. There are always lots of complicating factors. 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.

Bookworm

I take your point to a point:E 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

Actually, that is an reasonable position to take, because of two important considerations :

(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.

Right. And I make it a personal rule to get checked out by an experienced pilot once a year, in exchange for a fee for his time of course. Rules seem to be fine with you as long as they're consistent with your own habits and practices, even though, in a carbon constrained world with AvGas at £2/litre, they seem to be a profit creation scheme for fuel companies. But the ones that are consistent with mine are "bogus safety arguments to perpetuate job schemes for flight examiners".

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? ;)

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. Hardly worth looking up from the ballgame I'm watching to dignify that one with a response.

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.

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? :E

Pace

I guess I owe you an answer to this one. AFAIK, flight crew of commercial operations based in the EU already need EASA licences. So I guess you mean non-commercial ops using remunerated flight crew, like corporate ops. I wasn't aware that CPL/ATP was being treated any differently from private licences in that regard.

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.

Sorry to clarify ATP and CPL on corporate hence private GA! What I have heard is that there is an acceptance that 2014 will not be met and that is likely as long as there is progress towards a Bi Lateral that that will change to 2016.

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

Biennial Biennial Biennial BIENNIAL GODDAMMIT!