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-   -   N-reg situation update (https://www.pprune.org/private-flying/482087-n-reg-situation-update.html)

mad_jock 25th April 2012 11:42

Neither me or Bose have any problems with fellow european pilots.

We are just telling you something that you don't want to hear.

Having a personal attack on everyone that tells you the bad news isn't going to change the situation.

It really doesn't matter who you employ and what tickets they have. Its not going to change the politics of whats going to happen.

S-Works 25th April 2012 11:44

Thomas, I think you have misread what I wrote. I am not wishing anyone out of a job, I merely pointing out the facts. My original post about filling the gap which seems have vanished did have THREE raspberries after it indicating it was meant to be tongue in cheek humour.....

I don't need your job by the way, I have enough to do with my own....

FAA commercial pilots are not being denied a living, they are just being told they ALSO have to comply with EASA rules. That does not deny them the right to feed there children, it just means they have hoops to jump through.

This is no different from an EASA pilot wanting to go and work in the USA. You have to convert and I see nothing wrong with that.

I think the conversion path is more onerous under EASA than it needs to be and thats something that seems constantly being failed to be addressed but even so for a current commercial pilot especially a type rated one its not insurmountable.

Pace 25th April 2012 11:48

If that is the case then why dont you fight the system that is costing our industry so dear instead of fighting the results of that system N reg.
Take away N reg and the system does not go away.


It really doesn't matter who you employ and what tickets they have. Its not going to change the politics of whats going to happen
Mad Jock what exactly is going to happen I am glad you know!!!



Pace

421C 25th April 2012 11:48


421, I AM NOT, Saying that at all. You of all people should know better
Sorry bose, I should have directed that differently. You have written your understaning of why we are where we are. I agree with it as an explanation but I feel obliged to push back on it whenever I see it written, if only because people writing it often enough (even as an explanation, as you have done) has a way of "normalising" it and making it seem "OK". I fully accept that you think it is a bad thing.

421C 25th April 2012 11:57


If that is the case then why dont you fight the system that
is costing our industry so dear
If I may say, knowing Bose in real life, he does his bit and more. You may not like his prose or his opinions at times, but I'd confine the discussion to that. He is highly experienced, highly and legitimately qualified (including his UK CAA Examiner approvals) and is a contributor to the GA community in his flying/teaching/examining and AOPA work well beyond the typical private or working pilot.

mad_jock 25th April 2012 11:59


If that is the case then why dont you fight the system
We have better things to fight for like the IMC and maybe we realise that you don't go into battle when you know your going to loose everything and for that matter there is great potential for making things worse in a system that we are fully intergrated into.

What is going to happen?

I think they will by hook, crook and what ever means they require, make EU residents and resident aircraft comply with local oversight and thier way of doing things.

Thomascl605 25th April 2012 12:13

Thanks Bose, for clearing that up.

I do disagree though that your comparison of a European pilot working in the US and converting doesn't quite stack up.

We are talking about two completely different things.

I am a European Pilot / Citizen who chooses to fly 'N' reg aircraft which happen to be in Europe. I have made a living like this for many years. I did not require a European licence to fly before and the FAR's do not state that a European licence is required to fly 'N' reg aircraft.

It's like the FAA specifying that you need an FAA licence to fly a European aircraft on say the German D register, that happens to be based in the US (even though you have a European licence) This of course wouldn't happen.

S-Works 25th April 2012 12:18


If that is the case then why dont you fight the system that is costing our industry so dear instead of fighting the results of that system N reg.
Take away N reg and the system does not go away.
Because I don't have the time or inclination to enter into a bun fight of that scale. It was easier for me to comply. ;)


It's like the FAA specifying that you need an FAA licence to fly a European aircraft on say the German D register, that happens to be based in the US (even though you have a European licence) This of course wouldn't happen.
Maybe, but that does not stop them owners of the airspace defining there own rules and that is where we are now. Although as far as I am aware the US do not allow you to operate a foreign reg on US soil long term.

Fuji Abound 25th April 2012 12:19


Bose

There is a significant dichotomy in your posts:

On the one hand you say:


You chose what was perceived and easier and cheaper system. Cheaper becauseit is paid for by tax payers in another country. A system that you only takefrom.


but then:


Do you really think I would not jump on the chance for EASA to just vanish
and the FAA system fill the void. Lets put it in perspective on how I and thecompany would benefit by that.




By implication you decry those who have taken the FAA route for the reasonsyou give, and with the next breath wish the same system was adopted.

I can understand a state or union wanting "control" of itscitizens. I also understand that in reality aviation operates on essentiallytwo levels - with inevitably some grey in the middle. There are thoseoperations that are truly international, essentially limited to the commercialoperators or upper echelons of the business jet market and the private operatorwho will spend their life within the bounds of Europe.It would be a farce to inhibit international operators and EASA has essentiallynot done so.

Where I part company with EASA is that as laudable as it maybe to exerciseregulatory control over your citizens you cannot ignore practices which havebeen endemic in Europe for almost as long asaviation. The CAA has time and again recognised the concept of"grandfathering" and EASA should do the same and in a way that givesfull and meaningful recognition to those that are already operating within thesystem. Inevitably as those grandfathered retire or fall by the way side the"new" system applies to all, and during the transition you have keptthe majority happy.

Whether the "new" system is better than others system is anentirely different argument. There are many of us who have thought for a verylong time Europe's approach to instrument rating private pilots is contrary toany claimed aspirations of creating safer pilots but that is another story.

Equally endemic in all of these discussions are those who take some delight in telling us "well, we do warn you, we told you it was coming". Yes, but do we need constantly reminding? And is their a slightly hollow ring when the same people plead they dont favour the new system on the one hand, but embrace it on the other. := I also am dual licensed so it really doesnt matter one wit to me, but actually it does, because I dont agree with what has taken place for the reasons set out. For that reason I will support Pace and everyone else on his side of the fence till the cows eventually come home and taken no pleasure at all for the hoops he may have to jump through to preserve the right to carry on doing what he has always done.

I will also never accept that EASA has embarked on an open and transparent process as suggested time and again by 421C. I maintain the process is flawed and I think more and more of the flaws are being revealed. Politicians have become terribly good at playing the cards in such a way that they are able to claim there has been consultation and that they have "listened" to the responses received, but in reality have had little or no intention of changing their original agenda. It is terribly easy to be taken in and not surprising given how well their techniques have been perfected - after all our friends in Europe have become particularly good at doing so. Fortunately the cracks are beginning to appear, and not just in so far as EASA is concerned. When times are good people will accept just about anything if you dress it up and make it look pretty, when times are not so good they tend to want to look underneath before they committ, or even after they have committed.

mad_jock 25th April 2012 12:22


It's like the FAA specifying that you need an FAA licence to fly a European aircraft on say the German D register, that happens to be based in the US (even though you have a European licence) This of course wouldn't happen.
And it really wouldn't bother anyone if it did require it. It would just be another card in the back of your green book with all the rest of the collection.

S-Works 25th April 2012 12:26


By implication you decry those who have taken the FAA route for the reasonsyou give, and with the next breath wish the same system was adopted.
Jesus, I don't decry anyone. I have merely stated a number of times how the situation currently is. Of course I would love EASA to cease to exist and be replaced by the FAA or an FAA like system. It would save me a fortune, but as it is not going to happen, we are where we are and we either have to put up or shut up.

I have chosen to adopt the compliance route. Others choose to complain.

There is no dichotomy in that.

Thomascl605 25th April 2012 12:54

I think it would bother the pilots involved MJ. But then again the FAA have a far more practical approach and wouldn't require an unworkable transition of 14 written exams and expensive flight tests, which couldn't be undertook whilst currently employed due to length of time it would take to pass the said conversion process.

The end result of all of this in Europe is that the Pilot is flying the same aircraft with a big 'N' on the tail, no differently than he/she has done before. We are not going to accept a conversion such as this due to the many many years of precedent already set.

Fuji Abound 25th April 2012 13:07



Jesus, I don't decry anyone. I have merely stated a number of times how the
situation currently is. Of course I would love EASA to cease to exist and be
replaced by the FAA or an FAA like system. It would save me a fortune, but as it
is not going to happen, we are where we are and we either have to put up or shut
up.

I have chosen to adopt the compliance route. Others choose to
complain.

There is no dichotomy in that.
Yes, I fully understand, it is the easy option.

I was making two points earlier.

We may chose to comply; we may also chose to do everything we can to resist changes with which we dont agree (including for example supporting AOPA if they adopt the same position),

We can support those to chose to complain rather than constantly reminding them "we told them theirs was a lost cause". It might well be, it might not. However if you keep spouting the same message inevitably some might think you are just taking the p***, which would be a shame. Me, well I suspect you take some pleasure in stirring the pot at most available opportunities, but then I am a bit of an old fart.

mad_jock 25th April 2012 13:17

I honestly don't think it would.

It would just be like any other conversion/validation, you would just crack on with it.

I can asure you that learning 4 different sets of airlaw hasn't been all joy. Especially as most of the differences are usually about VFR and how close to a hippo or camel you can fly when its having a dump. And if you say Flight level one zero zero or flight level one hundred. Never seems to be an option of read it back the same way the controller said it.

The theory apart from a quick reread of ace the pilot technical interview the JAR stuff covers everything you will need.


We are not going to accept a conversion such as this due to the many many years of precedent already set.
You won't have any choice in the matter. The general population really don't care about your plight and 99% of the other resident european pilots don't care either.

I don't think he is stiring more like trying to get them to face facts. A Young family and the high risk of not being able to provide for them. I would have the CC out quick as a flash.

Unless of course you have started down the JAR route in the past and found them to much and the FAA was the only way you could get into commercial flying. If thats the case the exams are a completely different kettle of fish for the last 5 years or so with the online exam question banks. Its monkey see and monkey tick the box next to what it's seen before these days. If you leave it until they change the question bank again you really will be knackard.

Thomascl605 25th April 2012 13:25

No, they probably don't care unless it was to affect them. But then again there may be some other law to come from EASA that could affect everyone else in the future, who knows ?

That's not to say that just because people don't care that I'm just going to accept this latest set of drivel.

There will be a stand made against this for sure.

mad_jock 25th April 2012 13:39


But then again there may be some other law to come from EASA that could affect everyone else in the future, who knows ?
I know there will and there has been, the FTL scheme for a start.

Hence much bigger things to be worried about than a load (or should I really say a very small percentage in the grand scale of things) of private aircraft pilots getting shafted.

Thomascl605 25th April 2012 13:43

If you are not bothered then you probably won't want to post on this thread anymore then. Hope the FTL's don't sting too much.

mad_jock 25th April 2012 13:55

What and let other pilots be infected with fantasys that its not going to happen?.

Better yet why don't you start up your own forum where all the pilots that are going to get shafted can talk themselves into believing that its not going to happen. I think you already have one and nobody has posted anything this year.

You would be more sensible to make the forum a place where you could all group together to try and make the groundschool less of a bitch by clubbing together to make it worth a groundschools while to do the brush ups in two/one day chunks at venues that are more convenient for bizjet pilots. Get similar type pilots together to get block bookings of sims and TRE's to get the costs down.

frac 25th April 2012 14:52


Maybe, but that does not stop them owners of the airspace defining there own rules and that is where we are now. Although as far as I am aware the US do not allow you to operate a foreign reg on US soil long term.
The USA Allow operation of foreign registration aircraft in US Airspace even if the aircraft is "based" in the US.

We see a certain number of P4 (Aruba) or VP- business jets in the US.

Last time I flew to Mc Carran (KLAS), I saw VP-BLK, a 747SP Registered to Las Vegas Sands Corporation. I understand that they also operate VQ-BMS, another 747SP.

Regards,
Frac

peterh337 25th April 2012 15:13


Although as far as I am aware the US do not allow you to operate a foreign reg on US soil long term.
Yawn, another piece of old bollox which does the rounds.

There is no such reg.

It would merely be stupid to operate a plane out there if it doesn't run under the FAA regime, because all the other regimes are going to be poorly supported and more costly. For a G-reg you will need to find a Part M company.

There is an apparently true story that somebody did a round the world flight in a G-reg and when they got to Australia, they needed an Annual but the UK CAA refused to allow the local MO to do it; they wanted to fly out a couple of their inspectors out there at a vast expense. In the end, the plane was moved to N-reg and continued the trip :)

I've been operating under both regimes; 3 years under G and 7 under N, so I know them both.

S-Works 25th April 2012 15:56

I still think its a moot point though. I liken dealing with the politicians on this the same as fuel taxes. They are going to go up regardless of him many lorries blockade a refinery or how many threats of it bringing down a government are made, they may delay things to make you think you are winning and then when not expecting it they slip it through. Nearly £1.50 a litre for Diesel today at a supermarket.......

Methinks you can shout and wail as much you like, but unfortunately you are not going to beat the faceless political machine.

Pace 25th April 2012 16:34

Bose

Firstly apologies over the licence issue earlier in the thread! I know a few guys who jumped through licence conversion loopholes and they can be the worst at slating N reg. I appreciate that was not your route it would not have been an issue had it been ;)

You are probably right That EASA are just going through the motions with the intention of then turning around and stating that it was not their fault that negotiations on a bi lateral failed.

They will still have a legal problem with employed pilots should anyone make a legal challenge in the EC courts.
This appears to be ignored yet it is a real issue they are aware of.

My contact who is on the June negotiating team states that both EASA and the FAA are serious about adding FCL to the existing Bi Lateral.
My question re starting exams was met with a do nothing so we will see how genuine they are.

Remember the whole thing nearly fell apart at Parliament stage where 5 MEPs were against were persuaded to vote the ship through with promises!

I do not think as Mad Jock reckons that it is a done deal. I am sure by 2014 we will have a different picture again! What that picture is ??? Only Mad Jock knows for certain :E

My own jet may go out of EU ops anyway so I will hold fire for a few months and see where its all heading.

Pace

S-Works 25th April 2012 17:08


My contact who is on the June negotiating team states that both EASA and the FAA are serious about adding FCL to the existing Bi Lateral.
See my point about fuel taxes, industry put pressure on the government who just delayed the rise and then slipped it in later. We are still being hit by outrageous fuel tax and I bet it goes up again in the next budget.


My question re starting exams was met with a do nothing so we will see how genuine they are.
Same as the fuel tax, said by the haulage and lobbying firms.



Remember the whole thing nearly fell apart at Parliament stage where 5 MEPs were against were persuaded to vote the ship through with promises!
Yep, and they still got it through because its the dirty way that politics work.

You only have to look at the demands that EASA are making with regards to the bi lateral to realise the FAA are not going to give in. Can you really see the FAA agreeing to annual tests for everything or EASA giving into rolling currency?

We keep talking about the other bi lateral agreements with the FAA, but if you look at say the US-Canada agreement the revalidation requirements were already aligned, the TK was already aligned. At the moment we have a massive gulf between the FAA and the EASA requirements that I do not see a bi lateral overcoming. What we need to concentrate on is making or own system more proportional. It's the vast gold plating that needs to be pulled away and made in line with other countries that is going to foster proper bi lateral agreements.

At the moment we have an entire system that is just not fit for purpose. Look at the licences we now have 5 or 6 of them at last count to replace what my old UK CAA ICAO licence or my singe FAA certificate does. This is standardisation?

mm_flynn 25th April 2012 17:34


Originally Posted by bose-x (Post 7155748)
You only have to look at the demands that EASA are making with regards to the bi lateral to realise the FAA are not going to give in. Can you really see the FAA agreeing to annual tests for everything or EASA giving into rolling currency?

No, but my understanding of the process of the bilateral is not 'your paper is accepted as though it was mine', but more like 'I will recognise your paper as proving the competency that my testing proves'.

As such, it would be quite reasonable for EASA to say, 'I recognise your paper, but you need a revalidation now to align with my currency rules for me to give you my paper'. Equally, it would not be at all surprising that both countries might want people to prove they can speak English and have been tested on things that are objectively different - such as airlaw (and physics :) )

Do you have a reference to the two party's current negotiating positions?

S-Works 25th April 2012 17:42


'I recognise your paper, but you need a revalidation now to align with my currency rules for me to give you my paper'.
That already exists. Unfortunately it is rather to onerous for many.... What people are looking for is simplification of this down to effectively something like an air law exam and skill test.

The requirements to get a permanent certificate are actually the same already at face value.

ATPL JAA to FAA - Pass the ATP exam and check ride on type and bobs your uncle.

ATPL FAA to JAA - Pass the ATPL exam and check ride on type and bobs your uncle.

CPL FAA to JAA - Pass the CPL & IR Exams, training as prescribed and check ride.

CPL JAA to FAA - Pass the Cpl & IR Exams, training as prescribed and check ride.

I only know what the headline 'agenda' items are from discussion with contacts in the EASA licensing team through my interaction with them in the day job. I am sure Pace's contact can supply the full details.

If you just want a plain validation then it is pretty much the same as the 61.75 process but obviously time limited.

peterh337 25th April 2012 20:51

Most people have lost the will to argue this stuff over and over, a long time ago, but 1 or 2 keep coming back because quite a lot of unknown people read these threads and might get duff info from them.

I think mm_flynn has got it right. Any bilateral agreement will not deliver a straight paper swap because EASA would be trashing the whole gold plated Euro FTO establishment, which simply isn't going to happen.

The FAA has very little to "give away" on the FCL front because they already allow most of what one would reasonably want. It is EASA that would be giving up a huge amount of a long-entrenched position. I just can't see what is there to usefully negotiate.

What big prize has the FAA got for EASA that would make it worthwhile trashing the European ATP cadet sausage machine which despite occassional (but in this business utterly inevitable) "setbacks" like Cabair ;) is making loads of dosh for loads of people?

mm_flynn 25th April 2012 20:59

Bose-X,

The difference between today and my hypothetical bilateral would be.
  1. Rather than pass 7 or 14 exams (or 1 going the FAA way) designed to test all relevant (and much irrelevant) knowledge, It would be one exam /or possibly Oral to test knowledge of the legitimate differences.
  2. Rather than an initial skills test, it would be the normal periodic check flight
  3. There would be no minimum qualifying experience - i.e. no 100 hours P1 instrument time (the IR) or 100 hours as pilot (PPL) or 700 hours including 200 in the activity (CPL)
  4. There would be no requirement for a minimum training period or training at the X's discretion

All in all it would be an acceptance that the pilot is as qualified as if the paper was issued by the local authority - with specific allowances for real local difference. Human factors would be a good example of a real local difference where European physiology is significantly weaker than North American :):) and hence its requirement to be tested for a non-commercial conversion

peterh337 25th April 2012 21:13

Historically, I think it's true to say that most ICAO papers have been converted with an air law exam (to supposedly address the local airspace issues) and a flight test.

Logically, it's hard to argue with the above. The flight test is the ultimate check for somebody arriving with forged or otherwise bogus papers, which would be an obvious thing to try when going for a conversion route (and reading the airline pilot forums on here it seems to be common in certain parts of the world).

The problem is that even the air law stuff in Euroland is nearly all utter crap. Reportedly it was generated (excreted) by a Portugese ATCO and you get gems like this

http://www.peter2000.co.uk/aviation/jaa-ir/morebull.gif

which make a mockery of any pretence that this is being studied to make you a safe pilot in Europe.

Then, in the present system, for a working pilot, multiply the above by 14. To even get signed off to sit the exams (by the ground school FTO) you have to wade through some 3000 pages of this crap to do their homework. (CATS uses a better online system).

Even for the FCL008/CBM IR proposal, EASA did not have the resources to re-do any of the IR syllabus, so they took the existing Learning Objectives (syllabus) and chopped them down.

Can you really see EASA signing a bilateral with the FAA and comprehensively re-hashing the TK?

I like the comment about human factors :) Here are a few more gems

http://www.peter2000.co.uk/aviation/jaa-ir/bull4.gif


http://www.peter2000.co.uk/aviation/jaa-ir/hpbull1.gif


http://www.peter2000.co.uk/aviation/jaa-ir/hpbull2.gif

Pace 25th April 2012 22:25

I tend to agree that any Bi Lateral will not be a straight swap or even anything which will water down the training structure already in the EASA system.
A Bi lateral agreement could be shared authority over N reg aircraft based in Europe.
The complaint of EASA revolves around not having oversight/control over N reg so a Bi Lateral in that sense would work.
Sadly all this Rubbish churned out of EASA has cost 300 million Euro.
EASA had the opportunity in this rewrite of bringing FAA, Canada, much closer together where a proper Bi Lateral was possible! Using the FAA structure they could have achieved a result which would have cost a fraction of the price and achieved uniformity ....But ???
So sadly a missed opportunity which could have decomplicated aviation in Europe and reduced costs.
I tend to agree with Bose that self interest has driven the structure we are faced with and self interest towards the regulators themselves rather than the safety issues EASA are supposed to protect.

Pace

chubbychopper 26th April 2012 00:48

Pace, with the GREATEST respect old chap, but please....

We know which side of the fence you are on
We have heard ALL of the arguments that you repeat day after day
We KNOW it's sh1t
We know that there is protectionism going on
We know they are a corrupt bunch of w*n**ers writing this cr*p
We KNOW they promised a bi lateral agreement
We know they lied
We know you don't have an EASA licence
We certainly KNOW there is no safety issue

Please mate, believe me - I AM on your side, but repeating the same mantra day after day really isn't gonna make a jot of difference! We know it is a scam, we KNOW there is no safety issue, but PLEASE PLEASE STOP REPEATING IT OVER AND OVER AGAIN. Please.

Pretty please.

They are NOT reading you.

They do not care.

They are not in the slightest bit concerned about the threat of potential legal action.

It is a done and dusted deal.......please please please STOP, accept it, get studying and spare us all the same broken record stuff that we know inside out and upside down! Please!!!!!

Thomascl605 26th April 2012 01:00

Well Chubby if Pace bothers you that much then don't read this thread, pure and simple.

I am totally with Pace and many others on this subject.

1. No, we won't roll over and get shafted and won't be studying for the 14 exams crap. A true professional Pilot will evaluate this situation for what it is, apply common sense and decide not to accept the idiotic decisions coming from EASA.

2. If you wish to doff the cap and in essence be another clone of the decision making of these idiots then be my guest.

3. Don't underestimate a court case, and don't underestimate the positive outcome for the pilots that will bring it.

S-Works 26th April 2012 07:17

Thomas, the problem as I see it.....

The N reg flyers died a death and they were supposed to be fighting the corner.

How many pilots do you know with the money to take a EASA to court? Who has the pull to organise a class action or whatever it's called and has the money to represent the pilots enmasse? I would doubt you would get a lawyer to represent no win no fee as the case us just not strong enough. So I think that your 'clutching straw' of a legal case is a no hoper. However if you can share expert legal opinion rather than barrack room law I would certainly be interested in looking at it. My pilot lawyer friend thinks its a no hoper, but who knows!

Don't fall back on telling people not to read the thread just because they don't agree with you and are telling you things you don't want to hear it dies nothing to help your position.

edit: speeeeling and grammar...

peterh337 26th April 2012 07:56


A Bi lateral agreement could be shared authority over N reg aircraft based in Europe.
The complaint of EASA revolves around not having oversight/control over N reg so a Bi Lateral in that sense would work.
Lack of oversight is another massive misconception.

The CAA here can ground any unsafe aircraft here.

The CAA and the police can inspect any aircraft here.

The CAA here can inspect the papers of any pilot here.

The CAA can make a report to the FAA of a dodgy A&P/IA (etc) and the FAA will bust him faster than he can read this (and I know of a few who got banned from practicing for a few months, which rather tends to concentrate the mind when your livelihood is gone).

An N-reg in Europe is much more vulnerable to inspections because it has no VAT treaty protection.

An N-reg maintained here is 99% likely to be maintained by a Part M company, so it supports the industry and helps the company to pay the CAA the annual approval fees ;) The only difference is that the N-reg return to service is signed by an individual rather than by the Part M company (but under the new EASA OPS rules any "complex" will require the Part M signoff also..... so more ££££££££ going to the local CAA ;) ;) ).

Does the CAA do ramp checks on G-regs? No.

Does the CAA bust EASA145 companies who use bogus-history parts and thus issue bogus EASA145 forms and the CAA has known about them for years? No. Not, apparently, as long as the said company is paying the CAA approval fees ;)

So, "lack of oversight" is a load of nonsense.

If I was going to operate a plane which

- has never been serviced
- is unregistered
- has a bogus number on the side
- is uninsured
- no FM Immune avionics
- runs on car petrol

and I had

- no license
- no medical
- no nuffink, never even had formal flight training but I knew how to fly and do the radio

and I wanted to fly it all over Europe, airways, the lot, what reg would I pick?

G

S-Works 26th April 2012 09:00

Wow..... I had no idea the UK GA licensing and certification system was so corrupt. have you thought about sharing your evidence with the UK CAA Peter?

Or am I to assume that the Belgrano is like some corrupt African state and they are in it for the back handers as well?

mad_jock 26th April 2012 09:22


A true professional Pilot will evaluate this situation
And realise that they are pointing the machine into a situation where they don't have an escape route.

The wake vortex question is for civilians operating into military airfields which don't seperate you for wake votex. You can ask for anything and they will clear you for it. Also in alot of the world outside europe they don't have a clue about wake vortex or its the pilots responsability.

Another situation that you have to watch is helicopters operating a seperate circuit to a spot or ruff ground next to the runway.

The numbers are neither here nor there but its more the concept you need to have vortex seperation.

421C 26th April 2012 09:24

Bose,
Peter didn't say that. He said lack of oversight was a massive misconception and he is right.

His other points are that Europe has a safety model based on "organisational approvals" rather than "individual accountability". The former works well in the airline world, because there is the scale to make it work and no other model makes sense. Part 121 is much the same in the US.

For GA maintenance and training, the organisational approval model adds a lot of overhead and little benefit IMHO. As an aircraft owner, I would have zero extra confidence in the costs and complexity Part M introduces. I also think the Peter is right that an organisation can "hide behind its approvals" and I do get the sense that if a poor Part M business ticks the boxes, pays its fees etc, the actual quality of what it does is almost secondary. Similarly for flight training to an extent. UK training is of a good quality because there are a lot of good people involved. The vast amount of paperwork adds little. You run a TRTO, you know this. The students who lost £70k when Cabair went bust know this.

The CAA's economic model adds to the distortion inherent in the EASA and pre-EASA framework. The CAA can't charge a general tax or a ramp inspection fee, they can charge for approvals and paperwork. It's no criticism of the people, you make any organisation dependent on a hammer, and that organisation will start seeing a lot of nails out there.

brgds
421C

mad_jock 26th April 2012 09:28

Your getting focused on real reasons again which as we have all said safety is not the reason why they are doing it.

They just want local pilots and local aircraft under there control and paying them money. Just like all the other pilots who are under local reg.

421C 26th April 2012 10:05

MJ
For once we agree. I think its probably not even the fees, since outside the UK the NAAs are less fee dependent. There's not one single EU cabal masterminding the FRA issue. My impression is that there's a mix of motives going back many years.

Until say around the early 2000s, the N-reg had operated fairly low key, in limited numbers and no-one really cared. In the UK, it was mainly bizjets operated sensibly for obvious reasons and a few high-end pistons like the Baron or Malibu or Cessna 300/400 series for owners who wanted FAA medicals and IRs.

The "problem" started about 10 years ago. The light aircraft market revitalised, with Cirrus at the lower end and the promise of the VLJs at the higher end. A few things then happened.
- the effects of the JAA were felt, including the various medical and training difficulties
- people started buying new aircraft. Most, apart from VFR light sport stuff, went straight onto the N - Cirrus, Beech, Socata,etc
- some of this was driven by better regulation under the FAA, some by the fact the many exciting new aircraft couldn't get UK TCs (TBM700, PC12, Columbia 300-400)
- people started moving older simple SEPs onto the N (PA28s, C172/182s) as awareness of the ease of the FAA system and frustration with the JAA increased

This resulted in various different reactions around Europe (I am sort of making up the next bit, but I think it impressionistically right). The German regulators got into a panic about the prospect of thousands of Eclipse light jets swarming around flown by FAA PPL/IRs. Various UK and French regulators realised that the trend was such that most of the future light aircraft fleet, other than trainers, would end up on the US register. The collective view was that "something must be done", in particular about FAA IRs. I suspect professionals like Pace and Thomas were just collateral damage, sadly.

The obvious remedy would have been to fix the bad elements of JAA regulations, and indeed this is what EASA initially promised. Unfortunately, the temptation to preserve and gold-plate the JARs was not resisted, except for some useful exceptions like the LAPL and Part MED in places.

The final irony, of course, is that this EU system for GA, that's meant to be so important that FRA operators have to be forced into it, was acknowledged to be a failure by the EASA Management Board and a group of countries tasked with rethinking the whole thing....

soaringhigh650 26th April 2012 10:11


Please mate, believe me - I AM on your side, but repeating the same mantra day after day really isn't gonna make a jot of difference!
peterh337 - given your a pilot of substantial experience, you need get up from your chair, start contacting your representatives and look at how to getting things changed.

I've said this before and I make no apologies for saying this again:

Moonlighting on Internet forums with an attitude of "all other parties are on some vested-interest gravy train" and "the whole world is totally out there to screw me over" is clearly not going to help yourself or any of us here.

If what you speak is substance, please go and act on it!

peterh337 26th April 2012 10:22

I don't think I wrote that quote, but IME writing to one's MP just produces a pre-prepared standard response letter.

The best thing is creating awareness, and like it or not pilot forums are effective in that. Look at the bizjet community - probably 99% of them are still totally clue-less about this stuff. That's because they fly instead of chatter :)

Re the earlier stuff, I don't see there has been any organised top level anti N-reg move in the principal "GA" countries i.e. UK Germany and France. Not even recently.

As I've said, the CAAs get most of the money off the N-reg community anyway, via maintenance facilities, and the Govt gets the tax via avgas (whose purchases by the IFR community are substantial). Route charges are collected off the lot. The only bits they don't get are license renewals and AME fees which amount to a miniscule % of the "flying taxes" one pays. The average IFR pilot probably pays more money to Jeppesen :) Hey - there's an idea. Tax Jepp :E

N-reg GA seems to have been happily tolerated by the regulators in these countries. They had ample opportunities, and means, of clobbering it. (I won't list some obvious ones). But they very deliberately didn't do that. They merely prevented foreign regs being operated for money and this kept flight training and most AOC ops on the local regs, thus protecting the bulk of the income stream.

I think the EASA FCL anti-N-reg stuff is a private project run by a few individuals in Cologne. Looking at the "legal" crap they have drafted and forced through the transport committee, they are not even particularly clever.


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