This is for people in Europe who will be affected by EASA's proposed
changes to pilot licensing. If you are outside EC jurisdiction (or if
you don't care what sort of licence you can have or what it will let
you do) you can skip the rest of this message.
EASA have proposed changes to the pilot licensing system, contained
in Notice of Proposed Amendment 2008-17 and available for download as
3 PDF files from:
http://www.easa.eu.int/ws_prod/r/r_npa.php
Part a is an introduction; b is where the meat is; and c is mostly on
medicals. These documents are many pages long and will require some
effort to read and form comments on. You may want to focus on
subparts A (general), B (LPL) and C (PPL), but there are many other
parts worthy of attention if you can spare the time.
If no-one bothers to respond we'll get what the bureaucrats think is
good for us. (An indication of how much they know about aviation was
the initial insistence during a previous rule-making exercise that
all balloons must have an ASI!)
Note that if there's stuff you like you should say you support it, as
there may be other bodies objecting to it. For instance, there is
probably an organised campaign by AMEs to prevent the adoption of
simpler medical standards which would mean less/lower fees paid to
them! So if you like that part of the Leisure Pilot's Licence (LPL -
based on the UK NPPL) then say so.
On Saturday last (22nd) I attended a seminar at Turweston on these
proposals and with permission reproduce the following parts of the
presentation about the documents and hints on how to comment
effectively.
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Part a Explanatory Note
General backgound - read for context
Provides the outline structure and content of the other documents
Contains extensive tables which cross reference every element of the
proposals to the JAA rules, where applicable
Part b FCL
Sub parts:
A General requirements
B Leisure Pilots Licence
C PPL, SPL, BPL
D CPL
E MPL (Multi-crew)
F ATPL
G Instrument Rating (IR)
H Class and Type Ratings
I Additional Ratings
J Instructor Certificates
K Examiner Certificates
Part c Medical
Sub parts:
A General requirements - general, issuance, revalidation,
renewal, revocation, suspension
B Requirements for medical certificates - Class 1 and 2 and LPL
C Requirements for aero-medical examiners
D Requirements for General Medical Practioners
Licence proposals:
PPL A:
No significant change; 17 years; 45 hrs; (25 Dual)
ICAO Medical Class II:
up to age 40 5 years;
40 to 50 2 years; above 50 1 year
LPL A Basic
16 years; 20 hrs (10 Dual); 2000 kg + 1 person, 50 km radius
LPL A
16 years; 30 hrs (15 dual); 2000 kg + 3 persons
LPL Medical
Initial to age 45; 45 to 60 5 years; above 60 1 year
RESPONDING TO EASA NOTICES OF PROPOSED AMENDMENT
KEY POINTS:
EASA does not respond to lobbying
EASA does respond to well structured, well argued, constructive
formal responses to NPAs
EASA will count multiple, duplicated (copied) responses as one
response, where it is obvious that the duplication is deliberate
EASA recognises that the collective opinions of the representative
bodies are important and should be weighted accordingly
The quantity of responses saying essentially the same thing will
count (as long as they are not just "photocopies" using the same
words)
EFFECTIVE RESPONSES:
Are brief, to the point, address the specific question or issue
Provide criticism of the particular that is well argued and based on
the safety case / proportionality
Propose alternative solutions with rational argument, briefly, with a
safety case
Are credible
INEFFECTIVE RESPONSES:
Are rambling, long, or rude, or do not address the point
Do not provide a reasoned alternative
Do not provide a safety argument for the alternative
Technical Aspects in responding:
Your response must be made through the EASA website using the
'Comment Response Tool'
You register first and get a unique code to enable you to go in more than once
You can draft your responses off-line (and save them!) then paste
them into the CRT on-line
You can go back and amend your responses before the comment deadline
(currently 15 Dec 08 for NPA 17 but expected to be extended further,
shortly)
DON'T LEAVE RESPONDING TO THE LAST MINUTE - IT IS A TIME-CONSUMING PROCESS
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As you can see there's only a few weeks before the deadline (and
don't bank on it being extended!). The presenter on Saturday was
David Roberts of the British Gliding Association (BGA) and he told us
that the corporate response of the BGA is published on their website
(sorry, haven't had time to look up the full URL for that, but Google
is your friend in this sort of situation) so you might want to have a
look at that to see how they have approached it. As noted above, do
NOT copy and paste from it into your response. EASA are now using a
very sohisticated software tool to analyse responses and lump
together all those with identical wording, which then count as just
one response.
There is probably further advice and indications of their response on
the LAA website but again I haven't looked yet.
Note that the ratings part of the proposal includes Mountain ratings
which are only for French & Swiss Altiports. Strange that these
country-specific ratings should have found their way in while the UK
IMC rating did not! There are moves afoot to remedy this, but if you
say anything about the need for a "starter" Instrument Rating, please
do not push it as the "British solution" - this will not help your
argument as there is a certain amount of "not invented here" syndrome
to overcome. Push it instead purely on its safety merits.
Please pass this message on to any other UK pilots who may not be on
this forum.
regards
Rowland
--
| Rowland Carson LAA #16532 http://home.clara.net/rowil/aviation/
| 1160 hours building Europa #435 G-ROWI e-mail <rowil@clara.net>
|