The FTO perspective on the new proposed EASA Regulations

1
The FTO perspective on the new proposed EASA
Regulations

• Anthony Petteford

2
(No Transcript)
3
(No Transcript)
4
(No Transcript)
5
(No Transcript)
6
My 3 key points are

• EASA has not carried out an appropriate and
  comprehensive REGULATORY IMPACT ASSESSMENT (RIA)
  against KPAs for FCL regulations. Continuing with
  implementation without a full RIA will have a
  significant negative impact upon our industry
• New regulations always provide an OPPORTUNITY for
  an improvement to an existing system. This
  opportunity for improvement will be MISSED if
  EASA FCL regulations are introduced in
  unnecessary haste
• The interpretation of EC regulation 216/2008 in
  terms of non EU instructors will create SEVERE
  CONSTRAINTS upon our training industry with
  significant consequences for European Airlines
  unless the interpretation is REVIEWED by the EC

7
A definition of perspective

• In mathematical and geometric terms perspective
  is defined as a property of triangles

8
A definition of my ideal perspective

• In mathematical and geometric terms perspective
  is defined as a property of triangles
• In terms of the new EASA regulations an
  EQUILATERAL TRIANGLE would seem appropriate an
  equal input from
• OPERATOR
• REGULATOR
• TRAINING PROVIDER

9
A definition of my ideal perspective

• In mathematical and geometric terms perspective
  is defined as a property of triangles
• In terms of the new EASA regulations an
  EQUILATERAL TRIANGLE would seem appropriate an
  equal input from
• OPERATOR
• REGULATOR
• TRAINING PROVIDER

OPERATOR
10
A definition of my ideal perspective

• In mathematical and geometric terms perspective
  is defined as a property of triangles
• In terms of the new EASA regulations an
  EQUILATERAL TRIANGLE would seem appropriate an
  equal input from
• OPERATOR
• REGULATOR
• TRAINING PROVIDER

OPERATOR
REGULATOR
11
A definition of my ideal perspective

• In mathematical and geometric terms perspective
  is defined as a property of triangles
• In terms of the new EASA regulations an
  EQUILATERAL TRIANGLE would seem appropriate an
  equal input from
• OPERATOR
• REGULATOR
• TRAINING PROVIDER

OPERATOR
REGULATOR
TRAINING PROVIDER
12
My current perspective in reality

• In terms of the current situation, an OBTUSE
  TRIANGLE would seem more appropriate

REGULATOR
OPERATOR
TRAINING PROVIDER
13
My current perspective in reality

• In terms of the current situation, an OBTUSE
  TRIANGLE would seem more appropriate
• The word OBTUSE also has another meaning
• Think about it!

REGULATOR
OPERATOR
TRAINING PROVIDER
14
1. Regulatory Impact Assessment (RIA)(Document
Issued 30 Oct 2008)
15
RIA (30 Oct 2008) - Key Performance Areas

• The depth of the RIA shall be proportionate to
  the likely impact of the proposal. This RIA,
  affecting the aviation sector and in particular
  flight crew licensing, considers in particular
  the following KPAs for impact assessment
• Safety
• Economic
• Environment
• Social
• Regulatory harmonisation, at both EU and global
  level, which, in the case of FCL, means
  compatibility with ICAO standards (e.g. Annex 1)
  and with the regulatory regime of the most
  important international partners (e.g., USA FAA
  and in particular FAR Part61).

16
RIA (30 Oct 2008) Scope

• The development of each set of rules will be
  accompanied by a Regulatory Impact Assessment
  (RIA).
• The SCOPE of the present RIA is therefore to
  analyse, in the above context, the impact of
  possible
• Implementing rules for flight crew licensing and
  in particular for
• Ways of implementing the new Leisure Pilot
  Licence (LPL)
• Possible extension of the privileges for some
  categories of pilots, instructors and examiners
• Requirements and procedures for pilot medical
  certificates.

17
RIA (30 Oct 2008) Out of Scope

• Conversely, OUT OF SCOPE of the present RIA are
• Requirements for pilot training organisations and
  aeromedical centres, which will be discussed in
  the RIA related to the rules on organisations
• Commercial Pilots (CPL) and Air Transport Pilots
  (ATPL) of aeroplanes, since the Agencys
  proposals on rules applicable to them are
  substantially the same as those contained in
  JAR-FCL1 which had been implemented in all Member
  States
• Multi Crew Pilot Licences (MPL) whose
  requirements are equally unchanged from JAR-FCL1

18
2. Opportunity to make Improvements
19
Modernise ATPL Theoretical Knowledge
20
Modernise ATPL Theoretical Knowledge
21
Modernise ATPL Theoretical Knowledge
22
Modernise ATPL Theoretical Knowledge
23
Mandatory pre-assessment
24
Mandatory UPSET training
25
3. Basic Regulation 216/2008 non EU Instructors
26
Non EU Flight Instructors who train students for
an EASA CPL, must hold at least an EASA CPL AND
an EASA Instructor Rating IRRESPECTIVE of their
own ICAO CPL/ATPL licence status and
instructional experience
27
RIA (30 Oct 2008) Key Performance Areas

• Safety
• Economic
• Environment
• Social
• Regulatory harmonisation, at both EU and global
  level, which, in the case of FCL, means
  compatibility with ICAO standards (e.g. Annex 1)
  and with the regulatory regime of the most
  important international partners (e.g., USA FAA
  and in particular FAR Part61).

28
Basic Regulation (EC) 216/2008

• Article 12 Acceptance of Third country
  certification
• By way of derogation from the provisions of this
  Regulation and its implementing rules, the Agency
  or the aviation authorities in the Member State
  may issue certificates on the basis of
  certificates issued by aeronautical authorities
  of a third country, as provided for in
  recognition agreements between the Community and
  that third country

29
Why FTOs EXPORT training from Europe

• EXCESSIVE Direct costs
• Tax on already expensive fuel
• IFR Landing/Approach fees deter training at busy
  airports
• Spare Parts are made of Gold!
• SALES TAX on training fees
• Discriminatory compared with other professions
• SEVERE SHORTAGE of Flight Instructors
• The WEATHER in Europe is generally crap

30
Why WE train our students outside of the EU

• Direct Operating Costs are 50 LOWER than in
  Europe
• Landing and approach fees are MINIMAL
• Other countries ENCOURAGE FTOs to operate there
• Flight Instructors are PLENTIFUL
• The weather is CONSISTENT

31
Why WE train our students outside of the EU

• Direct Operating Costs are 50 LOWER than in
  Europe
• Landing and approach fees are MINIMAL
• Other countries ENCOURAGE FTOs to operate there
• Flight Instructors are PLENTIFUL
• The weather is CONSISTENT

32
How FTOs train non EU FIs today

• Current pre-requisites
• ICAO CPL
• ICAO FI Rating
• 500 hours Total Time
• 200 hours Dual Given
• Additional FI training required
• Abridged EASA FI course
• MIN 15 hours Flight Training for SE VFR
• MIN 30 hours Ground Training
• ADDITIONAL upgrade training for IRI and Multi
  Engine training
• Company SOP Training

33
Why this BR is such a THREAT

• The existing FI abridgement rules are PERFECTLY
  SATISFACTORY
• EASA CPL theoretical training is too ONEROUS a
  task for a full-time FI
• An EASA CPL is of NO USE to a non EU FI due to
  EU employment laws
• The costs for the FTO to achieve the requirements
  are PROHIBITIVE
• The PRICE of training will rise considerably
  limiting applicants
• Some FTOs/TRTOs may CEASE TRADING

34
RIA KPAs Economic

• Any new aviation safety rule may imply
  expenditure, income or other economic effects for
  a number of entities, typically
• The regulated persons - in this case the pilots
• The direct employment generated by the former
• The competent Authorities
• The Agency
• All the citizens in the society at large
• Tax payers

35
(No Transcript)
36
(No Transcript)
37
(No Transcript)
38
(No Transcript)
39
IMMEDIATE actions are required!

• This BR has been interpreted without regard for
  the demand for future airline pilots in the EU
  make COMMENT on the EASA NPA!
• FTOs, TRTOs and airlines LOBBY EASA for an RIA
  NOW!
• Support a lobby to encourage EASA to agree
  RECIPROCITY with third countries
• The future of our pilot training industry depends
  upon YOU!