Primarily for general aviation discussion, but other aviation topics are also welcome.
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By Genghis the Engineer
FLYER Club Member  FLYER Club Member
#1592344
Flyin'Dutch' wrote:I take it that Irv has me down as an Europhile.

For the avoidance of doubt, this proposal is in my view dumb and incomprehensible. What are they trying to achieve. Bonkers.


It's probably a reasonable position to be a Europhile but an EASAphobe, or at the very least an EASAskeptic.

Or even a Europhile but an EUphobe, but that's an argument best kept to other threads :twisted:


In the meantime, if we returned Concorde to service, that is Annex II. So a British or French Concorde co-pilot would not be able to count their Concorde right hand seat hours towards achieving a full EASA ATPL and thus Captaincy. That alone, even if a fictional concept, should be a good enough argument to show the utter absurdity of this.

In the non fictional world...

- Hours in a Super-Cub will count to a CPL, or to maintain an EASA PPL, but in a Europa won't.

- Many research aeroplanes are Annex II, so the UK's Metman BAe-146-301 will suddenly find that its pilots can no longer count their BAe-146 hours to maintaining their ATPLs.

- (Virtually) all military aeroplanes are Annex II, so military pilots with decades of service in any country in Europe, will be treated as ab-initio students for the purposes of trying to obtain an EASA CPL or ATPL on leaving their respective services. So that will, for example, mean suddenly drying up the main source of air ambulance and police helicopter pilots.


(Just adding to the cake of absurdity.)

G

Europhile, EUphobe, EASAskeptic.
Also known as Spartacus.
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1592346
Flyin'Dutch' wrote:I take it that Irv has me down as an Europhile.

For the avoidance of doubt, this proposal is in my view dumb and incomprehensible. What are they trying to achieve. Bonkers.

It was EASAphile as G hints at, but are you completely comfortable as one of the small minority of GA pilots who wants to fly other States' GA aircraft with no hassle to yourself that the majority of fellow aviators are the ones paying for greasing your passage? (other non double-entendre phrases are available). I don't want to stop you but why should the huge majority of fellow aviators who just simply fly nationally or fly the registration matching their licence effectively pay for you to do that? Easa needs to be voluntary at grass roots level.
Anyway, the timing and the French situation suggests this could be the EASA matador waving a red cape with nothing behind it in one hand but a sword with April 8th written on it in the other hand
#1592351
Genghis the Engineer wrote:
- (Virtually) all military aeroplanes are Annex II, so military pilots with decades of service in any country in Europe, will be treated as ab-initio students for the purposes of trying to obtain an EASA CPL or ATPL on leaving their respective services. So that will, for example, mean suddenly drying up the main source of air ambulance and police helicopter pilots.
.


Military hours in military registered and certified aircraft / the Military Accreditation Scheme hasn't got anything to do with EASA or non-EASA type certification so I don't think that will be a factor.
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By Dave W
FLYER Club Member  FLYER Club Member
#1592363
Thanks for the link to the other thread, @Edward Bellamy.

It might be useful to quote @nickwilcock's post from there, giving some key background as to what is going on behind the scenes - and timescales.

nickwilcock wrote:On behalf of IAOPA (Europe), I presented our proposals for recognition of flight time achieved in Annex II aircraft to an EASA meeting in Dec 2017. The proposals had already been agreed by the EASA FCL&TPG.

Less combative for once, EASA listened to my speech without interruption. The proposals were fully supported by the UK CAA, the representative from the Czech CAA (who told them about the number of Annex II aircraft they operate) and not one of the 30 or so delegates spoke against our proposals.

These are, in summary:


SUMMARY OF IAOPA (EUROPE) ANNEX II PROPOSALS:


Revalidation:
- Flight time on Annex II aircraft shall be accepted for revalidation
- To include flight time on historic aircraft and historic aircraft replicas
- To include flight time on 3-axis microlight / ultralight aircraft (1 hr PIC must be on non-microlight aircraft)

Training and Testing:
- Aircraft must be of the relevant Class
- Aircraft must be fit for purpose (i.e. have dual controls, brakes / critical controls and flight instruments available for the instructor)


We did not make any points regarding PMD or LAPL medicals; however, since then we have certainly made the CAA aware of the scale of the problem. We have also made proposals for NPPL(M) to LAPL(A), which are currently being considered by CAA legal - the CAA is also aware of the fact that there is no EASA equivalent of an NPPL(M), hence 'something has to be done'.

Since my meeting, EASA has stated that 'EASA has recognised the problem and is working on it'.

Unfortunately though, the next meeting has been delayed until after 8th April.
By patowalker
FLYER Club Member  FLYER Club Member
#1592371
The wording in NPA 2014-29(A)
In FCL.035 Crediting of flight time and theoretical knowledge, in (a)(2) a new paragraph is added to allow credit for flight hours on aircraft listed in (a), (b), (c) or (d) of Annex II to the Basic Regulation. In FCL.035(b)(4), it was decided to add the possibility to obtain credit for the theoretical-knowledge training and examination for licences not only in another category of aircraft but also in the same category of aircraft.

was rejected forthe reasons described in Opinion 5/2017:
FCL.035 Crediting of flight time and theoretical knowledge
In (a)(2), a new paragraph was added to allow credit for flight hours on aircraft listed in (a), (b), (c) or (d) of Annex II to the Basic Regulation. After consultation with EASA and Member States experts, the decision taken was to remove this paragraph as it represented an amendment of the requirements of the Basic Regulation. This should be done in the Basic Regulation and cannot be done via an amendment to an implementing rule. In (b)(4), it was decided to add the possibility to obtain credit for the theoretical-knowledge training and examination for licences not only in another category of aircraft but also in the same category of aircraft.


The final text of the BR agreed with the European Parliament was published on 11 January and includes this wording:
4b. Training and experience on aircraft not subject to this Regulation may be recognised for the
purpose of obtaining the pilot licence referred to in paragraph 2, in accordance with the
implementing measures adopted pursuant to Article 21a.

If 'aircraft not subject to this Regulation' are accepted for issue of a licence, one would expect the same to apply for revalidation.
#1592407
Thanks for posting that patowalker. The new BR text should remove doubt in this area, assuming the implementing rules are appropriately configured to facilitate.

I think the Pilot article is a bit misleading - it describes this as a new EASA 'initiative', whereas what has really happened is that an attempt to clarify the situation legally with regard to use of time in Annex II aircraft has sat in a pile at EASA for more than three years and upon the very tardy review by EASA legal, they have decided it is more an issue for the Basic Regulation. I do not see any attempt by EASA to actually amend anything to specifically exclude time on Annex II.

There have been disagreements between EASA and a few Member States, including the UK, on this issue of EASA and non-EASA legal interface for a long time. For example, I think EASA actually raised a finding against the CAA due to the statement on UK issued EASA licences about them also being valid for non-EASA aircraft. But that's just indicative of a lot of lower level disagreements that happen sometimes (there was another one over LAMP for example) and are not important enough to go any further.

So long as the CAA remain confident of their legal interpretation of the situation, I don't see anything to fear here.
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By Genghis the Engineer
FLYER Club Member  FLYER Club Member
#1592417
Edward Bellamy wrote:Aircraft that are on active military service are not Annex II, since the EASA BR already excludes itself from military or other state activities in Article 1.

This possible amendment was already discussed on this thread. I think it unlikely this will actually happen since there are so many member states opposed it.

I disagree,

This is from the CAA's website here.

More detailed information on these categories can be found in annex II to Regulation 216/2008 (EASA Basic regulation), as follows:

Non-complex, historic aircraft, whose initial design was established before 1 January 1955 and production stopped before 1 January 1975.
Aircraft with a clear historic relevance, related to a noteworthy historic event, a major aviation development or that played a major role in the armed forces of a member state.
Aircraft specifically designed for research, experimental or scientific purposes, likely to be few in number.
Aircraft where at least 51% is built by an amateur or non-profit making association, for their own use without any commercial reason.
Military service aircraft that have not had a design standard adopted by the Agency.


That last line is exactly what current military aircraft usually are. Ergo the vast majority of current military aircraft are Annex II.

As you say, most states are likely to actively oppose it, but we should stay very vocal on the point to ensure that doesn't change.

G
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By James Chan
FLYER Club Member  FLYER Club Member
#1592419
Sorry if I'm being naive, but isn't current military aircraft being regulated by the MAA?
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By Genghis the Engineer
FLYER Club Member  FLYER Club Member
#1592421
In the UK, yes.

The point here is that Military Aircraft are NOT administered by EASA, and Annex II is the list of aircraft not administered by EASA.

Therefore EASA in refusing hours in Annex II / non-EASA aeroplanes are not just going to eliminate permit aircraft in the UK, and old Jodels and Rallys in France - but most of the flying experience by military pilots. Presumably anybody hour-building in the USA in any type/variant that hasn't got an EASA Type Certificate would also have those hours refused. Also all your Concorde hours - wouldn't be able to count them.
G
#1592425
Genghis - military aircraft are nothing to do with the BR or Annex 2 as Ed referenced. That line is only applicable when attempting to put them on he civilian register. Military hours are via the Military Accreditation Scheme which has no requirement for EASA equivalence of types.
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By Irv Lee
FLYER Club Member  FLYER Club Member
#1592447
@peter272 Last of EASA's worries, no real concept of the working coalface. If you raised that you would end up paying to re register aircraft to introduce distinguishing registrations, you will find them very free with your money to solve that one ;-)
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