Polite discussion about EASA, the CAA, the ANO and the delights of aviation regulation.
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By Cookie
I've recently communicated with a LAA member which has resulted in the CAA DTO Guidance being amended in the last few days. This means there's no need for Class Rating Instructors to remain outside the auspices of a Declared Training Organisation, as you can now start your own.

The UK CAA previously incorrectly stated the EASA requirement in CAP 1637 requiring an unrestricted Flight Instructor at paragraph 3.2 to be nominated as Head of Training. Actually, EASA regulations only require a Head of Training to have an unrestricted instructor certificate under EASA Commission Regulation 2018/1119, AMC1 DTO.GEN.210(a)(2). CAP 1637 has now been amended to correctly reflect this.

When issued, a Class Rating Instructor certificate is not restricted in the same way as an initial Flight Instructor certificate and is an appropriate instructor certificate to conduct training for those pilots who already hold a licence. Therefore, any suitably experienced Class Rating Instructor can now apply to become a Declared Training Organisation and obtain approval to include SEP and/or TMG Class Rating training, Towing Ratings, and Aerobatics Ratings, where the instructor(s) are so qualified. This then allows training towards issue, renewal, and revalidation of the ratings for which you hold approval.

For the SEP and TMG Class Ratings, the Honourable Company of Air Pilots have kindly published a free syllabus for you to nominate on your application.

AlanC, riverrock, Flyin'Dutch' and 2 others liked this
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By derekf
Hi Cookie,
That's very interesting (and most generous of the Honourable Company of Air Pilots)
For. a CRI doing purely CRI training, what are the benefits of setting up a 'one man DTO' as opposed to being 'feral'?
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By derekf
Ah yes - that makes sense as I knew renewals need to be done through ATO / DTO, but revalidation by experience didn't. Does that mean that for the CRI with renewal if they had their own DTO they could (as HoT) identify the training required prior to the renewal LPC with the examiner?
By Bathman
But in reality how practical is this?

Lets say I do 50 hours of CRI work a year this is spread around about 10 unlicensed airfields. So according to the DTO application form (SRG2145)

" If aerodrome is unlicensed, confirmation that safety assessment required in Article 209, ANO 2016 has been conducted."

Firstly I have no idea how to do this. Secondly is it actually worth it for say the 2 hours that I may fly from a particular airfield?

I also have to draw up a safety policy - again I have no idea how to do this

Then having looked though the CAA guidance material (CAP1637) it also states

the following documentation must be available for inspection by the CAA Inspectors during audits:

* Aircraft, engine and component log books as appropriate;
* Certificates of Airworthiness and Registration;
* Mass and Balance Schedules;
* Certificates of Maintenance Review (except where exempt) and Release to Service;
* Aircraft Radio Licence and Radio Installation Approvals;
* Flight Manuals or Pilot's Operating Handbooks; Certificates of Insurance;Checklists;
* Noise Certificate (if required);
* EU Part M Appendix 1 contract between DTO and CAMO.

Am I really going to keep copies of these for every aircraft that I fly? At some airfields I’m lucky if the have a kettle yet alone a photocopier

Also as part of the DTO Annual Audit the I have to inform the CAA of the

“Hours flown in previous 12 months” for every aircraft that I fly!

So what am I supposed to do ring up every aircraft owner ask them how many hours their aircraft has flown in the last 12 months? What happens when they say I’m not telling you?

Frankly I don’t know if I can be bothered
By johnm
@bathman I fear that you are falling for the old gold plating problem.

I think you'll find that most of the items you highlight apply if the DTO is based at an unlicensed airfield and owns aircraft. If based at home and flying aircraft owned by third parties, then the usual due diligence of a PIC and a training organisation ought to suffice I would imagine.....

If I'm wrong then words with the CAA and/or EASA would be appropriate I think.
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By derekf
So as it turns out, having reviewed the guidance it looks like the Channel Islands and Isle of Man have been abandoned by the CAA in terms of DTOs now RTFs have gone.

However, when looking at CAP1637 section 2.2 says that an organisation with principle place of business outside of an EASA member state cannot make a declaration as a DTO, and then goes on to clarify that this applies to the Channel Islands and that they will not accept applications from organisations located in those territories.

I know Jersey and Guernsey aeroclubs have now affiliated with UK based ATOs, but not clear on if that was the only route from their RTF basis.

I've emailed the CAA for clarification
By johnm
I fear this may be the gotcha….Pity we didn't see it coming :-(

DTO.GEN.105 Competent authority
For the purpose of this Annex (Part-DTO), the competent authority in respect of a DTO shall be the authority designated by the Member State on the territory of which the DTO has its principal place of business.