Use this forum to flag up examples of red tape and gold plate
#1405831
The current system just doesn’t work. It’s too complicated. For the umpteenth time someone presented me their licence for me to sign only for me to point out to them they are flying illegally. And I would guess that’s the case for about 10% of licences that I see. Now these are not people who are trying to break the law they are perfectly honest people but they simply don’t understand a system that is too complicated.

I would even go as far to say that a fair number of CAA employers don’t understand it either and this summer a guy who flies a single seat TMG based on a SEP rating had to point out to me the requirements he needed to meet to revalidate. Now I don’t charge for doing this, I do it to promote aviation, but by the time I put in a good couple of hours reading and research. Well it would have been better for me to not even bother.

A huge number of posts here and on pprune are with people venting their frustration and the sheer stupidity of the subject and frequently they have to part with a large amount of money just to be legal and thus allow them to keep doing what they are doing.

First up this 12 hours in the second year is simply stupid so is the fact its different for the LAPL and its different again for the NPPL.

I know we often compare EASA to the FAA system but I have yet to come across a single FAA pilot who does not know what they have to do in order to remain current.

I know this is above the Red Tape Challenge but the current EASA system needs at least a radical overhaul if not scrapping altogether and replacing it with something that works e.g. the FAA system or the old UK system.
Last edited by Bathman on Fri Sep 18, 2015 11:35 am, edited 1 time in total.
By cockney steve
#1405862
Totally agree, It's this sort of civil servant/quasi-government job-creation bullcrap that has always put me , and i suspect, a lot of others, off attempting to obtain a pilot's licence.
Many forms of boat activity are completely unregulated. I do not advocate that for flying. However, the heavy hand of regulation has allowed SSDR and we have yet to see a shower of unsafe machines raining down upon us....there will always be self-selecting Darwin Award candidates, the legislators never stopped them.

Those who fly, hopefully have a good sense of self-preservation. A mandatory "nudge" to maintain their skills is one thing. the ridiculous, labarynthine rulings presently in force can only encourage total non-compliance. AFAIK, they have to catch you first....then what? -hanging's abolished. make sure your family Trust owns everything....blood/stone 8)
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By flybymike
#1405875
Bring back five hours in thirteen months and a stamp in the logbook, or better still let pilots and/or the rental organisations decide for themselves who needs a checkout and how often they need it.
#1405876
You beat me to such a post. I was going to start one on 'revalidation for the 21st C', as the process we have is distinctly 20th.
For those who weren't around in the 1990s, the current EASA revalidation rules were put forward by the JAA committee. Perhaps there are some JAA reps still around who might like to comment, but at the time JAR came in, I was told directly by someone involved in those discussion that the rule we ended up with were practically a fudge just to get something, anything, as no-one could agree. There was nothing magic about 12 hours, no trace of any safety study or logic, it was merely that the German system did this every year. (Perhaps it originally started there as 'well that is one hour a month' which of course ignores the fact that GA pilots do not fly on a regular fixed basis through the calendar year. - Note the 'perhaps', who knows?)
This 12 hours per year was thought too strict for PPLs, but instead of saying it could be spread over two years, they adopted the German 12 hours BUT just made it apply every 2nd year. That is how we have the situation we have. I got the impression this was almost in desperation, simply to agree something, rather than fail to provide anything by deadlines. This is no way to run what should be a safety scheme.
Personal view (not set in concrete, willing to be swayed):
I would ignore all p1, take offs and landings, and simply concentrate on 'training refresher' but make the instructor feel more involved than today. This would mean both ground and flight, on regulations, process, changes in the past two years, changes known to be coming up, (eg: the list I have been using for years for this - http://www.higherplane.co.uk/bfr-ground.pdf), and safety in flight, so some flight training/checking - for example, the current worries - partial engine failure on take off, landings, pfls - GASCo could usefully supply the items) PLUS pilot requests (eg: the pilot might admit he always finds it difficult to join a circuit).
I would make the instructor more 'responsible'. Have a ground element where the current hot topics and relevant GA accidents and incidents (eg: infringements, preflight planning, landings, etc) have to be discussed and training (both ground and flight) given on mitigation measures. The list of compulsory topics could be produced on a regular basis by involved organisations. Pilots of different ages, histories, and abilities need different times to absorb these things, so I would not limit the 'biennial' to one flying hour, it could be more or less, but would require ground discussion/training on non-flight items. The key would be that the instructor signs the pilot off, and that signature would be along the lines of the instructor thinking the pilot was now not a danger to himself or others, and the pilot has the knowledge and skill to preflight plan properly -and understands what his licence/rating covers and doesn't cover.
So when the pilot, fresh from his biennial three months before, busts a Red Arrows display and clearly afterwards shows he does not know how to check for them, the instructor is brought into the tea without biscuits scene, to supply records of the biennial and discuss why it might be that the pilot clearly doesn't have a clue about notams or freephone numbers. (It might be 'the pilot is simply thinking of any excuse for not bothering' not realising he will have to confront the instructor who actually showed him). Being brought into the post-incident discussion, the instructor might then feel more 'responsible' for the quality and content of the biennial rather than thinking of it as an admin process as many do, and all involvement/responsibility ends when the pilot walks out the door.
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By Cookie
#1406008
However, the heavy hand of regulation has allowed SSDR and we have yet to see a shower of unsafe machines raining down upon us


For SSDR the pilot is still required to hold a current pilot licence with a valid class rating and medical.

I know we often compare EASA to the FAA system but I have yet to come across a single FAA pilot who does not know what they have to do in order to remain current.


I agree in that the FAA method is much simpler for pilots to understand. However, the FAA system differs significantly from EASA in that it's not just 'one hour with an instructor', it's a minimum of one hour ground training (reviewing the equvalent of the ANO and EASA regulations) and one hour flight training, during which the pilot must demonstrate proficiency in those manouvres chosen for the review:

§61.56 Flight review.

(a) Except as provided in paragraphs (b) and (f) of this section, a flight review consists of a minimum of 1 hour of flight training and 1 hour of ground training. The review must include:

(1) A review of the current general operating and flight rules of part 91 of this chapter; and

(2) A review of those maneuvers and procedures that, at the discretion of the person giving the review, are necessary for the pilot to demonstrate the safe exercise of the privileges of the pilot certificate.


So it's pretty much what Irv has suggested.

Cookie
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By kanga
#1406084
cockney steve wrote:.. It's this sort of civil servant/quasi-government job-creation bullcrap..


er, which jobs could have been created thereby ? As this came in with JAA (replacing, in UK, the former BoT then CAA system of '5h P1 in 13 months'), I assume that the current mishmash came in with an attempt to 'harmonise' at JAA the different rules for the different classes of aircraft (balloon, glider, SLMG/TMG, microlight ... multi, heavy, fixed and rotary, piston and turbine ..) and status of authority (national or delegated eg BGA/BMAA pre-JAA) and pilots (SPL to ATPL, national to ICAO) and medicals which existed in each JAA State pre-JAA. I expect the relevant officials in each State tear their hair out as much as pilots do, but I doubt that there are any more of those officials because of this. Happy to be proved (with evidence) wrong, though ..
By bookworm
#1406101
So scrap all hours and take-off/landing requirements for revalidation and simply make it a rolling 24 month BFR requirement?

While we're at it, can we rationalise the differences training and class ratings?

  • Remove the revalidation requirement for MEP as well.
  • Confine differences training to three-axis controls, flexwing, TMG/SLMG, tailwheel, maybe high altitude


Would you all support that?
#1406119
Well haven't considered mep at all, like many others, haven't worried about them since JAR came in, I was thinking about the "by experience" scheme. i think we need to do what I doubt the originators of our current sep reval did, and think through "what is the point of revalidation by experience?". ie what are we trying to achieve?
The point could be any or all of a few things, but if it has a point that a majority might sign up to, I am fairly sure it wouldn't be anything to do with needing to do a minimum of zero hours in one year and twelve hours the next.
My thoughts are that behind it somewhere ought to be an intention to protect the pilot, the passengers, and other airspace users, and also should include a recognition that sep or tmg hobby pilots do not fit a standard mold, and eventually deteriorate at different rates, but perhaps ought to be noticeable in two year periods. And on top of that, recognition that some have learned to fly at a time or place when/where no-one really gave a fig about preflight planning. Also, many in GA do not have Ops and compliance departments keeping track of recent and future changes for them, it is simply something they do as a hobby every week or month and simply don't spend hours reading documents each month.
Many instructors are very good at deciding when a pilot is safe to fly either a rental aircraft or a syndicate aircraft. That could take 45 minutes, or it could take five hours, but the point being the instructor would not sign off the guy for rental or syndicate until happy there was every chance the pilot was ready to fly it. I think the whole process needs to be tilted that way, and the most recent instructor brought into discussions following any incident.
I am sure there will be all sorts of "yes but what about.." ... But .... I think we have to start again from first principles of what is reval by experience meant to do, and then build from there.
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By flybymike
#1406137
Well haven't considered mep at all, like many others, haven't worried about them since JAR came in,

Which says much for the demise of MEP flying since JAR and EASA got their hands on wrecking it.
By low&slow
#1406186
bookworm wrote:So scrap all hours and take-off/landing requirements for revalidation and simply make it a rolling 24 month BFR requirement?

In other words, every 2 years you fly a proficiency check? If it's been more than 2 years since your last check you might need some training & then you fly the check flight?

Yes, that sounds simple enough, I can't see anything complicated about that.
By cockney steve
#1406191
@KANGA When Beeching was decimating the rail network, I hada friend who was employed in a Drawing office,-note, I do not say he WORKED.- The dept. planned signalling and electrification of the lines. He assured me, not only did they have a "bunking-off" rota, which ensured all only attended 4 days a week, but they whiled away their time making the systems as complex as they possibly could, ostensibly to be "failsafe".

Absolutely no account was taken of practicality, cost, necessity or maintenance.....before Beeching visited the place, virtually no work was done for some weeks....this ensured they were "busy" and snowed under with a backlog, when the hatchet-man made his inspection.

There is no reason to suppose Aviation regulation follows any different principles. If it did, there would not have been a need for the "Gold Plating " investigation.
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By flybymike
#1406195
low&slow wrote:
bookworm wrote:So scrap all hours and take-off/landing requirements for revalidation and simply make it a rolling 24 month BFR requirement?

In other words, every 2 years you fly a proficiency check? If it's been more than 2 years since your last check you might need some training & then you fly the check flight?

Yes, that sounds simple enough, I can't see anything complicated about that.


Except that history has shown that those who have already been through a training course and have passed a flying test and have a licence and who fly at least 5 hours every thirteen months and who are at liberty to have a checkout just as frequently as they like would be just as safe without any form of periodic review.
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By kanga
#1406204
cockney steve wrote:..

There is no reason to suppose Aviation regulation follows any different principles. If it did, there would not have been a need for the "Gold Plating " investigation.


er, this may be correct; but as I said, evidence ? The business of a regulation office is (I assume, having worked in neither) likely to be different from that in a drawing office ..
By Emerald Islander
#1406226
Bathman is indeed correct. The system is not working, it’s FUBAR. When instructors struggle to understand the myriad of regulations what chance does the average recreational pilot have.

As Cookie pointed out the FAA pilot must demonstrate proficiency in their biennial flight review otherwise the instructor will not pass them. EASA offers a similar Proficiency Check except it must be administered by an Examiner not an instructor. The major flaw in EASA’s regulatory system is its failure to trust. EASA doesn’t trust the trained pilot to determine if they are safe to fly. It doesn’t trust the instructor to determine the pilots ability either, despite instructors having the responsibility of authorising students for solo flight and cross country nav. FCL 945 permits the instructor ( if they get the privilege on their license) to sign the pilots log book after their one hour training flight yet the instructor has no authority to fail or even refuse the pilot if they are not proficient.
I fully agree with Irv's proposal that instructors should perform the flight review/proficiency and GASCO attendance (also Wings credits) but I totally disagree with his concept of a post incident interrogation of the instructor. Why not drag in the pilots abinitio instructor(s) and skills test examiner while we are at it? The pilot alone is 100% responsible for their actions! (Ignorantia juris non excusat – ignorance of the law excuses not)

As for the 12 hour requirement route it’s a complete farce. It is technically possible to fly after an absence of two years nine months yet a pilot who flies 100 hours in Year 1 and due to personal circumstances is unable to fly in Year 2 or flies 100 hours on a microlight but can’t count the hours, has to undergo the check with an examiner. Which one is the more experienced, safer pilot?.
A considerable number of pilots give up flying because they fall victim to the 2 year regulations and need to perform a full GST. (The LAPL provides a way out but PPLs are then forced to down grade to a non ICAO license just to keep valid; yet the risk posed is still the same.)
By applying SSDRs deregulation concept to flight currency, a pilot who has recent currency (eg past year), should be able to fly solo without any biennial flight review or signoff; just like motorists. (One of best pilots I’ve flown with in Central Africa never had a medical or flight review in his life.)

To return to Bathmans initial observations, the entire system must be overhauled as it is unworkable. Experienced Instructors like Irv and Cookie should be able to focus on improving pilots knowledge and flying skills instead of wasting their expertise endlessly advising on stupid regulations that have no proven link to safety. The CAA should scrap all PPL licenses and return to one UK ICAO compliant PPL with different ratings and experience levels and simple revalidation procedures. They can do this with a simple derogation.