Use this forum to flag up examples of red tape and gold plate
User avatar
By G-BLEW
#1406928
Irv, the only way that is different to the FAA's BFR is that in your plan instructors need organisations to stipulate what has to be covered on the ground. Or am I missing something?

Ian
#1406934
I left the following out of the previous post as it was too long anyway-
i only know the faa system from the pilot end, and quite rarely, so can't comment other than to say i seem to have satisfied an faa instructor on the flying side in an hour, but have no idea if he would have refused to sign at all, or if he would have been drawn in if i had done something wrong or stupid in the next two years, but i do know the ground school might have petered out very quickly if i hadn't driven it, there was so much i felt i needed to know that i had forgotten since the last time about flying in the US.
User avatar
By Flyingfemme
#1406935
I think that the CAA/EASA need to come clean about the meaning of their approach and the consequences of a small omission/delay on the pilot side. There was a lot of twaddle promulgated about "licence for life" with EASA coming in and yet a lapse in validity leads to a practical removal of said licence and the requirement to retest and get it back. What is the safety justification for this? I think it irritates and (possibly) worries some pilots.
In contrast my FAA ticket is truly "for life" and I can let it "lapse" by not doing a BFR or medical then revalidate at my convenience without any form filling or interaction with the FAA. All I need to do is pass another medical with my local AME and fly with my local CFI until they are happy I am safe.
What's so wrong with that? EASA/CAA simply don't trust anyone - even the people they have authorised themselves.
And @Kanga; maybe "job creation" is the wrong phrase but "job maintenance" is certainly applicable. The CAA could probably make the same profit margin by automating, slashing clerical jobs and end user costs. It would also free up the examiners to get on with examining rather than signing logbooks and conducting "revalidations".
User avatar
By G-BLEW
#1406973
Irv wrote:I left the following out of the previous post as it was too long anyway- snip


I suggest that a BFR (done properly) would work just fine.

Ian
User avatar
By Irv Lee
#1407004
Sounds like nearly there then, all that is needed is that they be
G-BLEW wrote: (done properly)

And the only way I can think of having reasonably high compliance for that is to cover the known current concerns and confusions on the ground, replace the specific requirement of an hour in the air with "sufficient", and make the instructor doing it feel more responsible for "sufficient" by including them in any review by Capt Hindsight.
Glad we agree... ;-)
User avatar
By kanga
#1407007
Flyingfemme wrote:..
And @Kanga; maybe "job creation" is the wrong phrase but "job maintenance" is certainly applicable. The CAA could probably make the same profit margin by automating, slashing clerical jobs and end user costs. It would also free up the examiners to get on with examining rather than signing logbooks and conducting "revalidations".


oh, quite possibly :) .. but I am still reluctant to believe that regulators planned complications or now oppose simplification simply from a malign motivation to maintain their own and colleagues' jobs. Happy, however, as always to hear evidence to the contrary .. :roll:

Rather, I'd expect that this all arises from the introduction of JAA in the era when only Governments and well-funded corportate interests' lobbyists had any chance of influencing changing anything at the EU level, so JAA FCL was driven by the airlines' need to harmonise ATPL rules to allow free movement of pilots between countries of basing and of registration. The complications of the 'light GA' end then arose because each nation had its own system of classes and validations, and it has been a low priority for regulators to harmonise let alone to simplify all of those. Meanwhile CAAs of nations like the UK with a relatively active and lightly regulated private/amateur GA scene (many JAA nations have not) have 'derogated' (as in UK, often fortunately) to allow continued GA activity until there is acceptable harmonisation, and this itself has led to some of the current complexity.

Meanwhile the UK and EASA regulators probably know and may regularly hear from their national Governments and national and European elected representatives that among the electorate there is little interest in the topic, and there may be public animosity towards anything which suggests that things are being made easier for 'rich boys and their dangerous and noisy flying toys'; any incident or, worse, accident will prompt some MP/MEP to call for more/tighter regulation.

So I have some sympathy for the regulators, both at the top who try to improve the rules (as seems now to be true at both UK CAA and EASA; but it's a long road, with many potential obstacles) and for the junior staff who may have little or no understanding of aviation let alone GA (if that were a job requirement on recruitment they would probably have to be paid more) who have to administer the complex rules and give accurate answers to complex queries.
User avatar
By G-BLEW
#1407017
And the only way I can think of having reasonably high compliance for that is to cover the known current concerns and confusions on the ground…


Yes, the FAA leave that to the instructor, but over here we seem to need to specify anything for fear that professionals will be unprofessional.

…replace the specific requirement of an hour in the air with "sufficient", and make the instructor doing it feel more responsible for "sufficient" by including them in any review by Capt Hindsight.


Works for me. The FAA BFR is a minimum of one hour in the air and one on the ground - if you haven't flown for 20 years you might need to do more to get back up to speed, but once you satisfy the instructor you are good to go.

Glad we agree... ;-)


Just the minor difference in philosophy between Europe – which feels the need to be very prescriptive, and the US – which puts more responsibility on the individual.

I think it is that European need to be prescriptive and cover all of the bases (in writing) that has lead us to the mess we currently find ourselves with.

Ian
#1407290
Except that in this instance it is the FAA that is being prescriptive.

From the pilot's perspective there is little practical difference between an FAA flight review & an EASA proficiency check flight. The FAA insist that you must do it this way, EASA offers a choice between a proficiency check or any flight training hour covering any subject. The FAA insist that you must do an hour's review of airlaw & procedures with an instructor, EASA do not. There's nothing to stop an EASA instructor making a review of Part FCL/CAP 804 a requirement before signing the logbook, it's at the instructor's discretion. The FAA mandate it.
User avatar
By Flyingfemme
#1407324
low&slow wrote:Except that in this instance it is the FAA that is being prescriptive.

From the pilot's perspective there is little practical difference between an FAA flight review & an EASA proficiency check flight. The FAA insist that you must do it this way, EASA offers a choice between a proficiency check or any flight training hour covering any subject. The FAA insist that you must do an hour's review of airlaw & procedures with an instructor, EASA do not.

Actually the FAA requirement for a BFR is nullified by any "checkride" for any licence or rating. As with all checkrides - the examiner can ask anything they like as part of the oral :lol:
I don't have a problem with that.
By Emerald Islander
#1407361
low&slow wrote:From the pilot's perspective there is little practical difference between an FAA flight review & an EASA proficiency check flight.


Sorry low&slow but there is a massive difference between the FAA BFR and the EASA PC. As Bathman stated in the first post a significant number pilots dont understand the regulations. Its no wonder, instructors and examiners are not fully aware of the regulations and even the CAA is a clear as mud. The FAA system is simple and reasonably clear.

http://www.faa.gov/documentLibrary/medi ... 61-98B.pdf

“The CFI must be aware that the flight review is not a test or check ride, but an instructional service designed to assess and enhance a pilot’s knowledge and skills. “

“The FAA does not intend the flight review to be a check ride. If the review is not satisfactory, the CFI should log the flight as “dual instruction given” and not as a “failure.” The CFI should then recommend additional training in the areas of the review that were unsatisfactory.”

“A pilot who does not receive an endorsement for a satisfactory flight review may continue to exercise the privileges of his or her certificate.”{so long as it is less than 24 months since last successful review}

A checkride or wings module can replace the BFR requirement

EASA PC

CAP 804 states the following:
“within the 3 months preceding the expiry date of the rating, pass a proficiency check in the relevant class ... with an examiner”

The CAA Web Site has very ambiguous wording: http://www.caa.co.uk/default.aspx?catid ... geid=15220
“passing a proficiency check with an examiner up to three months before the rating expires.”

Irv Lee on his website (http://www.higherplane.co.uk/faq.html) is far more informative
“You can actually do this one flight (the proficiency check with an examiner) at any time, but if it is not in the final 3 months before expiry, your rating will be renewed from the date of test, not the date of original expiry. ”

Irv also highlights the big caveat
“One thing to note is that if you abandon the 12 hour route to take this test and FAIL, you cannot fly again as pilot in command until you have passed a re-test, so the 12 hour route effectively disappears if you take the test and fail.”

The huge elephant in the room however is that is you fail to get the revalidated before your validity expires you now have to go to an ATO for training and when they deem you ready, undertake a GST.


Why is the GA community dependent on good graces of Irv, Cookie and others like them on this forum to keep them informed of the correct procedures when the regulator, with hundreds of staff, seems incapable of doing so? The current system has failed. JAA/EASA tried to reinvent the wheel and after a thousand committee meetings come up with an octagon.

What chance does the average GA pilot have with such complex regulations ? You need to a lawyer, computer programmer or both to make sense of them.
#1407422
Whether or not the FAA intend for a review to be a check ride is irrelevant, the pilot is expected to display a minimum standard of competence, that makes it a test, even if it's an easy test. For the first 8 years of my licence I didn't fly enough SEP hours to revalidate by experience, I had to do a proficiency check every 2 years to keep the rating. There is nothing remotely difficult about a proficiency check, it is also an easy test & anyone who fails one really shouldn't be flying solo & definitely needs retraining.

A successful FAA flight review renews the pilot's privileges for a max. 24 months, a successful EASA proficiency check revalidates the rating for up to 27 months. A failed EASA proficiency check doesn't require mandatory retraining until the rating has expired by at least 3 months. The LAPL(A) has no mandatory retraining requirements, the pilot may not have flown for years but a successful proficiency check will renew his privileges for another 24 months. Six of one, half a dozen of the other.

An FAA flight review & an EASA proficiency check are to all intents & purposes effectively the same. Yes, there are differences in application, instructor/examiner, groundschool/no groundschool etc. but from the pilot's perspective these are mere details. If you like the FAA system, there is an EASA near-equivalent already in place, just do a proficiency check every 2 years.

The alternative revalidation by experience is not complicated:
(ii) within the 12 months preceding the expiry date of the rating, complete 12 hours of flight time in the relevant class, including:
— 6 hours as PIC,
— 12 take-offs and 12 landings, and
— a training flight of at least 1 hour with a flight instructor (FI) or a class rating instructor (CRI). Applicants shall be exempted from this flight if they have passed a class or type rating proficiency check or skill test in any other class or type of aeroplane.


Imposing an FAA-style flight review system on EASA pilots doesn't give us anything new, instead we lose the chance of using any instructional hour as a revalidation flight. We would also have a requirement to sit through & pay for an hour's groundschool every other year.
User avatar
By Paul_Sengupta
#1407430
low&slow wrote:A failed EASA proficiency check doesn't require mandatory retraining until the rating has expired by at least 3 months.


Are you sure this is the case?

Due to aeroplane permit issues, my SEP rating expired by about a week last year. I had to have a course completion certificate to say I'd completed a course of retraining, then had to do the test.

It wasn't onerous, just a bu&&er's muddle of completely unnecessary paperwork.

(and I guess someone in the CAA had to spend time processing it as well....)
User avatar
By GrahamB
#1407443
When all said and done, whatever the relative merits and demerits of the two systems in terms of contribution to safety by oversight, the EASA regime fails big time by being:
- overly complex
- documented in the least friendly way possible, requiring a degree in Euro-librarianship and indexing methodologies to navigate through
- poorly understood by instructors and examiners, let alone the average PPL who doesn't have time or knowledge to unravel the two points above

It's no wonder that people give up, or fly illegally.

The whole thing needs tearing up and starting again, with all the petty national 'bees in bonnets' and arrrrse-covering bureaucracy cast aside and a simple, safety outcome driven, system established which firstly trusts approved individuals to do their job, and secondly is documented in one reference manual, and not Byzantine reams of incomprehensible Basic Legislation, Implementing Rules, Guidance Material, AMCs, blah blah blah.
By Emerald Islander
#1407445
GrahamB wrote:The whole thing needs tearing up and starting again, with all the petty national 'bees in bonnets' and arrrrse-covering bureaucracy cast aside and a simple, safety outcome driven, system established which firstly trusts approved individuals to do their job, and secondly is documented in one reference manual, and not Byzantine reams of incomprehensible Basic Legislation, Implementing Rules, Guidance Material, AMCs, blah blah blah.


:thumright: :thumleft:

I think this just proves Bathmans original point, no one knows anymore, either low&slow is correct and Paul got screwed or low&slow is in for an expensive surprise if he fails to get the examiners signature (or his instructors if they before they paid the £51 and got their license endorsed,) before the rating expiry date.

We need simplicity and clarity with NO GOTCHA's

One route for revalidation by experience, with 12 hours not crashing, some ground revision or attendance at a GASCO event combined with training that includes 3 circuits which should be performed to the instructors satisfaction along with a detailed critique and advice by the instructor.

or as an alternative route

a Flight Review along the US lines and a rating that can be reinstated by the instructor alone.

No more examiners , LAPL dispensed with this need for this requirement ,

I dont really want to discuss LAPL as it is a completely unnecessary con job by EASA, but can anyone please direct me to any CAA material on the contents of the LAPL "flight review" and how it differs from the PPL "flight training".
User avatar
By Paul_Sengupta
#1407504
Emerald Islander wrote:either low&slow is correct and Paul got screwed


Didn't really get screwed as I went to a sensible and pragmatic "ATO"...and we completed the paperwork over a pint in the pub.