Sun May 10, 2009 11:51 am
#744138
1. FCL 008
As a reminder, FCL008 is the EASA Working Group formed late in 2008 to review 3 elements of the EASA FCL NPA which, it was felt, were not fully addressed in the time available to the original FCL Working Group. These topics were:
FCL008 is a small “Industry” group, and includes 3 members from European NAAs (including one from the UK CAA), 3 from Europe Air Sports (including the ex-Chairman of PPL/IR Europe, Jim Thorpe) and 1 from AOPA (the CEO of AOPA Germany) and Jim has also had the support and assistance of AOPA UK in the process.
2. PPL/IR Europe’s Input
Jim Thorpe has led a significant body of work from PPL/IR on topics 1 and 2 above, that many Exec Committee and other members have contributed to. It has involved an analysis of all the ICAO, FAA, JAA and UK IMCr training regimes and options for each of the regulatory elements. It has included a review of every one of many hundreds of line items in the JAA Theory learning objectives. We produced a detailed set of proposals, including the drafting of how they could be incorporated in the FCL NPA.
3. The outcome so far
The process has proved to be a very positive one to date. Although each stakeholder holds their own views on specifics, there has been a very welcome consensus around the key principle that IFR qualifications for European PPLs should be much more accessible and practical. In essence, the PPL/IR proposals have been adopted in full. Of course, there are very many steps left in the process:
4. Draft Proposals for the IR
FCL008 has adopted a much more “competency-based” approach to IR Flight Training, and has adopted a significantly slimmed down version of the Theoretical Knowledge (TK). In both cases, there is no lowering of standards. The TK syllabus work has simply eliminated content not specifically relevant to the privileges granted by the IR. The competency-based training process does not change the high standards of the IR Flight Test – these remain the same for all (private and ATPL) IR candidates. The key change is that instead of requiring a single, contiguous course of 50-55hrs with an Approved FTO, the minimum for such a course will be approximately 15hrs for candidates who have built up IFR training and flight experience through a variety of other methods.
5. Draft Proposals for a “Enroute Instrument Rating” (EIR)
The UK IMCr is based on “Airspace Restrictions”: it’s privileges cannot be exercised in Class A. This is contrary to EASA principles – EASA want to avoid individual countries using airspace design as a means of modifying EASA FCL privileges. Therefore, the qualification has to be based on License Restrictions. The proposal is that the EIR should permit enroute IFR in all classes of airspace, but that departures and arrivals must be VFR – based both on actual conditions and TAF planning minima. This is a reversal, to an extent, of the IMCr privileges; but, combined with the option of a more accessible IR, we think it should be effective. The necessity for a full IR in order to depart and arrive in IMC has a positive element we should welcome: EASA does not favour the denial of airports and airspace to private GA through a combination of pricing and Class A which is the only thing that makes IMCr privileges “acceptable” in the UK.
As a reminder, FCL008 is the EASA Working Group formed late in 2008 to review 3 elements of the EASA FCL NPA which, it was felt, were not fully addressed in the time available to the original FCL Working Group. These topics were:
- The training process and requirements for the full EASA IR
- The possibility of a sub-IR IMC flying qualification (analogous to the UK IMCr)
- The issue of Glider flying in IMC
FCL008 is a small “Industry” group, and includes 3 members from European NAAs (including one from the UK CAA), 3 from Europe Air Sports (including the ex-Chairman of PPL/IR Europe, Jim Thorpe) and 1 from AOPA (the CEO of AOPA Germany) and Jim has also had the support and assistance of AOPA UK in the process.
2. PPL/IR Europe’s Input
Jim Thorpe has led a significant body of work from PPL/IR on topics 1 and 2 above, that many Exec Committee and other members have contributed to. It has involved an analysis of all the ICAO, FAA, JAA and UK IMCr training regimes and options for each of the regulatory elements. It has included a review of every one of many hundreds of line items in the JAA Theory learning objectives. We produced a detailed set of proposals, including the drafting of how they could be incorporated in the FCL NPA.
3. The outcome so far
The process has proved to be a very positive one to date. Although each stakeholder holds their own views on specifics, there has been a very welcome consensus around the key principle that IFR qualifications for European PPLs should be much more accessible and practical. In essence, the PPL/IR proposals have been adopted in full. Of course, there are very many steps left in the process:
- EASA FCL008 has to produce its final report by the end of 2009
- This has to be accepted by EASA and published as an FCL NPA amendment
- This NPA is then subject to consultation and a final EASA redrafting
- The EASA document then enters the whole EU review process before it becomes law
4. Draft Proposals for the IR
FCL008 has adopted a much more “competency-based” approach to IR Flight Training, and has adopted a significantly slimmed down version of the Theoretical Knowledge (TK). In both cases, there is no lowering of standards. The TK syllabus work has simply eliminated content not specifically relevant to the privileges granted by the IR. The competency-based training process does not change the high standards of the IR Flight Test – these remain the same for all (private and ATPL) IR candidates. The key change is that instead of requiring a single, contiguous course of 50-55hrs with an Approved FTO, the minimum for such a course will be approximately 15hrs for candidates who have built up IFR training and flight experience through a variety of other methods.
5. Draft Proposals for a “Enroute Instrument Rating” (EIR)
The UK IMCr is based on “Airspace Restrictions”: it’s privileges cannot be exercised in Class A. This is contrary to EASA principles – EASA want to avoid individual countries using airspace design as a means of modifying EASA FCL privileges. Therefore, the qualification has to be based on License Restrictions. The proposal is that the EIR should permit enroute IFR in all classes of airspace, but that departures and arrivals must be VFR – based both on actual conditions and TAF planning minima. This is a reversal, to an extent, of the IMCr privileges; but, combined with the option of a more accessible IR, we think it should be effective. The necessity for a full IR in order to depart and arrive in IMC has a positive element we should welcome: EASA does not favour the denial of airports and airspace to private GA through a combination of pricing and Class A which is the only thing that makes IMCr privileges “acceptable” in the UK.
Timothy
Not sent from my iPad.
Not sent from my iPad.