Primarily for general aviation discussion, but other aviation topics are also welcome.
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By Dave W
#1700132
@patowalker I don't see that wording helps if the regulator is determined to make the most restrictive interpretation of the phrasing used.

The intent of the wording is - explicitly - "to make access easier" yet the chosen pedantic interpretation (it could go either way) has been to make access considerably more difficult.

Now, it is true that 'my' chap's case is doubtless an unusual one - but it's not an unreasonable situation in practice.

Pedantic bureaucrats need to look at these things with a mindset of "How may I interpret to facilitate...?" rather the apparent all too common "How can I interpret to block...?" :(

More background info on this case to demonstrate further the absurdity: The chap had already successfully completed separate NPPL SLMG and LAPL SEP Skills Tests prior to the PPL Skills Test also successfully completed. (Or maybe the order was SSEA and TMG, but you get the picture.)
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By Irv Lee
#1700141
Usually, any large organisation where you find that these sorts of decisions regularly come down on the side of making it the harder/dearer/time-consuming option is usually a symptom of fear (of top management) at the lower management and the working levels
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By patowalker
#1700171
Dave W wrote:@patowalker I don't see that wording helps if the regulator is determined to make the most restrictive interpretation of the phrasing used.

The intent of the wording is - explicitly - "to make access easier" yet the chosen pedantic interpretation (it could go either way) has been to make access considerably more difficult.


That is why I wrote 'reason' in inverted commas. I don't believe the intention was to impose the restrictive interpretation. It is far more likely that the phrase 'to allow small ATOs owning only a TMG to perform training for the PPL' was included to emphasise (to the EC) the need for the amendment. Unfortunately, it sems to have had unintended consequences, probably because those who dafted the NPA are not the ones interpreting the amended rule.

If the restrictive interpretation has been challenged, we may see a clarification in the next version of the BR implementation rules.