EASA FCL Partnership Group meeting – Cologne – 15 & 16 October 2012
This forum is essential for both industry and National Authorities, indeed it is the only EASA forum where the new FCL regulations can be discussed and interpreted. This is born out by the fact that there were very few absentees and the agenda was very long – over 40 items.
Whilst the UK CAA takes a very active part they too learn a lot and the exchange of views is proving invaluable to all, including EASA itself.
Many of the issues discussed related to private pilots – a part of the FCL that has caused more problems within the UK than most probably because for the first time the regulations have the full force of law and, for some states, the changes are quite significant. However the greater part of the many items were relating to interpretation and the all important area of standardisation between states.
There were two key items which affect BBGA and IPPTG members.
The first was with regard to the use of complex aircraft for the purposes of initial ab-initio training. At a meeting held some three months ago the pilot unions opposed the use of complex aircraft in training in a very hostile manner and the EASA person chairing that meeting agreed with them. Unfortunately neither ourselves nor any other training organisation was represented and this was therefore accepted without challenge. The issue was raised an agenda item for this meeting but this time with a different pilot union representative and the original interpretation was overturned. Members may not understand the significance of this but the EASA definition of a complex aircraft needs to be understood and includes all turbine powered aircraft. Increasingly this type of propulsion is appearing in training programmes with many ATOs using them for initial instrument ratings. Of course the MPL is specifically tailored to jet operations but got around the interpretation by doing this training in simulators.
The next issue was the whole question of SFIs and SFEs. We have put a great deal of effort into this particular problem since as originally written there would be a need for all SFIs and SFEs to hold valid licences. It is however a simple fact that most instructors using synthetic devices are doing this because they have lost their medicals yet still have all the experience and ability to train pilots in simulators.
The effect was largely on the training of Corporate and business jet crews where the major providers of this training would have been forced out of the market within three years, indeed there would have been immediate effects – no more initial or recurrent checks and training being possible in simulators, and indeed the lack of a suitable number of TREs qualified on type would have led to the eventual elimination of such training and testing even of the undesirable situation of using actual aircraft.
Initially we had tried to achieve a solution through UK CAA but their hands were tied and it had to be a matter for EASA. After a number of meetings a solution was hammered out at the highest level in EASA but this neede to be approved by the States and Industry and this meant putting it before the EASA FCL Partnership Group./ This occurred at the above meeting and the responses from both Regulator and Industry representatives were 100% in favour of the proposed solutions. Surprisingly the only major airline affected by the EASA FCL original ruling was Ryanair and the Irish CAA had the same stance as in UK – in other words their interpretation was the same as UK CAA – this would seriously affect Ryanair recurrent training and thus they were very supportive.
The result of this meeting was the complete ratification of our proposals and the UK CAA were instructed by EASA to submit a 14-6 exemption which would be unanimously accepted by EASA and all Member States.
One wonders what would have happened to the European Corporate aviation scene had we not been successful!
For financial reasons within EASA Mr Goudou wished to close this Group – he believes that there is no need for such a Forum yet the rest of Europe will introduce EASA FCL within 6 months and the problems are not going away – indeed they are actually increasing. Everyone in the room, including the EASA representatives was aghast at the proposal. It is clear that M. Goudou feels that there is no need to consult with Industry, yet alone the National Authorities on whom EASA must rely for implementation. It was therefore decided that the Group would continue with a policy of 3 meetings a year – the next in January 2013. Already, after just under two weeks we have over 30 agenda items for the next meeting with many of these coming from the airlines on training issues which were not dealt with at this meeting.
From our own perspective it seems very likely that further issues will arise, particularly with regard to the Corporate Aviation training arrangements since a large proportion of this is carried out outside of Europe due to a lack of sufficient full-flight simulators within the continent. It is very important to watch carefully the decisions of EASA and the member states to ensure that there is no back-tracking on the agreements reached at present.
Peter Moxham 27th October 2012 Page 1