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1 PPL/IR Europe Views on JAA Instrument Rating training requirements for non-atpl candidates 25 March

2 Introduction A number of regulatory processes in the UK and Europe are reviewing training requirements for the JAA Instrument Rating. PPL/IR Europe has developed the following proposals as an input to these regulatory reviews Our position is that JAA IR Training regime currently serves two purposes: 1. It ensures that the skills and knowledge of JAA pilots operating under IFR are of an appropriately high standard 2. It is an integral part of the 200hr Frozen ATPL training programme, and used as the most demanding gatekeeper element of preparing and evaluating ab-initio students for First Officer roles in large jet airliners. Our view is that this dual purpose creates unnecessary barriers and costs for non-atpl candidates, who need to meet the first criteria (high standard of skills and knowledge) but not the second criteria (ab-initio training within a highly controlled regime for Airline First Officer duties). It has thus resulted in an IR syllabus that is both too complex and outdated, and too inaccessible for candidates who are not full-time airline cadets. Hence, our proposals are intended to Fully maintain the current IR flight test standards and tolerances Adapt the theoretical knowledge content to be appropriate to the privileges granted within General Aviation IFR and omit professional pilot and pure theory content relating to the CPL/ATPL Amend the regulations of the training process that are not relevant to non-atpl candidates, to make the training more accessible for such candidates

3 Summary of Issues Key current barriers to a PPL/IR A very detailed Theoretical Knowledge syllabus Mandatory classroom learning Restriction of flying instruction to Approved Flying Schools A demanding requirement of 50 hours of dual instruction for an SEP IR The effect of these barriers Only about ~40 PPL IRs issued per year by the UK compared, with 10,000/yr in the US The demise of the light aircraft as a safe and reliable means of personal transport Reduced safety standards for GA Discrimination against citizens who are denied access to controlled airspace Interference with the free movement of people within the EU Denial to SMEs of the benefits of improved executive productivity through the use of business aircraft Mass exodus from European registers to the US register

4 IR Requirements (1): Theoretical knowledge Regulatory Element Current JAR-FCL IR PPL/IR view ICAO Annex 1 IR FAA IR IR Theory Syllabus Includes elements relating solely to commercial jet operations and a considerable volume of academic background knowledge ( Ohm s Law ) Develop a practical syllabus consistent with the ICAO principle of knowledge appropriate to the privileges granted. Transfer pure theory and professional pilot content to the CPL or ATPL exams. applicant shall have demonstrated a level of knowledge appropriate to the privileges granted to the holder of an instrument rating Details subjects similar to JAA/FAA Includes only practical knowledge related to General Aviation IFR. Airline IFR knowledge tested separately in ATP exam IR Theory course approval Only approved Theoretical Knowledge (TK) Providers can conduct theoretical knowledge training Additionally, independent JAA IRIs, IREs and IR Ground Instructors may conduct theoretical knowledge training. Approval for 100% online courses No specific course approval required Allows FTO-style schools, small schools and independent instructors to conduct theoretical knowledge training Requirement for Distance Learning study 200hrs minimum required by JAR-FCL, estimated by FTOs Requirement at the discretion of the training provider/instructor None No minimum hours required Requirement for Classroom study 20hrs minimum under JAR-FCL but all UK current approved courses require 2 weeks classroom time Classroom training should not be mandatory None No minimum classroom time Requirements for entry into the examinations Course completion and approval from the TK Head of Training Certificate from an approved Ground School or online training provider. Authorised instructor endorsement(?) Written Instrument Instructor endorsement, or endorsement of Online training provider suffices providers CAA Any approved provider Main providers are 2 large commercial testing companies venues 1 venue: Gatwick Any approved venue Thousands of flight schools and testing sites dates 1 series of 2 day sittings per month, on weekdays On demand On demand papers 7 individual multiple choice papers 1-4(?) multiple choice papers, consistent with revised syllabus 1 multiple choice paper Medical JAA Class 2 plus Class 1 initial Audiogram Recommends Class 1 initial audio JAA Class 2 FAA Class 3 and visual standards

5 IR Requirements (2): Flight training and testing Regulatory Element Current JAA IR model PPL/IR view ICAO requirements FAA model IR Flight Training Syllabus Operation of SEPL/MEPL, with traditional radio avionics, under IFR. Little in the way of an official syllabus, left to individual FTO course approval process A defined and structured syllabus for flight training to be agreed between the regulator and the industry To include RNAV/GPS procedures where applicable. To include use of autopilot where applicable. Annex 1, lists key training items, not in detail A very detailed FAA syllabus is available in the Practical Test Standards. Test will include any avionics and auto flight control fitted to the test aircraft IR Flight Training course approval Only approved FTOs can conduct IR flight training and it may only be conducted as part of a Course Flying training should not be restricted to approved schools but include individual instructors (similar to the current system of authorised examiners) subject to measures that ensure standards are maintained. Such instruction must be in accordance with the agreed flying training syllabus. Requires only a qualified Instrument Instructor. Requires only a qualified Instrument Instructor. Hence small schools and independent instructors to conduct IR flight training. Course approval needed only for Part 141 schools. Min. Flight time prior to grant of IR ~130hrs implied 200hrs if not an approved FTO course ~130hrs implied Similar to JAA, ~130hrs implied Minimum Training Hours 50hrs SEPL 55hrs MEPL 25hrs SEPL (min 50hrs IF time) 30hrs MEPL (min 50hrs IF time) 10hrs (but min 40hrs IF time) ME instruction required for ME- IR but no minimum time 20hrs (but min 40hrs IF time) No difference SEPL/MEPL Continuity of Training All hours must be part of a single JAA course Any ICAO IR training hours contribute to the total, except for 10hrs required from a JAA IRI or IRE Any ICAO IFR training hours accumulate to the total Any ICAO IFR training hours accumulate to the total, except for final 3 hrs Max Simulator time credited to training 35hrs SEPL 40hrs MEPL 15hrs SEPL 20hrs MEPL 30hrs of required 40hrs IF time None towards the 10hrs IF Dual 10hrs Credit for IMC Rating none Reduction of total training by 10hrs and full credit for all IF time Full credit for all instrument training Full credit for all instrument training Flight Examiner CAA Staff Examiner only Note: authorised examiners allowed in other JAA states e.g. Spain Any JAA CRE/IRE Any authorised examiner Any FAA DPE Aircraft Approval Needs specific IR test approval Needs to be Airways IFR equipped and approved No particular approval needed Needs to be Airways IFR equipped and approved View-Limiting method Screens over the aircraft windows Pilot view-limiting device Pilot view-limiting device