Justification: Consistency with forthcoming PBN IR. Comment: It is not clear whether helicopters are in scope for the BIR.

Similar documents
Fuel planning and management Sub-NPA (C) Aeroplanes/helicopters Part-NCC, Part-NCO & Part-SPO. 0 Page No: General Comment

Development of FTL for commercial air transport operations of emergency medical services by aeroplanes and helicopters NPA Number NPA

Civil Aviation Authority INFORMATION NOTICE. Number: IN 2016/082

IAOPA(EU) NPA RESPONSE

of 26 August 2010 for a Commission Regulation XXX/2010 laying down Implementing Rules for Pilot Licensing

Notice of Proposed Amendment Easier access for general aviation pilots to instrument flight rules flying

Easier Access to IFR. (RMT.0677 / NPA ) The BIR. GA Roadshow Switzerland 26 October 2017

AMC to FCL.1015 EXAMINER STANDARDISATION PROPOSED REWORDING EXAMINER CERTIFICATE CORE COURSE

The type rating of test pilots having flown the aircraft for its development and certification needs to be addressed as a special case.

Terms of Reference for a rulemaking task. Review of provisions for examiners and instructors

RMT.0701 Focused consultation workshop. 26 June 2018

CRD NPA 05/ / Theisen Andre-Cargolux Airlines S.A. (No paragraph affected). Header on pages 2, 3, 5, 6 and 7. Text changed.

If the ELA 2 aircraft weight category is going to be increased then the reference in the above paragraph should be amended coincidentally.

ANNEX TO EASA OPINION No 03/2013. COMMISSION REGULATION (EU) No /.. of XXX

Application certificate of validation

EASA NPA on SERA Part ENAV Response sheet. GENERAL COMMENTS ON NPA PACKAGE Note: Specific comments are provided after the General Comments

Terms of reference for a rulemaking task

LASORS SECTION E INSTRUMENT RATING, INSTRUMENT METEOROLOGICAL CONDITIONS RATING AND NIGHT QUALIFICATION

European Aviation Safety Agency

Notice of Proposed Amendment

FCL Rulemaking update

Explanatory Note to Decision 2016/009/R

Justification: Clarification and facilitation of timely SERA Part C Phase 1 implementation activity.

Report for instrument rating - IR(A) skill test

Examiners Record FI/TRI/IRI/SFI/STI (H) Assessment of Competence

Seychelles Civil Aviation Authority SAFETY DIRECTIVE. Validation of Non-Seychelles licenses issued by States other than the Seychelles

Explanatory Note to Decision 2013/022/R

GM1DTO.GEN.110 Scope GM1 DTO.GEN.115(a) Declaration GM2 DTO.GEN.115(a) Declaration AMC1DTO.GEN.115(a)(2) Declaration

ARM - AIR CREW ANNEX III. CONDITIONS for the ACCEPTANCE of LICENCES. ISSUED by or on BEHALF of THIRD COUNTRIES. ARM - AIR CREW Annex III GDCA of RA

Acceptable Means of Compliance and Guidance Material to Part-DTO 1

Civil Aviation Authority INFORMATION NOTICE. Number: IN 2017/034. Implementation of Performance Based Navigation Guidance for Pilots

Opinion No 10/2013. Part M General Aviation Task Force (Phase I)

FLIGHT INSTRUCTOR CERTIFICATE SKILL TEST AND PROFICIENCY CHECK FORM

Terms of Reference for a rulemaking task. Implementation of Evidence-Based Training within the European regulatory framework RMT.0696 ISSUE

APPLICATION AND REPORT FORM ATPL, MPL, TYPE RATING AND CLASS RATING, TRAINING, SKILL TEST AND PROFICIENCY CHECK HELICOPTERS (H)

1. GENERALLY. date of entry and signature

EGU Congress Paris. February DTO/Medical


Annex to draft Commission Regulation (EU) / amending Commission Regulation (EU) No 1178/2011

Terms of Reference for rulemaking task RMT.0325 (OPS.057(a)) & RMT.0326 (OPS.057(b))

JANUARY 2016 Part One Consultation

Explanatory Note to Decision 2015/001/R. Update of CS ADR-DSN.D.260 Taxiway minimum separation distance CS-ADR-DSN Issue 2

NOTICE OF PROPOSED AMENDMENT (NPA) No 07/2007 DRAFT OPINION OF THE EUROPEAN AVIATION SAFETY AGENCY,

Explanatory Note to Decision 2015/013/R. Additional airworthiness specifications for operations CS-26

Training Offers Aeroplane Trainings

Certification Specifications and Acceptable Means of Compliance for Aircraft Noise CS-36

Terms of Reference for a rulemaking task. Requirements for Air Traffic Services (ATS)

Operations. Henrik Svensson TO Operations & Flight Safety European Gliding Union. From NCO OPS to Part-SAO

NZQA unit standard version 3 Page 1 of 5. Apply knowledge of air law to the certification of aeronautical maintenance

Form No. RPPL-F-104AE AMDT No. 1.0 Page No. 1 of 6 Issue Date: 08/04/2013

DIREÇÃO DE SEGURANÇA OPERACIONAL DEPARTAMENTO DE LICENCIAMENTO DE PESSOAL E FORMAÇÃO

Summary of Rule Changes - NZ CAA Omnibus Rule Project Effective 25 March 2010

GA ROADMAP: UPDATE MOVING TOWARDS IMPLEMENTATION UPDATE

Advisory Circular AC19-1. Test Pilot Approvals 03 July Revision 0

Microlight Policy Review. Comment Responses

Annex 1 Part FCL. 11 December Federale Overheidsdienst Mobiliteit en Vervoer Service public fédérale Mobilité et Transport

European Aviation Safety Agency

Explanatory Note to Decision 2015/019/R. CS-25 Amendment 17

Better regulation for general aviation (update July 2010) July 2010 Better regulation for General Aviation 1

Reference No: Issue Issue Date: 16/02/2018 Area : FCL

SARI NPA M-02-G. SARI Part M Issue 2 dated 31 July 2017 includes inconsistency with other SARI Parts, incorrect references and omissions.

Air Activities Review Pre-launch Check

ANNEX TO EASA OPINION No 03/2015. COMMISSION REGULATION (EU) No /.. of XXX

Form SR FCL 1105 (JAR FCL 02) Issue 8 (Jan 2009) Page 1 of 6

European Aviation Safety Agency NOTICE OF PROPOSED AMENDMENT (NPA) NO 2008-XX. Dd Mmm 200X

Introduction to declared training organisations (DTO)

TRI/SFI. Final result: Passed Failed. A. First issue TRI. To be completed by the examiner TRI

REPORT FORM IR(A) INITIAL SKILL TEST. (Use Type or Class Rating forms to revalidate IR(A) or renew expired IR(A)) Type rating: Type rating:

TRI(A) - Revalidation/Renewal

Briefing for non-ccaa Examiners

Singapore Air Safety Publication Part 1. Licensing of Student Pilots and Private Pilots

RED SKY VENTURES. Study guide. COPYRIGHT RED SKY VENTURES AVIATION CC First edition published JULY 2003 This edition: January 2005.

1. APPLICANT DETAILS To be completed by Applicant. Date of Birth (dd/mm/yyyy):... Nationality:... Permanent Address: Post Code:...

NNF Work-shop on Navigation, Safety and Technology. Dato: 2. February Gunn Marit Hernes Luftfartstilsynet

BELGIAN CIVIL AVIATION AUTHORITY EUROPEAN UNION

Delegations will find attached document D042244/03.

EASA. Comment Response Tool

NZQA registered unit standard version 2 Page 1 of 7. Demonstrate competence for a Category B flight instructor rating

2.1 Private Pilot Licence (Aeroplane/Microlight)

Terms of Reference for a rulemaking task

EASA 0-ATPL(A) with Time Building in US FLYINGACADEMY.COM

Contents. Subpart A General 91.1 Purpose... 7

Certification Memorandum. Large Aeroplane Evacuation Certification Specifications Cabin Crew Members Assumed to be On Board

NZQA registered unit standard version 2 Page 1 of 9. Demonstrate flying skills for an airline transport pilot licence (aeroplane)

INSTRUMENT RATING (SENIOR PRIVATE PILOT) UK FLIGHT TEST STANDARDS

Check form Synthetic Flight Instructor

October 2007 ISSUE AND RENEWAL OF AIRCRAFT MAINTENANCE ENGINEER S LICENSE

Comment-Response Document Appendix 1 Aircraft type ratings for Part-66 aircraft maintenance licence

DAC-LIC Price List 1

Helicopter Recurrent Training and Checking. This document is an Alternative Means of Compliance issued by FOCA

Terms of Reference for a rulemaking task

EASA 0-ATPL(A) Zero to Airline Transport Pilot License FLYINGACADEMY.COM

Flight Evaluation Schedule For GPS IFR Approval Primary Means Enroute, Terminal and Non-Precision Approach

Private Pilot License

Letter of Agreement between the UHPC and NATS

EC135 Type Conversion Course (Single Pilot)

Unmanned Aircraft: Regulatory Framework in the EU EASA team High Level Conference on Drones Warsaw 24 November 2016

Class rating instructor(cri) Single engine Multi engine. Date of birth (yyyy-mm-dd) State of licence issue Licence no. Street or box Country Telephone

An advisory circular may also include technical information that is relevant to the rule standards or requirements.

From January 2019, this new syllabus must be used by all new students.

Transcription:

EASA Comment Response Tool You can save this page as HTML and then open it in Microsoft Word for further editing. Title Easier access for general aviation pilots to flight rules flying NPA Number NPA 2016-14 UK CAA (European.Affairs@caa.co.uk) has placed 23 unique comments on this NPA: Cmt#Segment description 138 (General Comments) Page Comment 0 Page No: N/A Paragraph No: General comment Comment: It should be ensured that the BIR training and privileges automatically includes PBN. It is suggested that the EASA RMG should determine whether the text needs changing, the key point is to ensure the skills test schedule includes PBN, which the NPA currently does not address. Justification: Consistency with forthcoming PBN IR. Attachments 139 2. Explanatory 2.4.1. Principles of the proposal 14-15 Page No: 14 Paragraph No: 2.4. Comment: It is not clear whether helicopters are in scope for the BIR. Justification: Clarity required. 140 2. Explanatory 2.4.1. Principles of the proposal Question on the deletion of the EIR in FCL.825 15 Page No: 15 Paragraph No: 2.4.1 (Question Box) Comment: The UK would not object to the removal of the EIR from the regulation. Although existing holders should not be disadvantaged (EASA principle of protecting grandfather rights). Justification: If the BIR is successful we would not see much demand for the EIR and indeed the EIRs issued to date by the UK have been in very limited numbers. We believe having unnecessary ratings in Part-FCL adds to the overall length and complexity of the. 141 2. Explanatory 2.4.2. Training structure 15-16 Page No: 15/16 Paragraph No: 2.4.2 (Modules) Comment: It is recommended that individual modules must be completed at the same organisation to ensure standardisation Justification: Standardisation. 142 2. Explanatory 17 Page No: 17

2.4.5. Training organisations Paragraph No: 2.4.5 Training organisations Comment: The UK supports allowing the BIR to be conducted at a Declared Training Organisation (DTO). Justification: It was the UK understanding that this would be included within the scope of the DTO. However, the NPA does not reflect the position agreed in the Task Force instead it requires training at an ATO. In the UK the IMC rating has been taught by independent qualified Flight Instructors and at Registered Training Facilities with no issues. Furthermore were the BIR to be limited to ATOs it would become impractical and effectively, unavailable to many GA pilots. Most GA pilots have easy access to a DTO but not ATOs. Proposed Text: See text provided with CAA comment on paragraph No FCL.835, (c) & (d) 143 3. Proposed FCL.035 Crediting of flight time and theoretical knowledge 21 Page No: 21 Paragraph No: FCL..035 Crediting of flight time and theoretical knowledge Comment: Provision does not appear to have been made for any expiry dates of theoretical knowledge exams. Justification: Clarity is needed as to whether the exams have an expiry date or not. 144 3. Proposed Paragraph No: FCL.835, (c) & (d) Comment: DTOs should also be included and it is recommended that the text is amended as Justification: GA pilots access to BIR training will be facilitated by inclusion of DTOs Proposed Text: Amend paragraphs (c) and (d) as follows: (c) Training course. Applicants for the BIR shall have completed at an ATO or DTO: (d) Notwithstanding point (c), the module as referred to in point (c)(2)(iii) may be delivered outside an ATO or DTO. 145 3. Proposed Paragraph No: FCL.835, (c)(2), subparagraphs (i) to (iii) Comment: It is recommended that sub-paragraphs (i) to (iii) are amended as Justification: Clarity.

(2) flight instruction modules: (i) Module 1 - the core flying training module of flight handling skills by sole reference to s; (ii) module 2 - the applied flying training module of IFR departure, holding, 2D and 3D ; (iii) module 3 - the applied flying training module of en-route IFR flight. 146 3. Proposed Paragraph No: FCL.835, (e) Comment: It is recommended that paragraph (e) is amended as Justification: Clarity (e) If BIR privileges are sought for multi-engine aeroplanes, flight training under instruction in multi-engine aeroplanes, shall include asymmetric and goaround. 147 3. Proposed Paragraph No: FCL.835, (i)(2)(ii) Comment: It is recommended that sub-paragraph (ii) complete at least 1 hour of flight time with an instructor holding privileges to provide training for the BIR should include some guidance on the content of the flight. Justification: To ensure that the skills required for flight in IMC are sufficient for continued safe use. 148 3. Proposed 25-27 Page No: 25-26 Paragraph No: GM1 FCL.835 Comment: It is recommended that the Modules and tolerances are AMC rather than GM. Justification: To enable standardisation. If it is only guidance material it will be difficult for an FE to fail a candidate as this is only guidance rather than a standard to be met. Proposed Text: Move to AMC. 149 3. Proposed Page No: 44 Paragraph No: Table, SKILL (B) Comment: It is recommended that the text is amended as Justification: Recognised terminology.

and (2D) 150 3. Proposed and (2D) 151 3. Proposed and (2D) 152 3. Proposed and (2D) 153 3. Proposed and Complete a short self briefing with regard to arrival, holding,, minima, weather conditions, associated performances, taxiing and missed procedure. Page No: 45 Paragraph No: Table, ATTITUDE (A) (2) to (5) Comment: We believe the attitudes numbered (2) to (5) are in the wrong area and should be relocated as they seem to be skills rather than attitudes. Justification: Appropriateness and clarity. Page No: 46 Paragraph No: Table, SKILL (C) Comment: It is recommended that item (C) is amended as Justification: Clarity. Arrive at the minima on a stabilised in order to Page No: 49 Paragraph No: Table, SKILL (B) Comment: It is recommended that the text is amended as Justification: Recognised terminology. Complete a short self briefing with regard to arrival, holding,, minima, weather conditions, associated performances, taxiing and missed procedure. Page No: 50 Paragraph No: Table, KNOWLEDGE (D) Comment: In item (D) Autopilot and flight director limitations there is no reference to understanding the modes on GPS systems that are more likely to be used in GA aircraft. Justification: Safety and proportionality. Incorrect use of GPS modes has resulted in at least one fatal accident in the UK.

(2D) 154 3. Proposed and (2D) 1 3. Proposed and (2D) 156 3. Proposed and (2D) 157 3. Proposed and (2D) Page No: 50 Paragraph No: Table, ATTITUDE (A) (2) to (4) Comment: We believe the attitudes numbered (2) to (4) are in the wrong area and should be relocated as they seem to be skills rather than attitudes. Justification: Appropriateness and clarity. Page No: 51 Paragraph No: Table, SKILL (C) Comment: Suggest re-wording Arrive at the minima stable in order to make a correct decision to perform a landing, go-around or circling safely. Justification: Clarity Arrive at the minima on a stabilised in order to Page No: 51 Paragraph No: Table, ATTITUDE (A) Comment: It is recommended that item (A) identify whether the is not stabilised is amended as Justification: Clarity. confirm the is stable Page No: 53 Paragraph No: Table, OBJECTIVE Comment: It is recommended that the text is amended as Justification: Improved grammar. At the minima, or as directed by ATC, in the event of an unstable or in due to a loss of integrity, make a smooth transition to a climb at the correct speed and complete the checks.

158 3. Proposed Module 3: Enroute IFR 56-65 Page No: 60 Paragraph No: Table, SKILL (C) Comment: Suggest re-wording item (C) [...] or navigation aircraft system Justification: Better phrasing [.] or aircraft navigation system 159 3. Proposed Module 3: Enroute IFR 160 3. Proposed Module 3: Enroute IFR 56-65 56-65 Page No: 60 Paragraph No: Table, SKILL (D) Comment: It is recommended that item (D) should include GPS systems. Justification: There is a greater likelihood of a lighter GA aircraft having a GPS system on the aircraft. Page No: 63 Paragraph No: Table, SKILL (B) Comment: It is recommended that item (B) should be reworded as Justification: Clarification. Navigate by means of an appropriate navigation system for the cleared route. Page viewed on 2017-01-13 14:56:01 GMT Copyright 2005-2017 EASA