Comment Responses
Background In February 2010 the Irish Aviation Authority issued a Request for Comment document relating to Microlight Policy By the close of the comment period 14 comments had been submitted
Review of Comments The overall response has been positive to the proposed changes. Some additional requests have been made along with the submissions. The following is a breakdown of the comments received. In each case it must be borne in mind that the proposed change is based on a safety case study and the figures do not represent a majority decision.
Proposed Change 1 Re-classify microlight licence ratings to Three Axis SEP Microlight (Land) and Weightshift Flex Wing SEP (Land). This would include the removal of Foot Launched Powered Parachute from this classification. Total Number of Comments In Favour Opposed 7 6 1
Proposed Change 2 Reduce the hours requirement to a minimum of 30 hours flight time of which at least 20 hours shall be dual instruction. Total Number of Comments In Favour Opposed 11 11 0
Proposed Change 3 Theoretical knowledge examinations will be revised to include examinations based on a syllabus appropriate to the operation of microlight aeroplanes. Total Number of Comments In Favour Opposed 8 8 0
Proposed Change 4 Intention of the IAA to form a dedicated Panel of Examiners for microlight operations Total Number of Comments In Favour Opposed 6 6 0
Proposed Change 5 Introduce a formal requirement for an applicant to demonstrate an adequate knowledge of Irish Aviation Legislation. Total Number of Comments In Favour Opposed 7 7 0
Proposed Change 6 A validation not exceeding 12 months. Amended to include that a validation would only be issued for two consecutive years, Total Number of Comments In Favour Opposed 9 8 1
Proposed Change 7 Possibility of issuing a Short Term Validation Total Number of Comments In Favour Opposed 9 8 1
Proposed Change 8 All requests for validation will be at the behest of the Authority Total Number of Comments In Favour Opposed 6 5 1
Issue date of F.203 There was some confusion regarding the issue date of F.203 (1 Comment) F.203 is the form template used for the request for comment on proposed changes to any policy, the date refers to the issue date of the form, it does not indicate the preparation date of the specific document. The IAA apologises for any confusion caused and will review the layout of the template.
Class 2 Medical The majority of the respondents see the Class 2 medical requirements as being too restrictive. (10 Comments) The IAA acknowledges the level of comment and will undertake a review of the current requirements when the medical requirements for the LAPL are published.
Theoretical Exams A request was made to delegate the running of theoretical exams to the CFI of an RTF. (1 Comment) In accordance with current policy, the IAA will continue to maintain control of the setting and administration of all theoretical examinations. Assistance will be sought from the NMAI in compiling an appropriate bank of questions. The IAA is currently evaluating the development of a computer based examination system. Once this is in place it will facilitate the running of specific examination sittings at the IAA Headquarters at more frequent intervals.
UK - NPPL Several submissions requested that a system similar to the UK-NPPL be copied within the State. (3 Comments) It is the intention of the IAA to develop requirements that are by and large in line with and proportional to the EASA proposals for the LAPL.
Training From Un-Licensed Airfields The Aerodrome Standards Department of the IAA has agreed to implement a procedure that will allow a RTF to carry out training for the award of a licence from an un-licensed airfield subject to the following limitations: 1. Only one registered facility operating at the airfield. 2. RFF facilities appropriate to the level of activity will need to be in place. 3. Some form of booking out/in and alerting system will need to be in place.
Requirement for RT Qualification The rationale behind the IAA requirement to hold an RT qualification is as follows: 1. It is a requirement for flight in Class C airspace. 2. Without, operations are restricted to Class G. 3. Prudent to have RT skills in the modern age. Comparison with UK 1. In Ireland qualification is gained by continuous assessment during training and on LST. 2. In the UK specialised training and formal test is required which means additional costs incurred.
IAA v EASA LPL and UK Requirements The following slides show a comparison of the proposed IAA requirements for the issue of a microlight licence against the current IAA requirements, UK CAA NPPL(M) (Unrestricted) licence, EASA Leisure Pilot Licence (LAPL), JAR PPL(A) and EASA PPL(A).
Age UK CAA NPPL (Unrestricted) LAPL Proposed Microlight Current Microlight JAR PPL EASA PPL 17 17 17 17 17 17
Privileges UK CAA NPPL (Unrestricted) LAPL Proposed Microlight Current Microlight JAR PPL EASA PPL Without Remuneration. Without Remuneration. Without Remuneration. Without Remuneration. Without Remuneration. Without Remuneration. PIC on 3-axis SEP land weighshift flexwing SEP land, (Max 450 kg land and 495 kg sea) Max 1 Passenger (2 total on board ) PIC on SEP-Land or TMG <= 2000KG. Max 3 Passengers (4 total on board) PIC on 3-axis SEP land weighshift flexwing SEP land, (Max 450 kg land and 495 kg sea) Max 1 Passenger (2 total on board ) PIC on 3-axis SEP land weighshift flexwing SEP land, (Max 450 kg land and 495 kg sea) or powered parachute Max 1 Passenger (2 total on board) PIC on SEP-Land or TMG (Except FI or F/E for instruction) PIC on SEP- Land or TMG
Training Course UK CAA NPPL (Unrestricted) LAPL Proposed Microlight Current Microlight JAR PPL EASA PPL Theoretical and Flight with ATO Theoretical and Flight with ATO Theoretical and Flight with ATO Theoretical and Flight with ATO Theoretical and Flight with ATO Theoretical and Flight with ATO
Theoretical UK CAA NPPL (Unrestricted) LAPL Proposed Microlight Current Microlight JAR PPL EASA PPL Common: Common: Common: Common: Common: Common: Air Law, Air Law, Air Law, Air Law, Air Law, Air Law, Human Performance, Human Performance, Human Performance, Human Performance, Human Performance, Human Performance, Meteorology, Meteorology, Meteorology, Meteorology, Meteorology, Meteorology, Communications. Communications. Communications. Communications. Communications. Specific: Specific: Specific: Specific: Specific: Specific: Principles of Flight, Principles of Flight, Principles of Flight, Principles of Flight, Principles of Flight, Principles of Flight, Aircraft General Aircraft Type (Oral) Navigation. Operational Procedures, Flight Performance and Planning, Operational Procedures, Flight Performance and Planning, Operational Procedures, Flight Performance and Planning, Operational Procedures, Flight Performance and Planning, Operational Procedures, Flight Performance and Planning, Aircraft General Knowledge, Aircraft General Knowledge, Aircraft General Knowledge, Aircraft General Knowledge, Aircraft General Knowledge, Navigation. Navigation. Navigation. Navigation. Navigation.
Skill Test UK CAA NPPL (Unrestricted) LAPL Proposed Microlight Current Microlight JAR PPL EASA PPL 2 failed attempts: Further training 2 failed attempts: Further training 2 failed attempts: Further training 2 failed attempts: Further training 2 failed attempts: Further training 2 failed attempts: Further training
Medical UK CAA NPPL (Unrestricted) LAPL Proposed Microlight Current Microlight JAR PPL EASA PPL Medical Declaration or Class 1 or 2 TBC Class 1 or 2 Class 1 or 2 Class 1 or 2 Class 1 or 2
Experience Requirements UK CAA NPPL (Unrestricted) 25 hours of flight instruction to include: 10 hours of supervised solo time, 5 hours of navigation training, 3 hours of solo cross-country flight time with at least 2 cross-country flights of at least LAPL 74 km during which150 km during 1 landing at a site which not less than 28 km from the takeoff site. 10 hours as PIC on microlight within past 9 months prior to issue. 30 hours of flight instruction to include: 15 hours of dual instruction, 6 hours of supervised solo time including at least 3 hours of solo cross-country flight time with at least 1 cross-country flight of at least 1 full stop landing at an aerodrome different from the aerodrome of departure shall be made. Proposed Microlight 30 hours of flight instruction to include: 15 hours of dual instruction, 10 hours of supervised solo time including at least 5 hours of solo cross-country flight time with at least 1 cross-country flight comprising of a distance that equates to 90 mins flight time at cruise speed during which 1 full stop landing at an aerodrome different from the aerodrome of departure shall be made. Current Microlight 40 hours of flight instruction to include: 25 hours of dual instruction, 10 hours of supervised solo time including at least 5 hours of solo cross-country flight time with at least 1 cross-country flight of at least 270 km during which full stop landings at 2 aerodromes different from the aerodrome of departure shall be made. JAR PPL EASA PPL 45 hours of flight 45 hours of flight instruction (up to 5instruction (up to 5 in FSTD) in FSTD) to include: to include: 25 hours of dual instruction, 10 hours of supervised solo time including at least 5 hours of solo cross-country flight time with at least 1 cross-country flight of at least 270 km during which full stop landings at 2 aerodromes different from the aerodrome of departure shall be made. 25 hours of dual instruction, 10 hours of supervised solo time including at least 5 hours of solo cross-country flight time with at least 1 cross-country flight of at least 270 km during which full stop landings at 2 aerodromes different from the aerodrome of departure shall be made.
Introduction of New Policy Following a meeting with the NMAI some minor alterations to the content of the proposed changes were agreed, these changes will be incorporated into the final draft. It is the intention of the IAA to try and achieve an introduction of the new policy early in the third quarter of 2010. This will include the re-issue of Aeronautical Notice P.17 and AIC 11/04 and the publication of a Comment Response Document on the requirements for Powered Parachute Licensing.
Commitment to Further Review It is the intention of the IAA to review the requirements for the issue and validation of microlight licences in the State once the EASA NPA-17 process has been completed and the LAPL has come into force or within a period of not more than two years.
Thank You The Irish Aviation Authority would like to thank all those who took the time and effort to respond to the proposed changes. Additionally we would like to thank the NMAI for its valuable input throughout the consultation process.