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Regulators attack cost and bureaucracy
EASA has played a major part in an FAA Aviation Rulemaking Committee in Washington which has recommended wholesale regulatory changes to improve the safety of general aviation aircraft while reducing certification and modification costs. IAOPA will be pressing for similar measures to be adopted in Europe.
The FAA-led international committee was asked to examine the existing standards for the design and certification of aircraft ranging from small piston-powered airplanes to high-performance business jets. They recommend changes in design, production, maintenance and safety requirements and identify ways to streamline the certification process, making it cheaper and easier for manufacturers to incorporate safety improvements, allow for upgrades to the existing fleet, and provide flexibility to incorporate future technological enhancements.
The ARC recommends that compliance be based on the complexity and performance of an aircraft instead of simply weight and type of propulsion. Under existing requirements small, relatively simple planes have to meet the same regulations as complex aircraft.
“Streamlining the design and certification process could provide a cost-efficient way to build simple airplanes that still incorporate the latest in safety innovations,” says US Transportation Secretary Anthony Foxx. “These changes have the potential to save money and maintain our safety standing – a win-win situation for manufacturers, pilots and the general aviation community as a whole.”
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NAAs in confusion over Cessna SIDs
Differences of opinion among European regulators are threatening to make the problems faced by owners of older Cessna singles even more acute, and may effectively write off such aircraft if no solution can be found. 100 and 200 series aircraft manufactured before 1986 are subject to a Cessna Supplemental Inspection Document (SID) which calls for, among other things, corrosion inspections involving in some cases the removal of the wings. In America, the SIDs are not mandatory for private aircraft, and EASA has agreed that they should not be mandated for private aircraft in Europe. But the French and German national aviation authorities are treating the SIDs as mandatory and expect all private owners to comply. For some, this means spending up to €10,000 on inspections which may not uncover any problem, but which is completely disproportionate bearing in mind the low value of the aircraft and could lead to them being scrapped.
Other national aviation authorities are following the EASA line and allowing private owners to choose whether to remove their aircraft’s wings. Germany has the highest number of affected aircraft, and AOPA Germany’s Managing Director Dr Michael Erb has been actively seeking to resolve this issue in favour of owners. “Quite apart from the direct effect on the owners of older Cessnas, we are in a situation where we are allowing Cessna’s liability lawyers to write German aviation law,” he says.
Dr Erb has obtained from EASA a written ruling that private owners are not bound by the SID. It reads: “We can confirm that the Cessna Supplemental Inspection Documents for 100/200 series are not included in the airworthiness limitations sections of the Cessna instructions for continuing airworthiness (ICA), and at this point they are also not covered by an AD. Hence, the Cessna SIDs for 100/200 series qualify as non-mandatory inspections in terms of ICA, even if they are designated ‘mandatory’ in the revisions to the Cessna maintenance documentation. The position of the Agency is that compliance with SID for Cessna series aircraft should generally be recommended to aircraft owners/operators in line with the principles set out in M.A.302 and the related AMCs (cf. in particular Appendix I to AMC M.A.302 and AMC M.B.301(b) ‘Content of the Maintenance Programme’, item 1.1.13a). If the owner/operator then decides not to include the optional modification/ inspections in the maintenance programme, he/she takes full responsibility for this decision.”
German and French authorities, however, continue to insist that the SIDs are mandatory. Dr Erb, who has confirmed the EASA position with the Agency, says: “Obviously the value of Cessna singles built before 1986 is in many cases very low, and pulling the wings off is very costly and could force owners to scrap their aircraft. While EASA states unequivocally that the inspections are at the discretion of owners if the aircraft are flown privately, it does not impose its ruling on member states mandating them.
“A decision is to be made during the summer break, but if the decision is left up to the member states, there might be some hundred German Cessnas migrating to the UK register. We have upcoming meetings with the officials of the Federal Ministry of Transport, the Federal Aviation Office (LBA) and the Agency to finally get clarity on this issue.”
Details and a video of the SIDs can be found here
UK CAA to let GA off the leash?
In contrast to other National Aviation Authorities in Europe, the UK CAA has expressed its intention to remove where possible all unnecessary obstacles to general aviation and has appointed a General Aviation Manager to plan the future regulation of the sector.
The CAA has made an unprecedented apology for its slow performance on licensing during the EASA changeover and has promised “no more gold plating” of EASA rules for general aviation in the UK. The Authority’s latest statements have been welcomed by AOPA as evidence that a new culture of support for GA has taken root in Britain, and a new partnership between regulator and GA industry is being created.
The CAA is reflecting industry concerns about EASA’s new Aviation Training Organisation requirements, which impose new bureaucracy and cost on flying schools. The Authority believes the current small-scale training organisations, known as Registered Facilities, already achieve acceptable safety standards and need no additional regulation, and that their oversight could be delegated to an industry representative group. “We will also seek to impose the minimum amount of regulations allowable,” the CAA says. “We have committed to eliminate any ‘gold-plating’ of EU regulations, and will not impose any higher standards or extra requirements than those required by the EU.”
The CAA has appointed Mike Barnard, a GA pilot, engineer, aircraft builder and owner, to run its General Aviation programme. In an interview with the AOPA UK magazine General Aviation Mr Barnard said he believes there is an appetite for change across the world in the way GA is regulated. “There is a realisation that the sort of top-down regulation we have traditionally had does not work well for GA, and a new approach is needed,” he says. “Both in the UK and Europe it is accepted that the current regulatory environment is bureaucratically burdensome, and we are working with our European colleagues to deliver a safety strategy for general aviation, proportionate to the needs and viability of our sector. In other words, if the GA industry is to survive, it has to be allowed to breathe more freely.”
Regulation must he risk-based, he says – and the CAA is not there to save you from yourself. If you understand and accept the risks, you are entitled to take them. “Aviation regulators recognise their principal duty of care to the genuine uninvolved third-party. (However) the pilot of a single seat de-regulated aircraft is fully aware of his own risks and is personally responsible for mitigating them; where the risk to society is small and the participants are fully aware of any risks involved, the level of intervention need not be onerous. We are looking carefully at the concept of ‘informed consent’ to help us develop more appropriate approaches to some operational aspects involved in GA; watch this space”
AOPA UK CEO Martin Robinson says: “The UK CAA has always been a European leader and we hope other authorities will follow its lead on this matter, as they have on so many other issues.”
Planning a future for the Open FIR
AOPA UK’s Chief Executive Martin Robinson was a keynote speaker at a conference on Britain’s Future Airspace Strategy, described by incoming EASA Executive Director Patrick Ky as “the only credible airspace strategy in Europe”. The thorny issue of how uncontrolled Class G airspace fits into the future structure was debated by industry leaders, airlines, military men and regulators, all with different imperatives. Airlines operating from regional airports must fly through uncontrolled airspace to reach them, with passenger aircraft often flying at 250 knots and with severely limited field of view through the flight training areas of GA airfields. Many GA aircraft without transponders do not show up on their TCAS collision avoidance systems. The Royal Air Force, which has suffered several losses from mid-air collisions in recent years, is equipping all its aircraft with TCAS from next year. Opinions ranged from banning all commercial traffic from Class G below 10,000 feet to imposing more controlled airspace and forcing all of GA to equip with transponders. A middle way must be found, and Martin Robinson has agreed to chair a CAA-sponsored working group on electronic conspicuity systems. Martin says: “If a small, lightweight, portable transponder-like system could be made available for the price of a mobile phone, would that change the nature of the debate? The challenge is to increase traffic awareness without changing the nature of Class G airspace, which is there for all users.”
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Spain makes progress on saving GA
July saw the last meeting of the working groups promoted by the Spanish CAA, the Dirección General de Aviación Civil. The meetings of the Airport Access and GA Airspace Access working groups mark the conclusion of a first, intense year in which all members around the table (DGAC, airports operator AENA, Safety and Security Agency AESA, AOPA Spain and other GA and aerial work representatives have developed specific measures to save general aviation in Spain.
Rafael Molina of AOPA Spain reports that a new Real Decreto (bill) which will add flexibility to the operation of public airports, a new ministerial order on ultralight aircraft, the slow but steady implementation of VFR/N and the simplification of flight plan filing are the highlights of these work programmes.
Also in the final staging phases are items such as the Real Decreto on restricted use airfields, terminal building segregation for general aviation, and handling services, as well as fuelling service requirements for GA.
We hope that the momentum given by the Director General de Aviación Civil Mr. Angel Luis Arias, will continue into the future in order to keep on working on the many subjects that still need improvement.
The new board of AOPA Spain, elected in June, is preparing for the start of the next round of working programmes in September, pursuing the updated version of the “19 key measures to save general aviation in Spain” manifesto, which was delivered one year ago and which has served as a template for these meetings.
UK IMC rating – not dead yet
The United Kingdom is fighting to retain its IMC rating, which EASA says cannot be awarded after April next year. Andrew Haines, Chief Executive of the UK CAA, and Mark Swan, who is responsible for GA safety, are to meet with EASA and European Commission officials to try to find a compromise which will allow the rating to continue in the UK. The British believe the IMC rating underpins their excellent GA safety record. Despite Britain’s unpredictable weather – and EASA accepts that bad weather is the big killer of GA pilots – the UK’s safety record is said to be as much as four times better than elsewhere in Europe with similar levels of activity.
The IMC rating is a 15-hour flying course which teaches GA pilots to maintain control of aircraft in IMC and return them to the ground by whatever means are available. IMC-rated pilots are encouraged to practice their instrument flying skills, and renewal requirements are strict. Since AOPA UK wrote the syllabus for the rating 40 years ago some 26,000 pilots have obtained it, and the CAA says only one IMC-rated pilot has been killed flying into IMC. The system has co-existed with Commercial Air Transport for decades without problems, and professional pilots’ bodies are among the rating’s strongest supporters.
Because flight in IMC outside controlled airspace is forbidden in some European countries, EASA says the UK must abandon the IMC rating. It also says the IMC rating is untenable because it is a sub-ICAO qualification – but so is EASA’s En-Route Instrument Rating. EASA cannot remove qualifications that pilots already have, so IMC rating holders will be granted an EASA Instrument Rating (Restricted) which will allow them to exercise the privileges of the IMC rating in UK airspace. This means the full IMC rating instruction system must remain in place for currency and renewal purposes – but instructors will be prevented from teaching the same lifesaving skills to new pilots.
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Visit Athens Flying Week
Athens Flying Week is coming up again! AOPA Greece is once again assisting Podimatas AudioVisual S.A, in organising the biggest aviation event in the Athens area. Podimatas is the main audio visual company in Greece, owned by an AOPA member.
This is the second annual Athens Flying Week. Last year it managed to attract 20,000 visitors, and this time targets are set much higher. For the first time this year military aircraft from Greece and abroad will participate in the air show. The organisers welcome this inclusion of military aircraft in an otherwise general aviation air show, which helps with publicity, attracts bigger crowds and shows confidence in the professional way the air show is organised.
All pilots are welcome at a fly-in at Tatoi airfield during Athens Flying Week, which runs from September 23rd to 29th. A comprehensive list of all the activities of Athens Flying Week can be found on the website www.athensflyingweek.com. There you will also find the registration form for the fly-in and information about the event, accommodation, excursions and much more. For further information, please contact us by email.
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AOPA UK fly-in at Duxford
All European pilots are invited to Duxford Airfield, near Cambridge in England, for the annual AOPA Bonus Day when members of AOPA UK fly in to one of Britain’s most exciting airfields – home of the Imperial War Museum’s world-class collection of historic aircraft. Speakers from AOPA, the CAA and other bodies will be giving pilots the most up-to-date information on the issues that matter most to them, while the entry fee to the event includes free access to the magnificent museum. There will be free guided tours of the collection, which includes everything from Concorde to the SR71 Blackbird, the B-52 and of course the iconic fighter aircraft of World War Two. The date is Saturday September 14, the place Duxford (EGSU). See www.aopa.co.uk for more details.
IAOPA-Europe Regional Meeting
The next Regional Meeting of IAOPA Europe will be hosted by AOPA Germany and take place at the Marriot Hotel, Heidelberg, on Saturday 28th September. The Co-ordination and Technical Affairs Teams will meet on the previous afternoon. For those who are flying there, Mannheim City Airport (EDFM), located only 15 km west of Heidelberg, is offering delegates a free landing and no parking charges during the meeting. Mannheim is a GA friendly airport; runway 09/27 is 1066m, and runway 27 has both a LLZ and a GPS approach. Avgas and Jet A1 are offered. If you intend to fly in, please provide your details to Dr Michael Erb of AOPA Germany.
‘Get Your Head Right’ on Airsoc.com
Piloting is as much a mindset as it is an activity. Whether it’s a familiar local jaunt in the sunshine or a hard-core international IFR airways leg, what you are really stepping into at that point is another environment, profession and decision-making framework that probably doesn’t resemble anything else in your life.
So, how do the professionals do it? Taking advantage of that privileged proximity that our activity allows, here are a few tactics the pros deploy that appear to work and we might think about. Read more here
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