EASA CRT application

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Title	Implementing Rules for Pilot Licensing - Explanatory Note and Appendices
NPA Number	NPA 2008-17a

IAOPA Europe (info@iaopa-eur.org) has placed 6 unique comments on this NPA:

Cmt#	Segment description	Page	Comment
518	Appendix I: Explanatory Memorandum to Part-FCL - Subpart B	21 - 23	IAOPA welcomes the introduction of the LPL and the easier access to aviation that it provides. The new LPL regulation however underlines the need to also make adjustments for the next level of licenses and privileges, particularly the instrument rating and multi-engine rating. From an overall perspective the current regulation creates a disproportionate barrier for the private pilots who want to use his priviliges for other than pure pleasure flying. Particularly the requirements to obtain and maintain an instrument rating or multi-engine privileges are now more disproportionate than ever. EASA should follow up on the good work of the MDM.032 working group by focusing on the segment of general aviation where an aircraft is not just used for pleasure flying but for personal transportation. The initiave of the FCL.008 working group focusing on the instrument rating is a good start but it should be followed up by a group dealing with multi engine operations and operations with the light end of complex aircraft.
519	Appendix I: Explanatory Memorandum to Part-FCL - Subpart I	28 - 29	IAOPA is missing a solution for both the UK IMC rating and the general problem under the JAA regulation, that the very extensive requirements for the instrument rating makes it practically impossible for a PPL holder to obtain an instrument rating. Particularly, the extensive theoretical requirements cover a number of issues which are irrelevant for the PPL holder, who just wants to fly IFR in Europe in a General Aviation aircraft. This consequence of these very extensive theoretical requirements are that a PPL holder whishing to obtain an Instrument Rating typically must attend full time class-room training for almost a full year in order to learn about subject which are irrelevant for him. The effect is that only a minority of PPL holders (less than 2 percent) in Europe holds an instrument rating. That is considerably less that in other regions of World and not benefitting safety. The JAA FCL working group has already done substantial work to identify subjects which are covered elsewhere in the curriculum and can therefore be removed from the requirements for the instrument rating. IAOPA warmly welcomes the EASA initiative to form a working group dealing with all aspects of the Instrument Rating for General Aviation. A solution for both the UK IMC rating, the situation for PPL-IR and cloud flying for gliders are all highly urgent.
520	Appendix I: Explanatory Memorandum to Part-FCL - Subpart J	29 - 30	IAOPA suggest maintaining the special provisions of JAR-FCL for instructors working for training organisations outside the territory of the Member State. Aviation is in its essence a worldwide activity and restricting or limiting the possibility for flight training to take place outside the European territory will eventually have a negative impact on aviation industry in Europe. The proposed move will most likely generate generate retaliatory restrictions against European Instructors and is the wrong way forward. The European aviation industry should not be made competitive by building barriers and making it harder for European pilots to do their flight training outside the Union. Instead the European regulatory framework should support a healthy European business climate so that European businesses eventualy can attract business from outside the Union.
521	Appendix I: Explanatory Memorandum to Part-FCL - Appendices to Part-FCL	31 - 32	IAOPA supports the view of EASA that the mentioned appendices containing detailed technical requirements should not be implemented as hard law, but transferred to AMC material in order to ensure flexibility and to facilitate later revisions.
522	Appendix II: Explanatory Memorandum to Part-Medical - Subpart A	33 - 34	IAOPA welcomes the initiative to allow GMPs to issue, revalidate or renew medical certficates for the LPL. The restriction ”when permitted under national law”, seems odd and in contrast with the intent of creating a set of common regulation. IAOPA is aware that the restriction comes from the basic regulation, but it should be made clear if a medical issued by a GMP in one Member State will be valid or not in another Member State where national law does not permit a GMP to issue a medical certificate.
523	Appendix II: Explanatory Memorandum to Part-Medical - Subpart B	34 - 36	IAOPA strongly supports the effort to align class 2 medical requirements with ICAO standards. This will remove many of the problems where pilots with a long flying experiance outside the EU are denied a European license because of the more strict European medical requirements. IAOPA also supports the view of EASA that the medical requirements for the LPL should be kept below the ICAO Class II standards. Compared to the PPL, the license is limited in both the maximum mass of the aircraft and the number of passengers that may be carried. Risk is therefore mitigated through these measures and this should be reflected in the medical requirements. Aligning LPL medical requirements with those of the PPL would take away one of the major arguments for creating the LPL in the first place. Should that be the outcome IAOPA would find it necessary to reconsider if creating an LPL Licence in the proposed form is at all the right way forward.