The limitation to hold only one license might cause problems in some cases. Particularly because of language barriers and because the authority for different segments of aviation  might be delegated to different entities (for instance one for gliding and another one for powered aircraft).

For instance in the case where a pilot has taken a glider license (LPL) in one country and now wants to get a full PPL or CPL license for powered aircraft in another country.

In this case transferring all license administration from the gliding authority in one country to the powered aircraft authority in another country offers no real benefits. Instead it causes problems because of language barrieres and because an authority which specialises in one segment of aviation now must deal with another segment for which it is not competent.

According to ICAO language proficiency requirements, pilots flying abroad that are required to use radio must be able to communicate in English also on "common" and not just work related topics. This is a hurdle that cannot be taken by many Private Pilots flying purely VFR and not having an academic language background. Consequently they will be limited to flying in the area of their national language.

This is a severe limitation of personal freedom in aviation whereas a significant increase in safety cannot be expected. Sailplane pilots that are sharing the same airspace according to the same Visual Flight Rules and use the same aerodromes do not have to fulfill these language requirements.

For the LPL EASA remains in many respects below ICAO standards, as long as safety is not compromised and an economic or operational benefit is expected.

Consequently it should also be evaluated if the ICAO language proficiency requirements could safely be lowered for LPL-VFR pilots.

In Germany good experience was made with English radio telephony licenses, for which an applicant had to demonstrate to examiners that he or she is able to:

• translate texts of an Aeronautical Information Publication (AIP) from English into the National Language
• conduct an approach to and a departure from a towered airport using aeronautical phraseology
• emit emergency calls.

A europeanwide radio telephony license based on a similar principle should be limited to VFR operations only and good for life-time!

The name of the new socalled ”Leisure Pilot License” is by the whole Genaral Aviation industry regarded as very unfortunate. The term ”Leisure” associates the license with just sport or hobby purposes. In fact the license will be used for many other activities where the most prominent is simply ”personal transportation”.

A car you can be used both for driving to work and going to leisure activities. Yet your drivers license is not tagged ”leisure”, and the risk is that this new license will not get proper recognition with this ”leisure” brand.

The requirement that a pilot must pass a proficiency check with an EXAMINER every 6 years  should not apply for the LPL and PPL and for the class rating for a SEP. The option to do a training flight with an instructor is preferable for the non-profesional pilot, since it actually gives the pilot training and upgrades or helps maintain his skills.

The normal atmosphere in a checkride situation does nothing to improve the pilots flying skills or knowledge. On the contrary, the pilot will typically refrain from asking questions and touch subjects where he knows that he has weknesses.

If a check is regarded as necessary in order  to satisfy the basic regulation, it is proposed to combine it with a training flight,  that may be conducted by the FI or LAFI, and where the instructor  by the end of the flight will pass or fail the pilot  based on the same objective criteria as the proficiency check.

Training flights with instructors as introduced under JAR-FCL are fully sufficient for fulfilling the  requirements of the Basic Regulation.

The Basic Regulation in its respective Annex III 1.c.2. and 1.e.2. doesn´t require Proficiency checks from Examiners, but regular "assessments, examinations, tests or checks". Assessments or checks can of course be conducted by Flight Instructors. Considering that a flight instructor is authorised to send a student solo, it should be obvious that s Flight Instructor is able to assess the if a pilot operates safely.

If the Agency believes that training flights with flight instructors were to an unacceptable degree not conducted as intended by the authorities, appropriate measures have to be taken to assure the desired quality of future training flights. Flight Instructors could be required to follow an official checklist of required exercises and to sign that all exercises were performed by the applicant in an acceptable way. Such a checklist could also be used for checking the theoretical knowledge of the applicant.

If a proficiency check with an examiner is maintained IAOPA fears that this will create a mental barrier for a number of non-professional pilots and push people out of General Aviation. Feedback from IAOPA members shows that many pilots regard the introduction of Proficiency Checks as a signal of severe mistrust and that they are rather willing to give up flying than to undergo these proficiency checks.

It is also unclear where the high number of required Examiners could come from, a new dangerous bottleneck would be created.

Crediting of holders of other licenses should be competency based. A pilot with thousands of hours flying a glider will relatively easy be able to convert to a powered aircraft and should get credited accordingly.

The current proposal with just 10 percent of the total flight time required is way too rigid.

To have IR Refresher courses only in a ATO is not reasonable. Any IRI can also offer the refresher training, an ATO environment is not necessary

Experience Requirements for the Towing Ratings are too high.

The rating should be granted if the applicants perform well during their checkflights. If a minimum hour requirement is regarded as necessary at all, it should be lowered to 50 hours for banner towing and to 20 for glider towing.

IAOPA support the initiative to remove the CPL requirement for a PPL-FI.

A TRI has to pass a proficiency check for each 2^nd revalidation, this is immoderate and wasn´t required until today. This has not ben a problem till now and the requirement should be deleted.

A SFI has to pass a proficiency check for each 2^nd revalidation, this is immoderate and wasn´t required until today. This has not ben a problem till now and the requirement should be deleted.

Why is an aircraft with retractable gear required for CPL courses? Most modern aircraft don´t have it and are complex enough, like a Cirrus SR22, Cessna 182 or 350, etc. It will be a problem to find enough old Piper Arrows for this purpose!

It is proposed to rewrite the requirement into: ”Aircraft with retractable gear OR more than 200 hp.”

Why is for the PPL-IR acceptance an experience of 100hrs required? This can´t be a safety requirement, because the pilots abilities are already controlled in a skill test.

The requirement for PIC time should be deleted or drastically reduced.