IAOPA seeks clarification on unnecessary 'mandates'
IAOPA Europe has written to EASA asking the Agency to inform national aviation authorities (NAAs) that manufacturers’ recommendations and service bulletins are not mandatory and aircraft owners should not be forced to comply with them. The request, set out in an IAOPA White Paper on maintenance, follows an increasing number of sometimes bizarre decisions by national authorities who have misinterpreted the Part M maintenance requirements. As an example, Sweden has made it mandatory to have the door seals on some aircraft lubricated by a licensed engineer every 30 days, battery boxes and cables to be checked on a similar schedule, and oil to be changed every four months regardless of flight hours. The situation has led to major problems in Sweden, where aircraft have had to be flown for some hours to a licensed engineer who can lubricate the door seals each month – a two-minute job accompanied by 45 minutes of expensive paperwork. When challenged, the Swedish CAA blames EASA and points to AMC M.A. 302 (d) 1. of the Part M requirements: “An owner or operator’s maintenance programme should normally be based upon the maintenance review board (MRB) report where applicable, the maintenance planning document (MPD), the relevant chapters of the maintenance manual or any other maintenance data containing information on scheduling. Furthermore, an owner or operators maintenance programme should also take into account any maintenance data containing information on scheduling for components.” This means, according to some NAAs, that manufacturer’s recommendations must always be complied with. IAOPA points out that other sections of Part M specifically refer to documents such as Service Bulletins as ‘non-mandatory material’, and it is requesting speedy clarification from EASA.
IAOPA points out that the effect of mandating compliance with service letters or bulletins – which are not officially approved as instructions for continuing airworthiness – is to give privately-employed non-EU citizens working for the various Type Certificate holders legislative powers that cover the European Union. This situation is completely unacceptable.
IAOPA’s White Paper also requests that EASA clarify the situation concerning ‘grandfathered’ documents on continuing airworthiness that pre-date the adoption of the JARs in 2003. Some NAAs have been citing Part M when demanding full and complete documentation going back 20 or even 30 years, with aircraft grounded until all the paperwork can be produced – which in some cases is not possible. IAOPA’s position is that maintenance documents overseen by NAAs prior to the adoption of the JARs were effectively accepted by the system in September 2003, and that no owner should now be required to provide documentary proof that maintenance schedules were adhered to in the 1990s, 80s or even 1970s.
IAOPA plans strategy on Single European Sky
IAOPA-Europe’s main delegates involved in the Single European Sky programme met in Brussels at the end of February to plan strategy and set out policy on SESAR. IAOPA is involved in 84 SESAR work streams covering a vast array of subjects, and co-ordination is paramount. Dr Michael Erb and Klaus-Peter Sternemann of AOPA Germany, and Ben Stanley of AOPA UK, are most closely involved with SESAR, which is planning Europe’s air traffic management system for the future. The scope of SESAR is vast and involves everything from future airspace categories and control systems to data provision and aircraft equipment. Consultation and planning involves regulators, airlines, aircraft manufacturers, equipment providers, European air forces, ATC providers and trades unions, airfield operators and many more groups, and as is often the case, the big beasts have the loudest voices; if general aviation is not represented at every level, there is a risk that 20 years from now its place in the skies will be in question.
The meeting followed a European Commission conference the previous week on funding and financing for SESAR. The European Parliament has laid down that those who are forced to pay while reaping no benefit should be recompensed, and GA falls into that category. While it has not been decided what on-board systems will be required, they will certainly cost money, and there will be aircraft which cannot comply with equipage requirements. None of this means much to the airlines or large aircraft manufacturers, but thanks to IAOPA’s lobbying the EC recognises that GA is a special case. IAOPA Senior Vice President Martin Robinson attended the conference. “Views on funding are very diverse,” he says. “The attitude of the airlines is that funding is not a problem, and that if there’s a good business case, loans will be available. That of course is not GA’s position. The military have their own budget constraints, the air traffickers have a position, and the European Investment Bank is closely involved. But for the GA pilot and owner, the demand to equip with 8.33 radios, perhaps ADS-B and whatever other systems will ensure interoperability with CAT constitutes a significant cost with no financial return, and the EC recognises this. How they will handle it is unclear. The regulations allow for some of the income from airline emissions trading, which starts this year, to be used for ‘network improvements’, so that is one avenue to pursue.
“One positive outcome of the meeting was that I discovered that one of the European Investment Bank delegates is a GA pilot and a member of AOPA Germany, and he could be a useful source of advice.”
Regional Meeting in Beirut postponed
The Regional Meeting of IAOPA Europe which was to have been held in Beirut on March 26th has been postponed, and the next RM will be in Friedrichshafen, Germany on April 16th. Political uncertainties in Lebanon led to the decision to put the meeting off. Martin Robinson said: “Haytham and Hadi Azhari of AOPA Lebanon have put a lot of work into organising the Regional Meeting and it is galling to have to postpone it, but we look forward to meeting in Beirut in the near future when the situation is clearer.”
The Friedrichshafen Regional Meeting will coincide with Aero, Europe’s biggest general aviation event, which runs from April 13th to 16th. IAOPA has a booth at the show, which will be jointly manned by personnel from AOPA Germany and AOPA Switzerland, with representatives of other AOPAs present from time to time. Despite the economic situation, the show boasts 550 exhibitors from 26 countries and covers every facet of general aviation. More than 40,000 visitors are expected, two thirds of them licensed pilots. IAOPA has arranged a conference with representatives of EASA who will answer questions from the audience, so if there’s anything you’d like to know directly from EASA, here’s your chance.
Looking further ahead, the next Regional Meeting will be in Krakow, Poland, on October 1st. AOPA Poland’s Blazej Krupa is trying to overcome the perception among pilots in western Europe that Poland is far away. “Look at the map of Europe,” he says. “Poland is actually closer to you than many popular tourist destinations.” It also benefits from relatively inexpensive avgas. Blazej has sent a calendar of events at Ketrzyn Airfield (EPKE) in north-east Poland. This is the gateway to the Baltic States, and is the airfield at which AOPA Poland holds most of its fly-ins and rallies. You are promised a warm welcome here; your own AOPA can put you in touch with Blazej or the owner of the airfield Stanislaw Tolwinski if you need any help or information.
Licence transfers should be free of charge
IAOPA-Europe is concerned at the cost to pilots of transferring licences to EASA and is asking authorities to issue new paperwork free of charge. From April next year, when EASA takes over responsibility for flight crew licensing, pilots will have to obtain EASA licences, and in some cases this is likely to cost them several hundred euros. In the case of Great Britain, because EASA does not recognise national licences issued by their Civil Aviation Authority, pilots will have to surrender their national licences – which are valid for life – and pay for JAA licences, which are valid for five years. The conversion currently costs £176, or over €200. When these JAA licences expire, they will have to convert them to EASA licences, which are once again valid for life. The proposed cost of this is not yet established. Martin Robinson says: “Collectively this is going to cost general aviation millions of euros, and it is unjust that pilots should have to pay it, especially at a time when activity is suppressed by the economic downturn. This is a bureaucratic change for the convenience of regulators. Effectively, they have changed the rules to force pilots to get new paperwork in order to carry on doing what they’ve been doing for years, while charging them excessive sums of money for new documents. No cost should fall on pilots who are forced to conform to old regulations written on new pieces of paper.”
AOPA in the United States has conducted a study of flight training to help us understand how we might attract more students and keep them in general aviation, and has come up with some interesting proposals. In particular, it says, the flight training industry is not exploiting the “cool” factor in aviation – student pilots feel special because of the skills they are learning and the new world they open up, and the industry is not exploiting that factor enough. While this is an American study, it seems unlikely that the European situation will be greatly different. It shows that some 70 percent of students believe their learning experience was ‘very good’ with only three percent saying it was ‘very bad’. Not surprisingly, when they found a good instructor they wanted to stick with him or her; the relationships with the instructor was one of the most decisive elements of the whole process. Students want to feel they were valued by training schools and are not being ripped off – some students resented the fact that their instructor did not seem to care whether they passed or failed. But what is not emphasised enough is the sheer exhilaration and enjoyment of being in the air, which obviously affects the student more than the instructor. It’s also no surprise to learn that the greatest single negative aspect of learning to fly is cost. While there’s not much schools can do about that, they can address many of the other issues raised. Focus groups linked to the study suggest that inclusion in an exclusive, achievement-orientated aviation community is a powerful draw. Jennifer Storm, who heads AOPA’s Flight Training Student Retention Initiative, says: ‘The research shows that there’s a huge element of the specialness of being a pilot that we’re not especially tapping into.’
New President of AOPA Italy
AOPA Italy has a new President. Carlo Golda, President since April 2009 has relinquished the post because he has insufficient time to dedicate to the association and the Board of Directors has appointed the former Vice President Rinaldo Gaspari to see out Carlo Golda’s term, which was due to end in April 2012. Rinaldo, a TV director, has been a PPL since the 1980s and owns a Piper Sport Cruiser. He was part of the Italian delegation at the IAOPA World Assembly in Tel Aviv, as well as part of the crew of one of the seven planes that flew to Israel from Italy.