EC works to reduce ATO burden on flying clubs
Following a meeting with IAOPA officials, the European Commission has informed us that they are working on a derogation for flying clubs (or aero clubs, depending on which country you’re in) with the aim of removing their activities from the definition of ‘commercial’. This could be a huge relief to flight training organisations which would otherwise face serious increases in bureaucracy and cost. The Commission has responded to IAOPA’s concerns and believes this could be a ‘quick win’ but it warns that it needs the support of EU member states.
IAOPA believes the EASA definition of ‘commercial’ flying is too wide – basically it encompasses almost everything where money changes hands. This leads to a situation in which EASA indicates that you must be a commercial pilot operating on an AOC in order to give trial lessons, or even under certain circumstances to cost-share. Being designated as a commercial operation opens up new levels of bureaucracy, complexity and cost. UAOPA has been pressing for a change to the Basic Regulation, the EC’s guidance document for EASA, in order to narrow the definition. The Commission is sympathetic to our position but now believes the same goal can be accomplished by a derogation rather than a change to the Basic Regulation.
IAOPA Senior Vice President Martin Robinson says: “Where Registered Facilities and aero clubs must transform themselves into Aviation Training Organisations (ATOs) under EASA, there is a step-change in the level of bureaucratic oversight and cost. We need to find ways to alleviate that, and we must congratulate the Commission on making a serious attempt to help. The Commission is listening and proposing positive changes. It doesn’t by any means overcome all the problems that ATOs face, but it shows that the goodwill is there, and the EC is intent on removing a significant obstacle to business. We need all member states to agree with this, and IAOPA will work towards that end.”
IAOPA is advising flying schools to wait before applying to become ATOs because there are still issues to be settled, and there is ample time. Martin says: “It’s advisable to wait until the acceptable means of compliance are settled, because only then will we have a good understanding of what’s required.”
IAOPA prevails on accelerate-stop law
IAOPA-Europe has mounted a successful campaign to amend EASA rules which would have closed some 900 European aerodromes to turbine twins. The effect would have been catastrophic for small aerodromes for whom such aircraft represent premium traffic, and would have forced some owners to downgrade to piston twins or singles, markedly reducing safety.
Dr Michael Erb, Managing Director of AOPA Germany, co-ordinated the successful campaign. Here, he outlines what has been achieved:
‘There is light on the horizon for non-commercial twin turboprops who would have been adversely affected by EASA-OPS.
‘When the latest draft of the EASA-OPS requirements for Non-Commercial Operators of Complex Aircraft went out, the message for IAOPA and the affected operators of complex aircraft below 5.7 tonnes MTOW was shocking: take-offs from shorter runways would no longer be possible following the requirements of OPS.NCC.POL.125 for Accelerate Stop, specifically:
b) In the event of an engine failure during take-off, the pilot-in-command shall ensure that:
-1. for the aeroplane where a V1 is specified in the AFM, the aeroplane shall be able to discontinue the take-off and stop within the accelerate-stop distance available;
‘A turboprop aircraft, which could up to now legally take off on a 700m runway, would need under the new rules almost 1200m to fulfill the requirements. The consequences would have been that at about 900 European aerodromes used by workhorses in corporate aviation such as the Beech King Air 90 and 200 could no longer operate as they’d done safely for decades.
‘IAOPA presented these facts, which had obviously been overlooked in the respective Rulemaking Impact Assessments, in a well-organised information campaign to its members, the European institutions and Members of the European Parliament. The message was clear: corporate aviation would lose access to almost 50% of their aerodrome network, with devastating consequences for aircraft operators, aerodromes and regional economies. IAOPA’s critical comments in the Rulemaking Process were noted, but not accepted by EASA.
‘Many aircraft operators and aerodromes joined IAOPA’s criticism and wrote to their MEPs, with remarkable success Vice-President of the European Commission Siim Kallas and the EASA Rulemaking Department have now declared concurrently to MEPs and IAOPA that turboprops below 5.7 tonnes should be exempted from the new Accelerate-Stop requirements.
‘They now say: “It could indeed be justified to question the proportionality of the new rule in relation to a small number of twin-engined turboprops at around 900 aerodromes in Europe. Besides this it has to be seen that the non-commercial operation of complex aircraft is not under competitive pressure and that the owners, having far-reaching control over the safety standards of their operations, naturally make provisions for the safety of themselves and their passengers.”
As the OPS-NCC regulations can’t be changed any more in the running legislative process before they reach the European Parliament for acceptance, it is foreseen that they will be adapted before the three year-transition period to OPS-NCC ends.
‘It is still unclear what will happen with the jet aircraft below 5.7 tonnes MTOW, for which both the Certification Standards of Part 23 and the ICAO Operations Requirements of Annex VI Part 2 do not require Accelerate Stop calculations. IAOPA requested that they be exempted as well, but there appears to be strong pressure from aircraft manufacturers and commercial operators to implement OPS.NCC.POL.125, which is obviously more an issue of competition than of safety. Non-commercial corporate aircraft are allowed to operate from relatively short runways which are not accessible to commercially operated aircraft any more, for which more strict take-off criteria are applicable since JAR-OPS commercial rules were introduced – a fact that has always been a thorn in the side of commercial operators, and against which they are obviously seeking action.
‘We will keep you updated.’
Europe moves ahead on unleaded avgas
The world’s only remaining producer of tetraethyl lead (TEL) has confirmed it will continue to manufacture the product as long as aviation needs leaded avgas. There had been concerns that Innospec Ltd, based in the UK, would discontinue TEL production before general aviation had arranged viable alternatives.
The news comes as Europe is making positive progress towards a viable unleaded alternative, and there are indications that Europe will no longer consider itself tied to the American ASTM D910 fuel standard, allowing it to take control of the situation and capitalise on its lead in the field. Unleaded avgas has been available in parts of Europe for 30 years, and it’s now possible to fly from the Mediterranean to the North Cape with unleaded avgas available all the way.
The Aviation Fuels Committee (AFC), formed to plan strategy on unleaded avgas, is to meet again in London in March after setting out an ambitious work programme. IAOPA is represented on the committee by Rob Hackman of AOPA US and Lars Hjelmberg, who as well as representing AOPA Sweden owns Hjelmco Oil, the Swedish company which produced the first unleaded avgas.
At the last AFC meeting, Lars Hjelmberg outlined the options for transition to unleaded avgas and warned that whichever route was adopted, there would be additional costs to industry which would challenge progress. IAOPA undertook to examine lobbying opportunities for tax incentives to encourage the spread of unleaded avgas, and IAOPA’s Brussels lobbyist Lutz Dommel has been talking to officials and MEPs.
The AFC is hugely important because the whole European avgas industry is there, together with manufacturers including Piper, Cessna, Cirrus and Diamond and Lycoming, EASA, the UK CAA and Ministry of Defence. As well as transition routes the AFC is addressing issues relating to decals, dyes and misfuelling possibilities, engine manufacture, and military requirements.
Euro safety concerns pose IMC questions
EASA and the European Union have identified their top five safety concerns for general aviation in a ‘roadmap for regulation of general aviation’ which raises more questions than it answers. Addressing their concerns would not seem to be a matter of regulation, and in some cases EASA’s rulemaking could be seen as reducing safety, particularly in the case of flight in bad visibility.
The top five concerns are:
*Loss of control in visual meteorological conditions. These are basic handling issues, typically stall/spin accidents.
*Controlled flight into terrain, typically a non-instrument rated pilot scud-running in worsening weather ending with hitting the ground or an obstacle.
*Low altitude aerobatics or buzzing.
*Loss of control in instrument metrological conditions – often similar to the poor weather accidents in item 2 except that to avoid CFIT the pilot elected to climb into cloud where he lost control.
*Forced landings due to pilot error, most often caused by running out of fuel.
IAOPA is concerned at how EASA reconciles its list with its actions, notably on instrument flying qualifications. The United Kingdom is fighting to retain its Instrument Meteorological Conditions (IMC) rating, which has saved hundreds of lives in the last 45 years and is seen as being partly responsible for the UK’s exceptional GA safety record. It successfully addresses concerns 2 and 4 with a training course of a minimum of 15 hours which teaches the low-time pilot to maintain control in IMC, and to return an aircraft to the ground safely using whatever aids are available. From 2014, EASA intends that no further IMC ratings can be issued, although the UK CAA is still fighting to retain the rating, given Britain’s capricious and unpredictable weather.
IAOPA Senior Vice President Martin Robinson has raised concerns about the data on which the EU/EASA list is based, particularly with regard to stall/spin accidents. Spin training was abandoned on the introduction of JAR-FCL because it caused too many accidents. The current PPL syllabus allows for spins and spin recovery to be demonstrated by the instructor in a suitable aircraft. However, under JAR-FCL the emphasis was placed on stall/spin avoidance.
Martin Robinson believes the number of accidents attributed to stall/spin where no amount of stall/spin recovery training would make any difference has not been properly taken into consideration. A recent UK analysis of stall/spin included several such incidents. Martin says: “In one, an overloaded aircraft taking off from a short runway clipped a tree, stalled and spun in. In others, aircraft stalled by getting too slow on the turn from base leg to final approach and spun in from around 300 feet. Mandating spin recovery training in response to these accidents is pointless; the current recognition and avoidance training is the key.”
EASA accepts that in many cases, such as low-level aerobatics or ‘buzzing’, a pilot’s actions are already illegal and new regulation will do nothing to improve safety. The document containing the five points, however, is said to be laying the foundations for the way GA is regulated in future.
Harmonisation without standardisation
One of IAOPA’s major concerns is the wildly different national interpretations of EASA rules, exemplified by the EASA private pilots licence, which will be a 17-page document in some countries, two pages in others – with both countries interpreting exactly the same EASA requirements. Lack of standardisation in what was originally supposed to be a harmonisation exercise has long undermined EASA’s raison d’être. Sweden’s application of the Part M maintenance rules, for instance, turned an already-complex problem into an impossible one. “Unless we get this right, general aviation is really going to suffer over the coming years,” Martin Robinson said.
The issue of national interpretation will be examined at the Regional Meeting of IAOPA-Europe in Malta in March. EASA was set up to address the deficiencies of the Joint Airworthiness Authorities, which made common rules but allowed national authorities to adopt or interpret them in their own way. The JAA system achieved a harmonisation of around 95 percent, which was deemed to be insufficient. Now, it looks as though EASA’s harmonisation rate will be lower.
Martin Robinson says: “The situation is made worse by the translation requirements, which allow room for inherent ambiguity. No language in Europe is deemed to have primacy, so every translation is law, however much it varies from the intent of the writers. The whole point of harmonisation is lost if standardisation is inadequate. After all this upheaval and pain in our industry, we have to ask whether we have really moved on from the JARs.”
New Channel Islands registry on the cards
The Channel Islands of Jersey and Guernsey are moving ahead with plans to set up their own aircraft registry after witnessing the success of the Isle of Man ‘M’ register, which has attracted more than 500 aircraft in five years. Like the Isle of Man, Jersey and Guernsey are self-governing Crown dependencies, which means they are not part of the United Kingdom, nor are they part of the European Union. They have attractive tax structures, and it is expected that like the Isle of Man, they may allow their aircraft to be maintained under the regimes of any reputable aviation authority.
The establishment of a Channel Islands registry has been delayed by internal friction, with Jersey and Guernsey jealously guarding their autonomy to the point where co-operation is handicapped. Guernsey precipitated action by deciding to go it alone and will be establishing the 2-XXXX registry. Jersey is now deciding whether to join Guernsey in a single register, establish a separate register, or run two separate registers under a single administrative system.
With EASA making it increasingly difficult to operate in Europe on the N-register, the attractions of a flexible non-EASA register are obvious and include lower cost, less complexity and greater flexibility.
One serious issue in the Channel Islands is that Jersey imposes a 5% VAT equivalent on aircraft, while Guernsey imposes none – the Jersey registry would therefore be rendered uncompetitive. Moves are being made to find a solution.
Women pilots to meet in Italy
AOPA Italy is helping to organise a meeting of woman pilots and aviation industry workers in Venice in June, and women from all over Europe are invited. This conference, to be held at Venice Lido Airport on June 22 and 23, is the sixth of its type and aims to foster networking among women in aviation, as well as exchanging ideas and sharing projects.
All women engaged in any branch of aviation are invited, and already a large number of professional and private pilots have registered to attend. The event is strictly reserved for ladies, although the airport will remain open throughout and there will be an ‘accompanying persons’ programme. AOPA support means attendees will be fed gratis, and accommodation in Venice will be discounted.
Venice Lido Airport is easy to reach by private or commercial aircraft, and full details will be posted soon on the website www.flydonna.it. Registration is required. Email Donatella Ricci for more information if you need it.
Visit Greece for Athens Flying Week
AOPA Greece and Podimatas AudioVisual S.A. and are doing it again this year – the second Athens Flying Week will take place in the last week of September. Last year the event attracted 20,000 spectators, and in 2013 AOPA Greece intends to increase that number by 50%. This time the emphasis will be on the commercial aspects of the event There are signs of strong commercial interest in the less expensive sector of general aviation, particularly small two-seat aircraft and microlights.
While the Greek economy is struggling, general aviation is a bright spot because under pressure from AOPA Greece, the government has turned a welcoming face to GA training and is making good on its stated intention of becoming ‘the Florida of Europe’. New training organisations have been set up in several locations and are attracting students from elsewhere in Europe. Even so, AOPA Greece warns that in the difficult economic situation, the survival of general aviation depends on successful co-operation between all interested parties. Athens Flying Week is a private venture heavily supported by AOPA Greece. Panos Podimatas, owner of the organising company, is a PPL holder and a member of AOPA, while two other members of AOPA’s Board participate in the organising committee.
Perhaps you’d like to visit ‘the Florida of Europe’ for Athens Flying Week. Dates for the diary are Saturday September 28th and Sunday 29th, at Tatoi military airfield.
What element of landing an aeroplane is (or was) problematic for you?
No matter what we accomplish in flight training, nothing (it seems) quite eclipses the ability to nail a landing. Is it any wonder? Landing the airplane is probably the toughest part of flying it.
So it was that our January digital poll asked the question in the title. The idea for the poll was sparked by the student pilot who wrote Rod Machado to ask for guidance on how to control the plane during rollout. Rod was puzzled, so he contacted the student to ask for some additional details. It turns out the guy had a shoe size 14. Aha! Rod theorised that the student was having difficulty properly placing his feet on the cockpit floorboard so as not to accidentally touch a brake pedal... click here to see the results and add your view!
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