The Transition To EASA Aircrew Regulations: One NAA s experience. Ray Elgy. UK Civil Aviation Authority, Licensing & Training Standards November 2012
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1 The Transition To EASA Aircrew Regulations: One NAA s experience Ray Elgy UK Civil Aviation Authority, Licensing & Training Standards November 2012
2 Content Context Volumes of UK licensing activity The task: - issue new licences, medicals and organisation approvals - conversion of existing licences and approvals; and - consolidation of the remaining national licences, medicals, and approvals into a coherent and manageable system. What the programme involved Our Approach and key decisions What went well What we could have done better Slide 2
3 EASA Aircrew Regulation (regulation 1178/2011) comprises: The EASA Aircrew Regulation - setting out the main rules; Annex I - Part-FCL Replaces JAR-FCL 1 & 2 Annex II - Annex III - Conversion of European non-jar Licences Validation/Conversion of 3rd country licences Annex IV - Part-MED - Replaces JAR-FCL 3 Annex V - Annex VI - Annex VII - Part - CC - Requirements for Cabin Crew Part-ARA - National Aviation Authorities. Part-ORA - Organisations.
4 Licensing & Medical Context v ~18,000 active professional pilots (Class 1 Medicals) v ~30,000 active private pilots (Class 2 Medicals or Medical Declarations. v ~2,000 active air traffic control officers (Class 3 Medicals) v ~400 Registered Flight Training Facilities v ~200 Approved Flight Training Organisations v 91 Approved Type Rating Training Organisations Slide 4
5 Licensing & Medical Volumes Annually Licensing v ~8,000 new Licences v ~13,000 Ratings v >60,000 Telephone calls v >10,000 s plus ~10,000 Letters/Faxes (Licensing) v ~15,000 Licence/Operator Proficiency Checks v ~100 Foreign Licence Validations v ~35,000 Theory Examinations v ~2,500 Flight Examinations v ~250 annual audits of approved companies, v ~300 FSTD Qualification certificates v ~400 FSTD User Approvals Medical v Correspondence ~10,000 v ~33,000 Telephone calls v Clinic Initial Class 1 ~2,000 applicants v Reviews/investigations ~1,700 v Support of AMEs (263) and, v AME On - Line Slide 5
6 EUROPEAN RULEMAKING TIMETABLE RULE CRD Publication Opinion Published as law Part-FCL April 2010 August 2010 Nov 2011 Part-MED 15 June 2010 January 2011 Nov 2011 Part-ARA August 2010 June 2011 Q Part-ORA August 2010 June 2011 Q All of these became applicable from 8 th April 2012, subject to the use of derogations / opt-outs / exemptions. The CAA Transition Project was formally launched in March 2011 (But much preparatory work done beforehand)
7 Timetable The Aircrew Regulation itself became effective on 8th April Derogation/Opt Out of Annexes for up to 12 months: Amendment 1 the Aircrew Regulation allowed Member States the flexibility to opt out of individual Annexes until dates of their choosing between 8th April 2012 and 7th April However, the end dates for conversion of national licences remain fixed. Key Decision The CAA determined that the date of applicability of all of the Annexes in the UK would be 17 th September 2012.
8 Other Derogations/Opt Outs Timetable - The CAA has invoked the 3 year opt-out for the mandatory requirement to hold the new EASA licences and ratings that have no JAR equivalent Light Aircraft Pilots licence (Aeroplane / Helicopter / Sailplane / Balloon), and SPL(Sailplane), BPL(Balloon); Aerobatic, Towing, Mountain and Flight Test Rating. - The CAA has invoked the permitted deferment of application of validation requirements for private flights until April The CAA is taking the permitted period of 2 years to convert national licences (being used for purposes outside the LAPL privileges).
9 To fly EASA aircraft: Aircraft and Operation Licence Conversion Deadlines Aeroplanes and helicopters used for commercial purposes. Aeroplanes and helicopters outside scope of LAPL used for any purpose. Aeroplanes and helicopters within the scope of the LAPL and used for non-commercial purposes. Pilot must have an EASA licence by: 8th April th April th April 2015 Balloons, Airships and Sailplanes. 8th April 2015 Aerobatic rating Towing rating (Banner or Glider) Mountain rating Flight Test rating 8th April 2015
10 There were three distinct areas of work for the CAA: - to be ready to issue new licences, medicals and organisation approvals in accordance with EASA rules Parts FCL, MED, ORA, and ARA; - conversion of existing licences and approvals into appropriate EASA equivalents; and - consolidation of the remaining national licences, medicals, and approvals into a coherent and manageable system.
11 Rationalisation of the national rules and legacy licences. Key Decision. As far as is practicable, the privileges of national licences should be the same as the EASA equivalents where these exist (except that they will not be valid for EASA aircraft). For ratings on national licences that are the same as EASA ratings, EASA rules will apply in their entirety.
12 EU rules apply to all aircraft (wherever registered) except: - Microlights. - Light Gyroplanes. - Amateur-built aircraft. - Ex-military Aircraft, (and replicas of these)*. - Vintage/Historic aircraft (designed before 1955). - Complex Historic aircraft (and replicas of these)*. - Research / scientific aircraft. - Light gliders, including foot-launched - UAVs with an operating mass of less than 150kg - Any aircraft under 70 kg without pilot. - Plus - State Aircraft (including military, Police, SAR) These aircraft remain under national rules, (except those marked * when used for Commercial Air Transport).
13 EASA aircraft and National aircraft Use of EASA licences for Annex II and State aircraft. The UK CAA and Dept for Transport amended UK law so that EASA licences with Class ratings are valid for non-easa aircraft within the same Class ratings (avoiding the necessity to hold a national licence with SEP as well in order to fly an Annex II machines such as an Auster, Tigermoth, or homebuilt aeroplane). Pilots with EASA licences are able to fly EASA aircraft and most non-easa aeroplanes (subject to class and type ratings).
14 EASA aircraft and national aircraft Pilots with ratings for non-easa aircraft. Issues arise where existing holders of JAR and national licences have ratings that are not included in Part-FCL, such as a type rating for a non-easa aircraft. There is no provision in Part-FCL or Part-ARA to include national ratings on EASA licences. To allow the flexibility to address such cases the CAA has reintroduced the UK PPL, UK CPL, and UK ATPL, alongside the NPPL(A), but valid for non-easa aircraft only. This provides for an ICAO licence to be issued to EASA licence holders as necessary to provide UK national ratings; (not valid for EASA aircraft). There will also be an NPPL(H) to cater for pilots who obtain a LAPL(H) and then a rating for an Annex II helicopter.
15 The Scale of the Task: What The Project Involved. Over 17 man-years of effort expended in 18 Months. Over 270 Individual Work Specifications Over 70 application forms created/updated Over 30 Standards Documents (Guidance Material) revised 5 Project Teams; Licensing Implementation Change Team (ICT) Medical ICT IT ICT Engineer Licensing ICT Readiness & Practical considerations group
16 The Project involved.. 2 break-out projects identified, to take forward the Webinar delivery of Training and forthcoming Engineer Licensing changes AME Seminars delivered by Medical Department Numerous presentations to Industry CAP804 published Numerous updates to website content Quick-Guide to EASA-FCL changes (over 35,000 hits on web) Podcast on the changes (Over 4,500 downloads) Quick-guides for the introduction of the LAPL Webinar delivery of non-uk examiner briefings on-line
17 And also involved. Changes to our main Licensing IT system, which included; lines of reference data - Each line has many values. Over 1500 individual tests run during UAT Non-stop implementation from 17:00 Wednesday 12 th to late afternoon Sunday 16 th September Centralising the use of an Exemptions Database to record exemptions against regulations across disciplines. Creation of an ATO Register combining RTF and FTO/TRTO records Creation of a solution to allow LAPL Medical assessments to be recorded Creation of an online Fee Calculator to illustrate how the scheme of charges applies to applications, including conversion fees etc
18
19 What went well. Engagement with, and support from EASA Close liaison with, and support of Industry: Airlines Approved Training Organisations Ground Instructors Representative bodies Project Management Communications plan Use of a single page on our website to which industry were directed in all correspondence throughout the project:
20 What could have been done better... Ensuring all activities were assigned to an accountable manager (We missed the application forms!) We did under-estimate the amount of work and the resources required. We under-estimated the degree of changes required in the licensing assessment process, and the time that it takes to process applications. This has increased the turnround times.
21 CAA Information on licensing and EASA: We have a dedicated page on our website where EASA related information may be found However, the purpose of this page was predominantly to inform industry of what was coming, so we are changing the content of this page accordingly. Currently still available, however, are documents such as; A Quick Guide to the changes. European Legislation The expected effects on the licensing of pilots in the UK Frequently Asked Questions Thank you for your attention.
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