Consultation

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EASA PROPOSALS - MEDICALS FOR PILOT LICENSING 16th August 2010

You may recall that some time ago EASA developed draft proposals for a ‘light’ pilot licence (known as the LAPL), that would include glider pilots. The LAPL would use a GP issued medical certificate, along similar lines to the current BGA/NPPL medical requirements.

The BGA and many other air sport organisations contributed to these proposals, including those relating to the LAPL medical that resulted in an EASA consultation Notice of Proposed Amendment (NPA) 2008-17c.

EASA has now published its review of the consultation in Comment Response Document (CRD) 2008-17c and, along with this, a set of revised proposals. These indicate that:

• The medical for the LAPL will require a complex clinical examination.
• These examinations can only be carried out by either an aero-medical examiner or a specially qualified GP.
• Any pilot who does not fully meet the LAPL medical standard will automatically be referred to an AME. 
• Examinations will be required every 5 years for pilots up to age 50 and at least every two years thereafter.
• British Medical Association recommended fees indicate that the cost of this proposed GP medical will be higher than an AME Class 2 medical (£150+).

In developing the latest proposals, we believe that EASA has relied on the opinion of Aero Medical Examiners than medical evidence.  Any possibility of a cheap and simple method of demonstrating medical fitness by general practitioners using their clinical records has effectively been eliminated and the ability of less fit pilots continuing to fly with limitations has been ignored.

The BGA is already engaged with its partners within the GA Alliance to respond politically to this renewed threat to gliding and other air sport. Meanwhile, you may want to respond to this CRD on behalf of your club or indeed as an individual and therefore the following information may be helpful. The consultation closes on the 23rd August.

The CRD 2008-17c can be viewed here;

http://easa.europa.eu/rulemaking/comment-response-documents-CRDs-and-review-groups.php

A draft of the BGA response text is available here. Even though there are only a number of ways of describing concern over this disproportionate approach by EASA, you must respond using your own words. Cut and paste responses will be ignored by EASA’s document checking software.

The EASA Comment Response Tool (CRT) is quite complex and, at times, non-intuitive. It does, however, have a comprehensive help system. We have produced a brief step-by-step guide to using the CRT - available here.

EUROCONTROL PROPOSALS - STANDARDISED EUROPEAN RULES OF THE AIR 15th March 2010

This news item requests action by clubs and members in response to a significant threat. It is a different issue from the other European regulatory proposals that currently concern us.

Eurocontrol, the ‘European Organisation for the Safety of Air Navigation’ is currently consulting on its proposed Standardised European Rules of the Air. Given the nature of the proposals, we are asking that as many glider pilots as possible take the time to respond in order to highlight our very significant concerns.

As the name implies, the proposals seek to unify rules of the air across Europe by cancelling all agreed national differences from current ICAO standards. This will result in the removal of decades of appropriate and sensible national modifications and differences to the ICAO Rules of the Air. These national differences – as seen for example in the UK ANO and in the series of exemptions put in place by UK CAA - are appropriate and safe. The safety, operational and economic impact associated with inappropriate Standardised European Rules of the Air is likely to be significantly damaging to gliding.

• normal gliding flight would be classed as aerobatic and would, therefore, be prohibited unless specific permissions were obtained
• no more field landing training in motor gliders
• no more ridge soaring, as we know it
• the potential closure of unlicensed aerodromes
• having to file flight plans with ATC

If established, these rules would affect all pilots from 2012.

While the BGA will be responding directly and in detail to Eurocontrol, you can hopefully understand why the BGA feels that it is necessary to ask as many glider pilots as possible to respond personally to this consultation, so that the regulators are left in no doubt about why these proposals are unacceptable.

Please take the time to familiarise yourself with the issues and, if you care for the future of our sport, please respond to the consultation which closes on April 12th.

Resources and How to Respond

1. Look through the BGA RESPONSE

2. Look through the Eurocontrol consultation information here

3. Please respond using the Eurocontrol ‘Consultation Response Sheet – Enclosure 3’ here - noting;

• You are asked to state which organisation you are from. Unless you are representing a specific organisation, you could state 'Glider Pilot'
• You are asked to state your position (within the organisation). Unless you are representing a specific organisation, you could state 'Pilot'
• If you can sign and scan the document, then fine. If not, you could note your name and 'electronic signature' in the signature block and then submit the form electronically as an attachment to an email that is attributable to you. We believe that this constitutes an electronic signature.

You must respond in your own words – cut and paste responses are ignored. Please send your completed comments to Eurocontrol before the closing date of 12th April 2010.

Consultation

A key role for the BGA is defending members rights to operate with maximum freedom and minimum cost and bureaucracy.

Within the UK the BGA works particularly closely with the General Aviation (GA) Alliance, the General Aviation Awareness Council, the Royal Aero Club, the Central Council for Physical Recreation, Govt agencies and Members of Parliament. Beyond the UK, the BGA is a very active member of the European Gliding Union (EGU) which in turn is a member of Europe Airsports (EAS). Where required the BGA also talks directly to EASA.

This co-operation ensures that the voices of BGA members, reinforced by some 700, 000 air sport users, are heard throughout the European political and regulatory environment.

Hot Topics The latest BGA 'hot topic' consultation issues are identified on the BGA general news page here

Working With Others The BGA is a partner in the General Aviation (GA) Alliance. Together with our partner members we consult with each other with the aim of ensuring the enormous amount of regulatory development currently underway does not overlook our interests. Clearly the BGA focusses on gliding related issues in particular, just as others focus on their own unique interests.

The joint consultation action list collated by the GA Alliance facilitator is here

How can you help? The BGA will of course let you know if the subject matter is so critical we need full involvement by members. This is rare - the BGA will respond to consultations on behalf of the BGA as a whole. However, if you have time and feel strongly about an issue, it is always worth of course fully understanding the issues - the BGA can provide a summary, advice and even its own response before deadline time - and then submitting your own response.

Where can I find consultation detail? There are of course numerous sources. The BGA will identify and advise members regarding important consultations.

The GA Alliance action list shows almost all the consultations that the BGA and others are, and have been, involved with. Our colleagues at the LAA are also members of the GA Alliance. Their consultation page often includes helpful summaries.

EASA consultations are listed here

CAA consultations are here

DfT consultations are here

Ofcom consultations are here