Future Licensing

NPA 2008-17 and NPA 2008-22 EASA Response 18th June 2009

The BGA has now responded to NPA 2008-17 and 22, and is about to respond to NPA 2009-02 (Operations). Following pressure from industry, including gliding, EASA has decided that their comment response documents to the licensing, organisation and operations NPA's should be published togather. We can expect these documents in early 2010.

NPA 2008-22 re EASA FCL Training Organisation Requirements 31st March 2009

This NPA, which will be responded to by the BGA, has been extended by EASA and now closes on 28th May 2009.

Final Update to NPA 2008-17 BGA Response 27th February 2009

The BGA has finalised its response to the soon-to-close EASA consultation about pilot licensing. These final documents contain minor changes in detail to previous versions agreed after further discussions with our European colleagues. To see the documents, follow the links in the news item below. The BGA identified early on a number of serious problem areas within the EASA proposals - see the previous news items below for information - and would urge any pilot who has still not yet done so to respond before the deadline of tomorrow. Pilots who have already responded can, if they wish, update their responses. Both new responses and updates to existing responses can be made using the EASA Comment Response Tool. The consultation closes on 28th February.

Further Update to NPA 2008-17 and NPA 2008-22 BGA Draft Response 2nd February 2009

The BGA has further developed its draft response in anticipation of the closing date of 28th February. The key area of development is around the non-VFR issues. The revised document is here. The BGA has added additional comment re the FCL 600 proposal ie that "the BGA does not consider it appropriate for NPA17 to remove our existing privileges for IFR flight and our proposal to address this and to further improve safety as a result is attached under our response to NPA 17a, Subpart J, para 48, Page 29". The BGA is continuing to significantly contribute through Europe Air Sports to the EASA FCL008 working group which is looking at the whole IFR issue under EASA FCL.

Glider pilots who have used the original, pre-Dec BGA response text to form their own responses to NPA 2008-17 are urged to consider the latest BGA response comment before finalising their own comments. Please note that your comments on the EASA CRT can be modified at any stage up to the closing date of 28th February 2009.

NPA 2008 17a (updated 27 February 2009)

NPA 2008 17b (updated 27 February 2009)

NPA 2008 17c (updated 27 February 2009)

Regarding NPA 2008-22, the BGA will respond in detail to EASA. The BGA response will detail why a number of the proposals applicable to gliding are disproportionate or unecessary, and will offer alternatives. The BGA view is that the BGA should continue to be an approved training organisation that continues to absorb much of the responsibility and overhead for compliance management and standards, thus allowing BGA clubs and their fundamentally volunteer operations to continue to deliver high quality training at minimum cost and with minimum bureaucracy. As with NPA 2008-17, we are working closely with fellow EGU members to ensure a cohesive and effective response from the gliding community.

Update to NPA 2008-17 BGA Draft Response 30th December 2008

As previously reported, the BGA works extremely closely with the European Gliding Union (EGU)and others in all areas of EASA regulatory activity. In addition, the BGA is of course noting helpful feedback from the BGA membership. With that in mind, the BGA has developed elements of its draft response to NPA 2008 17 a, b and c. The 30th December revised draft is here;

NPA 2008 17a Dec 30th draft response

NPA 2008 17b Dec 30th draft response

NPA 2008 17c Dec 30th draft response

Additional documents identified in the above documents are here re non VFR and drafting differences

Glider pilots who have used an earlier BGA response text to form their own responses to NPA 2008-17 are urged to consider the latest BGA response comment before finalising their own comments. Please note that your comments on the EASA CRT can be modified at any stage up to the closing date of 28th February 2009.

Points of note include;

Medical. Please note that the BGA strongly supports the LPL medical standards. We have reservations about how EASA propose that the GP medical is delivered, but the GP medical must of course be supported. If EASA does not see adequate support in the responses, those who would prefer us all to pay commercial Aero Medical Examiners will get their way.

Non-VFR Privileges. The BGA is working with Europe Airsports and EGU to develop an appropriate set of proposals to EASA. We are seeking a non-VFR/cloud flying qualification within the LPL and SPL. Please note that BGA will detail its comment in on this particular issue having had the opportunity to consider advice from Air Sport industry experts and EASA rulemakers within the EASA FCL008 working group working on this issue. The BGA comment will be published in early February in anticipation of the consultation closing date of 28th February.

Minimum Requirements. Much of the EASA FCL proposal detail affecting gliding has been developed following advice from the European gliding community. The BGA is comfortable with most of the mimum requirements proposed. Where minimum requirements are excessive, eg for aerotowing and aerobatics, the BGA has proposed alternatives within its response.

BI Rating. The BGA has written to club chairmen explaining why the BGA believes the BI rating will not be required under EASA FCL because of proposed licence privileges.

ALL PILOTS ARE ENCOURAGED TO CONSIDER THE EASA PROPOSALS AND RESPOND USING THE EASA COMMENT REPONSE TOOL AT http://hub.easa.europa.eu/crt

Extension to Consultation Period 3rd December 2008

The deadline for submissions to this consultation has been extended until 28th February 2009.

Update to BGA Response 30 November 2008

The BGA is of course monitoring comment from members regarding the BGA's draft NPA 2008-17 response and we are grateful for the feedback received. In addition, we are listening closely to our EGU colleagues developing views. The BGA will be slightly modifying its response in due course.

Meanwhile;

Medical. Please note that the BGA strongly supports the LPL medical standards. We have reservations about how EASA propose that the GP medical is delivered, but the GP medical should of course be supported. If EASA does not see adequate support in the responses, those who would prefer us all to pay commercial Aero Medical Examiners will get their way.

Cloud Flying. The BGA is working with its EGU colleagues and elsewhere to ensure continuation of existing rights ie flying gliders non VFR where airspace permits. We are seeking a non-VFR/cloud flying qualification within the LPL and SPL. Again, EASA needs to understand the importance of this issue and numbers help.

Please note that EASA consultation responses should be worded individually (don't cut and paste), and where content is criticised, alternative proposals should be provided. Your text on the EASA consultation Comment Response Tool may be monitored by EASA leading up to the closing date, but of course your final comments are those that will inform the consultation.

EASA NPA 2008-17 BGA First Draft Response - Removed 13th December 2008

EASA NPA 2008-17 - BGA Guidance 31st October 2008

The Proposals

Through NPA 2008-17, EASA is proposing pan European rules detailing EASA licensing affecting all pilots of EASA aircraft including gliders. Please note that high level requirements for the licensing of pilots including glider pilots are already established in European law. The NPA proposes the detailed implementing rules. The BGA licensing working group under Chris Gibson has spent many weeks studying the NPA. Their work is nearing completion. The following guidance is provided to support glider pilots and clubs who may wish to respond to this highly significant consultation that closes on the 15th of December. The proposals refer to requirements that when finalised will be fully implemented from April 2012.

How to access the NPA and how to respond

The NPA is presented in 3 main parts dealing with general information, pilot licensing and medical and can be accessed here or via the EASA Comment Response Tool - this tool is the best way of adding your own comments. You can edit a saved comment at any time up to the consultation closing date.

The BGA has put together a handy index that will help you identify the relevent parts of the pilot licensing info within the 650+ page document.

The BGA view

The BGA has identified a number of important issues as well as a number of serious problems within the NPA. The BGA is responding using good practice that experience has demonstrated is accepted by EASA ie clearly identify the existing text in the NPA, identify and justify the concern and propose alternative text. In addition, there is a need to support helpful proposals. Examples of helpful proposals are the GP medical and the self launching endorsement on a glider pilot licence (no separate powered licence required).

The BGA is working very closely with its European Gliding Union (EGU) colleagues to ensure that all European gliding organisations support each others concerns.

The BGA will publish its detailed response to NPA 2008-17 on this website during the first half of November. Meanwhile, a number of issues are respectfully brought to your attention here in anticipation of you responding to the consultation with your own views;

Key Issues within the NPA

Cloud Flying

The NPA does not include a cloud flying qualification for glider pilots. This is an issue for licensed glider pilots because without an appropriate qualification, flying closer than 1.5 km horizontally or 1000' vertically from cloud above 3000', or indeed flying in cloud, is theoretically not permitted under ICAO VFR. The BGA has developed a detailed set of proposals to include a cloud flying qualification in concert with other European gliding bodies who are equally concerned.

EASA had included a cloud flying qualification in early drafts, but the rating was dropped in the final NPA. The BGA is working with bodies including EGU, Europe Air Sports and in the UK the CAA to ensure that this issue is properly addressed in the planned EASA working group activity regarding an IMC rating and cloud flying mentioned in the NPA at 17a.

Medical

The NPA identifies that a GP medical is available for the LPL pilot and instructor. The GP medical standard is acceptable to the BGA and the BGA believes that this must must be strongly supported. Influential representatives of European aeromedical examiners who make millions of Euro's out of aeromedical examinations oppose GP medicals within EASA pilot licensing.

The BGA has some concerns that the GP medical process requires a physical examination (albeit simple) and a complex form. The expert view is that this will increase cost as well as affect GP's willingness to get involved.

The SPL ICAO 2 medical requirement (less onerous than JAR class 2) is acceptable to the BGA.

Instructing

The proposals do not include a direct equivalent of the BGA Basic Instructor rating. Although the priveleges of the licensed pilot could cover this particular issue, there are other regulations in the pipeline that may influence this issue. The BGA is keen to ensure that EASA is aware of its needs in this area. As well as commenting in its response to the NPA, the BGA intends to follow up this issue through other channels.

Status of LPL(S) and SPL Holders

The proposals include two gliding licences. The Leisure Pilot Licence(Sailplanes) and the Sailplane Pilot Licence. These two licences fit the EASA FCL concept of a sub ICAO EU sporting licence and an ICAO compliant private pilot licence. Gliding input in the formative stage of this NPA ensured that the syllabus and other requirements for the LPL(S) and SPL are the same - the only difference between the licences is that the SPL requires an ICAO class 2 medical. The LPL(S) and SPL instructor rating requirements are also the same other than the medical.

The problem in the NPA is, for example, that the NPA proposes that an SPL instructor can teach a trainee SPL and LPL(S), but an LPL(S) instructor cannot instruct a trainee SPL. This is, of course, complete nonsense and is a process that has been transferred from JAR FCL without any thought. The BGA response proposes a detailed alternative that essentially provides interoperability across the two licence types.

Other Issues within the NPA

Buried within the NPA are a number of potential traps that the BGA has commented on in its response, including;

Experience requirements for licence ratings including aerobatics and towing

Experience requirements for licence endorsements including launch methods

Flight training and theoretical knowledge syllabus detail

Flying instructor training

TMG rating requirements

Please find the time to engage with this issue. It is important for the future of our sport.

EASA NPA 2008-17 Pilot Licensing - Royal Aero Club Briefing 31 October 2008

The Royal Aero Club is hosting a briefing and workshop on the subject of NPA 2008-17 at Turweston on 22nd November (0900-1200). The briefing will help attendees to understand some of the key elements of the proposals and to be in a better position to respond to the consultation, which closes on 15th December 2008.  The proposals affect all pilots of aircraft within the scope of EASA, but the briefing will focus on the impact on pilots flying non-commercially with aeroplanes up to 2mt MTOM, light helicopters, gliders and balloons.  If you would like to attend, please Email the RAEc Secretary by 18 November. Please use an email header ‘NPA Briefing 22 Nov’. More details of the RAeC briefing are here.

UPDATE 1 September 2008

EASA has advised that the closing date for submission of responses to the NPA has been extended to 15 December 2008.