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EASA threat to operation of N Reg Aircraft

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Old 20th Jan 2011, 09:20
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Lembit who I know well is no longer an MP whether he has the ability to contact MEPs now to convince them? He has the aviation knowledge to put over that case.

Sadly though it all appears to have been pushed through as the MEPs cannot vote to have parts of the proposal removed they can only vote to have the whole removed which is very very unlikely.

Some sort of bi lateral agreement appears the only real option ahead

Pace
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Old 20th Jan 2011, 11:36
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Is there any money, sex or inducement involved ?





Beware of the evildoers both sides of the pond !

EASA, "one size, fits no-one" , costs 110 Million too
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Old 20th Jan 2011, 13:42
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Eckard and Sarah now there is a marriage made in heaven.

What a thought.
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Old 20th Jan 2011, 15:34
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Where would the Germans who control EASA ......
huh?? just because their headquarters is in Cologne, doesn't mean it's "controlled" by the Germans! In fact, we in Germany are just as upset as you guys in England.

And that's another point... what are the opinions of the other EU states? There are, I believe, about 27-30 of them. It is not the problem of only ONE EU nation but many. The UK CAA alone cannot help, neither can the UK AOPA...

P.S. when you move to any country, you usually must change your car driver's licence within a year to the local one, so why shouldn't that rule apply to aircraft as well?
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Old 20th Jan 2011, 16:04
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huh?? just because their headquarters is in Cologne, doesn't mean it's "controlled" by the Germans! In fact, we in Germany are just as upset as you guys in England.
German pilots and owners sure. But EASA's overregulation mania is going exactly in the direction that the LBA has been going for years. Ok, they are not alone, I agree, but well... In the end, it doesn't matter who is responsible, but it has to be stopped if we wish to have any GA at all in Europe in the future.

P.S. when you move to any country, you usually must change your car driver's licence within a year to the local one, so why shouldn't that rule apply to aircraft as well?
Because unlike the drivers license, which is usually a simple exchange or maybe a quick test involved, to convert those licenses is very time and money intensive and for many people impossible to do. There are loads of Pilots who have been forced into N-reg due to the fact that the European medicals are far stricter than the US ones. Additionally, most N-reg airplanes feature a lot of STC'd extras which are not certifiable in Europe.

Europe finally gives up and adopts the FARs, lock stock and barrel.
Would solve the whole problem at one, that would. Or, better, adopt a European version of them which makes the whole N-reg thing in Europe obsolete. Maybe do even better?

Sam, yes, good idea. Maybe AOPA will jump on the bandwagon if we unearth a few good heads for the advertizing campaigns.

Best regards
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Old 20th Jan 2011, 18:28
  #766 (permalink)  
 
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what are the opinions of the other EU states?
Most of the small ones have no backbone. They are desperate for EU financial support so they go around with their noses stuck firmly up the backsides of EU officials and they vote for almost everything.
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Old 21st Jan 2011, 11:58
  #767 (permalink)  
 
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IO540

Most of the small ones have no backbone. They are desperate for EU financial support so they go around with their noses stuck firmly up the backsides of EU officials and they vote for almost everything.
Most of them are under the pressure of the money lenders. Many are in fact bancrupt and on the drip of the three big ones, that is Germany, France and the UK. So whenever someone mutters discord, they'll review the next payment.... if private entities would do it it's called blackmail, but here it's politics.

Some of those countries should have known better than to sell themselfs to EU rule, alas they did not. The movements which turn up in some of those are not really too encouraging, see Hungray. They won't stay alone. Many in the former East Block countries are hungry and cold since they are in the EU. That makes a huge potential for political rat catchers.

Best regards
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Old 21st Jan 2011, 13:55
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I hope Croatia does not join up. It would be a disaster for them to join that bunch of crooks in Brussels. It would jack up prices and damage their tourist trade which is their main business.

I have been especially sad to see Czechs brown-nosing every EU official they can dig out.
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Old 21st Jan 2011, 14:42
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IO540,

well, Croatia is aiming to join up and unless they get the message from Bulgaria and Romania, they will. So will Kosovo, Albania, Serbia eventually. that leaves preciously little outside the EU, and those will be assimilated, according to EU politicians. More than once Switzerland has been threatened that way and looking at the history of this continent, it would not be the first time that small countries simply get run over.

I see two problem blocks. One is the currently insolvent countries like Greece, who are basically under EU dictatorship in return for financial bailouts. More of those are likely to follow, Ireland, Spain, Portugal and some Balkan states too. Well, the people don't like oppression and neither should they, so what will happen? Hungary is a sample of one possible direction?

The other possibility is that the Slavic countries will mass together eventually and as such build a very strong block within the EU. Where people are suffering, extremist groups have an easy way to take control, see Hungary. If they flock together in politics, they will be quite powerful. Too powerful for the de facto rulers of today?

What the EU and the USSR have in common today is that they are lying to themselfs about their status. Which country actually fulfills the EURO conditions, fully and to the letter? Not many I reckon. So why is nothing done about it? Because a law which sais you get punished if you do something is useless if the punishment (exclusion) is not enforcable. Otherwise, it would be an easy way out for some EU countries.
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Old 15th Feb 2011, 20:15
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EASA is expected to release the Rule Part-FCL (EASA CRD on NPA 2008-17b).

EASA is expected to release the Rule Part-FCL(EASA CRD on NPA 2008-17b).


Once released by the EASA to the Parliament, the Part-FCL rules will be called for review and a vote must take place to accept or reject the text. At this stage no amendment can be done, the only options are “yes” or “no”.


There is a lot of misleading information and argument going around, so we would like to point the True.


The comitology accepted the text on the Dec 8th, 2010 without any substantial change concerning the crew licensing rules and without considering the thousands of objections received by the Commission.
  1. No appropriate BASA can be expected within the time frame set in the Rule.
  2. No possibility to delay the entering into force from the text behind April 2014.
  3. This text is implementing a true apartheid between EU residents and non-residents pilots.
  4. No safety progress to refuse EU airspace to pilots used to fly into it while allowing others.
  5. EASA recognized to have no clear understanding of the situation.
  6. The Rule is in conflict with ICAO and does not contribute to enhance safety.
  7. No mention with regards to the UK IMCrating
  8. more arguments against this text
1.
Copy of the response from Mr. Kallas from the Commission to questions asked by Mr. P. van Dalen TRAN vice-chair:
The modified text proposes a transitional period until April 2014 for pilots flying in the EU with third-country licences (e.g. licences issued by the US Federal Aviation Authority). This time will allow for further discussions on the recognition of non-EU licenses within the framework of bilateral aviation safety agreements between the EU and third countries.

Such agreements have already been signed with the United States, Canada and Brazil but have not yet entered into force. Once these agreements enter into force, the necessary work can be done towards an agreement on simplified conditions for mutual acceptance of pilot licences issued by those third countries.
European Parliament and TRAN members are misleaded into believing that some Bilateral Aviation Safety Agreements (BASA) will alleviate the concerns voiced by the private pilots. Contrary to official statements, the BASA text signed on the June 30th, 2008 is all about technical issues and even if the article 2c state “The parties may agree to additional areas of cooperation and acceptance by written amendment of this Agreement in accordance with Article 19” the Article 19 is all about mutual recognition of aircraft and parts certification, maintenance and repairs standards, and aircraft airworthiness standards; which is absolutely not relevant for crew licensing, we may therefore expect that this BASA is in no way applicable to the private pilots licensing concern.


2.
Article 10.4 from the Part-FCL was amended with a transition period and state:
  1. Member States may decide not to apply the provisions of this Regulation to pilots holding a licence issued by a third country involved in the non-commercial operation of aircraft specified in Article 4(1) (b) or (c) of Regulation (EC) No 216/2008 until 8 April 2014.
  • May decide is no obligation for member states to apply article 10.4
  • Until 8 April 2014, give no opportunity to delay the entering into force from this rule behind this date if the bilateral agreements are not completed
FAA has confirmed that as per today, they are no discussion on calendars with regards to bilateral agreements for crew licensing; and no one may reasonably expect that from this starting point a bilateral agreement will be in force before April 2014 as the date set in the text.


For comparison purpose; US and Canada spend 8 years to complete a bilateral agreement, with regards to crew licensing and those two countries have relatively similar standards compared to EU standards.


3.
Using the pilot’s country of residence as the determining factor for regularly standard of licensing, is implementing a true apartheidto the detriment of those who reside in Europe and which additionally pay their taxes and VAT.


4.
Accepting non-European resident pilots to fly within the European airspace with third country issued license on-board of third country registered aircraft and refusing this right to European residents pilots where are used to fly safely within the European airspace is not a safety progress.


5.
Mr. Goudou, Director of the EASA, has publicly stated, in front of about 50 European journalists and representatives of International press agencies at a press meeting past Jan. 11th 2011; “in the light of the unprecedented concert of protests affirmed that EASA was to launch and finance a study to understand the differences between FAA (American) licenses and Current European licenses”. Therefore, EASA has recognized that it made an NPA and advised the Commission without having a clear understanding of the situation, from a safety, economic or technical standpoint.


6.
During the same press meeting, Mr. Goudou, director of EASA, stated that, because they are Europeans residents, between 80'000 and 90’000 pilots holding a 3rd country license (mainly all FAA licenses) would, under this rule, be required to hold and maintain two distinct pilot licenses”, ONE as as European resident, and a SECOND of the country of registration of the aircraft they fly, and have distinct medical certificates.


This is in conflict with ICAO Annex I and does not contribute to enhance safety.


ICAO member countries recognize airmen certificates (licenses and ratings) across borders. This also applies to the Instrument Rating, which provides the ability for safe flight in poor weather. The ICAO Agreement further provides, as a rule, that an aircraft should be flown by a pilot licensed under the rules of the country in which the aircraft is registered.
All EU member states have signed the ICAO Convention and its Annexes.
ICAO Annex 1 excerpt: 1.2.1 Authority to act as a flight crew member.


A person shall not act as a flight crew member of an aircraft unless a valid license is held showing compliance with the specifications of this Annex and appropriate to the duties to be performed by that person. The license shall have been issued by the State of Registry of that aircraft or by any other Contracting State and rendered valid by the State of Registry of that aircraft.
7.
At the TRAN discussion of Novembre 9th, 2010, Mr. Goudou stated his support to maintain UK IMCrating, but no one word is to be found about it in the proposed text.


8.
If the above arguments are not sufficient, here a few more:
  • Expect € 15'000 and above per pilot for IR conversion only
  • 2000+ pilots jobs lost (corporate pilots)
  • 200 millions Euros turnover lost by manufacturers, repair station and related jobs lost
  • Working group on FCL 008 is still far away from a substantial and viable improvement for a relevant and cost-efficient EU IR rating
  • 850 millions Euros market value lost of GA aircraft
Even if you are not concerned by the third country licensing, your aircraft with G, F, HB,....and other EU registration will suffer from a massive increase in aircraft for sale and aircraft value will decrease correspondingly what ever is the registration.




You feel concerned, it's the last opportunity to act !


Write to your MEP's and urge them to REJECT this text with a “NO” vote.


Here is the list of the TRAN members:
Transport and Tourism (TRAN) : Members














































source:


Link to the questions asked by Mr. P. van Dalen TRAN vice-chair:
http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+WQ+E-2010-010837+0+DOC+XML+V0//EN&language=EN


Link to the answers from Mr. Kallas from the Commission:
http://www.europarl.europa.eu/sides/getAllAnswers.do?reference=E-2010-010837&language=EN


International press meeting Jan. 11th 2011


Market study and survey results from N-flyers of Europe, a non-profit association www.november.aero


DGAC France press release:
http://www.developpement-durable.gouv.fr/IMG/pdf/CP_DGAC_FLC_point_sur_les_discussions_en_cours-2.pdf


BASA agreement signed June 30th, 2008, not in force:


Article 2 and 19



ARTICLE 2


Purpose and Scope


A. The purposes of this Agreement are to:
  1. enable the reciprocal acceptance, as provided in the Annexes to this Agreement, of findings of compliance and approvals issued by the Technical Agents and Aviation Authorities;
  2. promote a high degree of safety in air transport;
  3. ensure the continuation of the high level of regulatory cooperation and harmonization between the United States and the European Community in the fields covered in paragraph B.
B. The scope of cooperation under this Agreement is:
  1. airworthiness approvals and monitoring of civil aeronautical products;
  2. environmental testing and approvals of civil aeronautical products; and
  3. approvals and monitoring of maintenance facilities.
  1. The Parties may agree to additional areas of cooperation and acceptance by written amendment of this Agreement in accordance with Article 19.

ARTICLE 19


Entry into Force, Amendments, and Termination


A. This Agreement, including its Annexes, shall enter into force on the first day of the second month following the date on which the Parties have exchanged diplomatic notes confirming the completion of their respective procedures for entry into force of this Agreement.


B. This Agreement may be amended in writing by mutual consent of the Parties. Such amendments shall enter into force on the first day of the second month following the date on which the Parties have exchanged diplomatic notes confirming the completion of their respective procedures for entry into force of this Agreement or any amendments thereto. Amendments of the Annexes may be effected by a decision of the Board.


C. Any individual Annex developed by the Board after the date of entry into force of this Agreement shall enter into force upon a decision of the Board.


D. This Agreement shall remain in force until terminated by either Party. Such termination shall be effected by sixty day's written notification from one Party to the other Party. Such termination shall also act to terminate any amendments of this Agreement and all Annexes to this Agreement. Such termination shall not affect the validity of any certificates and other approvals granted by the Parties under the terms of this Agreement, including its Annexes.


E. Individual Annexes to the Agreement may be terminated by either Party. Termination of any individual Annex shall be effective sixty days following the date of receipt of notice of termination from one Party to the other Party, unless said notice of termination has been withdrawn. In case of termination of one or more Annexes, the remaining Annexes remain in effect. However, the Parties shall consult on preserving the remainder of the Agreement. Failing consensus to do so, this Agreement may beterminated by either Party. Termination shall be effective sixty days from the date of written notification to that effect from one Party to the other.
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Old 17th Feb 2011, 09:32
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New EASA rules on FRA will badly affect G-reg as well

For all those who do not have an N-reg, please understand that the new EASA regs on N-reg will have a drastic affect also on European registered aircraft.

The effect of the EASA regs will be that over the next few years:

a) a few thousand high value aircraft will come on to the market - a very large additional number in a short space of time - depressing substantially values of ALL aircraft

b) the substantial amounts spent by these aircraft operators will be lost to European GA - often N-reg operators spend disproportionately more than their number would suggest. The effect of the FRA regs will be to reduce substantially the amount spent with maintenance organisations, on fuel, at airfields etc. which will negatively impact everyone.

So if:
- you don't want your G-reg (or other European reg) aircraft to be de-valued substantially
- you don't want availability of maintenance organisations to be reduced, and
- you don't want airfield facilities to be reduced
WRITE TO YOUR MEP
to request that they vote "No" when the Part-FCL vote when it comes up soon.
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Old 17th Feb 2011, 10:04
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Yes; it will wipe out a big chunk of maintenance company and avionics installer business, especially upmarket avionics.

But EASA knows all this... everybody knows all this, unless one is deaf, blind, stupid, and lives in a bunker.

The key thing in politics is to always leave yourself a ladder to climb down with dignity. "Discovering" that there are many pilots affected by this is hopefully just the beginning of such a process.

I guess Goudou must have got some behind the scenes flak for his blatent lies on TV last year. That was just unbelievable, completely unbelievable. Had he stood up and said EASA is dull of d1ckheads and totally incompetent, he would not have caused more damage.

The more you dug yourself in over issues which have absolutely zero objective (e.g. safety data) basis, the more important it is to be able to climb down with dignity. EASA has dug itself in so deep that dignity is going to be in a short supply, which is a problem for EASA and an equal problem for those which EASA is trying to screw, because we might end up with some crappy outcome.

This is Yes Minister all the way through. Nothing to do with aviation.

EASA should be shut down completely. About the only thing they have ever achieved is the grandfathering of past EU component certification, and that was done some years ago. They did not need to spend hundreds of millions doing that.
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Old 17th Feb 2011, 10:05
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I lose faith with writing to "Government" officials and the way they work and have come to the conclusion that the only way to influence people is to know someone. This is especially true in aviation.

This is how property developers get monstrosities passed by the planning committees; yet Mrs Miggins doesn't get planning for a simple balcony which she needs for her wheel chair.

With our MPs expenses recently, this even more re-enforces my view.

The ONLY way to get this situation resolved, IMHO, is for someone who knows someone to have a word. I am sure if someone in Socata or Pilatus complained that TBM or PC12 sales would plummet and they'd go bust, then EASA would take a very great interest. In fact looking at the documents, it seems they have been written with protecting Pilatus and Socata in mind, probably for this reason.

If this all goes through as planned, I'll fly my aeroplane to the USA and keep it there for a while, then sell it. I might then buy a RV in the UK, or I may just say fcukit and buy a boat.
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Old 17th Feb 2011, 10:17
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I think you will find Socata and Pilatus are on the case.

Especially after I briefed Socata at the top level, last June

Of course this will all be done quietly because it cannot be done openly.

But EASA will run its gravy train until there is no steam left. That's what I would do if I was them. Capitulation is not a word in the EU dictionary.
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Old 17th Feb 2011, 10:19
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.....unless one is deaf, blind, stupid, and lives in a bunker.
Which, alas, describes our political classes pretty well.

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Old 1st Mar 2011, 17:51
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Not all members of the political class are like that...

Which, alas, describes our political classes pretty well.
Just was pointed to another pertinent question by an MEP in the transport committee :

Written question - Pilots' licences - E-000048/2011

Subject: Pilots' licences
A good many private pilots in Europe hold US pilots’ licences with an ‘instrument rating’. It is possible to obtain such an American rating in a fairly flexible manner (e.g. by means of video or CD lessons). The European equivalent, on the other hand, is said to be rather inflexible and inaccessible.
In the USA, 48 % of private pilots are said to have an instrument rating, as against barely 5 % in the EU. This has an enormous impact on safety: the number of accidents is apparently 70 % [lower]* in the USA than in Europe.
A recent opinion delivered to the Commission by EASA proposes banning US pilots’ licences.
1. Can the Commission shed any light on the major differences in training between the US and European instrument ratings?
2. Does the Commission acknowledge that the number of pilots who have obtained instrument ratings is far larger in the USA than in the EU?
3. Can the Commission indicate the impact which this has on safety and on the number of accidents, on the basis of specific statistics?
4. Does not the Commission consider the proposal to ban US pilots’ licences to be counterproductive?
5. Will the Commission reform the European instrument rating and make it more accessible and flexible?


I'm curious to see the cock and bull that good Mr. Kallas is going to come up with when answering this one.

Probably his answer on question 4 will be :

But the Commission is not proposing the ban US pilots' licences, it only requires them to hold an EASA license in addition...

------

I've also been told that the EASA commitee named member list is now known. Can anyone who has this one PM me with it ?

------

Apart from that, it is business as usual. Please write to your MEP because the Cologne four letter word demolition squad is ALSO writing to your MEP. But there are over 60,000 of us against only 500+200 slightly overpaid ones of them.

*this is the correct translation of the Dutch tekst. Unfortunately some translator put "higher" there instead of "lower", which obviously is not helpful.

Last edited by proudprivate; 1st Mar 2011 at 18:02. Reason: correcting translation
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Old 2nd Mar 2011, 07:57
  #777 (permalink)  
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Go, Frieda, go !!
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Old 8th Mar 2011, 07:58
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Answer by Kallas to Frieda Brepoels' question

E-0048/11EN
Answer given by Mr Kallas
on behalf of the Commission
(23.2.2011)

The Commission is aware of the fact that the number of the pilots holding an instrument rating, in addition to a pilot licence, might be higher in the United States than in the EU and that there are differences between the US and EU training requirements for instrument rating, one of the main differences being the minimum amount of instrument flight time during the training.

The requirement for pilots residing in and involved in the operation of an aircraft in the EU to comply with European licensing requirements stems from Regulation (EC) 216/2008 adopted by the Parliament and Council[1]. The relevant conditions, including the validation of pilot licences issued by third country authorities, have recently been considered by the Regulatory Committee established under Article 65 of the said Regulation. The view of this Committee, based on a proposal from the Commission, is that an additional transitional period until April 2014 should be foreseen for the validation of pilot licences issued by third country authorities. This time will allow for further discussions on the recognition of non-EU licenses within the framework of bilateral aviation safety agreements between the EU and third countries. Subject to the outcome of the scrutiny procedure by the Parliament, the Commission Regulation on this matter will include this additional transitional period.

In addition, the review of instrument rating requirements aiming at their simplification is the subject of a dedicated EASA proposal that has not yet been published. A public consultation (so-called Notice of Proposed Amendment for NPA) is due to be published in the second half of 2011.

[1] OJ L 79, 19.3.2008


I have a few questions here :

1. I thought the main difference lie in the 100 hours of compulsory classroom attendence and the subsequent theoretical exams and not so much in the flight time requirements.
What are the JAR IR flight time requirements during training ? Are there really any significant differences in the actual flight training ? An outline would be most welcome.

2. Has Commissioner Kallas answered or hinted at an answer of question 3, i.e. "Can the Commission indicate the impact which this has on safety and on the number of accidents, on the basis of specific statistics?" ?

3. Commissioner Kallas is referring to the scrutiny procedure by Parliament : has the infamous document already been transmitted to the Parliamentary Committee ?

4. Has Commissioner Kallas answered question 4, i.e. "Does not the Commission consider the proposal to ban US pilots’ licences to be counterproductive?" ?
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Old 8th Mar 2011, 15:22
  #779 (permalink)  
 
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The minimum IR dual time under ICAO is 10 hours.

The minimum IR dual time under FAA is 15 hours.

The minimum IR dual time under JAA is 50 (SE) or 55 (ME) hours.

The minimum IR dual time under the "FCL-008 IR" is reportedly 15 hours.

If this EU gravy train driver is hanging his coat on 15 v 50/55 hrs, the FCL008 IR doesn't have a chance, despite apparently positive noises from the right places. But much more likely he is just being disingenuous.

Obviously nobody can meet the checkride standard (FAA or JAA) in 15hrs so it is in effect based on "demonstrated competence" which is how it should be. This is a principle which the EU reportedly accepts. They can hardly refuse it (morally).
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Old 9th Mar 2011, 08:55
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But the FAA also require 40 hours of "instrument" time, so 15 must be dual with a CFII but the remaining 25 can be with your IR'd buddy under the hood. Of course you have some other requirements too like a cross country flight "under ATC controlled routing". Bearing in mind one has to be good enough to pass the IR Oral and check flight as well.
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