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Wednesday, 18 December 2013

JAR-FCL RTF / EASA ATO, and the consequences for my PPL Training

Just to throw out some more abbreviations here, I wrote another article on the changing legislation in the world of aviation. More specifically: the world of Flight Crew Licensing. I'm hoping to shed some light on the matter, for the benefit of those that have recently started their PPL training, or are about to start that training (like myself). It all started with a discussion on the legislation concerning training organisations, and the licensing of those organisations, and on what the consequences for students would be. Especially the transition from the "old" regime to the "new" regime, and in how far the "old" education would be recognised end fully creditable towards the "new" education. Lots of that discussion is based on the personal interpretation of the applicable legislation, so there's a certain uncertaincy in the arguments used. Therefore, I decided to ask the executive institute for the Netherlands (the "competent authority"), IL&T (Inspectie Leefomgeving en Transport)

First off, a couple of abbreviations, essential to the following article:

  • JAR-FCL (Joint Aviation Requirements - Flight Crew Licensing). The "old" regulation
  • Part-FCL (Part Flight Crew Licensing). The "new" regulation
  • EASA (European Aviation Safety Agency). Founded as an advisory body for the European Commision, for drafting the legislation on aviation.Also, nowadays, given the role of enforcer of that legislation (there's a conflict of interest in there, but that's a whole other discussion)
  • IL&T (Inspectie Leefomgeving & Transport). The Dutch competent authority in the sense of the European Aviation legislation
  • RTF (Registered Training Facility). Training organisation under JAR-FCL, with certain qualifications and requirements
  • ATO (Approved Training Organisation). Training Organisation under EASA regulations
  • AOPA (Aircraft Owners and Pilots Association): Association representing (student) pilots worldwide, with national chapters in various countries, among which the Netherlands
I formulate this all in a generic sense, because it not only applies to me, and my situation, but to all PPL students and training organisations that provide PPL training.

OK, here we go. 

Training Organisations must be ATOs as from 08-04-2014. ATOs use the EASA syllabus for their PPL training. Until that date, Training Organisations may provide training according to JAR-FCL syllabus. Even more: the EASA syllabus, as defined by AOPA-NL in conference with EASA, is still in an approval phase by IL&T. Until the approval of the syllabus, trainers use the JAR-FCL syllabus.
Not a problem, as long as the proposed EASA syllabus is approved before 08-04-2014, and JAR-FCL RTFs are certified as ATOs, based on that syllabus.
All training according to JAR-FCL can be credited in full to EASA Part-FCL training, by means of a credit form (sort of checklist, cross referencing the JAR-FCL experience to EASA Part-FCL training requirements), and the training can then be proceeded under Part-FCL without a problem.

But: there is a transition period in place, during which the above JAR-EASA conversion of the syllabus can take place. The transistion period ends 08-04-2016. After that date, for the practical examination all training received under JAR-FCL is no longer considered valid. Only hours and excersises followed at an ATO under Part-FCL are considered for experience requirements.

Theoretically, this could lead to a situation where one could file for a practical exam after 08-04-2016, where not all minimum required 45 hours are counted (even though one may have received more than 60 hours of flight training already). I have to admit that one would need to fly less than 45 hours in a 2-year timeframe (assuming all trainers are ATOs by 08-04-2014), but that is not entirely unthinkable. If one aims for 1 hour training per week, and gets a success rate of 50%, that would take 90 week, which is almost two years. Not much needs to go wrong there, to cross the limit.

The sloution then would of course be to fly the extra hours, which would only be a few. But if you are thinking of starting out right now, it might be worth considering your time path, and perhaps wait a few months before you start. That way, you'll start with an ATO, under Part-FCL, and you would not have to worry about conversions, deadlines, and so on.
Those that have already started their training: no worries: as long as your exam is before 08-04-2016, nothing really changes, and if your exam is after that date, chances are that you will have flown your minimum hours under Part-FCL anyway.

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