The Transition To EASA Aircrew Regulations:
One NAA’s experience
Ray Elgy UK Civil Aviation Authority, Licensing & Training Standards
November 2012
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
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 - Conversion of European non-JAR Licences
Annex III - Validation/Conversion of 3rd country licences
Annex IV - Part-MED - Replaces JAR-FCL 3
Annex V - Part - CC - Requirements for Cabin Crew
Annex VI - Part-ARA - National Aviation Authorities.
Annex VII - Part-ORA - Organisations.
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
Licensing & Medical Volumes Annually…
Licensing
v ~8,000 new Licences
v ~13,000 Ratings
v >60,000 Telephone calls
v >10,000 E-mails 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
Slide 5
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
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 Q1 2012
Part-ORA August 2010 June 2011 Q1 2012
All of these became applicable from 8th 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)
Timetable
The Aircrew Regulation itself became effective on 8th April
2012.
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 2013.
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 17th September 2012.
Timetable
Other Derogations/Opt Outs
- 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 2014.
- The CAA is taking the permitted period of 2 years to convert
national licences (being used for purposes outside the LAPL
privileges).
Licence Conversion Deadlines
To fly EASA aircraft:
Aircraft and Operation Pilot must have an EASA licence by:
Aeroplanes and helicopters used
for commercial purposes.
8th April 2014
Aeroplanes and helicopters outside
scope of LAPL used for any
purpose.
8th April 2014
Aeroplanes and helicopters within
the scope of the LAPL and used for
non-commercial purposes.
8th April 2015
Balloons, Airships and Sailplanes. 8th April 2015
Aerobatic rating
Towing rating (Banner or Glider)
Mountain rating
Flight Test rating
8th April 2015
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.
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.
- 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).
EU rules apply to all aircraft (wherever
registered) except:
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).
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 re-
introduced 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.
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
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
And also involved…….
• Changes to our main Licensing IT system, which included;
•77500 lines of reference data - Each line has many
values.
•Over 1500 individual tests run during UAT
•Non-stop implementation from 17:00 Wednesday 12th to
late afternoon Sunday 16th 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
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:
www.caa.co.uk/eupilotlicensing
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 turn-
round times.
CAA Information on licensing and EASA: We have a dedicated page on our website where EASA
related information may be found–
www.caa.co.uk/eupilotlicensing
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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