Flight Crew Licensing

What is the issue?

The License of a pilot is a vital document for any pilot. While for decades the rules governing these licenses were determined within the Joint Aviation Authorities (JAA), the European Union has embarked on a process to transpose the JAR-FCL rules into EU-wide provisions. In 2008 the European Aviation Safety Agency (EASA) acquired a new mandate to create such rules, and is preparing "Implementing Rules" which will replace the JAR-FCL provisions by 2010/12 at the latest. These "EASA FCL" rules will have a direct impact on the way pilots licenses are governed in future. Whereas JAR-FCL was an "operational" text, easily understood by aviation professionals such as pilots, the new EASA Implementing Rules will be in legalistic language, more difficult to read and more difficult to apply.

How is ECA involved?

ECA has been active in this domain since its establishment, first in the framework of the JAA and now within EASA. In the former JAA days, ECA pilots worked to ensure that JAR FCL reflected the pilots requirements. During the development of the new FCL rules, the Agency invited a selection of ECA pilots to participate in working groups to effectively transpose JAR-FCL. These working groups contributed to the draft Notice of Proposed Amendments (NPA) and the Comment Response Document (CRD). The EASA process finished on August 26, 2010 with the publication of its Opinion 2010/04. The next step was the comitology procedure in the European Institutions and once formally adopted in Brussels, the EASA Part-FCL will enter into force on April 8, 2012.

Why is the issue important to ECA?

Obtaining a license is a big responsibility. ECA's aim is to ensure that the standard of initial and recurrent training are always sufficient to ensure the safety and the security of the flights. This is particularly true for new developments, such as the Multi-crew Pilot License (MPL) which risks undermining flight safety if not properly implemented and monitored. It is also true for the future EASA FCL rules that will replace JAR-FCL. Due to the ECA experts involvement the text improved a lot during the consultation. However, not all issues have been solved to ECA’s satisfaction. The new rules will thus still include:

Requirements for pilot training that remain part of AMC’s: ECA requested to move these into the Implementing Rule and its Annexes in order to keep important, safety-relevant parts in legally binding material.

A technical and safety problem is created by allowing Private Pilot Instructors to work without the need for a Commercial Pilot License (CPL) because these instructors are not included in the Flight Time Limitation rules (ie they are not subject to those rules that govern fatigue and thus safety).

The EASA proposal imposes an age limit on all EU Member States. This is in conflict with many national legislations on the retirement age, is a deviation from the JAR-FCL rules, and is not in line with ICAO.
In the EASA Opinion, parts of the JAR regulation on MPL implementation are moved to Guidance Material. However, these are fundamental points that need to be respected in the MPL implementation to avoid the creation of safety gaps, and therefore should be in legally binding material.
The existing requirements for cruise relief co-pilots are copied from the current EU-OPS into FCL. This is not in line with current EU practice, and not in line with ICAO and FAA.

IFALPA Pilot Training Standards (IPTS)

Legislative texts about FCL are very important, but one may wonder what pilot training is really like, is it sufficient, are the right skills trained? In short: what is the level of training? More and more the ‘Level of training’ as meaning both quality and quantity are both under pressure. And there is the challenge to cope with the ever increasing automation on the flight deck. Key questions therefore arise: shall we train pilots to understand what the plane is doing and teach them to simply “manage” the airplane? Or shall we train pilots to be able to really fly the plane using the so-called “stick and rudder skills” used since the dawn of aviation? The answers will brace the future aviation safety level. And it is the pilots themselves who will be part of the solution. And the pilots now have a common global view expressed in the IFALPA Pilot Training Standard (IPTS) that was released in March 2011. ECA and some of its Member Associations have been instrumental in establishing this IFALPA standard on pilot training. More information you can find here.

Who is responsible?