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The expressed intention of EASA is to do away with all national ratings and licences. In the absence of any amendment to that intention or the adoption of any grandfather rights, the following categories of licence and rating holders will lose rights and privileges:
1) Lifetime PPL holders - they will now have to renew the licence every 5 years at a cost (currently about £150) - a cost which may well deter many PPLs from continuing (data suggests that many PPLs give up after 150 hours anyway and they may now stop sooner, thereby taking revenue out of the industry); 2) IMC rating holders - they will no longer have any instrument privileges without doing an Instrument Rating - for PPL holders the costs and examinations for the IR are a huge deterrent, which is why there are only around 150 PPL/IR holders in the UK as opposed to 20,000 private pilots; 3) The holder of a BCPL(R) with grandfather rights enabling him to operate as an instructor for remuneration, will be downgraded to an EASA PPL and therefore not be able to receive remuneration if instructing. To convert his licence into a CPL, he will have to undertake ground school and pass a minimum of 9 examinations at CPL level and then do a full CPL flying course of 25 hours and pass a CPL Skill test, all of which would cost around £10,000 and take the best part of a year, not an option for the majority of this group who are in their 50s or more. 4) The BCPL holder with instructor rating who has passed the CPL exams will also revert to a PPL, unless he does a course on a complex type and passes a CPL Skill test, which will cost at least £2000, just in order to stand still and continue being remunerated for instructing. 5) UK CPL and ATPL holders without a valid IR have built-in (embedded) IMC privileges in their licence, meaning that they do not need to pass an IMC test or maintain an IR in order to fly an instrument approach.. These rights will be removed and thus these licence holders would be required to undergo a test for at least an IMC rating to continue with the privileges they currently hold. Many instructors are in this category and the removal of such privilege arbitrarily has safety implications as many instructors would not legall be able to do a cloudbreak procedure to recover to an airfield when the weather closes in. The cost of a test in a single engine aeroplane would be around £300 - 350, prohibitive for most instructors. 6) The holder of a UK ATPL without 500 hours multi-crew will be downgraded to a CPL - arguably no real loss other than the psychological one of loss of status and if one has done all the work and passed all the examinations it is illogical to downgrade their licence. Many instructors fall into the categories listed above and these are arguably those who will remain as instructors, as they do not have the licence to allow them to leave and go to the airlines. These changes will, with one fell swoop, reduce or remove rights and privileges from a large coterie of instructors at a time when the shortage of instructors and the crisis in instructor retention is at its worst for decades. Those few remaining who do not fall into the above categories, because they have JAA licences, include many whose aspirations are towards the airlines and therefore they do not intend to stay long in instructing. The training industry is in great danger of complete decimation and destruction. The costs in terms of training and the time factor required for the majority of the above-mentioned groups to convert to JAA/EASA licences are prohibitive, impractical and in all cases the changes involve reductions in existing status with no compensation. Many will lose their livelihoods and many will simply give up and leave the profession. It is highly likely that this is a fundamental breach of human rights for a very significant group of people. We must, as an organisation and as individuals, campaign to protect the existing rights and our industry, as it is likely that the burden on the majority of people will be so great as to deter them from taking the necessary steps to preserve their status. The loss of such a large group of mature and experienced instructors is incalculable and devastating to the UK training industry. Dorothy Pooley October 2007 |
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