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Remaining Positive in the Face of Uncertainty

What we currently know with regard to leaving EASA is, the 31 December 2020 is fast approaching and with that the end of the EU/UK transition period.

We also know that from the 1 January 2021 the CAA will continue to accept EASA licences, ratings and certificates for a further two years (31.12.2022).  This means that your CAA-issued EASA part-FCL will remain valid and as it meets the requirements of ICAO Annex I you will still be able to venture beyond the shores of the UK should you want to.

The big change is in respect of commercial licences from CPL to ATPL, as from next year they will be issued by the UK CAA, which in effect means that these licences will only apply to those individuals seeking to work for a UK AOC holder which is the law in any case.  That is not to say that a UK CAA professional licence cannot be accepted elsewhere in the world, it does mean that there is no automatic acceptance by an EU State and what EU States require will depend on experience.  Individuals thinking of gaining a professional licence will need to consider who they want to work for, assuming that they have the right to live and work in another EU country, as that will no longer be automatic right.

It is understood that the CAA/DfT are participating in high level discussions with EASA/EU and are discussing a BASA which may have several annexes, one of which is seeking to achieve mutual recognition of licences between the UK and the EU, however we are also being told that the EU is not, at this stage, willing to discuss licences although we may know more after the next round of discussions in September.

There is likely to be an impact for some schools as they decide whether to opt for an EASA approval or not. There are some unknown costs here which are not insignificant from what we have been hearing.  They are also likely to need to continue with their CAA approvals, if their business is to also focus on providing training for UK citizens, so the schools will have two lots of approval fees to consider when looking at their business model.  Instructors and examiners will also have the ability to hold dual approvals at the same time, but that too adds to their costs and as with any business all costs get passed on to the customer.  This change is not likely to make the UK more competitive in the world for flight training.

So, there are some difficult decisions ahead for many, uncertain business volumes from next year, uncertain costs/overheads, with no clear view of the future relationship between the EU/UK.  This could all change by the end of the year but for now the Government’s message is - To plan for the worst and to hope for the best.

General Aviation Partnership (GAP) Meeting 24 September 2020

The new chair of the CAA’s board Sir Stephen Hillier addressed the members of the GA partnership. Having been in the Royal Air Force as a Tornado pilot he eventually rose the position of Chief of the Air Staff. However as a teenager he benefited from a flying scholarship through the Air Training Corps and he completed his his PPL at Leicester Aero Club aged 17. Sir Stephen says he has had a life long interest in aviation and with all the issues today he is confident about the future of the UK aviation sector,  which is the third largest in the world and where the CAA has a global reputation to maintain.

It is clear that he sees the UK building on existing relationships with other NAA’s including EASA, but the freedom to regulate in the UK will allow new opportunities to take shape accordingly. I am sure that Sir Stephen genuinely believes what he says however the challenges will be in the delivery because the devil is always in the detail.

It should be remembered that the UK is a signatory to the Chicago Convention of 1947 which is an international body and specialist agency of the UN which we know as ICAO. The ICAO standards and recommended practices are globally agreed and adopted into national instruments of law. There is a requirement for the ICAO member states to comply and where a state files a difference that difference cannot be permanent. Where a state decides, for national purposes , not comply with ICAO standards then these operations are normally confined to the state’s airspace.  So we look forward to working with Sir Stephen and his team. He is the fifth Chairman of the CAA I will have worked with over the years, which started with Sir Christopher Chataway, and I feel the pendulum of time swinging once again.

The DfT is preparing an announcement which will outline how the Government intends to provide financial support to those who are willing to invest in  Electronic Conspicuity devices – it will be 50% funding up to a maximum amount. The details will be posted on the AOPA website once the DfT have finalised the terms.

When it comes to the CAA Scheme of Charges, it is clear from the recent impact of the pandemic that the authorities income has been affected – it remains unclear to me how any of the work the CAA is proposing will lead to lower charges for those who operate certified aircraft. As money becomes tighter I think we will once again see the issue of cross subsidies being highlighted – AOPA is aware of the costs to our members of CAA charges and how changes in regulations may impact all of us..
With all the uncertainty around the future trade agreements with the EU and as the withdrawal agreement comes to an end,  it is very difficult for businesses to plan their futures where the only certainty is 31.12.2020. That is why we are being told to assume that there will be no agreement and plan accordingly. We are hearing that there will be no agreement on mutual recognition of licences but AOPA has asked the Government / CAA to continue to pursue this aim even after the end of this year. There are other areas where we think the government needs to achieve reciprocity.

Between 1.1.2021 and 31.12.2022 we will see a number of changes. However, over this period the CAA will continue to accept EASA licences, but it will also be a requirement for operators of UK registered aircraft to have a UK licence. It is likely that the CAA will issue some kind of general authorisation for holders of EASA licences. During the period the CAA are going to conducting more consultations across a wide range of activities and AOPA will be there making the case for GA. There are challenges ahead but we are ready to engage with you, our members, as well as the CAA.

AOPA - Preparing to Move

In anticipation of a sale of 50a Cambridge Street we are currently clearing the premises and will be operating from a temporary location until we move into new permanent premises. We will let you know where we are moving to as soon as soon as possible.
Mail addressed to AOPA at 50a Cambridge Street will be redirected to the temporary location until further notice. Our telephone number and email addresses will remain unchanged.
We intend to any disruption to our operations during this period to a minimum.
If you have registered your aircraft at our office address we will let you know when we have a new permanent address for you to use.

Martin Robinson
Private Flyer UK

The event organisers and venue management have cancelled the October 2020 event at Wycombe Air Park, giving this statement to us :

"This [cancellation] is due to the venue (Wycombe Air Park) being reluctant to provide the venue to us this October, given the lack of clarity regarding HM Government's COVID restrictions for the events industry and further potential associated risks with hosting the event. We are extremely disappointed to announce this just 5 weeks before the show.
All exhibition bookings for this event will automatically be transferred to the new dates of 
Friday 14th & Saturday 15th May 2021."

Additionally, there will be a second Private Flyer UK event at Leeds East Airport, Church Fenton, on Friday 26th & Saturday 27th March 2021.

Keep up to date at :
Moving Map Survey for Private Pilots

We advised members that the Airspace Infringement Working Group had developed a survey for private pilots on the current use of moving maps and would welcome your views.

Unfortunately, the survey was faulty and unpublished shortly after we had emailed the information.

The survey is currently being revalidated to correct some issues and we have been advised that the survey should be  re-launched this week. 

We will let you know when the survey becomes available.

Answers to recent repeat Ask AOPA questions

EASA Aircraft - Engine operations extending beyond the manufacturer’s recommended overhaul period or calendar life

We were asked if an EASA aircraft could now be used for hire or training with an engine operating beyond the manufacturer’s recommended overhaul period or calendar life. Under Part-ML the answer is yes so long as the AMP
, as agreed with the maintainer, has suitable required checks on condition, which may include more frequent checks, oil analysis, engine compression tests and internal inspections with a boroscope.

EASA Aircraft - COVID Restrictions:  Airworthiness Review if Aircraft Abroad

At the beginning of the lockdown in March some aircraft owners found themselves in the position of having their aircraft "locked down" outside the UK with an airworthiness review due by a UK based CAMO/CAO.

The CAA have issued
ORS4 1426 COVID-19 – Requirements of  the Airworthiness Review and the Completion of the Physical Survey Utilising Part 145 Licenced Engineers. For EASA Aircraft, this allows a UK based CAMO/CAO to contract a non-UK Part 145 Licenced Engineer to conduct the review and inspection if COVID restrictions prevent the aircraft being returned to the UK, subject to the conditions in the ORS4 1426, which expires on 31 December 2020.

COVID 19 - Medical Exemptions

We have had a number of enquiries from confused members in respect of  their Part-MED medical extensions provided under the exemptions in
ORS4 1408 or ORS4 1413 and in particular what their extended expiry date was based on their original expiry date.

We have put together a simple check tool which should answer any such query, and indeed those related to other exemptions and extensions,

However, we recommend that you contact your AME to see if you can revalidate/renew your medical as close to the expiry date as possible and before there is a rush close to the extended expiry dates of your exemption period, or before further COVID restrictions prevent AME's from carrying out examinations. Any AME providing a service will be applying COVID protection requirements.

COVID 19 - Class Rating Revalidation

Similarly, we have had a number of enquiries in respect of what is needed to revalidate a class rating that has been extended using a COVID exemption.

The CAA published
ORS4 1416 & ORS4 1418 to explain the requirements. However, as a further aid to interpreting the requirements we have constructed this simple tool.

LAPL(A) Holders: ORS4 1416 Does not apply. Under ORS4 1412, if you met the briefing conditions and had your logbook endorsed as stated in Para 3(e) you could use a 32 month "lookback" for LAPL recency until November 2020. ORS4 1416, which runs until 30 April 2021, states that there is no need to introduce any further exemptions for LAPL(A) holders.  Thus after 22 November 2020 the normal 24 month "lookback" will apply.
FI & CRI Refresher Courses

The next AOPA FI Refresher Course dates are:
  • 24 & 25 November 2020
  • 9 & 10 March 2021
For more information see here.

The November 2020 Refresher Course will be held, with the approval of the CAA, by remote video using Zoom as a  one-off exemption due to COVID-19 restrictions.
Copyright © 2020 AOPA UK, All rights reserved.

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