During a hearing beginning today through October 14th, the European Union Commission will vote on the adoption of a new set of EU-wide rules pertaining to pilot certification and airplane registrations. The AOPA and the IAOPA have both been vocal with their opposition of the new rules and the negative worldwide impact they will have on the international aviation community.
The new regulations being proposed were introduced in 2008 by the European Aviation Safety Agency (EASA). During the public comment period, ending February 28, 2009, the EASA received over 11,000 comments on the proposal. After reviewing the comments, the EASA submitted the final proposal to the EU commission for a vote, which is taking place today and tomorrow.
The proposal, if a vote is successful, will lead to drastic changes in how general aviation and pilots operate within EU countries with the effects truly being felt globally. Currently, general aviation is expensive across Europe with expensive landing fees fuel in excess of $8 per gallon. The proposal would eventually require what equates to a re-certification for pilots with a private pilots license. Currently, many international aspiring pilots, especially from Europe come to the US to train and obtain their pilot licenses. The prior programs at many US aviation schools were known as JAA programs and training was held to JAA recommended standards for certification. (The JAA was the predecessor to the EASA).
If the proposal passes, foreign issued pilot certificates will not be valid for use in Europe as current reciprocity will no longer apply between the US and the EU. In the initial two years, a US certificated pilot would be able to receive European validation of their license; however, after two years, the pilot would need to obtain a European pilot license.
The biggest financial and economic impact that this proposal will have on the US is on US flight schools and manufacturing. Pilots that come to the US for flight training would need to repeat virtually all of the training upon returning to the EU. A pilot certificated in a non-EU country would be required to obtain a Class 2 medical certificate, take the EASA's Air Law and Human Performance exams, demonstrate language proficiency, and fulfill all the requirements that would apply to a normal issuance of the type and class ratings equal to the privileges the pilot already holds. The pilot would also be required to have 100 hours of pilot-in-command time in the aircraft they plan to fly in Europe. In addition, the pilot would also need to pass all the pilot skills tests applicable to their license. This could result in costs nearly equal, or in some cases in excess, of the initial costs to obtain the license in the US. A private pilot could end up paying in excess of $15,000 for the license in order to fly in Europe, with US flight schools specializing in international training suffering tremendous loss of revenue and possibly closure and unemployment for their staff and instructors. With the new rules, there will be no benefit for a aspiring pilot to travel to the US for training, but at the same time, there is not nearly the same level of training infrastructure in Europe to handle all the pilots that come to the US for training.
The FAA instrument rating would also be useless in Europe as the new EASA rules will not recognize the FAA's instrument rating. EASA requirements for obtaining an instrument rating are considerably more strict than the FAA requirements and viewed by many aviation authorities, manufacturers and pilots as excessive. The extra time, effort and money involved have led to many European pilots coming to the US to obtain the rating or not obtaining one at all. Obtaining an instrument rating is highly encouraged as a common cause of general aviation accidents is a result of inadvertent flight into instrument meteorological conditions. Private pilots in the EU may pass on obtaining an instrument rating for financial reasons resulting in more risk when flying around worsening weather conditions.
Another aspect was the proposal to prevent European pilots from registering their airplanes overseas, as obtaining N-registration (US based) was much cheaper than registering in Europe. One serious side-effect of this could leave US ex-pats that relocate to Europe and bring over their plane with severe financial penalties, from registration fees, to training fees to even obtaining type ratings on airplanes that do not require type ratings in the US.
This editorial written by Jan Brill, the managing editor of the German aviation magazine 'Pilot und Flugzeug', gives three examples and further details on the effects this will have on aviation in the EU. Want to fly during vacation? Under the new rules, it will literally be a once-in-a-lifetime experience, unless you fork over the money to get licensed in the EU. Validations by the EASA on a foreign certificate only apply for a year and is only granted once, with no exceptions.
Further Jan provides an example of a company executive who relocates to England to help in the international growth of his company, bringing his King Air C-90. He can obtain a validation of his FAA ATP license, however, that is only good for a year and cannot ever be validated again. To continue to fly it in Europe after one year, he will need to complete all the prior mentioned training even though he maintains a US ATP license and has over 2,000 hours flying the King Air. He will need to obtain a type rating as the EASA requires a type rating on the King Air. He would need to take a brand new EASA instrument rating course as his FAA instrument rating will not carry over. Finally, since the airplane is not registered in the EU, he will not be able to use his own airplane for any of this training, as the EASA will ban any flight training in a non-EU registered airplane.
Once all his training is done, and the King Air is a 'complex' aircraft, he is mandated to turn over all control of the airworthiness of the plane to a still non-existent organization, Continuing Airworthiness Management Organisation, (CAMO). Unfortunately, doing so would put him in direct violation of federal US regulations as the owner can never delegate responsibility for the airworthiness of the airplane.
The effect these proposals will have on general aviation in Europe could be devastating. Endeavours such as Fly4MS may never be undertaken again, people wanting to soar over the Alps, or hop from country to country will be restricted to commercial travel. Watch the General Aviation column for the results of the vote when it's finally announced.
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