Balloon Repair Station

The Ups and Downs of the Great British Balloon Licence – Chris Dunkley

Its been a cracking day, the winds light and variable and the temperature still t-shirt. My dog and I have walked miles and watched a balloon float gently across the sky, albeit very slowly, and land almost where we cut into the woods. Pleasant happy waves exchanged with the retrieve crew. A degree of considered, careful and controlled normality is returning. It does depend, of course, on common sense which, around our part of the country, appears to have been taken, in the main, onboard. That, combined with the news that we can now use our old licences until at least late 2022, fills me with joy. Ballooning, as they say, is back and could be even better.

When it was announced earlier in the year that, not only would we properly, eventually, might be leaving the European Union this year but that, despite all the reassurances from those at the top of the CAA that ‘we won’t leave EASA’, it was announced that we would be gone on the 1st January 2021. I had to admit, for me, there was a bit of hope that perhaps a lot of the nonsense and ream upon ream of more nonsense that is EASA would be lobbed firmly in the out tray and we could get back, albeit steadily, to running our own affairs again and, for ballooning at least, after we bid ‘auf wiedersehen’ that will be that. We will then have no further influence on, nor be bound by, the rules and regulations they impose on the countries of the European Union of which we are no longer a part. Until then we are still in EASA and burdened with EASA rules but it is going to have to change. It won’t be overnight as there is a lot of BREXIT stuff, like fishing rights, the Irish border and many rules and regulations that have to be re-written but change will come. Lessons from the past confirm that second guessing is really a waste of time but doing nothing and waiting to see what happens is never a good policy. It was, in reality, many years before EASA got round to attacking balloons and the licencing and so started a series of negotiations which developed into the BBAC putting an expensive Training Organisation in place that, it turned out, we didn’t need on account of a ‘hold up’ and everything was put ‘on hold’ (did we get a refund?). Then we might need it after all and now, in the closing months of EASA we sort of do. Well, not really now but in a couple of years. But we sort of do again to support the poor souls that have BPL or a redundant LAPL or might be training for a BPL. In order to get the best deal we could under EASA a hard fought series of negotiations has resulted in the BPL that we are now being encouraged, or maybe not, to apply for. It isn’t perfect but we should grateful for the hard work that Phil Dunnington and Paul Spellward put in to getting it and that the CAA decided that they would continue to support the old National Licences. Had we not ended up leaving EASA then I’m sure that over the coming years more could have been gained but now we are leaving. Things have changed and so should we.

Apologies for acronyms that follow but you know how it is. For the sake of simplicity read BPL as the EASA licence we have been awarded and UK PPL/CPL as the old National Licence that we can now use for a couple of more years. Both, in this case, only apply to balloons (well maybe hot air airships and gas balloons). Now for the small print. This is my take on it or rather the bits that we (me) hadn’t realised were included or not included in the BPL. It’s a bit of a read I’m afraid.

With the looming arrival of the BPL set for 8th April 202I I decided that it wasn’t for me. I wouldn’t bother applying for a BPL and simply revert back to my old PPL/CPL thankful for the concession from the CAA to retain them. The advent and push to get the BPL meant that there wouldn’t be much need for UK PPL/CPL Examiners and as the number of candidates is falling it would be a fitting time for me to retire. Then we got the announcement that we were leaving EASA and then we imported COVID and then the shut off for the PPL and CPL was extended to October 8th 2021. Perhaps it was time for a rethink? I started reading up on this smashing new licence in a lot more detail, a by-product of lockdown once I’d got bogged down in that light read, Gravity’s Rainbow. Was the BPL worth keeping? I also kept a keen eye on the BBAC website, Aerostat, Pilot’s Circular, Committee Meeting reports and the general circulars and rumours from the BBAC. Now we would be divorced from EASA surely we would get on with the job of getting our own licences back. No such luck. If anything the BBAC was now resolved to stay with the EASA licence, something we would have no control over and, as I discovered, had a lot of shortfalls. Examiners and Instructors were told to apply ‘as soon as’ so the system could be up and running ahead of any deadlines. Quite a few pilots did apply ‘as soon as’ and still don’t have their lovely BPL licence. For some, in the meantime, their trusty UK CPLs expired and now they had to get them extended! ‘A software glitch’, explained the CAA. Blinding. It seemed to me that there wasn’t much enthusiasm for the BPL. Then as if by magic the UK PPL/CPL validity was extended until the end of 2022. You know what? I decided that maybe I wouldn’t retire just yet! If the BBAC weren’t going to push for a return of the UK PPL/CPL then I, along with a fair number of like-minded souls, would. We’ve got at least two years to do it.

Meanwhile, back in the gazebo with a bottle of Weston’s finest, more and more on the downside of the BPL was coming to light. Stuff I hadn’t realised. Further questions were asked and along with information coming from the BBAC Flying Committee it pointed to there being now less than no intention to discuss a return to the old system with the CAA. We got onto our customers and asked them what they thought. Some weren’t bothered and had applied and were now spending much time trying to find out why their donation hadn’t resulted in a licence popping through the letterbox. Others had no idea what the implications or alternatives were or intended to hang onto their UK licence and Self Declared Medical and not bother with the BPL. Almost all were simply ‘disgusted of Bovingdon’ and asked ‘What can be done?’ On the commercial front there was general discontent that the CPL, the most respected balloon licence in the world, would become pretty much unobtainable for new pilots and it would not be possible to re-validate it in Europe or the UK. Then I discovered that I couldn’t fly my UK registered T&C 56B in the UK on a UK licence. “Good grief Carruthers! Fetch my pen.”

There are pro’s and con’s to everything I grant you, but having had a good long study of the subject and listening, and continuing to listen, to pilots, my peers and those that understand it far better then me, here are the only pro’s I can currently find and both have caveats. For the defence. It seems to be that the ‘BBAC’ is promoting that ‘the new BPL will be accepted in all the EU countries’ and that ‘the LAPL (EASA) medical will also be accepted throughout the European Union’. Here’s the thing, the new, what will probably be known as the ‘UK BPL’, licence will not necessarily be automatically accepted by EU countries after the 1st January 2021 as we will no longer be part of the EU or EASA. Fortunately the PPL/CPL is ICAO compliant which means that all those countries that subscribe to that standard, like the UK, will accept it but actually that won’t be the case in the UK or the European Union because the requirements and privileges of the BPL are set by EASA and include not being able to fly an EASA Type Certified, as in Cameron, Ultramagic, Lindstrand, Kubicek, Schroeder and the like, balloons on the UK PPL/CPL in the UK. Annex1 and Head Balloons are OK. Try and Keep up! Basically that means you cannot fly a G-reg type-certified balloon in the UK on an ICAO compliant UK licence? That’s a bummer. More later. As for the LAPL medical that you will need to have to use a BPL, it may well be accepted across the EU region but it isn’t outside of it. If you want to use it outside of the EU you’ll need a Class2 medical.

Sadly the LAPL medical is about as (or in many cases slightly more) expensive than the Class2 medical with the same standards required. Sadly many pilots relying on the Self Declared Medical will not meet the requirements or will only at a huge cost. Answer given is, that if you build your own balloon, or own a Head Balloon, you can fly on your UK licences and on a self declared medical. Sorted.

Now at this stage I was thinking that it is the time to get into explaining ICAO compliant licences but the relationship between the BPL and the PPL/CPL and flying in the UK on a PPL/CPL becomes very complicated. Its another article on its own. Simply put, ICAO is a system whereby other countries and their National Aviation Authorities (NAA) recognise other NAA’s licences. EU countries have EASA as their NAA so are effectively one country and subscribe to ICAO. The USA for example recognise ICAO licences so you can go there on your UK PPL/CPL licence and happily fly your G-reg balloon. Once out of EASA you will not be able to fly your G-reg balloon (except home-builts and the like) on a PPL/CPL although those licences are ICAO compliant because EASA says we can’t. As luck would have it, because of the UK licence extension, we can still fly on our PPL/CPLs for another couple of years. This needs serious sorting, like bin the BPL. Maybe that’s what the ‘B’ stands for?

Initially the BBAC’s stance appeared to be that it would be best to wait and see what happens after we leave EASA and that the CAA are looking at alternatives anyway. Despite polite requests for the BBAC Flying Committee to publish some sort of Manifesto on their intentions with regards to licencing following our departure from EASA nothing has been forthcoming but I did read, with a bit of a smile that in the latest Pilot’s Circular we are now told that ‘The note in the previous PC that there is a new initiative in process where the General Aviation sector may retain the national licences [in our case the PPL(BA) and CPL(B)] to use alongside the UK-EASA licences [in our case the BPL] for use on all aircraft [in our case therefore on all balloons] has caused excitement amongst some pilots. Please can we stress that the note was not an announcement of certain fact, it is advice of the start of a process of discussions which will run from the Autumn and into 2021. BBAC and CAA will look at all options for how UK balloon licences get configured for the future, bearing in mind ease and costs of getting and keeping a licence, medical requirements (a crucial point) and of licence validity outside as well as within UK. BBAC is engaged closely with this initiative with the CAA and will be working for the most flexible solution covering the needs and aspirations for all pilots and for future pilots.’ Is there a plan chaps? Any chance we might have a glance at it before it goes to the CAA? As for discussions from Autumn this year, I doubt very much that there will be any point until 2021 as the CAA doesn’t know what the true outcome of leaving EASA will be so now is the time to merely express our concerns and desire to retain the UK PPL/CPL so it is on the record when discussions start.

So, as one of the ‘excited pilots’, here is my take on why we must get on and start putting a campaign into gear to ditch the BPL and ensure we get our licences back. We’ve got time to get a presentation together to put the CAA in December giving them a heads up and this is my ten bobs worth. I don’t expect everyone to agree and welcome feedback and comment. If you are still waiting for your BPL then I do know of a number of pilots who have, or are about to, request a refund! Best of luck on that! Trusting to luck is never a good idea. I think it paramount that CAA are made fully aware of the wishes of both the sport and the industry ahead of the game so they themselves know what to plan for.

Following the exit from EASA retain the UK National Balloon Licencing system.
I would like the Department for Transport along with the UK CAA to review the UK balloon licencing requirements with a view to retaining the UK PPL/CPL balloon licences and the system that supports them once we leave EASA in January 2021 and also to ensure that they can be fully legally maintained for the next couple of years at the least. As a result of the Pandemic and Brexit legislation needs, the validity of the PPL/CPL have now been extended until late 2023. With the UK leaving EASA on January 1st 2021 it would be very straightforward to move back to, or rather not move away from, a UK National Balloon Licence System.

There would be minimal influence on legislation and requirements if the EASA/UK BPL is adopted.
Following the UK’s departure from the EU and EASA all UK issued pilot licences, whether called a “BPL”, “CPL(B)” or “PPL(B)” will be UK national pilot licences and none are, or will, be afforded any automatic recognition by any EU/EASA member state. If the EASA/UK BPL follows EASA pilot licencing in the future, by way of changing UK law to “mirror” changes in EU law, we would have no involvement whatsoever, nor influence, in the development of any future changes. Thus, UK ballooning will have transitioned from being the most influential state within EASA to having absolutely no influence whatsoever. The single EASA/UK BPL licence is complicated.
With the introduction of the EASA/UK BPL there will be three UK balloon licences all of which are fundamentally ICAO compliant. Exemptions from some of the restrictions of the BPL are still being negotiated. Each exemption sought is to bring the BPL more into line with the old existing UK Balloon Licencing System. Why bother? The UK PPL(B) and UK CPL(B) are already fit for purpose and allow two separate licences one at PPL level having a much ‘lighter’ touch and one at CPL level where more oversight is expected. Why put all that effort into changing the BPL into what was the existing UK PPL(B) and CPL(B) licence when it is already, and sort of remaining, in place. The BPL as single licence is hard to understand, difficult and costly to manage and does not work.

The UK PPL(B) and CPL(B) are the most sought after and respected ballooning licences worldwide.
Existing UK national balloon licences have always been recognised as the world leading balloon pilot licences, particularly the UK CPL(B), which is considered the world’s number one commercial balloon licence and has been highly sought after by many non-UK nationals. It has been copied by many countries throughout the world and is the first-choice licence for local verification by third-party states (of which the UK will be once we leave EASA). Many overseas pilots have trained for them as the preferred choice. Commercially this will be a serious loss for existing and future CPL pilots and the industry worldwide.

The EASA/UK BPL will prevent holders of UK National Licences from flying G-reg EASA TCDS balloons in the UK and the EU.
Although available, and re-issued, to existing holders it will not be possible to train to get either of the two old National licences or train for a larger CPL balloon group in the UK or Europe as the BPL requirements has the EASA caveat that within EASA countries you cannot fly EASA type rated balloons on a UK National licence despite it being ICAO compliant. The largest size (currently under revue) for a UK Annex1 balloon is currently 105,000cu.ft., paying passengers cannot be carried and training on an Annex1 balloon is prohibited. If, of course, you go outside the EU then you can fly your G-reg balloon on your old licences, just not in the UK which isn’t in the EU. How on earth did we get that as a deal?

Training and re-validation for the BPL will be expensive and complicated.
Training for the EASA/UK BPL involves an expensive Declared Training Organisation and a minimum of 12 training flights must be carried out  by DTO instructors. Under UK PPL requirements candidates only require four instructor flights which can prove tricky to arrange. This means that there will be a 200% increase in demand for instructor flights. Add to this that an instructor has to sign off a student prior to sitting the exams and that both tether flights (should the student want the rating) have to be carried out by an instructor this now means that 15 requirements of instructor involvement are actually required. It is likely that there will be insufficient instructors to fulfil the training and revalidation requirements at all levels. This being the case it is probable that the shortfall will be reflected in instructor fees or the need to go to an approved balloon training school. We need to keep ballooning simple, affordable and easier to access if its to attract more to the sport. The BPL categorically does not do that. The UK Commercial and Balloon Ride Industries needs to attract more commercial pilots to fulfill the demand. The BPL’s training system and conversion to larger types is expensive, drawn out, unrealistic and will not help the situation.

Medical requirements are confusing and overly onerous for Private Pilots.
If the BPL is pursued and the BBAC are successful in getting an exemption for the BPL to use the Self Declared Medical in the UK then there will be three balloon licences in the UK and three medicals to cover them. The LAPL and Class 2 are almost identical in requirements. Currently it seems that many GPs are not prepared to carry out the LAPL examination so it falls to an CAA appointed AME doctor and the consequential even higher charges. The Self Declared Medical is free and it does allow some pilots who would not meet either the LAPL or Class2 medical to continue flying with no safety implications. To fly outside of the UK and EU countriest then a Class2 medical will be required. The LAPL is only valid in the UK and EU. We cannot have any influence over the LAPL medical requirements as we are not in the EU and won’t be in EASA.

Training for the UK PPL(B) and CPL(B) would still have to be in place and run alongside the BPL requirements.
As the UK National Licences will remain in place there will still have to be support for them. This will mean having two training systems along with instructor and examiner qualifications remaining in place. This is likely to remain the responsibility of the BBAC. Can they run two systems without increasing, or applying, additional charges which will, by definition, be much higher for non-members? If the BPL is retained then it is unlikely any UK PPL/CPL examiners will be able to afford to remain in the post or there be sufficient students for them to remain current. This is all irrelevant anyway as you cannot train on an Annex1 balloon. Any training for a UK PPL/CPL on G-reg EASA type-certified balloons will have to take place outside of the UK and the European Union.

Converting back to the UK National Licences will reduce costs.
Under the BPL licencing system a Delegated Training Organisation (DTO) is required at all levels from training to re-validating your BPL. There are insufficient trainees for anyone else to set up a viable DTO so there would be no competition in pricing for services. The majority of work carried out by the BBAC in this respect is currently by volunteers. The British Balloon and Airship Club is already having to pay for, and manage, a DTO. Once fully operational the management and day to day running of such an organisation will need a full time, probably salaried, Chief Training Officer. If the old system was retained fully then the payment for the privilege of a DTO and associated costs could be removed or hugely reduced.

There would be minimal cost to the CAA
The British Balloon & Airship Club are retaining the existing PPL/CPL training and instruction procedures and, if required, the BBAC Training Officer is in a position to fully re-instate them. At UK PPL level the written examinations could still be carried out by the CAA appointed examiners. At CPL level it would probably remain in the control of the CAA but could possibly be delegated. There would be no appreciable cost to the CAA to simply re-instate the old system and licences.

It makes no sense to run two licencing systems and three sets of medical requirements for balloons when the opportunity exists to run one.
With the old National Licencing system remaining in place, retaining the BPL seems unnecessary. The old system is tried and tested and accepted worldwide. It is not complicated or onerous. Its credibility and the opportunities it affords are attractive to both prospective pilots and existing ones, both at home and abroad, looking to take up ballooning as a hobby, fly advertising balloons or make a career in the Balloon Ride industry.

There you go then. My take on it, but I do believe it is the right way to go now we are leaving EASA and we have now been afforded the chance to, at least, put together an Agenda and Manifesto and put it to the CAA with a view to retaining the UK PPL and CPL licence system. Should opinion show that the BPL is favoured then so be it. ‘Can’t stop progress’ they say. Luckily John built a balloon so I’ll buy that and keep wobbling through the sky on me PPL. If you wish to let it be known that you would like to see the old UK PPL/CPL licences re-instated please drop a line to the CAA and the BBAC Chairman. Please feel free to circulate this. Please be aware that discussions probably won’t start until next year so please politely state your concerns, wishes and any suggestions you may have. Thank you.

Richard Allen Richard.Allen@caa.co.uk
Paul Spellward chairman@bbac.org
Chris Dunkley chrisdunkley@compuserve.com

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