Work Strand 3 – CAA Final Draft on the basic UK BPL requirements
In view of the lack of communication and consultation between the BBAC and its members along with the vast majority of balloonists not in the BBAC, herewith the final (and really final) consultation paper that has gone to the Subject Matter Experts (SMEs), a questionable title in some cases. The result of this CAA Work Strand when it is launched, currently in February 2024, as an open consultation with a set questions and answers and, hopefully a place for comments (deemed, very rudely, as ‘dissenting views’ by the CAA) will define the future of UK ballooning. Make no mistake the cost, route to a licence and the future the ballooning is seriously compromised by some of the proposed changes. Action will be required.
Despite claims to the contrary by the CAA, outside of the examiners group and their SME Ian Chadwick and the Commercial Balloon Association and their SME, Steve Richards and Cary Crawley, there has been little or no consultation between SMEs and the ‘industry’ which includes the manufacturers, CAOs, the BBAC, local regional clubs and the ballooning community in general. Two very well supported surveys showed that over 80% of balloonists did not want any change to the (UK PPL) licensing system so why the CAA did not take the existing system and tweak it, possibly re-naming it UKBPL, is beyond comprehension. It would have saved them an awful lot of time and money. There are many aspects in all of the proposals that are seriously flawed, herewith a few in the Work Stream 3 document from which the requirements for the basic licence will come. Some are of serious concern and need addressing urgently.
For all this to make sense and get a preview of what the public consultation is likely to be unless challenged in the strongest possible way you need to click on the link below to open the CAA pdf document in a separate window.
WS3 BPL basic requirements
Instructor Training Flights
In this particular paper the various points are discussed but not necessarily with any proper consultation outside of the Working Group so we end up with ideas that have had to be altered to fit the requirement. Take basic training and that all training flights have to be with an instructor.
One of the biggest problems is the way the proposed questions are set along with the response required. Under the proposed BPL system all training flights (minimum 12hours) have to be with an instructor. Let us have close look at what is proposed and the questions we are likelyto be asked according to the Working Group.
Had a proper consultation taken place they might have realised that numbers-wise this is not achievable so a get-out has been suggested. Rather than retain current UKPPL minimum of four flights with bona-fide Flight Instructors (FIs) the new regulation for the BPL requires all training flights to be with FIs (minimum 12). With the current number of FIs this is completely unachievable. The solution they have come up with is to create Assistant Instructors (unfortunately this transcribes into AIs).
Brilliant. Now remember the title of all this nonsense includes ‘CAA Licence Simplification’ and the ‘concerns of increased cost’. You’ll need training and a rating to be an AI. All training for the new licence will have to be through a Declared Training Organisation (DTO) with related CAA fees for establishing one and management fees for the operators of a DTO.Currently and probably as a result of the low numbers of trainee pilots and that one is not required to train for the UKPPL the only one is the BBAC DTO. There is little room and no need for another to be set up at the moment If you want to become a BPL AI and are not a member of the BBAC you’ll have to join (annual fee £65.00) or pay a premium. Through a DTO you will probably be able to go on a days course, maybe online, pay some cash and get the rating added to your BPL (fee to CAA) which will probably have to be periodically renewed (CAA fee). Now you can train people but not to the same level as a bona-fide Instructor FI as in you won’t be able to sign anyone off for their flight test nor does an Assistant Instructor flight count as an FI flight. As a student you’ll still have to do four proper instructor flights minimum of four hours. Got it? You know, just a bit of an official loop-hole. It appears at point 14 (BFCL.130 BPL and experience requirements).
Under the UKPPL system you can do all your training outside of the BBAC and no involvement with a DTO is required. You may have to pay for your four instructor flights. I think that is easier and cheaper.
See ‘A BPL Instruction Arrangements’ in Work Strand 3.(minimum of four hours).
(1) 12 hours of dual flight instruction of which at least 4 hours and 4 flights with a FI(B) the remainder to be undertaken with an Assistant Instructor.
In reality the average number of training flights is around 20 flights including four FI flights. That means that a student will probaby need at least 18 AI flights.
Possible consultation question
17. Do you agree with our approach of introducing an Assistant Instructor authorisation, and changing the minimum required number of dual instruction flights and hours to be undertaken with a FI(B) to at least 4 hours and 4 flights (instead of 12 hours)?
18. Possible answers:
▪ No, prefer Part-BFCL to remain unchanged
This highlights the problem with absurd assistant instructor rating. It does not go unnoticed that many trainee pilots are training outside of the BBAC. Many pilots who do train up their crew members or syndicate members are not members of the BBAC and have no wish to be, neither do they wish to become Instructors, Assistant or otherwise. Under the UK PPL(B) there is no requirement to be in a DTO. There then is an immediate cost in having to join the BBAC DTO to become an ‘assistant instructor’. I am not convinced at all that there will be sufficient numbers of ‘instructors’ to carry out training even if they create Assistant Instructors. Why don’t the SMEs just demand that the CAA just remove the requirement?
Taking the training requirement of 12 hours then we are already getting some interesting figures. Not so simple. Based on my personal experience most students take at least 18-22 flights to get the to the finish line. Minimum flight and hours are not the same thing. Most instructional flights are under an hour. Generally 45-50 minutes. It thus now becomes even more baffling. Forgetting the full implication of that requirement and no limitation on how many years it takes to get your BPL licence, year on year there will be an individual need for (at best) eight hours dual instruction with an Assistant Instructor, which would realistically translate into at least ten flights. If the worst case scenario that we are producing 20 (CAA figure) new pilots a year then that is 200 assistant instructor flights. Now if there are 50-80 pilots a year in training (as stated by the CAA) then then that is an additional300-600 assistant instructor flights a year. These figures are calculated from CAA figures and although rolling numbers it is a yearly figure being quoted. I’ll leave you to work out the numbers of FI flights required to meet the minimum four hours. Probably be at least five FI flights to achieve four hours unless of course all flights get treated as one hour!
Next problem is where are all the AIs going to come from? Many who train their crews and friends voluntarily are not actually in the BBAC and do not wish to be. Many pilots are more than happy to assist in training flights for free. Many pilots have no wish or inclination to become any type of official instructor and certainly not wish to have the burden of renewing ratings or paying fees for the privilege. Then you have to bring the question of improving safety in training. There is no evidence that there is anything wrong with the current UKPPL requirements. I can find no evidence that the proposed system will improve safety as there isn’t a safety issue and that there is actually a strong possibility that the actual hours flown may well become more creative to reduce costs. With the higher demand for training flights it is more likely that both Fis and AIs will get little or no hands on experience. Thereare a couple of safety issues.
This is all really stupid. The existing system is fine and workable. Currently with the actual numbers training it can be hard to get an instructor flight or examiner flight according to many. What willl actually be simplified?
Already numbers of trainee pilots and BBAC membership is dramatically falling and will continue to do so if it gets harder to get a licence. If the figures are correct then all this effort to alter the training regime for the PPL is, at worse, for 20, and best for 30 future pilots per year (CAA quoted figures). I think the Panel of Examiners would dispute those figures. This, in my humble opinion, will result in a further decline in ballooning.
Where does this take us with the offered choice of answers then?
Answer ‘YES’ and you are also agreeing with the appointment of Assistant Instructors and the 4 flights 4 hours with an FI(B) (4 hours is going to be realistically probably 5/6 flights)
Answer ‘NO’ and you are agreeing to all flights having to be with a FI(B) Not achievable.
What we need is an answer to permit training by any qualified pilot plus the four FI flights. Of course you may like to see a minimum number of P1 hours before a pilot can train another (say 50)? There is no evidence to suggest that there is any safety concerns with the current training procedure. Removing the proposed requirement is within the remit of the CAA and will not affect safety or the quality of training.
If that is your wish then the only way round this is to not answer either question but put your comment in the ‘Comments’ box but beware you will for evermore be tagged as having a ‘dissenting view’.
The Declared Training Organisation question
The purpose of a DTO as laid out by the CAA is to oversee the management and training of pilots. I agree some oversight is required but here is the rub. How you do it is complicated in ballooning. Under the proposed Assistant Instructor plan the requirement is that the DTO ensures that the student pilot gets their FI flights when they are due. How exactly do you do that from an office when the student is 100 miles away or training overseas? Balloon training is not like fixed wing. There are no Balloon Flying Schools in the UK operating out of an airfield. The weather is crucial and the availability of instructors and examiners is organised between them and the student. About all the DTO can do is to ensure those carrying out the training or examining are qualified and current. The Examiner ensures the logbook entries are complete and correct before carrying out the check flight and CAA examine the logbooks before issueing the licence. Returns are made annually to the CAA by Fis and Examiners. Why duplicate the process? Periodic Training for Examiners and Instructors is already carried out to ensure standards are maintained. Examiners require a periodic check flight. What exactly is having a DTO with all the associated costs going to achieve?
The Tethering Problem
Now nip down to Point 25, seductively referred to as ‘BFCL.200 Tethered hot-air balloon flight rating’. It is proposed to delete this and chuck it in BFCL.130 BPL Training course and experience’, meaning it becomes part of the basic training for the BPL. Appearing in 25(c). Well done if you ae still here. But guess what? You’ll have to do two tethered flights under instruction. One presumably with an AI although not stated and the other signed off by a FI(B), another FI job. It will then be removed from a section called ‘BFCL.315 FI(B) certificate – Privileges and Conditions’ I really don’t understand as it seems so complicated. It appears to remove the rating permitting FI(B)s from carrying out flight instruction for ‘a tethered flight rating’. Uh? Guidance or a translation required from the CAA.
Possible consultation question
27. Do you agree with our approach of deleting the existing tethering rating from the licensing regulations and instead embedding tethering into the base BPL licence requirements?
No, prefer Part BFCL to remain unchanged.
How about just ‘No’ put it in Commercial ballooning?
Well, it used to be that tethering was the remit of the CPL, a separate licence. This has to be looked at then with ‘Work Strand 1 : Commercial Pilot Licensing’ (up in a day or two) which is going to need some serious discussion and might even delay the forthcoming Consultation Paper. Should the tethering exam be part of the requirement or is this really more to do with holding a CPL and a later additional rating (smacks of additional fee)? There are pros and cons for this. If you have a sponsored balloon, or wish to fly from a commercial event and be paid for it then it is commercial work. If you have to fly a company’s director or guests then you may not be covered by a BPL. If you add tethering to the basic license then you will need to get training in passenger and crowd management, risk assessment, Techlogs and Flight time limitations. That’s not what you need when training for a basic licence. Having a stand alone CPL is a good way to move from private flying to commercial aerial work and onto passenger flying should you so wish. To benefit most surely a stand alone CPL is the best way to do this. The cost implication will actually be no different to what it is currently under the UK CPL. I feel a dissenting view is required.
Please remember that this is what will replace what we currently have, the UK PPL(B). The most popular answer, at the moment, is to keep the old system. The CAA say that is impossible so why don’t they just rename what we have?
The biggest failing is the lack of consultation between the CAA and the Subject Matter Experts who should have been consulting and seeking opinion from balloonists. It is now a matter of serious urgency that all parties are made aware of the concerns of the ballooning fraternity.
It is very important to bear in mind that any responses should be suggestions for the questions. If we can get the right questions being asked in the consultation paper then we will have got the first obstacle out of the way.
As the vast majority have not been consulted please send any views or comments on this paper to either the two BBAC representatives Philip Howarth <email@example.com>, Ann Rich <firstname.lastname@example.org> or to me <email@example.com> and I will ensure it is passed onto the appropriate person.
The Reference in all cases for this paper is ‘Balloon Working Group Recommendations Paper Work Strand 3’.
If you haven’t received, or were not aware of, any consultation in connection with the Balloon Licensing Papers or wish to express your views on this paper please write to the CAA at <Laurence.Baxter@caa.co.uk> or <Richard.Allen@caa.co.uk>