Balloon Working Group Recommendation Paper 1
Work Strand 1 – Commercial Balloon Pilot Licensing
Provided you’ve got over having to join the BBAC DTO and become an Assistant Instructor to partake in training up your daughter for the Basic licence then have a gander at this lot.
This paper and the proposed set of questions, plus the way it has been arrived at, is the most confusing, as far as you can get from simplification, and may well set back Part-BFCL for quite a few years if challenged hard. Of the Specialist Subject Experts in the Working Group only two have any ‘expert knowledge’ of Commercial Ballooning, especially passenger flying, Steve Richards,Chairman of the Commercial Balloon Association, Cary Crawley and Ian Chadwick who, in a past life worked for the CAA looking after all things ballooning especially commercial passenger flying. Members of the particular groups they have been consulting and working with have, in the main, been very supportive of having a fully separate CPL licence as we currently have, and the tremendous amount of pressure to keep the UK styled Commercial Pilot’s Licence does seem to have finally sunk home and there is a nod in that direction from the CAA. Unfortunately less informed and experienced SMEs forming the Working Group have actually written to the CAA individually indicating, in rather strong dictatorial terms, that the Commercial part of the BPL should be ratings tacked onto the basic BPL single licence.
It is reassuring that the three proper knowledgeable SMEs in this field have finally started to be listened to and the very well respected UK CPL might just survive as a separate licence but the questions we need to be asked are not necessarily going to work to achieve that.
The UK CPL is the most respected balloon licence in the world. Always has been. I agree there may be a few shortfalls in not having a written down training procedure but there is good reason for this. With the UK PPL that evolved over the years and because the road to a basic licence was delegated to the BBAC it has developed to meet the needs by various Training Officers, Instructors and Examiners. It all got written down sorted out and things like the Training Book got produced. Don Cameron, Bob and Carol Howe wrote training guides. The Aerostat used to publish training hints and tips along with featured articles as did Balloon & Airship magazine. The exams were set by the CAA but were, and still are, developed by the Examiners but all unpaid on behalf of the CAA who amend and publish them. The PPL exams have always been sat under the watchful eye of the examiners often in their homes.
In the case of the CPL this has always been under the total control of the CAA and despite many moves to actually write out and get published some sort of a syllabus it never happened. Lack of volunteers (the CAA wouldn’t do it) and funding being the most oft quoted reasons. Despite that there was guidance and many CPL pilots and examiners, when asked, gave practical help and training to help prepare the pilot for the check flight and exams that were set at a much higher standard than the basic PPL. There are then areas that can be improved to make the licence even better. On the flip side there are some areas of the proposed legislation that seriously compromises safety. How strange then that the basic BPL makes getting a basic licence much harder to get whilst the proposed CBPL makes it much easier to get and at the same time introduces aspects that compromises safety. One of the basic requirements for the current UK CPL is a 13 month Proficiency Check. Under the CBPL this becomes every two years. Is that safer? Please have a read through Cary Crawley’s piece Dissenting Views Part 2 to get a fuller picture.
Unfortunately, although most of it is a bit of a scrambled egg you will also need to have a read through the CAA Work Strand 1 document to get a flavour of how their consultation has arrived at the questions. Personally I don’t think there is anypossible answer that is the one we want. Links is below.
Proposed Questions contained in this paper
Possible consultation question 1 at point 30
The CPL(B) as a licence will cease to exist on full transition to Part-BFCL and commercial activities will be covered by a rating on the BPL. As regards the future of the Commercial Rating that could be added to the BPL, which is your preferred option?
For what it is worth and this is my opinion. I moved onto flying commercial balloons almost by default. Having spent sometime crashing around the commercial circuit, as it was in those days, at shows and commercial events the Hot Air Balloon Company decided passenger flying was the next step but as there was no AOC or anything then it was done in the grey area of ‘Join a Balloon Club’ and get a flight. They bought a ‘180, then the biggest balloon operating (that fact didn’t last long!) and off we went. Now the lessons learnt on the Circuit and the responsibilities that came with it like flying quite important people, checking the weather, actually planning a flight and all the logistics that went with gave me, I believe, a good solid grounding when it came to flying eight passengers at a time. It wasn’t long of course that the Balloon Ride Industry got into full swing and legislation was rightly introduced to improve and ensure the safety of passengers.
I like the idea of a single Commercial Licence covering both aerial work and passenger flying that both educates and ensures safety should you be flying Heads of State, Company Directors or employees of your sponsor, tethering in the dark or flying much closer to limits, when to recognise and counter commercial pressure put on you and ‘performing’ in front of crowds at ballooning specific commercial events and of course flying paying passengers. Good grounding here makes you a much better pilot as you move onto passenger flying, should you so choose. Legally, in many cases the same disciplines apply, load sheets, flight time limitations and the problems of flying in controlled areas. By all means allow students wishing to fly commercially to enter at lower hours on small balloons, sit the exams and get a CPL. Further hoops have to be jumped through to get a rating to fly larger balloons full of passengers once you get a CPL so I see it as natural evolution.
Loosely speaking currently (and there are caveats) to get a Restricted UK CPL covering Aerial Work but not passenger flying you need 50 hours, and to get an Unrestricted Licence you need 75 hours. For both ratings under the licence you need to sit the CPL exams, take an examiner flight test and carry out two tethers. Depending on the hours you have you can go straight for an Unrestricted licence. So apart from hours both the Restricted and Unrestricted Licence have the same requirements. Even if you choose to go for an unrestricted licence you will still need to fulfil further requirements before you can fly passengers.
If you look at the possible questions they are not very clear. Answer ‘A’ is for a single commercial rating in Part BFCL which is a cover all rating hooked onto the basic licence. This doesn’t come across as a stand alone licence just what Part BFCL is already proposing. The second ‘B’ suggests two separate rating tacked onto the basic BPL which is not really any different but what would the differences be? Not enough information to decide. Answer ‘C’ is rubbish and a trick question do not to press as we know what we want. Basically not enough information is provided to form any answer so that leaves the Do have any comments?/dissenting views’ box. My answer would be keep the Commercial Licence separate.
CAA Possible answers
A. A single Commercial Rating in Part-BFCL as is currently in place. All commercial operations can be undertaken with that one rating and there remain appropriate requirements for CPB privileges within the rating.
OR
B. Two separate commercial ratings as follows:
~ Commercial Passenger Ballooning (CPB) rating; the holders of which would be able to conduct CPB and any other commercial operations; and
~ Commercial non-passenger operation rating; the holders of which would be able to conduct commercial operations except those involving CPB.
OR
C. No view/don’t know
Dissenting view
How much more complicated do they want to make this? Retain the basic UK Part 2
Why not one separate commercial licence not attached to the basic BPL. You could call it a BPL(C) that would cover both non-passenger flying commercial operations (aerial work) with progression to passenger flying or, with higher entry hours, directly into passenger flying which would also cover commercial/aerial work. Oh, that’s what we have. Don’t let the CPL(B) cease to exist on full transition.
Possible consultation question 2 at 42-44
Do you agree with our approach of introducing into the licensing regulation a 100-hour PIC experience requirement as a prerequisite for CPB privileges?
Now thing is that I see no problem in upping the hourly requirement but what are the aerial work requirements going to be. There is reference to this in Cary’s piece. An answer ‘Yes’ applies to Part BFCL. It could apply to the current UK PPL. 50 hours is far too low and less than the current 75 hour requirement. How can that be an improvement. I think I am going to have to use the dissenting views comment box.
Possible answers:
- Yes
- No, prefer Part-BFCL to remain unchanged at 50 hours.
Do you have any comments?
Possible Consultation question 3 at 45-47
Do you agree with our proposal to introduce a stepped minimum number of PIC hours of CPB flying experience in the previous hot-air balloon size group before conducting CPB flights in the next group, in addition to the requirements for progression to the group under BFCL.150(b)?
Well the reason for this question and perhaps an excuse for answering it is a covering your bum question is that BFCL.150(b) is represented in this bit buried at the bottom of point 32. The requirements for experience in progressive hot-air group sizes are not adequately covered in a CPB context. Under current regulations, a pilot could qualify in larger balloons in accordance with BFCL.150(b), but have limited demonstrable experience carrying passengers in those larger sizes. If I even begin to understand this then it means BFCL.150(b) is not a good thing. The more you get into this the more daft it gets. Yes we do already have that provision in the UK CPL with a check flight with a Flight Examiner for each group progressed although hours are recommended before .moving up a grade they are enforced by Examiners. There is room for improvement in the current CPL structure. I did check the proposals in Table 1 but it does is difficult to interpret. Cary raises some sound points on this in his piece.
What did make me laugh was that under ‘Dissenting Views’ the CAA are asking for the opinion of the qualified SME’s. This is what they are supposed to be doing so one can only assume that perhaps they have finally realised some of the SMEs are not that qualified. That is most certainly is the case.
Go on then let’s have a laugh and highlight the reduction in safety of the CPB by answering ‘No’. Not really. They ask the same question later at Point 68, but add good old safety not conscious 150(b).
Possible answers:
- Yes
- No, prefer Part-BFCL to remain unchanged
Do you have any comments?
Dissenting view
What is the opinion of the qualified SMEs? This is a CAA question – Really!
Possible Consultation Question 4 at Point 65-70
Do you agree with our proposal to introduce mandatory commercial operations ground school training covering elements of both CPB and non-passenger commercial ballooning, ahead of the skills test?
Keep calm. This is nonsense and a serious step backwards from the mandatory CAA CPL written exams. Does this mean no exams, instead a day course with boxes to tick or quite what? I think you will find that to gain a UK CPL students have to study in quite some depth in order to pass the ‘set much higher’ CPL exams. Who will provide this? Who will write the syllabus? A DTO, the CAA, a qualified person? What qualifications would the operators of a DTO require to carry out ground schools for a CPL? Far too confusing. Take a while to sort that lot out. Now with little or no material to base your decision the possible answers are amazing. I think the Comments box should be used to the full here. It will be termed ‘Dissenting views for sure.
Possible answers:
- Yes
- No, prefer Part-BFCL to remain unchanged in this respect.
Do you have any comments?
Possible Consultation Question 5 at Point 68
Do you agree with our proposal to retain the stepped minimum number of hours for each hot- air balloon group size, and introduce an additional minimum number of hours in CPB operations stepped for subsequent groups, as described above?
Is this deja vu? In the question at point 45 it asks ‘Do you agree with our proposal to introduce a stepped minimum number of PIC hours of CPB flying experience in the previous hot-air balloon size group before conducting CPB flights in the next group, in addition to the requirements for progression to the group under BFCL.150(b)?’ Told you. Depends on what answer you chose for the answer to Question at point 45. Anyway I take it ‘above’ refers to the highlighted bits under BFCL.215 Commercial Operation Rating at Point 59 (d)1? How truly do you interpret that lot. Best check with Cary on that one.
Possible answers
- Yes
- No, prefer Part-BFCL to remain unchanged in this respect.
Do you have any comments?
Yes I do. If you answer ‘No” does this mean we are left with 150(b) which we may have answered Yes to in question 3? Some serious dissenting required
Possible Consultation Question 5 At Point 81-83
Do you agree with our proposal to remove for CPB pilots the optional nature of a proficiency check with an FE(B) every 2 years (the proficiency check becomes mandatory)?
Seriously? Whether UK CPL or CPB increasing the proficiency test from the current UK CPL 13 month period to 24 months is really a serious step backwards with regard to safety considerations. Table 3 is worth a laugh as it compares the current requirements with the proposed one. No need to answer either use comments to have a hissy fit using the word ‘safety’ frequently.
Possible answers:
- Yes
- No, prefer Part-BFCL to remain unchanged in this respect.
Do you have any comments? Yup many see above safety considerations ignored.
Possible Consultation Question 6 at point 84
Do you agree with our proposal to introduce a requirement for CPB pilots to undertake ground refresher training every 5 years?
Good addition for either CPB and UK CPL. but this needs defining and who will be responsible for setting the syllabus and who will be authorised to conduct such training? Remember that the answers only apply to the Part BFCL CPB so, yup, its use the Comments box.
Possible answers:
- Yes
- No, prefer Part-BFCL to remain unchanged in this respect.
Do you have any comments? Probably I’d stick an answer here.