Work Strand 2; Instructor and Examiner requirements for Instructing and Examining pilots seeking the Balloon licence and/or ratings.
I’ve read the title quite a few times and it actually makes no sense. Must be me. Before we get into the swing of things please bear in mind that you do need to have this editorial ad the CAA Work Srand 2 open side by side to appreciate the beauty of the efforts made. tend to print off the WorkStrand and have it on the side but you are probably a lot more competant than me in dual tasking.
Of all the changes proposed this is nearly the most complicated and I don’t pretend to understand the theory of the arrival at the changes the CAA are proposing. Cracks are appearing that is for sure. Despite what is written in the report there has, apparently, been a lot of disagreement between the SME’s. Now a lot of this probably comes from the fact that there is such a strong case and wish to retain a totally separate Commercial Balloon Licence such as we now have under the Air Navigation Order. It is certainly true that there are only three truly experienced SMEs in this field.
Extensive discussion has taken place with the experienced Commercial Balloon Association’s members and pilots through Steve Richards and Cary Crawley. It is worth a read to appreciate the rather abrupt tone put forward by the CAA. It is really quite disturbing in places. Their choice of words and phrasing is not what one would expect of a professional organisation. The best bits are in the discussion points concerning the appointment of Assistant Instructors. At point 29 they use the term ‘rebuttal to’. Who would say that unless they were, confrontational, dictatorial or simply frustrated? Surely the words should be ‘counter argument’? We thought ‘Dissenting views’ was pretty off piste but this paper takes derogatory wording a step further. When the CAA state in point 43 ‘The objection to this recommendation held by a minority of the working group’, this is because those that truly know what they are talking about are in the minority. Come on, really! It appears to me, that more and more the CAA are intent to rush this through with as little regard as possible to the wishes of balloonists, their views and recommendations of the true experts. Simplification this is not. Not anywhere is any simplification actually going to appear. In almost all cases the proposals are going to increase costs for everyone. Then, let’s not forget, all this lot is going to be managed by a Declared Training Organisation planning, organising and monitoring the noble art of balloon training. Instruction in General Aviation is done in regional flying clubs organisations based on an airfield that can be managed. True, some sort of oversight is probably inevitable whatever route is taken, but the vast majority of balloons fly from their own launchsites which themselves are subject to change. How exactly do the CAA expect a DTO to plan to ensure that a trainee pilot receives their instructor flights at the due time or is ready for their first or final instructor flight? How will this work? Now, with me head cleared of that I wonder why the function and operation of DTOs in connection with balloons isn’t a Work Stream all of its own? This commands further investigation, especially into the options available.
What is confusing that under Part-BFPL, if you read the Work Stream 3 document, the CAA option is to have a separate Passenger Flying Licence or rating (for want of a better description) attached to the basic BPL to carry out commercial work (aerial work) not involving fare paying passengers. Now this paper is about appointing instructors and examiners to conduct training and examination/renewal flights, not how to get a BPL(C). If you are an instructor or examiner it may be that you would like to move to the next level. Where exactly are these levels defined? Do we need a gentler route up the licence ladder? What the CAA haven’t decided yet is whether they intend to split the passenger and aerial work ratings. Does this imply that they need to have three types of instructor and examiner? That would be those rated to re-validate Assistant Instructors, those that can instruct at FI level and Examiners at PPL level and those to sort the aerial work rating and renewal. Drat! forgot the Passenger Flying Instructors and Examiners and a rating for those that can revalidate all those that can Examine. That’s more then three then! Simpler not. There are even more complicated processes to discuss buried in this lot I’m sure.
It does appear that no logical progression in the deliberation on the licensing ladder is taking place. Surely before the route to getting the licences, and how the system works, should be discussed after you have decided which licences or rating you want to end up with are. If this had been done there may be some very different questions. It would make it a lot simpler. Apologies, that is not in the CAA’s vocabulary.
If you have no desire to become an instructor or examiner then I would suggest you let them do their worst. If you want to teach a student to fly it is looking likely that you may need to become an Assistant Instructor so you may need to read that bit (good for a laugh) and comment on the process involved if it is only to say ‘it isn’t necessary’. An Assistant Instructor will be in this grouping so will need to be checked on a regular basis by someone else, examiner or instructor, depends really what will befall us as a result of questions not actually asked. How are the FIs going to be able to carry out such checks if 200 pilots decide to become Assistant Instructors. Answers on a postcard. Of course, we could always insist we retain the old system.
Both Ian Chadwick and Cary Crawley have some pretty fundamental views on all this so it may be worth cross-checking to help form an opinion.
Before you et very brave best you have the Working thing open so you can cross-reference.
There are quite few bits that don’t add up once you start trying to refer back to the requirements. A few are hi-lighted here and the Possible Questions looked at. Ths could go on for reams but this is the essence. Please make your own mind up (if it survives).
Point 13 – The working group took the view that the general instructor requirements as currently set out in Part-BFCL are appropriate and do not require any change. I ask then, ‘So why bother?’
‘You will have to have an appropriate BPL licence and rating to instruct in the area you want to’. The list of ratings you are going to need to pass on your valuable experience will mostly mean many will not bother especially when there is likely to be a fee and annual renewal.
Point 15/16 Seems that there is agreement that training to be an instructor or examiner does need reviewing and improving. I don’t disagree with that. Mention is made of tethered flying and Night Flying to come under the umbrella of such training and be applied and that instructors and examiners should have a minimum experience both as pilot-in-command (PIC) and line flying in the group(s) they intend to examine or train students. But that is what happens now?
Some of this gets tangled with the basic BPL licence requirements, then a rating permitting the flying of passengers, another for aerial work not involving flying fare paying passengers and a stand alone Commercial Licence (the best option in my opinion). Where are they going to put advaced tethering and Night Ratings and will tere be dedicated Instructors for such ratings?
Again please remember, this is how to gain and maintain instructor and examiner ratings, not getting a basic licence. It is also the case, as with all the other papers and questions, the proposed answers only apply to the BPL and the ‘additional rating’ system. If you don’t want to become or retain Examiner or Instructor ratings under Part BFCL then you if you have an opinion you could easily be termed ‘a dissenter’ and would need to just use the ‘Comments’ box. We’ll do a bit of a summary when we have all four papers out there.
Possible consultation questions
Do you agree with our approach of requiring instructors intending to instruct on commercial ratings to undergo specific training, along the lines of what is already required for tether and night ratings?
Possible answers:
- Yes
- No, prefer Part-BFCL to remain unchanged
Do you have any specific views on what should be covered in the training syllabus?
Hey up! This translates into, “Could you write some questions for us?”
Possible Consultation Question;
Do you agree with the view that instructors for the commercial operation rating should have a minimum number of 50 hours of PIC flying in CPB operations?
Possible answers:
- Yes
- No, prefer Part-BFCL to remain unchanged
Do you have any comments? Which commercial operation? Aerial work or passenger flying?
Possible consultation question
Do you agree with our approach of introducing an Assistant Instructor authorisation, and changing the minimum required number of dual training flights and hours to be undertaken with a FI(B) to at least 4 hours and 4 flights (instead of 12 hours)?
Possible answers:
- Yes
- No, prefer Part-BFCL to remain unchanged
Do you have any comments?
An example of how the proposed answers do not allow the possible preferred answer. Answer of ‘Yes’ suggests that if you want the BPL without all the flights being with an FI then you get the Assistant Instructor rating lobbed in. If you answer ‘No” then you get rid of the Assistant Instructors but all the flights have to be with an FI. So you will have to make a comment. Go with Part-BFCL but stick with the four FI flights and ditch the Assistant Instructors? Just insist on retaining the UK PPL?
Possible consultation questions
Do you agree with our proposals to increase the requirements in Part-BFCL for examiners undertaking examining to pilots seeking Commercial Passenger Ballooning privileges to bring them more into line with the ANO requirements they will replace? Namely:
- Increase the minimum experience as PIC in balloons from 250 hours to 500 hours (slightly less than the ANO CPL(B) currently requires, to apply to all examiners);
- Introduce a minimum 200 hours experience as PIC of CPB operations (when examining for the commercial operation rating and for commercial passenger ballooning proficiency checks);
- Introduce a minimum 100 hours experience as PIC of CPB operations in the hot-air balloon group size being examined (when examining for the commercial operation rating and for commercial passenger ballooning proficiency checks).
Possible answers (repeated for each bullet point):
- Yes
- No
Do you have any comments? (Not repeated)
This is wondrous. Consider all the questions separately and you can answer ‘Yes’ or ‘No’ to all of them separately but you can’t comment on all them separately? That is what it says. How does that work then. Must have been going home time when they got to this one.
Possible consultation questions
Do you agree with our proposal to increase the requirements in Part-BFCL for examiners undertaking examining in an additional balloon class by requiring a minimum of 25 flights and 50 hours of flight time as pilot on that additional class?
Possible answers:
- Yes
- No, prefer Part-BFCL to remain unchanged
Do you have any comments? Seems a tad low.
Possible consultation question
Do you agree with our approach to reword the regulations on the assessment of competence for examiners so that:
The CAA shall appoint, where required, Senior Examiners that are specifically authorised for assessments of competence of FE(B)s and oversee their validity, revalidation and renewal.
BFCL.445; BFCL.460 FE(B)
BFCL.470 SE(B) certificate
An applicant for the SE(B) certificate should have completed 1000 hours of flight time as pilot on balloons, including, when assessing for the purpose of the issue or revalidation of examining privileges for the commercial operations rating, at least 500 hours on Commercial Passenger Ballooning operations.
- Senior Examiners, in addition to an inspector from the CAA, are the only individuals who conduct FE(B) assessments of competence, both for initial issue and revalidation/renewal of examiner certificates; and
- In addition to specific authorisation by the CAA, Senior Examiners must have a minimum experience requirement of 1,000 hours of PIC flight time, of which [for senior examiners seeking privileges to examine commercial operations candidates] at least 500 hours PIC flight time in CPB operations,
Possible answers (repeated for each bullet point):
- Yes
- No, prefer Part-BFCL to remain unchanged
Do you have any comments? (Not repeated).
Three points ‘ere then. Firstly best you check up BFCL.445 etc etc, and secondly here we go again with the one comment box? Ah so, the CAA can make the judgement on the people they appoint without seeking guidence from those that know? What could possbly go wrong? Have you lost the will/thread? Understandable.