IAOPA eNews August 2011
IAOPA Airports Petition | ICAO PBN Comments | France Authorizes a Private Pilot Instrument Rating for Airplanes | AOPA-Malta and the Schengen Treaty | AOPA-Belize Drafts LSA/Ultralight Rules | AOPA-China Aviation Summit | EASA Part M review | AOPA-US says Government Report on Security at General Aviation Airports Misguided | Piston aircraft free of volcano regulation
Plan to attend the 26th IAOPA World Assembly Stellenbosch, South Africa, 10-15 April 2012
ICAO Annex 14, Aerodromes, provides standards and guidance for States operating international airports. However, not surprisingly, it contains no provisions for general aviation aircraft and clearly is designed for scheduled air transport activities. Further, it does not mention the concept for "public use," an important distinction for all types of operations. The Annex imposes extensive airport certification requirements for international airports, something that tends to exclude most general aviation airports, regardless of size. Finally, although not required, many States adopt many or all of the standards contained in the document for domestic airports as well, making it difficult and expensive for general aviation airport operators to comply with.
After years of requesting relief from the constraints noted above, IAOPA recently sent a formal request to the Director of the ICAO Air Navigation Bureau requesting relief from the shortcomings mentioned above and making suggestions on how to do so. In response the Director noted the issues mentioned will be added to the Air Navigation Commission work program. See the petition at http://www.iaopa.org/news/iaopa_icao.pdf
Performance Based Navigation has become a major issue in aviation electronic navigation issues because it provides standards for ensuring the reliability and accuracy of navigation equipment, particularly for GPS receivers. Unfortunately, some of the standards provided by both ICAO and other organizations, notably EASA, are very stringent, often placing the use of this equipment financially out of reach for general aviation aircraft.
Some States, notably the US and Canada, have made accommodations for the use of GPS receivers in small aircraft, opening hundreds of additional airports featuring GPS approaches. Therefore, IAOPA is working with the navigation section of ICAO to revise the standards to make precision navigation equipment readily available to general aviation aircraft during instrument flight conditions. Similarly, IAOPA Europe has teamed with the European PPL/IR group to request similar privileges from EASA.
Briefly, IAOPA asked, that States through ICAO guidance:
- Accept existing GPS receiver TSOs developed by ICAO member States.
- Permit simplified installation provisions for general aviation aircraft, relying on aircraft flight manual supplements and generic installation instructions, including service bulletins that apply to an entire aircraft family covered by a single type certificate data sheet.
- Specify that flight crews meeting training criteria similar to that shown in US FAA AC 90-105 section 9.g., authenticated by a pilot self-declaration of training course completion.
The full document may be found at iaopa.org, Current Activities.
Very few private pilots in Europe hold an instrument rating since it is very difficult and expensive to obtain. The training and ground school are conducted at the ATP level and total costs to obtain the rating may exceed €20,000. While IAOPA Europe and other organizations have attempted to convince first the JAA and now EASA to adopt an instrument rating program similar to that used in the US, little has come of the petition.
Over the past year AOPA-France and the French Federation of Aero Clubs have worked with the French CAA to devise a new instrument rating designed specifically for private pilots. It was officially announced on June 24th at the Paris Air Show.
The main features of the new instrument rating (IR) are to:
- Allow PPL pilots to take a course (written and flight training) that it orientated towards their real needs.
- Permit the PPL to fly instruments on the same basis as any other professional pilot using the same weather minimums.
- Fly IFR on French registered airplanes within French airspace.
- Permit foreign IR holders (FAA IR holders, specifically) to validate their IR on their French license.
This IR meets and exceeds all ICAO requirements for instrument flying licenses and, therefore, could be accepted by any other country that observes ICAO standards. Sources say that the new rating may be considered as a model system when EASA devises their own PPL IR.
Elizabeth Olivieri, AOPA-Malta President reports, "We are striving to continue resolving issues we have in relation to Schengen departures. We are unfortunately restricted to leave from our main Airport Terminal when flying abroad to Schengen countries with our aircraft and this causes unnecessary delays besides incurring a great deal more of expense – making it a burden on every pilot. It seems that someone within the government has made a decision in this direction (at a high level we are told) restricting us from leaving from our general aviation airfields directly. However, when we keep questioning to get this in writing no one seems to know from whom the directive came. So any ideas or assistance regarding this issue or how other countries have implemented it may be useful." Any AOPA located in a Schengen country with any insights on the issue, please send comments to Elizabeth.firstname.lastname@example.org.
Tom Wierum, President of AOPA-Belize, reports that the government of Belize has asked the association and others to assist with the drafting of light sport aircraft and ultralight regulations. This was due to the inexperience of Belize authorities with these classes of aircraft and a lack of time to develop the regulations on their own. The group's proposals closely parallel regulations for these aircraft employed by the US FAA, with minor modifications for local conditions and needs.
Mr. Wierum says, "The Belize CAA is now reviewing our work and we should have agreement from them by year end. If anyone has any suggestions regarding this subject contact him at email@example.com.
AOPA-China will hold its first meeting for the public, the AOPA-China Summit, in Beijing, 21-25 September 2011. Zhang Feng, AOPA Vice President notes, "China has quickly become the most promising future market for the worldwide general aviation industry. As an IAOPA member we believe it's our duty to provide excellent networking opportunities among high level government and military delegates, international and domestic general aviation organizations, businesses and customers. We invite you to join us during this five-day event and become a true insider of the Chinese general aviation industry."
Discussions at the meeting will be based on the theme, "2011 China Low Altitude Economic Forum."
Several years ago the European Aviation Safety Agency released a controversial set of maintenance requirements for all aircraft, known as Part M. The light aircraft maintenance requirements proved to be especially onerous and expensive. IAOPA Europe has made a number of comments regarding the negative impact of Part M on general aviation, with little effect thus far. Finally, EASA has scheduled a workshop in October 2011 to 'take stock of specific implementation issues relating to Part M in view of determining future adjustments or amendments to the applicable rules and guidance material." In support of this effort an EASA questionnaire has been sent to stakeholders in an effort to "…gather information to assist in an assessment on the impact of Part M on general aviation effectiveness and proportionality of maintenance requirements for general aviation." All interested parties may send comments to part-M-GA@easa.europa.eu; include a subject line of "WA Part-M General Aviation." Also, copy firstname.lastname@example.org and email@example.com.
IAOPA Europe Senior Vice President Martin Robinson notes, 'I am pleased that at long last our call fro a review of part M has now been heard. We look forward to a productive debate on improving the maintenance rules which covers European general aviation. This is of great importance to our members and to the overall future and well-being of general aviation in Europe."
The US Government Accountability Office (GAO) recently released a report that, according to AOPA-US, fails to accurately assess general aviation security measures, neglects to acknowledge security procedures already in place, and lacks justification for its misguided, broad-brush conclusions.
The critical flaw with the report, AOPA says, is that it does not accurately assess security risk, which comprises vulnerability, threat, and consequences. The report addresses only vulnerabilities, painting an inaccurate picture of general aviation airport security. "When misguided reports find their way into the hands of regulators there can be problems," said Craig Spence, AOPA vice president of operations and international affairs. "Thankfully Congress and the Transportation Security Administration are much smarter on the subject and will see the report for what it is – a classic misunderstanding of the issues and facts."
"The only access issues that the GAO has disclosed is its lack of access to the facts," Spence said, pointing to a 2009 report from the Department of Homeland Security's Office of Inspector General. That report says terrorist threats to general aviation are "limited and mostly hypothetical" and do not merit expanded regulation. In addition, it states, "The current status of general aviation operations does not present a serious homeland security vulnerability requiring TSA to increase regulatory oversight of the industry."
IAOPA's lobbying at ICAO level for special consideration for piston-engined aircraft during volcanic eruptions proved invaluable during the eruption of the Grimsvötn volcano in May, when general aviation was allowed to proceed unhindered across all of Europe.
During the eruption of Eyjafjallajokull in 2010, some European aviation authorities over-reacted by placing restrictions on all flights, even to the extent of banning flights by gliders and balloons. This over-reaction prompted EASA to issue guidance based on ICAO recommendations, which in turn followed suggestions from IAOPA during debates on the issue. These provide special exemption for piston-engine aircraft, which are allowed to fly in low-ash concentrations, which effectively means non-visible ash clouds. The guidance is contained in EASA Safety Information Bulletin 2010-17, which expressly covers only turbine-engine aircraft and helicopters.
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