AOPA Response to CAP3094:GA Pilot Licensing & Training Simplification Phase 3 Consultation

The AOPA response to CAP3094 has been submitted to the CAA as follows:

Q5  Do you agree with our proposed changes to the PPL(A) syllabus regarding partial loss of engine power?: Yes

Please share any comments you may have: Partial power loss should be discussed prior to first solo, but should be handled as total loss of power until completion of circuit consolidation.  Students would be unlikely to be able to deal with partial power loss until completion of Ex 16.

Q6  Do you agree with our proposed changes to the PPL (A) and (H) syllabi regarding the use of moving map devices?: Yes

Please share any comments you may have:Training should also include action in the event of the failure of a moving map device in flight and the use of alternatives/back-ups.

Q7  Please enter any comments you may have on the NPPL(A) to PPL(A) theoretical knowledge bridging requirements.

Please share any comments you may have: NPPL(A) SEP/TMG students should normally sit the PPL(A) exams so that NPPL(A) theoretical knowledge is equivalent to EASA LAPL(A) requirements of EASA Part-FCL 'AMC1 FCL.115; FCL.120 LAPL training course and theoretical knowledge examination' in order that potential future mutual recognition of UK NPPL(A) and EU LAPL(A) is not compromised.

Q8  Do you agree with our proposed changes to the PPL (A) and (H) skill test schedules regarding the use of moving map devices? Yes

Please share any comments you may have: Skill Test should include action in the event of degradation / failure of optional moving map devices and the use of alternatives/back-ups.

Q9  Do you agree with our proposed AMC1 to the revised FCL.210.A regarding crediting previous aeroplane experience towards the PPL(A)? Yes

Q10 Do you agree with our proposed GM to the revised FCL.210.A regarding crediting previous aeroplane experience towards the PPL(A)? Yes

Q11 Do you agree with our proposed AMC to facilitate a 35-hour PPL(A) course? Yes

Please share any comments you may have: We agree, but consider it unlikely that many applicants will be able to cope successfully with a 35hr course.

Q12 Please enter any comments you may have on the proposed GM for differences training.

Please share any comments you may have: In GM1 FCL.710(b), delete 'training'.

Q13  Do you agree with our proposed AMC1 and GM1 to the revised FCL.740.A? No

Please share any comments you may have: We partly disagree:

3.2 first bullet point should be amended to ‘Six hours of flight time must be flown in the second year of validity’ for clarity and should be as stated in OID 157-1-12 FCL.740.A(b)(1)(ii).

AMC1 FCL.740.A(b)(1)(ii) is directly from EASA AMC and GM to Part-FCL Issue 1, Amendment 13 and is OK.

GM1 FCL.740.A is excessively verbose for inclusion in UK Part-FCL. The section from “It is recommended [...]” to “[...] from personal experience.” is directly from EASA AMC and GM to Part-FCL Issue 1, Amendment 13 and is OK; however the section from “The following is [...]” to “[...] TEM and decision making” should be deleted and moved to a suitable CAA Standards Document. The bullet point which starts “If the instructor considers [...]” should be amended so that “[...] does not need to[...]” reads “[...] should not [...]”.

Q14  Do you agree with our proposed AMC2 to the revised FCL.740.A? No

Please share any comments you may have: It should not be stated that refresher flight training should normally be conducted as a single flight. As flight time experience can now be spread over 24 months, it would be reasonable for pilots to elect to receive refresher flight training as suits them throughout the period. Both bullet points should be deleted and the following inserted:

• The refresher flight training for the purpose of refreshing knowledge and skills applicable to the privileges of the rating may be satisfied by receiving instruction totalling at least 1 hour, which may be over the course of several flights. In this case, the instructor may only certify the training in accordance with FCL.945 after the required flight time has been completed.

Q15 Do you agree with our proposed AMC3 to the revised FCL.740.A? Yes

Please share any comments you may have: We agree only as a temporary expedient pending formal amendment of FCL.740.A(b)(1)(ii) to include the IMCR/IRR exemption introduced over 15 years ago in LASORS2010, so that it will then read:

“— refresher training of at least 1 hour of total flight time with a flight instructor (FI) or a class rating instructor (CRI). Applicants shall be exempted from this refresher training if they have passed a class or type rating proficiency check, skill test or assessment of competence in any other class or type of aeroplane or by a flight test for the issue/revalidation or renewal of a UK IMC / IR(R) rating.”

This exemption is widely applied throughout the industry and it is imperative that it remains so. If it is not possible to include it in the forthcoming 1^st October 2025 SI release, then an ORS4 exemption should be issued.

Q16 Do you agree with our proposed AMC and GM to the revised DTO.GEN.240 and ORA.ATO.135? Yes

Please share any comments you may have: To avoid any confusion regarding the alternative use of non-Part 21 training aircraft issued with a national permit to fly, ORA.ATO.135/DTO.GEN.240(aa)(1) should be amended to include the word ‘or’ as follows:

(1) hold a certificate of airworthiness issued in accordance with Annex 8 to the Chicago Convention; or

Q17  Please enter any comments you may have on the proposed removal of the AMC/GM listed above.

Please share any comments you may have: We agree with the proposals.