It’s time to simplify the UK’s arcane and messed up pilot licensing system
29 June 2022
By my reckoning there are maybe 11 people in the UK who fully understand Flight Crew Licensing as it applies to private pilots. The trouble is, there are probably only two or three of them who work for the CAA!
If you don’t believe me, try asking anything other than a plain vanilla licensing question of the CAA. Replies take ages and, better still, different people will get different answers to the same question at different times.
I have a lot of sympathy for the people at the CAA trying to administer the current system, and they must be as excited as we are to see the much-promised, all-encompassing licensing revamp that will deliver something worthy of the UK’s ambition to be the best place in the world for General Aviation!
Before trying to put right what we have, it’s probably worth looking at how we got ourselves in this mess in the first place.
I can see the appeal of blaming EASA, JAA or the CAA, but it takes a lot of work by a lot of people over many years to get something as impenetrable and illogical as this.
An awful lot of people, overwhelmingly with the very best of intentions and not always from within regulators, have fiddled and exempted and suspended and introduced over the years to create the not-so-well-oiled machine that we are currently operating.
Everyone’s fought their corner, but it doesn’t look like anyone with a cohesive and progressive strategy has been paying attention.
The mess we have has been good for many individual pilots, but simplicity was fatally injured and passed away long ago.
The good news is that the CAA assures me the consultation around the new licensing system is on the way and imminent.
“An awful lot of people have fiddled, exempted, suspended and introduced over the years to create the not-so-well-oiled machine that we are currently operating”
So I spoke to a couple of Subject Matter Experts (SMEs), neither of whom work for the CAA, to see what they’d suggest fixing. You probably won’t be surprised by their pragmatic suggestions…
Their first suggestion is that we should make continuous progression throughout licensing possible. A continuous skills-based pathway from all flavours of NPPL to the PPL.
I know that sounds radical, but hey!, if we (well, EASA) can create a Competency-Based Instrument Rating surely we ought to be able to do the same elsewhere?
Then it was suggested that we remove some of the now meaningless licensing constructs like Part 21 and non Part 21, FCL and non FCL (come on CAA, you know it makes sense for all of us).
One of the SMEs talked about the restriction that means PPL instructors can only teach for the LAPL if they have CPL theory passes.
ICAO only calls for CPL level knowledge, and this could be assessed at the initial FI Assessment of Competence, completely removing the complexity of LAPL-only instructors (and go some way to resolving the feast and famine that flight schools experience when airlines are hiring).
There was also quite a lot of comment regarding the revalidation of ratings and privileges where we have different requirements for different licences leading to different interpretations from Class Rating Instructors (CRIs), Instructors and even Examiners.
Both SMEs believe that something similar to the US system could work well. The FAA Flight Review (it used to be called a Biennial Flight Review) is one hour of ground training and one hour of flight training with an instructor.
At the end of that time, and only if satisfactorily completed, the instructor will endorse your logbook. It has to be done every two years, but if you had a break from flying and want to return, whether after 25 months or 25 years, all you need to do is the training required to complete a satisfactory flight review!
How simple and understandable would that be?
The CAA does not have an easy job. We’re all experts (well, the two SMEs I spoke to are real experts, most of the rest of us, including some regulators, just think we are) and simplification will take vision and humility, neither of which are qualities that have been omnipresent in aviation regulators.
On top of that, it has to be done in such a way that doesn’t deliver unintended consequences or ground those who are flying happily now.
It also has to be done in a way that can be simply explained, understood and followed.
Go on CAA, you can do it… if you ask I’ll let you have the names of the SMEs so they can lend a hand…
2 comments
Nit-picky I know, but the 1 hour ground and 1 hour flight time you mention are minimums, not definitive. It lasts as long as it needs to. And that’s the beauty of it. If you are (for example) poor at landings, it turns into a lesson until you meet the standard. Simples!
Some time ago the FLYER forum crowd-sourced, via unquestionably competent and knowledgeable Examiners (so not me!), a peer-reviewed table showing combinations of licences and Ratings, in order to act as a single reference source for Revalidation by Experience. Not in the table, but behind the scenes, it also had references to the definitive legislation.
On two occasions I offered that material to CAA FCL representatives to act as the basis of an official and managed CAA resource, but to no avail.
(To be fair, I likely made the offer to the wrong person!) Of course, if Ian’s suggestion was taken up then there’d be no need for such an unwieldy tool, but at least it might have helped in the interim.
A similar tool could be developed for other parts of the licensing mess, if the will was there.