The background is a couple of AICs, this and http://luftfartstilsynet.no/regelverk/aic-n/Utdanning_ved_utenlandsk_RF_Registered_Facility_%E2%80%93_Endring_av_praksis.
In the first one Norway CAA (LT) basically say they will not approve foreign EASA training done at a non-Norwegian facility unless that facility can prove that their theoretical training is done according to 1178/2011 FCL.210 and AMC1 FCL.210; FCL.215. Then they say that candidates shall contact LT before they start their training there, because LT may not approve it. The AIC ends with a message saying LT may prolong the acceptance of the exam if they suspect the training is not according to the book (seriously)
Then, in the end of June, they published the other AIC. Here LT don’t take it a step further, but they go all in. The message is: “Candidates having done the whole or parts of the theoretical or practical education [for PPL] at a foreign RF (Registered Facility), will from the published date of this AIC, not get their education approved, and will not get a Norwegian FCL” The reason, they say, is that candidates from foreign RFs are way below the accepted standard for LT.
They basically say that all education at any foreign RF means zero when applying for a Norwegian PPL. A Norwegian RF and Norwegian/foreign ATO is OK though. They suggest candidates doing their PPL at a foreign RF to get their PPL in that country (because they will never get a Norwegian PPL).
It sounds bananas to me, but then I don’t really know the difference between an RF and an ATO. Can LT just do this? I mean legally within the EASA regime.
The second thing that is an intrinsic, but highly important part of this, is AMC1 FCL.210; FCL.215. There is one sentence there, they refer to, and translate and use in their AIC. They have translated it wrong IMO, but I’m not a native English speaker, and I have no idea what other countries do. The sentence is:
An approved course shall comprise at least 100 hours of
theoretical knowledge instruction. This theoretical knowledge instruction provided
by the ATO should include a certain element of formal classroom work but may
include also such facilities as interactive video, slide or tape presentation,
computer-based training and other media distance learning courses.
What exactly does this mean, and what is the practice for instance in England? LT take this to mean that “formal classroom work” shall be a part, but can be combined with other elements. IMO that isn’t what it say. It literally say should include elements of formal classroom work, but may also include other stuff. I don’t read this as a combination is required. The definition of “should” in this context is according to the dictionary:
“Should” is specifically used to express advisability
Formal classroom work is advisable, but no requirement. If it was a requirement, then “shall” would be used, wouldn’t it?
I have already sent an email to LT (maybe I got a bit too carried away there… ugh ) But it really irritates me. When they sailed the ship alone so to speak, before EASA, all theoretical training was done as distant media, self study and exercises by snail mail. Then this EASA ATO nonsense came, and seemingly (according to LT) a requirement for classroom work is essential, or the quality of the candidates becomes too low. What a complete and utter nonsense. If they pass the exam without the needed qualifications, then the exam is bull for Christ sake. The problem is the exam, not the lack of classroom work. And now, also foreign hours at an RF counts exactly zero to get a Norwegian PPL. I wonder what this is all about. Have LT dropped into the pockets of some Norwegian ATOs ? That is really the only plausible explanation I can find.
LeSving wrote:
What exactly does this mean, and what is the practice for instance in England? LT take this to mean that “formal classroom work” shall be a part, but can be combined with other elements. IMO that isn’t what it say. It literally say should include elements of formal classroom work, but may also include other stuff. I don’t read this as a combination is required. The definition of “should” in this context is according to the dictionary:
I take should in that context to mean must.
Well the consolation is that flying training in Norway used to be a lot cheaper than the UK when I lived there many years ago…is it still?
Easy fix. All it will take is if Norwegian licenses suddenly become sub-ICAO on the market and their tune will change real quick. They have much more to lose than anyone else (hello Norwegian pilots).
LeSving wrote:
What exactly does this mean, and what is the practice for instance in England? LT take this to mean that “formal classroom work” shall be a part, but can be combined with other elements. IMO that isn’t what it say. It literally say should include elements of formal classroom work, but may also include other stuff. I don’t read this as a combination is required.
FWIW, the Swedish authority makes the same interpretation that you do.
LeSving wrote:
It sounds bananas to me, but then I don’t really know the difference between an RF and an ATO.
A RF (Registred Facility) is a “low end” flight school under the pre-EASA (JAA) regime. RFs today are operating on a derogation and are supposed to change into ATOs. The deadline is sometime next year. By then an RF has to have been approved as an ATO or stop operating. But I guess many RFs are hoping that the DTO concept will appear before then.
In any case the Norwegian AIC will soon be irrelevant, because RFs will disappear.
Does anyone know what the timetable for the introduction of DTOs looks like right now? @bookworm?
Airborne_Again wrote:
FWIW, the Swedish authority makes the same interpretation that you do.
Good. Do you have a reference in the Swedish regulations?
I thought part of the point of EASA licence regulations that everything became “portable”. If the LT gold plating is onerous, what’s stopping someone doing their PPL in, say, Spain and simply maintaining a Spanish EASA license?
alioth wrote:
what’s stopping someone doing their PPL in, say, Spain and simply maintaining a Spanish EASA license?
Exactly my thoughts. Something must have happened at LT lately, not sure what, but I also hear stories of instructors not getting their instructor licenses re-validated because LT all of a sudden has discovered made up some obscure “EASA regulation” that no one has heard of before.
LeSving wrote:
Good. Do you have a reference in the Swedish regulations?
No, only that the Swedish CAA complained that my club school had not documented 100 hours TK and then approved that we “filled up” not only with classroom work but also with things like a visit to ATC.
