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Rays of Bureaucratic Hope

I have spent enough time ranting over the years about European difficulties with general aviation. One can summarize my experiences as follows: high costs and airport aggravations that curtail aviation. While those are the most pressing realities in day-to-day flying, there are two other structures that have historically been in play: CAMOs and ATOs. I will preface with information about each and then get to the fact that Europe appears to have begun loosening things up a bit.

I have only alluded to CAMOs (Continuous Aviation Maintenance Organization) before. The gist I have gotten talking to various individuals is that there is no such thing as a freelance A&P. An aircraft must be maintained under the umbrella of an organization, which has requirements for lots of paperwork, manuals, quality procedures, and document retention. What I find, observationally, is that there are much less direct owners of general aviation aircraft, and a higher prevalence of flying clubs, which I presume are part of or closely affiliated with a CAMO. The more I try to research the concept, the more lost I get, so I confess some ignorance.

ATOs are “Approved Training Organizations,” which means no freelance flight instruction. Similar to a CAMO, an ATO is a procedure-driven organization where instructors operate as opposed to the direct model in the United States. As one can imagine, the net result is that things are harder and more costly, though the model tends to create a “flight academy” structure seemingly intended for the airlines, which I presume is what regulators had in mind.

Both of these constructs are a result of EASA (European Union Aviation Safety Agency), which is a creation that now has lasted over a decade. To Americans, EASA is a something of a bittersweet creation. Prior to its existence, effectively there were 28 European nations with different aircraft registers, licenses, and mechanics, operating under ICAO. That meant that Germans flew German-registered aircraft, maintained solely by German mechanics, and the like. One could see the complication attempting to rent or train in an aircraft elsewhere, to develop products for installation into aircraft, and the like, as each would have required licensure, type certification, inspection, and maintenance by professionals licensed various separate countries’ laws. For a period, JAR (Joint Aviation Regulations) existed, which were a precursor to EASA. I won’t get into them as they are obsolete.

EASA created intra-European recognition of aircraft registration, instruction, licensure, operation, and maintenance. With my EASA pilot certificate obtained a few years ago, I can walk in and rent a plane anywhere in Europe, without requiring license validation. I can take aerobatic training in Switzerland, or work on float rating in Italy, while it all feeds back to my license based in a separate nation. A Spanish mechanic could work on a Finnish registered airplane in Ireland, as long as the type certificate was honored. From a European perspective, it’s a brilliant concept which caused Europe to leap forward in aviation.

EASA is not without its difficulties. Enter in ATOs, CAMOs, and many other issues that are far more burdensome than in the United States. With the stroke of a pen, regulations spew out of Brussels that bind an entire continent into policies and procedures, good and bad. To Americans, this is not necessarily a model to pursue, as it is a union of national aviation authorities, whereas we just have one in the USA (imagine 50 state aviation agencies bound together under one umbrella). The primary difference is that electoral influence is all but moot. If a regulation from EASA eliminates the viability of a small business in Bulgaria, what is a Bulgarian member of parliament going to do about it in Brussels? Most likely nothing. Nonetheless, Europe has different points of origin, and one must remember the interoperability of the European aviation system, which is a benefit. It appears, from my point of view, that EASA initially followed maintenance and training models that worked well for the airlines: lots of manuals, procedures, quality inspections, and the like. For scheduled carrier flights, it works fine. In fact, local airport menus of fees, operating hours, and other procedures work just fine for airlines. If one knows that a flight will land on August 8th at 7:57PM, then it’s easy to plan in advance for whatever rules are thrown at the airline.

That doesn’t work for the freedom of general aviation, including private business aviation (which is comparatively much smaller in Europe than the USA).

On that note, I would like to point out some changes that have come down the pipeline for general aviation. This is the good side of EASA, where with the same stroke of a pen, change is brought into effect across an entire continent.

In 2019, “light” aviation mechanics licenses came into effect, called B2L and L-license. Prior to this directive, it is my understanding that a mechanic was licensed in a variety of categories – think “A” for airframe and “P” for powerplant – instead it is something like six verticals. To make it more complex, a mechanic would be type rated as would the repair station, with makes and models of airplanes, down to light aircraft. These new licenses are meant specifically to ease up on general aviation, changing to “systems-based” licensure, where a mechanic could work on light aircraft in certain areas (avionics, for example). More is hopefully to come in this light.

Part-DTO. With the stroke of another pen, Approved Training Organizations are no longer necessary for private pilot, LSA (LAPL in Europe), balloon, and sailplane instruction activities. Instead, a solo flight instructor files under Part-DTO with their national aviation authority, announcing the intent to undertake light aircraft instruction. Rules and requirements are much less than before, though it isn’t to the same level as the United States.

Cost-sharing flights. About two years ago, I saw some fanfare about EASA permitting cost-sharing flights, including the ability to advertise them in public online platforms. It appears that it was legal for quite a while, and some of the information I read indicated that it took a bit of time to filter into each country based on how certain air regulations propagated. Nonetheless, this is a highly rare instance where Europe is more flexible than America, allowing public advertising of private non-commercial flights, where similar pro rata cost sharing is allowed. The intent is to aid general aviation pilots to fly more hours and stay current.

After all of the shock, horror, fatigue, indignation, and now resignation after four years of flying in Europe, I figured it was time to give some credit where it was due, recognizing progress that EASA and Europe has made for general aviation, and can only hope that it continues. As an American, I am personally supportive of the existence of EASA in Europe, as I feel it’s the smartest answer to what would otherwise be 30 or more national aviation authorities creating a web of conflicting rules. I do suppose it is food for thought that what binds international aviation is the ICAO, created in the 1940s in the USA. That has formed the backbone of our basic international aviation ecosystem, and we can only hope that cross-border flying is something that can be improved.

Garrett Fisher is an aerial adventure photographer, having photographed some of the most rugged and wild terrain in America from his 1949 Piper PA-11. After living in Germany with the Cub, he recently moved to the Spanish Pyrenees to continue the flying adventure. He has published six aerial photography books covering the Colorado Rockies, Wyoming, high terrain in the Southeast, and the Outer Banks, with more US and European books in the pipeline. He blogs regularly about his flights at www.garrettfisher.me.

1 Comment

  1. Part of the systemic fault of EASA is that unlike the FAA it does not consider itself a service organization for pilots. EASA essentially makes rules and maybe monitors the outcome, but these rules are applied by 28+ national aviation administrations, some of which are more lenient or strict than others. I recently looked for something in the AIM and marveled at how a government organization like the FAA manages to publish a document that is practical and understandable, something which cannot be said of the three-tiered rules that govern European Flying. (Rules consist of IR = implementing rules, CS=certification specifications, AMC=acceptable means of compliance plus occasional GM=guidance material, forcing the reader to look up three to four sections of text to find out what to do). To be fair EASA is trying to standardize the way rules are interpreted nationally, but lacks sufficient power and mandate to do so. Unless Europe decides to change the EASA into a Euro-FAA things are unlikely to improve substantially and even that would not solve the problem of accountability as everything but IR is essentially published without political governance, accepted at a time when CS dealt with technicalities of aircraft certification like strength of bolts but highly problematic when the essence of e.g. flight time limitations or training requirements is covered there. Other impracticalities concern ‚synchronization‘ as e.g. EASA changed a syllabus outlining training requirements before taking a check ride, but the forms required are published nationally and don‘t reflect such changes (plus examiners need to be able to work with 28 different forms).

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