Answering your questions on the GA licensing consultation

Alex Blomley 0:00

Hello, and welcome to the CAA's General Aviation podcast. And today we're bringing you a bonus edition podcast talking about our recently launched licensing and training simplification consultation CAP 2-3-3-5. Now this was published a couple of weeks ago. And since that time, we have had a number of comments and questions raised that we thought we would have a chat through today. So we've invited Laurence Baxter back into the studio. Thank you for joining us, Laurence. And we thought we can maybe have a little chat through some of these comments and queries that have come up, and help put some of this into context. So thank you again, Laurence, for taking time to come and speak with us today.

Laurence Baxter 0:36

Hello, Alex. Really nice to be here again. And thanks for having me.

Alex Blomley 0:40

So it's great to get the consultation out over the line. And that's been out there in the public domain. Have you received any immediate feedback on how it's been received by the GA community?

Laurence Baxter 0:50

Well, very good feedback, actually. time of recording first two weeks is the consultation, we've had over six hundred responses, which is great to see the community expressing such an interest in this project.

Alex Blomley 1:02

Thank you that Laurence a fantastic response indeed. And really, really good to hear that so many in the GA community have voted with their pens, as it were. And I've mentioned we've had a few questions and comments. And I thought we could spend a bit of time talking about that today. And for those of you listening at home, who may be in two minds as to whether or not it's worth your while completing that consultation, we absolutely stress that you do so. And I wanted to first talk to Laurence about whether we could share any more information on the GA community experts that you and your team have been working with when drafting this consultation. I know we've talked before about a working group. And I wondered whether you'd be able to share more details on that working group, how it came to be, for example, and how it influenced you and your colleagues in drafting this consultation paper?

Laurence Baxter 1:41

Sure, no problem at all? Yes, we've been using experts within a working group, something we do is pretty much the standard nowadays, when we're doing a major policy exercise like this is to convene a working group of key GA community experts to give us ideas and to basically enlighten us on the specific details that are going on in the community to help us develop a more proportionate set of regulations. So we did that for this. One of the first things we did when we launched this project just over a year ago now was create a working group pulling together experts from across the GA communities. So I'm talking about aeroplanes. sailplanes balloons, all the key associations that cover those areas sent an expert to this working group. So we've had representation from the fixed wing airplane community, the microlights, the light aircraft and home built aircraft community. On the balloons side, we've had not just the main balloon, airship community, but also the commercial ballooning side, and the panel of balloon examiners. Meanwhile, on the sailplane side, the gliding association. So in addition to those long experienced experts, we also thought to bring in some fairly new people to this sort of regulatory consultation process. We brought in two trainee private pilots who are undergoing their training, or recently completed their private pilot training to get an idea what their own experiences were. In addition, we also brought in an instructor, someone from the instructor community and a seasoned instructor examiner. So all these people helped us pull together ideas. Now, we didn't always agree with each other. It was a quite a animated discussion, shall I say. But that's exactly what the policy process is all about trying to get an understanding of what the issues are, and then trying to develop proposals, to help us develop proposals that are set out in the consultation.

Alex Blomley 3:39

I think it's really important to stress here that this really is a cross GA undertaking that you've been doing. I mean, as you've said, the working group for this was pulled together over a year ago. And despite sometimes comments and criticisms that we don't really engage with members of our community. I think this project shows that we actually do. And it's great to hear that you've had representation from the community for quite a while, while this project has unfolded.

Laurence Baxter 4:05

Most definitely, we're really trying to get away from this approach of just going away and coming up with proposals ourselves, then asking the community in a consultation. Our idea is to involve people in the community from the very start before we even put pen to paper on the consultation. Now, there are always animated discussions, and there are always views that might be diametrically opposed. And that's where our job is, as the CAA comes in to listen to those views, and then try to set out the best approach forward. Now I know, sometimes it results in proposals that not everyone in the working group, particularly likes, that's absolutely fine. That's the way this process has to work. This is a public consultation so the idea is to take views from the different communities, develop proposals ourselves, we put pen to paper And then put that out to public consultation. And then from there, we will reconvene our working group, perhaps going into more detail as we look at the next phase of this project. And we might bring in more experts from other parts of the community, but to actually think about the specific details that are involved in the next phase of this consultation.

Alex Blomley 5:23

Thank you for that, Laurence. And I think before we move on to some other thoughts that we've had, I think it's worth here, reminding everybody of something that we talked about in our first podcast on this consultation, which was that this really is the first phase of what we think will probably end up being three phases, three consultations that will have to be done in order to get to where we hope the new GA licensing structure should be and what it should look like. And it'd be great if you're able to go through what those three phases are, because I think it will really help explain some of the comments that we've had, if that's possible.

Laurence Baxter 5:56

By all means, Alex, this is really, really important. This is not a one and done exercise. What we've published here is merely a high level kickoff, setting out a broad direction of travel, or a very complex and multifaceted project. This is why you absolutely have to have multiple phases in this because there's just too much there. This first consultation sets out the broad direction of travel, what we're doing strategic direction, the type of architecture. It sketches out how we would see the broad licensing architecture working in general aviation going forward. It also sketches out some proposals on what the different levels of licences could look like. And then also asks if we go away and make changes to the regulations what do you do about the existing licenses issued under the system that we're going to change? So that's the first phase, that's just the first phase. The next phase, we need to actually look at the detail this will be the devil in the detail phase. Phase two, after this constitution is finished, will be really the meatiest part of this project. Because having set out the broad direction, and sketched out the broad international licences, national licences, so on, and how are they going to integrate with each other, we need to look at the actual licences, ratings and certificates themselves, we need to look at training syllabuses, we need to look at the requirements. And not just a single set of requirements, we've got to look at them all for the different aircraft categories involved. Whilst there's some common ground between the aircraft categories, it's actually very little. In fact, there are quite a lot of unique aspects between aeroplanes, helicopters, gyroplanes, balloons and sailplanes. So as a result, we're going to look at those specific parts, bringing together as many experts as we can find on this so that we can put together a set of proposals, that's just phase two. Then consult on that, as we did this time, and then we move to phase three, which is the actual legislative changes, we'll have a list of policy proposals and we will then start looking at how we would change the regulations themselves to implement that. And something we're going to keep very firmly in mind in phase three about the legislation and communication is how to make the regulations as understandable and as accessible as possible. I know there's a need for a lot of legalese text in the regulations. But how can we possibly make it so that the regulations are a little bit easier to understand, so you don't have to be a regulatory expert to read the regulations. And then we're going to find better ways of communicating those regulations so that you don't have to be completely versed in how the CAA works in order to understand our licensing system. We want people to be experts at flying, not regulation. So the idea is to make it as clear as possible. And that's what phase three is all going to be about. So there's three phases here, a big project over several years.

Alex Blomley 8:53

So yes, it's a big project. And I think it's really important that everyone is aware of that. And I think it's really useful to set out those phases as you've done. And it does relate to a lot of the comments we've had about revalidation and renewal procedures, questions around how existing sub ICAO licences will be carried over. Quite meaty, quite detailed questions and thoughts that have been raised thus far. And is phase one the time for people to be suggesting those things, or is it a bit premature? What are your thoughts on that?

Laurence Baxter 9:20

Well, absolutely not, actually, I really welcome these sort of comments, because it really helps us sort of formulate a list of the things we really need to think about. I mean, I know we have a pretty long list already of things we need to look at in phase two, but I always welcome points. I'm very open to anything that we may have missed. So if you have thoughts about what we should include in phase two, by all means I want to hear them.

Alex Blomley 9:40

So really, I suppose the message here is to treat this consultation as an opportunity to share any ideas, any thoughts, any suggestions, previous examples and working examples that we're aware of and use this as an opportunity to get those messages across to us?

Laurence Baxter 9:54

Absolutely right, Alex? And I think a key watchword for this whole process is this is a once in a generation opportunity to have a major sort out of GA pilot licensing. We started this because of the need to consolidate the regulations after we left the European system. However, we see this as an opportunity to say okay, well what best suits the GA community or GA communities, the aeroplanes, helicopters, balloons sailplanes, gyroplanes. So this is an opportunity to really have a major sort out. And also people are a little bit tired of all these changes in regulation, changes that have been going on every couple of years, I'm sure many of us would like to see this done. And that's exactly what we were trying to get this done once and hopefully not be back here again in a few years time doing it again. And hence, we need to actually think about some potentially radical changes, we're used to operating within the EASA system. Now we're not part of EASA, its our toybox now we can do what is necessary for our community. So we can look to best practices in other jurisdictions,

Alex Blomley: 11:01

There's something else that comes up from time to time. And it's not just relevant for this particular consultation, but for other pieces of work that we do at the CAA as well. And that is how much we do or don't collaborate or even discuss our ideas and policies with other jurisdictions. So often, there's the criticism that we should follow what the FAA does in the US, or that we should be more relaxed, like some of our European counterparts, for example. And I am interested to know how much of a cooperative or bilateral review you've done with this consultation in respect to other jurisdictions,

Laurence Baxter: 11:30

Definitely, that's very much a part of this process. The CAA already has a team that deals with bilateral discussions holding formal, bilateral discussions with other National Aviation Authorities and other jurisdictions, it's increasingly important since we've left the the EASA system, but also we have informal discussions that extend into to GA. We also on a routine basis, look at best practices in other jurisdictions, whether it's in the context of this particular project, but also in other areas that we deal with from the GA unit, looking at responses to other issues, or occurrences, accidents, and so on. So we do have that ongoing relationship and in the context of this project its particularly important, because we're already active on the international level in the context of the International Civil Aviation Organisation, the various parts of that system, in which the CAA has long been very active. But we also look at how other ICAO member states comply with the international requirements. And there are some interesting ways they do it that we can perhaps think about looking to as an example. There are different ways to do it and we often get asked, for example, in our events at general aviation rallies, and fly ins and things, people come into our marquee and ask us well, why do they do it that way over there? Why can't we do it this way over here? It's a very frequent question we get asked. And so this is why we want to look at this properly this time, and possibly explore how it can be applied to the UK situation.

Alex Blomley: 13:02

Thank you for explaining that Laurence, I think it's really helpful to have that understanding shared with everybody. And thank you for joining us and going through some of those comments and queries that we've had. And just remind everybody, the consultation is still very much alive and well, as we've been talking, it will be closing on 16 of December. So there is still lots of time for you to read through. We appreciate it is a weighty document is 47 pages. But as Laurence has said, it is important that we get the detail across to you all so that you have the opportunity to be able to read through and then complete your submission online. But we've also had, I think it's important to share, some really good positive commentary on the actual submission process, it's been reported that it takes approximately 10 minutes to do, it's very easy. It's very straightforward. So please don't think that the actual act of completing and submitting your response is overly burdensome, because it's not. So once you've had the time to read through the consultation, go online, it's all online, it's very easy and straightforward to use as the form of an online survey. And with the click of a button, your responses are through to us, which is great. So yes, 16 December is the date to work towards. We will include all the links to the consultation and our web pages for supplementary information at the bottom of this podcast in the podcast notes. And we look forward to reading all of your responses. And I guess, Laurence, that's going to be the next job for you. Once the Consultation closes going through all of those responses and I suppose organising them.

Laurence Baxter: 14:24

Yes, definitely. One of the first things we're going to do following the closing of his consultation is analyse the responses and we will produce what we call a consultation response document (CRD) which will summarise the results of that and the next steps. So we're looking forward to receiving the comments and reading them. Please do send them in, any thoughts on your mind about suggestions, things we're doing right, things we're doing not so right. I want to hear them. This is the feedback process. And I look forward to getting ideas as well. I'm looking forward to hearing some suggestions. No comments are bad comments in my view.

Alex Blomley: 15:02

Wonderful. Thank you again, Laurence for your time, no doubt, I'll be knocking on your door very soon, maybe at the end of the consultation period, or perhaps when you're getting that consultation response document ready for publication to have a bit of a chat about where you're at and what the next phase is going to look like. Because I think it'd be really nice to be able to kind of keep a rolling update for our listeners on how this project is going. So thank you again, thanks for your time, and no doubt we'll speak soon.

Laurence Baxter: 15:26

Pleasure, we'd be delighted to keep in touch.

Alex Blomley: 15:28

So thank you, everyone, for taking the time to listen to this bonus edition podcast on our CAP 2-3-3-5 licensing consultation. As I said, All the links are in the podcast notes. We do really appreciate all of the people who have so far submitted their consultation response to this project. And we really would encourage all of you listening today to complete the online survey and send in your submission to us. Thanks for listening.

Voiceover: 15:58

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