Yes; the stuff is written by people who have no experience of drafting regulations.
To do it well you need to
ISTM that all of the above are simply missing. The stuff is written by inexperienced people. One UK aviation barrister told me that this is typical of legislation coming from this source. It is full of ambiguities and bad grammar.
And quite a lot of it is purely politically motivated, which results in a lack of buy-in from other staff in the organisation and a lack of buy-in from most European CAAs; a perfect example is the infamous dual-papers requirement if the operator is based in the Community.
Another problem is that unless you know how the whole system works, with the law, the AMCs, etc, you mostly cannot dig out the bit of the regulation which applies to you. However, that problem exists all over the place; for example with CE (EN) RF emissions/immunity regs, there are so many to choose from.
In light of this, can you really say that 1842 pages is “too long”?
Yeah, too long and with far too many regulations altogether, and with much of it really badly written. I chose a page at random just now. It includes this verbiage:
“The privileges of the holder of a flight test rating are to, within the relevant aircraft category: (1) in the case of a category 1 flight test rating, conduct all categories of flight tests, as defined in Part-21, either as PIC or co-pilot; (2) in the case of a category 2 flight test rating: (i) conduct category 1 flight tests, as defined in Part-21: — as a co-pilot, or — as PIC, in the case of aeroplanes referred to in (b)(2)(ii), except for those within the commuter category or having a design diving speed above 0,6 mach or a maximum ceiling above 25 000 feet; (ii) conduct all other categories of flight tests, as defined in Part-21, either as PIC or co-pilot; (3) conduct flights without a type or class rating as defined in Subpart H, except that the flight test rating shall not be used for commercial air transport operations. "
I rest my case.
Howard wrote:
The EASA Easy Access Aircrew Rules document (which I guess is handy to have, all in one place) is an incredible 1842 pages long. That crazy number, all by itself, tells me (and presumably many others) that the regulations are a failure.
This document includes six distinct regulations:
- Flight Crew Licensing (part-FCL)
- Medical requirements (part-MED)
- Cabin Crew requirements (part-CC)
- Rules for national authorities (part-ARA)
- Rules for ATO’s (part-ORA)
- Rules for DTO’s (part-DTO)
It also includes not only the regulations themselves but also advisory material (AMC/GM) and also things like complete syllabi for flight and ground school training.
In light of this, can you really say that 1842 pages is “too long”? The only failure I can see here is bundling too many things together in one document.
The EASA Easy Access Aircrew Rules document (which I guess is handy to have, all in one place) is an incredible 1842 pages long. That crazy number, all by itself, tells me (and presumably many others) that the regulations are a failure. The UK’s rules will be similar in total length I’m sure. Sadly, EASA and the CAA see no disbenefit to having rules that are so very complex that no casual user could possibly know where to find everything that they are looking for in concise form, nor, on many occasions understand what the rules mean.
The consequences of all this? Certainly an absolutely crazy waste of time for very many people, and also, more importantly, a large failure of the rules in terms of achieving what it is that they are meant to achieve.
…And there is no higher European or UK body with both the power and the interest to call EASA and the CAA to account.
I’ll get down from my soapbox now.
Howard
WilliamF wrote:
Published 16 Dec 2021 – A handy reference with everything in the one place…
It’s been around for years, but apparently updated the other day. Thanks for noticing. (I keep copies of the most important regulations.)
Welcome to the party 👍
Published 16 Dec 2021 – A handy reference with everything in the one place… 
Alpha_Floor wrote:
In general all of these exceptions are to be LESS restrictive than EASA, which I believe is a good thing. Are there any examples where the UK is “more” restrictive than EASA?
Strictly speaking, none of these are less restrictive than EASA, as SERA explicitly allows member states to make these kinds of changes. They are, of course, less restrictive than the default in SERA.
arj1 wrote:
… and it appears to contradict SERA/PART-NCO – ANO says (as I read it) that for any IFR flight you need a DME, while it is not the case in SERA/PART-NCO.
Yp to last year, it was quite clear that this requirement in the ANO had no legal force as EU legislation always override national legislation. Now it is not at all clear as in the UK part-NCO is not EU legislation anymore but national legislation which have adopted the text of the EU legislation.
So now there is indeed an interesting contradiction.
huv wrote:
So, nothing has really changed.
Yes, and the ORS4 exceptions to SERA continue to apply, the most important ones being:
In general all of these exceptions are to be LESS restrictive than EASA, which I believe is a good thing. Are there any examples where the UK is “more” restrictive than EASA?
