Or perhaps there is an opt-out ability that is being invoked by some but conveniently ignored here.
There is a “national safety case” opt-out, I believe, for all these EASA regs.
It seems to be very rarely used but it is what France invoked to kill the advertising of cost shared flights. No doubt a suitable search term would find that one, but one of the locals might know it right away. I think it was somewhere here
There is also a thing which here in the UK was referred to c. 2008 as “equivalent safety case” clause which the CAA said they would invoke to continue the IMC Rating (the IR(R)) indefinitely. That issue is now kicked into the long grass, both by the EU having bigger fish to fry and by Brexit itself which means the UK will not be automatically bound by EU directives.
A single person can start a “school”. We discussed it here some months ago.
This is possible now. I know a one-man EASA Part M Subpart G. The man has appointed his family to the various required positions 
But it probably isn’t economical because one FI can bill only a certain number of hours per day – there is 24 max and he has to sleep at least 4 of them… The CAA fees and other establishment fixed costs necessitate that you have several FIs working, and you skim a % off their billings to pay for the fixed costs.
The US system involves NO PAYMENT TO THE FAA OR ANYBODY ELSE. A CFI can work totally freelance. Then a totally freelance DPE does the checkride.
Peter wrote:
So, what are they paying the 20k for? It cannot be approvals to train Joe Bloggs in his plane.
Well, unreasonable fees by the local CAA are not EASAs fault, are they? And it depends what is included. For instance, the regional authority charges somewhat around 70€ for issuing a license. Normally the new pilot pays that fee directly to the local authority, but if you add this up to the ATO-fees, you might get to some amount for an active organisation. But other than that I’d be hard pressed to get anyway near that amount of fees for our ATO. So it can’t be EASA.
alioth wrote:
So is it possible for a completely freelance instructor (not part of or associated any organisation FTO, RTO, whatever – in other words “sole trader”) to train someone for an EASA PPL? In other words, exactly like a freelance FAA instructor in the USA?
You said you wanted EASA to accept a freelance system can work and they have understood, accepted and amended regulations. They are just not in effect, yet. But with a DTO you just declare how you will instruct and everything is fine. You need to build up or get your curriculum at some point anyway, especially if you work with more than one student or the student works with more than one instructor, so there must me some form of documentation of the training.
alioth wrote:
Similarly, can you now maintain an EASA aircraft type indefinitely, without ever seeing a CAMO or any other type of organisation, using only a “sole trader” engineer who has no association with any kind of organisation? In other words, exactly like a freelance A&P/AI in the USA?
Not yet, but Part ML will allow one-man-companies, essentially the same as a freelance A&P/IA. But to be honest, most aircraft can be released by the pilot/owner after the maintenance tasks and within a CAMO you only need a physical review all three years, so why get a 66-CFS every year unless you have a repair to sign off?
chflyer wrote:
In this chain there were separate entries stating that NCO is only implemented in the UK, and that NCO is only implemented in Norway, and not in effect in many places. I have no idea where NCO is really in effect across Europe, but it IS implemented in Switzerland:
That is a matter of timing 
Some countries like the UK and Norway implemented Part-NCO before the deadline of August 2016. This thread started before Part-NCO went into effect everywhere
chflyer wrote:
or citing references, but I would find it useful if there were a bit fewer inaccurate statements of “fact”. Simply qualifying a statement with something like “I believe” would make it clear that the statement is an opinion or belief, not a fact.
I admit I am sometimes too lazy to look up the exact reference that I have posted 10 times prior, especially most of my EuroGA browsing is from my phone. I believe that gives others the chance to set me straight
EuroGA is a good source of information but at the end of the day it is up to you to determine whether what is written is correct, or what advice makes more sense to you, although anything positively wrong will be pointed out relatively rapidly.
LeSving wrote:
I’m only observing the results. The results are visible all over.
Funny though, that your observations don’t match reallity. Not in Germany, not in the UK and not even in Norway. My Norwegian is somewhat limited but I managed to find this: http://www.luftfartstilsynet.no/selvbetjening/utdanning/Statistikk_over_flygersertifikater_for_fly_A
The number of PPL(A) licenses have increased from 1594 licenses in 2000 to 2165 licenses in 2011, when EASA published and implemented the first steps towards easier rules. So in the heydays of goldplating the number of licenses increased, only to decrease again violently to 1461 PPL(A) and LAPL(A) licenses. So your claims don’t correlate to the numbers. My guess is that EASA isn’t that big a factor overall. I did not manage to find figures for microlight licenses though.
In a tiny pilot population like the Norwegian, all possible effects can be reason for huge relative changes. It would be interesting to hear from other norwegian pilots about the real flying environment without Anti-EU and Anti-EASA prejudice.
Peter wrote:
So, what are they paying the 20k for? It cannot be approvals to train Joe Bloggs in his plane.
To be truthful nothing. You are paying for a load on manuals to sit on a shelf that nobody reads. At an ATO for every license or rating that you want to teach for you have to produce appropriate manuals and these then have to be approved by the CAA.
PPL, LAPL, CPL (single engine), CPL (multiengine) all require approvals
as does
Night, SEP, MEP, TMG
FI, FI (night), FI (aerobatic), FI, FI, CRI
Also on top of this you have the approval fee for the simulator which isn’t cheap.
The direct fees to the national aviation authority are over 20 grand a year. Fortunately the guy that runs the place has over the years drawn up all the manuals himself and is able to update them each year when a different ops inspector attends and decides that he/she doesn’t like something. For any new organization wanting to get approve its often cheaper and quicker to employ at retired ops inspector to write the manuals for you.
Its simply because of this huge outlay that the ATO I am familer with will not train in peoples own aircraft – They have to get that money back somehow and their profit margin is greater in their own aircraft.
mh wrote:
But with a DTO you just declare how you will instruct and everything is fine.
Not quite it allows you to undertake some forms of training but not all.
CPL, BIR, CBIR MEP and all FI course are not allowed.
mh wrote:
My Norwegian is somewhat limited but I managed to find this:
Jolly good show, mh!
What is interesting is that the same trend seems to apply to ATPL and CPL as well although I did not compute the relative numbers.
chflyer wrote:
I use the forum as a source of information about what is happening across the European landscape, and statements of opinions as facts leads me to take a lot of such statements with a grain of salt and not sure what really to believe. But I suppose that is a general problem with modern social media.
I never believe anything unless some kind of reference is shown, or I have previously seen similar results, opinions or I simply know stuff, logic reasoning etc. It has nothing to do with social media, it’s just media in general, society. It is everyone’s responsibility to decide for himself what to believe or not, and to what extent he need “proof”. I wouldn’t have it any other way.
Peter wrote:
The US system involves NO PAYMENT TO THE FAA OR ANYBODY ELSE. A CFI can work totally freelance.
mh wrote:
you wanted EASA to accept a freelance system can work and they have understood, accepted and amended regulations. They are just not in effect, yet. But with a DTO you just declare how you will instruct and everything is fine. You need to build up or get your curriculum at some point anyway, especially if you work with more than one student or the student works with more than one instructor, so there must me some form of documentation of the training.
FAA authority over instructors and their students extends to broadly lining out minimum training requirements prior to a check ride: e.g. number of logged hours, completion of solo cross countries and night training for private (etc). Then FAA examines the student through designees (DPEs) to uniform FAA published practical test standards. The instructor makes no payments to FAA, and in addition is not required to document his training & individual teaching methods, or report them to FAA or anybody else.
mh wrote:
Part ML will allow one-man-companies, essentially the same as a freelance A&P/IA
Nobody who signs off maintenance on my FAA certified aircraft has a company or is paid significantly on any books, or paid at all in many cases. An A&P/IA is not required to form a company, one man or otherwise. That would be a huge extra burden.
mh wrote:
It would be interesting to hear from other norwegian pilots about the real flying environment without Anti-EU and Anti-EASA prejudice.
Believe it or not, so would I. Don’t know where you get anti-EU from though. I voted YES for membership, but the majority voted NO, nothing I could do about that I am kind of anti-EEA, a treaty that has served us good economically (for the same reasons EU membership would have), but it’s like selling your soul to the devil (you will get filthy rich – buut)
mh wrote:
Funny though, that your observations don’t match reallity. Not in Germany, not in the UK and not even in Norway. My Norwegian is somewhat limited but I managed to find this:
Good job You have to look at the full picture though. There is very little data around, particularly for microlight. Already at 2009, PPL activity were at an all time low.
Looking at the activity from 1994 to 2009, the activity for “motorfly privat” and “motorfly klubb” (PPL, private and in clubs), had shrunk by approximately 25%. Mikrolett (Microlight) had already in 2009 become almost at the same level as private PPL. This was 8 years ago.
Then, I have plotted all the new issued licenses from “your” data (no new LAPL has been issued):
The average at 2000-2003 is about 150 per year, then it is steady at 120 until 2012, and it drops to hardly above 60 per year from 2012 and further. 60 per year is nothing, even in Norway with only 5 million people. It should be at least 150-300 if the number of PPL is to stay constant. This can be seen in the total numbers of active PPL:
Besides, I’m not against PPL mh, I’m not against certified aircraft. It just looks to me that EASA is. Edit: I should rewrite that to: It looks to me that EASA is even more against certified aircraft than I am
