Mission Aviation Fellowship

Does dual licence training work?

In the post-Brexit era, commercial pilot cadets training in the UK are now facing the conundrum of whether to train towards a UK licence; to train towards an EU licence; or whether to maximise their future employability by training for both. With a growing number of UK schools offering dual training programmes, cadets are now able to train towards both licences at the same time, but is this a realistic challenge to be undertaking and how are cadets coping with the additional workload?

To the surprise and dismay of many (and one can likely include the UK Civil Aviation Authority in this group), the UK terminated its membership of the EU Aviation Safety Agency (EASA) on 31 January 2020, despite repeated assurances from within Government that the UK would remain an EASA member state; or at least become a signatory member with voting rights removed in the post-Brexit world. That didn’t happen though, and it ended up being the hardest of all possible Brexit scenarios for the UK aviation industry. In the early days following Brexit, the general consensus was that UK Government would see the light and a political solution would be sought to allow the UK to retain EASA membership, but nearly two and a half years on the UK remains isolated from the wider European aviation community. Having adopted EASA regulations into UK law on Brexit day, the two aviation systems continue to be largely aligned. Nevertheless, the fact remains that to fly for a UK-registered airline a pilot now requires a UK licence, while to fly for an EU-registered airline a pilot requires an EASA licence, and a much sought after (in the UK at least) mutual recognition of licences has yet to be achieved.

“It’s not a matter of opening doors, but rather ensuring that we’re not closing them”

With the global airline industry hamstrung by COVID for the last two-and-a-bit years and with airlines only now just starting to recover as the pandemic eases, recruitment of new pilot graduates has been at very low levels, although there are now encouraging signs that this is starting to change. It is understandable therefore that cadets graduating in a tough marketplace will want to maximise their employability and many are therefore choosing to get dual rated. As Dan Watt, a recent dual EASA/UK fATPL graduate from FTA-Global puts it: “It’s not a matter of opening doors, but rather ensuring that we’re not closing them”.

UK pilot training academy FTA-Global, based at Brighton City Airport on the UK’s south coast, was an early adopter of dual licence training on their integrated fATPL programme and a number of cadets have now completed their training. FTA holds both UK and EASA training approvals and this dual approval allows them to train cadets simultaneously towards both UK and EASA licences, although this approach has increased the student workload. Cadets first need to gain two Class 1 medical certificates, although having access to a dual-rated Aeromedical Examiner (AME) can mean that it’s still only one physical examination. These AMEs are registered with the CAA and, in this case, the Irish Aviation Authority, although any EASA Member State will do. A cadet can then commence their training. The next step is the ATPL theoretical knowledge ground school, which FTA completes over a nine-month period. The standard ATPL theory programme requires passes in 13 ground exams, but this has now doubled to 26 for the dual training programme. Fortunately, there are a number of EASA exam centres in the UK, eliminating the requirement to travel into mainland Europe to sit the exams, but dovetailing those with UK exam sittings remains a logistical challenge, FTA confirms. Head of Training Phil Jones reports that cadets aren’t finding it too much of a challenge sitting exams twice, especially while the Learning Objectives of both training programmes remain aligned. In fact, students are often finding the second sitting less stressful after having already proven to themselves that they can pass the first set of exams.

 …why would EASA choose to play ball if that may mean taking business away from its member states?

The flying training programme then commences and aside from having to undergo two Instrument Rating (IR) flight tests there is no change to the academy’s standard fATPL flight training programme. Cadets do also need to gain two Commercial Pilot Licence (CPL) skills test passes, but FTA is fortunate in that their two resident examiners, Phil Jones and James Piper, are both dual rated, holding UK and EASA examiner qualifications and so cadets need only to pass a single CPL skills test for both licences. Where it gets slightly more complicated is that while EASA allows schools to use in-house examiners for the IR flight test the UK CAA doesn’t. For the UK IR flight tests therefore, FTA uses third-party examiners, but Phil and James are permitted to carry out the EASA IR flight test. Both the UK/EASA CPL flight test and UK IR flight test are conducted out of FTA’s Brighton City Airport base, but the requirements for the EASA IR flight test throws a new spanner into the works. EASA requires this IR test (and a prior acclimatisation flight) to be conducted in EU airspace, which of course now excludes the UK (being in Eurocontrol doesn’t count, apparently). The UK Aircraft Owners and Pilots Association (AOPA) has suggested to EASA that this could easily be rectified by changing the wording of the relevant regulation from ‘EU airspace’ to ‘Standardised European Rules of the Air (SERA) airspace’, which the UK continues to comply with. Unfortunately, it appears that there is little political will to do so at the moment and, on the face of it, why would EASA choose to play ball if that may mean taking business away from its member states? The upshot is that UK schools now need to deliver the EASA IR flight test elsewhere in Europe. By virtue of their south coast location, this isn’t too much of a burden for FTA, as it’s only a short flight to enter French airspace and so FTA are now conducting their EASA IR flight tests out of Le Touquet. Other UK schools based further west are meanwhile heading to Ireland for EASA IR flight tests, while those more centrally located are having to partner with other EASA approved schools in mainland Europe.

Dan Watt was one of FTA’s first dual licensed fATPL graduates

According to Phil Jones, conducting EASA IR flight tests in France during the pandemic added an extra challenge, as COVID rules meant that they weren’t allowed out of the aircraft on arrival, so pre-test jitters necessitating a trip to the airport’s restroom facilities were a no-go. In the post-pandemic world that restriction has ended, but Phil says that timing of flight tests still remains a bit of challenge at Le Touquet, due to Gallic dining protocol that results in the nation shutting down each day to enjoy a 90-minute lunch break.

So, having weathered the Brexit storm and gained dual approvals, is the new dual licensing system working for FTA?

“While it’s fair to say that it was little short of a nightmare getting through the Brexit period, due largely to the fact that no one – not even the CAA – seemed to fully believe that the UK would actually leave EASA, we worked tirelessly to ensure that our cadets were kept up to speed on developments and what their future options might be,” said Phil Jones.

“Initially, we were advising cadets to train towards an EASA licence, but it soon became apparent that dual training was an equally viable option and so we took the (expensive) decision to become dual rated. We managed to achieve this early on and it’s clear that this addition to our training programmes has been vindicated. Cadets are managing to cope with the extra exams and flight tests with little issue and, thanks to our location and dual examiner status, we’ve managed to absorb the extra cost burden placed on us, meaning cadets are still paying the same fee as those on single licence training programmes. The dual training programme works well, and we highly recommend it.”

And from a cadet’s perspective, are they finding it manageable?

FTA graduate Dan Watt told FTN: “It was a no-brainer switching to a dual licence training programme and I’m certainly glad I did it. Doubling-up on ground exams and flight tests may seem daunting, but once you’re immersed in the day-to-day training the reality is that it made little difference to me and, arguably, the extra work has improved my overall skills set. While the automatic right to live and work in the EU no longer applies to UK citizens and this may impact my ability to be based in mainland Europe, I’m nonetheless confident that holding both licences has increased my chances of securing my first airline position. In the interim, having dual licences is proving invaluable in my current flight instructing job [Dan has recently joined FTA’s instructor team] as I’m able to instruct on both licence systems.”

Another school offering dual licence training is Leading Edge Aviation (LEAL) based at London Oxford Airport. At the time of writing, LEAL has graduated three cadets who now have dual licences, have a few others who are currently waiting for their licences to be issued, and further groups of cadets who are partway through their training.

Graduate Ash, pictured receiving his dual licences from LEAL Head of Training Steve Rees FRAeS

LEAL has partnered with the Danish National Aviation Authority for the EASA licence element of their dual training programme and report that it is working well: We have strong contacts within the Danish Authority who have been very helpful with answering any questions we may have regarding the licence,” they told FTN.

Like FTA, LEAL is also choosing to conduct their EASA IR flight tests out of Le Touquet: “As part of the standard dual training package with Leading Edge Aviation, cadets undertake an acclimatisation training flight in European airspace. For most students this is a great experience and typically involves flying from Oxford to airfields in Europe, often in France, to undertake a series of approaches and landings. Once you have passed your UK IR, you then take another IR, for EASA, in European airspace and this involves a ferry flight to and from Le Touquet, with the exam starting and finishing in Le Touquet, and an approach in Lille.”

…the high price of UK CAA CPL and IR flight tests is a particular ‘bug-bear’ of the Independent Flight Examiners and Instructors Association (IFEIA)

Some schools, by virtue of their geographical location and having dual-rated examiners on their books, are managing to absorb the extra cost burden placed on them when running dual licence training programmes. Others, possibly located more remotely, are having to charge extra in order to cover the added expense of partnering with an EASA-approved school to get them to conduct the EASA IR flight test. FTN understands that the average cost increase when undertaking an integrated dual licence training programme compared with a single licence programme is in the region of £5,000. It’s not an insignificant amount of money, but when compared with the overall cost of an integrated training programme, priced at close to £100,000, it’s a relatively small price increase. Any cost savings, however, are of course desirable and the high price of UK CAA CPL and IR flight tests is a particular ‘bug-bear’ of the Independent Flight Examiners and Instructors Association (IFEIA).

IFEIA told FTN: “The costs of initial CPL and IR flight tests, rather like petrol, is at an all-time high and it won’t be coming down. Interestingly, it has kept pace exactly with inflation over the last twenty years, which is more than can be said for the fees examiners receive for conducting them.

 “This is despite CAA costs reducing with the closure of test centres, the reduction of employed CAA flight examiners and the introduction of the ‘authorised examiner’ [industry examiner]. More interesting perhaps is that the CAA takes 66% of the new £850 test fee for itself and just 34% is paid to the examiner.

“For a partial test, the split is even more exaggerated. IFEIA has been arguing against this situation at a recent meeting with the Authority, which maintains that the costs of running flight test bookings (from home) is considerable. The fact that flight tests in the UK are at an eye-wateringly high level, coupled with the fact that examiners used to be paid half the test fee, seems to be ignored or perhaps forgotten.

“European flight test fees are far cheaper, leaving the candidate with change from £500. IFEIA reminded the CAA that the fee should represent only the true cost of providing examiners and not cross funding other parts of the Authority.”

FTN asked IFEIA to conduct a poll amongst its members to get a snapshot of how many dual rated instructors and examiners there are in the UK and we are currently waiting for the results to come in. We are aiming to publish the figures in the next edition, but what does appear to be apparent from initial feedback we’ve received – and this is particularly apparent in the UK helicopter flight training industry – is that the cost of retaining examiner ratings compared to the income received is making many question whether it’s still worth it.

Returning to dual licence training programmes, it seems that the UK commercial pilot training industry is coping well with the regulatory change thrust on it and that as long as UK and EASA fATPL training programmes and Learning Objectives remain aligned then the extra burden placed on schools and cadets is not insurmountable. What seems to be of vital importance therefore is for the UK CAA to ensure that this close alignment of training programmes remains firmly in place, if cadets are to have a fighting chance of obtaining two licences in a timescale and at a work rate that was previously designed for just one.

Author: FTN Editor

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