CAA aeroplane licence consultation response guidance

The number of aeroplane licences currently in place across a range of aeroplane classes mean that the aeroplane licensing consultation is complex. Reading the CAA’s aeroplane licensing consultation document will be helpful to anyone responding to the CAA Phase 2 aeroplane licensing proposals consultation.

The BGA’s focus is on sailplanes and SFCL (see BGA guidance on the sailplane licence consultation, which is far less complex as there is only one sailplane licence). However, we recognise that several of the proposed aeroplane licence changes present opportunities, while others could present opportunities but depending on the responses could also result in INCREASED complexity and unnecessary bureaucracy and cost. Therefore, we have highlighted below several relevant aeroplane consultation sections and survey questions (in italics) that clubs and tug pilots in particular are encouraged to respond to using the consultation survey (link is at the bottom of this page). Please note that these questions are not relevant to SPL TMG; they are aeroplane licence questions.


CAA proposals:

  • Discontinue issuing the UK PPL under the Air Navigation Order (ANO) as a standalone licence. Where required, we would issue a combined Part-FCL and UK PPL licence document, allowing non-Part 21 type ratings to be added alongside Part-FCL class and type ratings.
  • Reduce the qualifying experience required for the issue of a PPL from 45 hours flight instruction to 40 hours flight time, in line with ICAO Annex 1: Personnel Licensing. It is not proposed to remove any content from the existing practical syllabus.
  • Maintain the content and number of questions for the theoretical knowledge exams, but consider combining topics, to reduce the number of individual papers.

Question 5: Do you agree with our proposal to discontinue issuing new UK PPL (and higher) licences under the Air Navigation Order? BGA view: Yes. To simplify the licence system in the UK, it would be preferable to have one sub-ICAO (national) aeroplane licence and one ICAO (international) aeroplane licence.

Question 6: Do you agree with including a 35-hour PPL option for students training at an ATO under an approved course of training? BGA view: Yes. This may benefit some pilots and encourage more to learn to fly, although why limit that to an ATO and not include a DTO?

Question 7: Do you agree with our proposed changes to FCL. 210.A(a) regarding the qualifying experience requirements for issue of a PPL(A)? BGA view: Yes.

Do you have any comments on this?  BGA view: The change from flight “instruction” to flight “time” is particularly relevant for pilots wanting to use other experience to count towards obtaining a licence.

Question 8: What changes should we consider for experience crediting towards the PPL(A) from other licences, as set out in FCL.210 (b), (c) and (d)? BGA view: Work with the sailplane community to identify any changes required in terms of crediting for SPL holders.

Question 9: Where a PPL(A) student has previous microlight aeroplane flight time, should this count towards the PPL(A) qualifying experience? BGA view: Yes.

Do you have any comments on this, including under what circumstances should this be counted? BGA view: It can be reasoned that flying a three-axis controlled microlight requires at the very least an equal level of pilot skill required in other aircraft, so skills and experience acquired on these microlights should be equally as valid.

Question 10:  Which approach would you support to the theoretical knowledge exams? BGA view: Combine exams into seven, as this facilitates a flexible approach.

Class ratings

CAA proposals:

  • Revise the class rating structure to allow for emerging electric and hybrid propulsion systems.
  • Possible wider simplification of the class rating system and allow more use of differences training when qualifying on different aircraft.

Question 11: Do you agree with revising the SEP class rating to incorporate pure electric and non-turbine hybrid-electric power plants, and introducing new variant groups to the class requiring differences training, covering pure-electric and hybrid-electric propulsion systems? BGA view: Yes. Different power plants require different skills and differences training promotes safe and effective operations.

Sub-ICAO licences

CAA proposals:

  • Consolidate the current NPPL(A) and LAPL(A), reducing the number of licences that provide similar privileges.
  • More proportionate training and knowledge requirements when moving between aircraft variants and classes.
  • An improved pathway from the sub-ICAO licence to the Part-FCL PPL(A).

Question 16: Do you agree with our approach to the flight training syllabus for the sub-ICAO licence? BGA view: Yes.

Do you have any comments on this? BGA view: A single licence is clearly the simplest system. The challenge for the change process is to avoid gold-plating.

Question 17: Do you support a skills test or differences training when moving between class privileges within the sub-ICAO licence? BGA view: Differences training. The system of differences training is well proven within NPPL and is suitable for all aircraft that could be flown with an NPPL.

Question 18: Do you support a fixed or rolling validity period for the privileges of the sub-ICAO licence? BGA view: Rolling recency is helpful, particularly if the experience requirement is removed.

Question 19: Do you agree that the existing microlight theoretical knowledge syllabus provides an adequate basis for the proposed sub-ICAO licence? BGA view: Yes

Do you have any comments on this? BGA view: The challenge is in ensuring exam question relevance.

Question 20: Do you agree that we should not expand the concept of operational limitations beyond the microlight category? BGA view: Yes.

Please share any comments on operational limitations BGA view: These potentially add complexity and seem to be a legacy microlight anomaly.

Question 21: Do you agree that we should allow the IMC Rating/Instrument Rating (Restricted) to be added to the NPPL(A) and LAPL(A) licence? BGA view: Yes

Question 22: Do you agree that we should allow pilot medical declarations to be made for the initial issue of the sub-ICAO licence? BGA view: Yes

Question 23: What do you believe the revised sub-ICAO licence should be titled? BGA view: NPPL

Do you have any comments or suggestions on the naming of this licence? BGA view: The great majority of those who would fly on this new licence already have an NPPL or have strong awareness of the system.

Question 24: Which option for the revised sub-ICAO licence would you support? BGA view: Option 1: single sub-ICAO licence

Do you have any comments, including any objections or alternative proposals? BGA view: To simplify the licensing system, the clear solution is one sub-ICAO aeroplane licence.

Question 25: Do you agree with our approach to existing licence holders? BGA view: Yes

Do you have any comments on this? BGA view: Existing licence holders should not lose privileges or be obliged to undertake additional cost or training as a result of this review in order to continue to fly.

Maintenance of privileges

CAA proposals:

  • Remove the requirement for flight experience when revalidating the single engine piston (SEP) and touring motor glider (TMG) ratings.
  • Possible alignment of the recency requirements between the sub-ICAO licence and the PPL(A), to create a single revalidation for SEP, TMG and microlight aircraft.

Question 26: Do you maintain your microlight or SLMG in accordance with General Exemption no.1582? e.g., your class rating was issued prior to 1 Feb 2008, and you comply with 5 hours’ experience in 13 months, with no refresher training required. BGA view: Free text as per your experience.

Question 27: Would you object to requiring all microlight and SLMG class rating holders (regardless of date of issue) to comply with the requirement to undergo at least refresher training with an instructor every 24 months? BGA view: Enforcing a mandatory hour of training would add cost and complexity. However, a single approach to this issue will reduce complexity.

Question 28: Do you support our approach to create Acceptable Means of Compliance and/or Guidance Material covering the conduct of Refresher Training? BGA view: Yes.

Please provide us with any comments or suggestions you have in this area. BGA view: We would propose Guidance Material that is proportionate and flexible according to the needs of the pilot and as directed by the instructor.

Question 29: Do you agree with this proposal of removing the experience element from the revalidation requirements? BGA view: No. Flight experience is in many ways more relevant than performance during a one hour flight. A pilot without sufficient hours should have the option of a skills test to maintain licence validity.

Question 30: If we were to remove the experience element from the requirements to maintain validity of a class rating, which of the following do you think is most appropriate? BGA view: ‘Undertake refresher training of at least one hour with an instructor during the validity period’.

Do you have any comments, including any objections or alternative proposals? BGA view: Refresher training is in most cases more effective than testing. We note that in some sectors of GA, the professional examiners both generate income from tests and have significant influence with CAA on this topic. Unless an examination is needed, e.g to qualify for or renew a rating, refresher training with assessment by instructors must be the preferred option.

Question 31: Do you agree with the approach of having a single revalidation requirement across all single-engine non-turbine aeroplane class ratings for the sub-ICAO licence? BGA view: Yes.

Do you have any comments, including any objections or alternative proposals? BGA view: A challenge here is to avoid a system that predominantly works for one sector or interest group (e.g. professional examiners) but increases burdens on others.

Other issues

CAA proposals:

  • Consideration of the theoretical knowledge requirements for Flight Instructors.
  • Aerobatic rating – potentially align the requirement for a rating between the
  • Tow Rating – potentially align the requirement for a rating between the ANO and Part-FCL.
  • Review the circumstances under which non-Part 21 aircraft may be used for training.
  • Proposed acceptable means of compliance (AMC) for training in partial power failures.

Question 50: Should a sailplane towing rating be required for all licence holders conducting this (sailplane towing) activity? BGA view: No.

Do you have any comments? BGA view: As the BGA detailed to the CAA during the work to develop this consultation, there is no safety or utility justification for a sailplane towing rating, which was introduced into the UK by FCL after decades of the UK managing without it. It is an unnecessary complexity.

Question 51: Do you believe any additional requirements for ATOs or DTOs should apply for using non-Part 21 aircraft, above those required for permit aircraft under ANO article 42? BGA view: No.

Do you have any comments? BGA view: Part DTO.GEN.240 allows use of non-Part 21 aircraft where the CAA has evaluated their suitability. However, despite requests from the GA sector including DTOs, the CAA has not evaluated non-Part 21 aircraft resulting in a training and capability gap. Part DTO and/or ANO Article 42 and/or the CAA’s approach to the existing opportunity may need to be updated to resolve this issue.

Question 52: Do you have any further comments or issues regarding aeroplane flight crew licensing that you wish to raise? BGA view: Free text.

Proposed AMC on Partial Power Failure

Question 53: Do you agree with this addition to the syllabus to cover partial power failure situations in aeroplanes? BGA view: Yes.

Do you have any comments? BGA view: A simple change to the syllabus AMC and/or GM should resolve the issue.

Submit Your Response Here!

Please submit your responses here via the CAA consultation survey.