CAA consultation re SFCL – response guidance
In October 2022, CAA published its General Aviation Pilot Licensing & Training Simplification – Phase 1: Strategic Direction (CAP 2335) as part of a three-phase program to simplify training and licensing for the UK’s General Aviation (GA) Sector.
The subsequent GA community response (CAP2532) showed strong support in several key areas for updating current legislation with regards to Licensing and Training.
To address changes to Sailplane Flight Crew Licensing (SFCL) requirements, a Sailplane Working Group led by the CAA was formed including BGA club glider pilots and gliding instructors/examiners. That group developed specific proposals for changes based on known issues and engagement with the gliding community.
The CAA has now published it’s Phase 2 consultation that looks at specific proposals to amend the Sailplane Flight Crew Licencing (SFCL) rules or Acceptable Means of Compliance (AMC) or Guidance Material (GM). You can view the CAA consultation document here.
The BGA guidance on this page aims to help respondents in developing their own responses to the CAA’s proposals and consultation questions.
Your responses to the consultation are important and should be submitted via the consultation survey – there’s a link at the bottom of this page.
The consultation closes on 22nd May 2024.
The following CAA consultation questions from the survey each has a suggested response and justification, as detailed in the consultation.
Amendments to Regulations
Question 5. Do you agree with adding the term ‘Gliding Club’ to the list of definitions in Article 2 of the assimilated Sailplane Regulations UK (EU) 2018/1976?
Suggested response. Yes.
Question 6. Do you agree that the definition of a ‘Gliding Club’ is ‘a club affiliated to the British Gliding Association (BGA), which is created with the aim of promoting aerial sport and leisure aviation’?
Suggested response. Yes.
Justification. The regulations refer to a ‘training organisation’, i.e. an Approved Training organisation (ATO) or a Declared Training organisation (DTO). CAA propose that the term ‘Gliding Club’ also be added and defined in the regulation. CAA propose that ‘Gliding Club’ is defined as a ‘club affiliated to the British Gliding Association (BGA), which is created with the aim of promoting aerial sport and leisure aviation’. Adding this definition will allow an amendment to the regulations that refer to a training organisation to include the term ‘Gliding Club’. This should remove unnecessary administrative burden.
Question 7. Do you agree that we should look to develop the procedures and privileges to authorise student pilots who are following a training course to gain a SPL to exercise limited privileges without the supervision of an instructor before they meet all the requirements that are necessary for the issue of an SPL?
Suggested response. Yes.
Justification. Regulation allows the CAA to authorise student pilots who are following a training course to gain a SPL to exercise limited privileges without the supervision of an instructor before they meet all the requirements that are necessary for the issue of an SPL. CAA would look to ensure that holders of this authorisation would receive a credit towards gaining the SPL based on these solo flights. This proposed authorisation would look to replicate current practices within the BGA Bronze Endorsement.
Flight Training Syllabus and Requirements
Question 8. Do you agree that we remove the validity periods, where necessary, and replace with the validity period of the skill test or assessment of competence?
Suggested response. Yes.
Justification. One area the working group focused on was to remove unnecessary validity periods from the regulation. For example, the regulation identifies that applicants for a licence, rating or certificate shall apply no later than six months after having successfully completed the skill test or assessment of competence for the specific licence, rating or certificate.
In the case of a skill test for the issue of a licence, once endorsed this is valid for 24 months and can be maintained in accordance with the SPL recency requirements. In most cases, once the applicant has passed the skill test or assessment of competence for issue of a licence, rating or certificate the applicant will apply as quickly as possible to gain these privileges.
CAA are proposing to remove the six-month requirement and replace it with the validity period of the relevant skill test or assessment of competence.
Question 9. Do you agree that the flight training syllabus and experience requirements for the SPL are acceptable?
Suggested response. Yes.
Justification. As part of the review, the working group considered the flight training syllabus and experience requirements for the SPL. Given the work that had already been accomplished in the development of SFCL, there were no changes identified.
The CAA has identified changes to the syllabus for the SPL with TMG extension to incorporate the additional elements covering training for partial power failure, these are detailed in Chapter 7 of the CAA consultation.
The group asked that CAA review the requirement for the Sailplane Towing Rating. This subject has been covered in the aeroplane consultation (which has proposed continuing with the towing rating). Please see the free text answer note at question 10.
Question 10. Is there anything else you would like to highlight with respects to the flight training requirements and syllabus?
Free text response.
Please note that the BGA believes that a sailplane towing rating is unnecessary for towing with either a TMG or an aeroplane. There is no safety case for requiring the complication of a towing rating. If you agree, please comment in your own words.
Theoretical knowledge syllabus
Question 11. Do you agree that we allow the theoretical knowledge examinations for the SPL to be delivered by the existing BGA system, rather than incorporate in the CAA eExams system?
Suggested response. Yes.
Justification. A review of the current BGA Gliding Certificate Bronze Endorsement theoretical knowledge syllabus and examinations show that it meets CAA obligations and complies with the relevant regulations on the delivery of theoretical knowledge examinations. Therefore, CAA will not be proposing to incorporate the theoretical knowledge examinations for the SPL in the CAA eExams system.
Question 12. Do you agree that we look to merge examinations that have overlapping areas and amend the syllabus and rules appropriately?
Suggested response. Yes.
Justification. As the BGA exam is a single examination (that can be delivered in parts), CAA can review the syllabus to ensure that any overlapping areas are addressed. A review showed that CAA can move the learning objectives associated with flight performance and planning to air law, navigation, and aircraft general knowledge examinations.
Question 13. Do you agree that we amend the 18-month validity period?
Suggested response. Yes.
Justification. CAA are considering amending the 18-month validity period, within which all examinations need to be completed. CAA are considering a requirement to complete all sections of the examination within a rolling 18-month period. If a student pilot finds that one section is outside of the 18-month period, they only need to retake that section rather than retake the whole examination.
Question 14. Do you agree that we should change the validity period after successfully completing the theoretical knowledge exams from 24 months to 36 months?
Suggested response. Yes.
Justification. CAA are also considering changing the validity period after the theoretical knowledge exams are successfully completed, to give applicants more time to apply for a licence. It is proposed that the validity period for a successfully completed theoretical knowledge exam will be 36 months instead of the current 24 months.
Question 15. Do you have any suggestions how we could replace the requirement to retake all the examinations where a candidate has failed to pass a section within four attempts?
If an examination candidate fails to pass a section within four attempts, they forfeit any examination section passes they have already and can only start again, after a period of theoretical knowledge training. CAA would like to see what alternative options there are instead of requiring all examination sections to be retaken. Free text response.
Powered sailplane partial power failure
Question 16. Do you agree that we should amend AMC for powered sailplanes, i.e. TMG and SLS (Self Launching Sailplane), to include partial power failure?
Suggested response. Yes.
Justification. Following accidents involving partial engine failure after take-off, the UK Air Accident Investigation Branch has recommended that the CAA explores proposals to include training to cover partial power failure situations. CAA are proposing to include partial power failure within AMC for powered sailplanes (TMG and SLS). CAA would also like to develop Guidance Material regarding partial power failure for SSS (Self-Sustainer Sailplane).
Instructor / Examiner requirements
Question 17. Do you agree that we work with the BGA and the gliding community to develop a Basic Instructor privilege within SFCL, similar to the BGA Basic Instructor rating?
Suggested response. Yes.
Justification. The BGA currently utilises a Basic Instructor rating, which allows a qualified BGA Gliding Certificate holder, with the required experience, to be trained and supervised to safely deliver a limited number of flight training exercises. This Basic Instructor rating presents an opportunity for pilots to develop valuable rear seat and other relevant experience ahead of stepping up to complete the BGA Instructor training course. CAA are proposing to develop a similar Basic Instructor privilege within SFCL, which would allow the holder to deliver flight instruction covering a similar section of the syllabus as the current BGA Basic Instructor rating.
Question 18. Do you agree that Basic Instructors should meet the FI(S) competencies listed in SFCL.325?
Suggested response. Yes.
Justification. The competencies are similar to those required on completion of BGA BI training.
Question 19. Do you agree that the Basic Instructor privilege should be limited to Exercises 1, 2, 4 and 5 of the SPL Course?
Suggested response. Yes.
Justification. Familiarisation with the sailplane, emergency procedures, initial experience and effects of controls are exercises currently delivered by BGA BIs and can be assimilated during a short BI course.
Question 20. Do you agree that we amend the privileges of the Flight Instructor to remove the requirement for the Flight Instruction to hold advanced aerobatic privileges if instructing for basic aerobatic privileges?
Suggested response. Yes.
The basic aerobatic privilege is an excellent tool for improving pilot handling skills. The number of pilots interested in and qualified to fly advanced aerobatics in sailplanes is small, as are the number of sailplanes which are permitted to fly advanced exercises. For a Flight Instructor (sailplanes) to offer flight training for the basic or advanced aerobatic privileges, the instructor must hold advanced aerobatic privileges. CAA are proposing to amend this so that an instructor offering to instruct for basic aerobatic privileges only needs to hold basic aerobatic privileges.
Question 21. Do you agree that we amend the privileges of the Flight Instructor to include self-launch in the launching methods?
Suggested response. Yes.
Justification. CAA are proposing to amend the wording in the Flight Instructor (Sailplanes) privileges and conditions with respect to launching methods to include self- launch. This will correct an anomaly in the current SFCL requirements.
Question 22. Do you agree that we work with the BGA and the gliding community to develop those procedures to allow Flight Examiners to issue Temporary Certificates?
Suggested response. Yes.
Justification. There is provision within the pilot licensing rules applicable to the CAA to develop procedures to allow Flight Examiners to issue Temporary Certificates where the applicant has passed a skill test (except for initial licence issue) or assessment of competence and has applied for a rating or certificate to be endorsed, so that the applicant can, for a short period of time, exercise those privileges. This will reduce waiting time for pilots to use new privileges.
Question 23. Is there anything else you would like to highlight with respects to the flight instructor and examiner requirements?
Free text response.
Submit your sailplane licence consultation response here
Please submit your response here via the CAA consultation survey.
The final proposals and legal drafting will be developed with the Department for Transport and presented for legislative amendment in Spring 2025.