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Volume 25, Number 16c
April 20, 2018
 
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FAA Will Issue AD for CFM Engines
 
Kate O'Connor
 
 

In the wake of the uncontained engine failure that killed a passenger on Southwest Airlines Flight 1380 earlier this week, the FAA has announced that it will issue an AD requiring inspections of certain CFM56-7B engines. This statement comes after NTSB chairman Robert Sumwalt said during a media briefing that a preliminary inspection of the engine on the Southwest Boeing 737-700 revealed that a fan blade had broken off at the hub and around the midpoint of the blade. Sumwalt also said that it appeared from a visual inspection that metal fatigue was the cause of the blade separation.

The FAA says that the coming AD will require ultrasonic, rather than just visual, inspection of engine fan blades after a to-be-defined number of takeoffs and landings. For any blades that fail the inspection, replacement will be required. The agency has said the AD will be issued within the next two weeks and inspections are expected to take about two hours each.

According to engine manufacturer CFM International, there are more than 8,000 of its CFM56-7B engines in operation on Boeing 737s. Including Southwest, several airlines that operate 737s with similar CFM engines have issued statements saying that they have already begun inspecting the engines.

FAA Reauthorization Bill Introduced
 
Kate O'Connor
 
 

New bipartisan legislation has been introduced in the House of Representatives that, if passed, would authorize funding for the FAA until 2023. Unlike previous iterations, H.R. 4, called the “FAA Reauthorization Act of 2018,” does not include provisions for removal of ATC from FAA oversight. The bill is scheduled to go to the House floor the week of April 23.

H.R. 4 is being sponsored by chair of the House Transportation and Infrastructure Committee, Rep. Bill Shuster, R-Pa. He is joined by the leadership of the Transportation and Infrastructure Committee and its six subcommittees. The bill includes the establishment of a task force “comprised of representatives of the general aviation industry who regularly perform part 91 operations, labor unions […], manufacturers, and the Government” to assess and advise on FAA oversight and authorization processes and requirements for Part 91 ops.

There is an FAA reauthorization bill working its way through the Senate as well. If both bills pass, the next step is for a committee to meet to reconcile the differences between the two. The FAA is currently operating on a temporary funding extension that expires on Sept. 30.

NTSB: ERAU Crash An In-flight Breakup
 
Kate O'Connor
 
 

The NTSB is officially calling the fatal crash at Embry-Riddle earlier this month an in-flight breakup, although its report thus far is only preliminary. The accident occurred on April 4 and killed ERAU student Zach Capra and FAA DPE John S. Azma. Several eyewitnesses reported seeing the left wing of the Piper PA-28 Arrow separate from the aircraft while it was climbing out after a touch-and-go at Daytona Beach International Airport (DAB). The wing was found about 200 feet from the main wreckage.

Although the investigation is ongoing, the NTSB’s report notes that “preliminary examination of the left wing main spar revealed that more than 80% of the lower spar cap and portions of the forward and aft spar web doublers exhibited fracture features consistent with metal fatigue.” Fatigue cracking was also discovered in the same location on the right wing. No signs of corrosion or other pre-accident damage to the wings have been found, the NTSB said.

The accident airplane was manufactured in 2007 and had 7,690 hours on the airframe. The plane’s most recent annual was completed on March 21, just 14 days before the accident. According to the report, Capra was taking his commercial practical examination at the time of the crash. The rest of Embry-Riddle’s Arrows are grounded with no word yet on plans to return them to service.

The Mantle Of Heroism
 
Paul Bertorelli
 

About a month after Chesley B. Sullenberger had ascended into sainthood after his skillful 2009 ditching of US Airways 1549 into the Hudson River, a network reporter took a few moments to ask him in depth what he thought about the mantle of heroism that had been thrust upon him. His response was memorable. He said he understood why people wanted and needed heroes and if he had to play the role for his moment in history, he’d do so without complaint. 

Tammie Jo Shults, batter up. Like Sullenberger, Shults was confronted with a serious inflight emergency when an engine on the 737 she was flying essentially disintegrated. Unlike Sullenberger, she and First Officer Darren Ellisor at least had thrust from one good engine. They handled the emergency ably and professionally.

But the narrative has extra richness this time because of Shults’ gender and the fact that she was one of the first women to enter the cloistered world of the military fighter community. I’ve seen reports that she was turned down by the Air Force before being accepted for flight training by the Navy. I don’t know if this is true as reported, but I’m sure you can see how the script just about writes itself.

Predictably, all of this is catnip to the working press. The headline writers couldn’t resist using a passenger quote about Shults having “nerves of steel.” Most of us in aviation will have the same reaction to that, I’m sure. Just once, I’d like to see a headline that says “Engine Explodes, Pilot Reduced to Whimpering Panic as Passengers Land Jet.” Well of course she remained calm. Would we expect anything less? Calm helps sort through the emergency checklist and the decision tree, just as the training doctrine requires. We sometimes forget—or maybe headline writers do—that the pilots are always the first to the scene of the accident so in addition to the duty of care they feel professionally for passengers, they have a certain self-interest. And besides, screaming and panic sound really bad on the tape.

It doesn’t take much reading between the lines to know that a parallel story hook in these reports is that it is somehow remarkable that a woman was involved in resolving this emergency, but my reaction is the same. Why would we possibly expect anything less? Or if it is remarkable, it’s only because of the rarity of such an event itself in a universe where airline accidents have effectively become zero or perhaps because Shults was among a small handful of women who broke into the boy’s club, thus paving the way for others to follow. I will admit to being an unreconstructed dinosaur here; a genuine 1970s Germaine Greer feminist. I put a period on this sentence decades ago and accepted at face value the declaration that women could do any job that men can. I haven’t changed that view, although I recognize that many still don’t embrace it. 

If the outcome of this emergency serves as a touch point for recruiting women into the cockpit or science or technology, fine by me, although personally, I am not necessarily animated in that direction. The most compelling argument for more women in such workplaces is to help remove what barriers remain for women in general, while at the same time acknowledging that for generational and cultural reasons not related to bias, they may not be interested in such professions. Call me naive, but I’d just like to stop discussing innate ability.

Here a word on the dark side of this emergency. A passenger died as the result of a cabin breach. In the midst of the adulation for an emergency well handled, spare a thought for the family of the deceased and for the trauma any professional airline crew feels at losing a passenger whose life it is their duty to protect. Rightly or not, the captain gets most of the attention in such events because it fits the easy-to-read narrative. But I think I’m on safe ground here predicting that when Shults gets her Sullenberger moment, she will deflect the praise toward her First Officer and, especially, the cabin crew. They had to deal with the emergency firsthand and, rising to the occasion, proved once again that flight attendants aren’t there just to serve drinks, but to save lives and salve the terrified. For them and for Shults and Ellisor, there is no need to write a hagiography, but merely to acknowledge duties performed professionally under duress. Just as we shouldn’t expect any less, I suspect they don’t expect any more.

Podcast: CubCrafters FX3 Fast-Build Kit
 
Paul Bertorelli
 
 

At Sun 'n Fun 2018, CubCrafters was showing its FX3, a fast-build kit version of the popular Carbon Cub LSA. But it's a lot heavier and has the CubCrafter proprietary ASTM engine.

Former Navy Pilot Praised For Handling Of Southwest Emergency
 
Kate O'Connor
 
 

Southwest Airlines captain Tammie Jo Shults, 56, is being hailed as a hero for her deft and calm handling of an uncontained engine failure that damaged her Boeing 737 and claimed the life of passenger Jennifer Riordan on Tuesday. Throughout the emergency, Shults’ communications remained clear and direct as she diverted the plane to Philadelphia, worked out an approach plan with ATC and made sure emergency vehicles and medical transport were standing by.

A former U.S. Navy pilot, Shults flew F/A-18 Hornets with VAQ-34, a tactical electronic warfare squadron based in Point Mugu, California. She also served as an instructor on both the Hornet and the EA-6B Prowler. Shults joined the Navy after graduating from MidAmerica Nazarene University in Olathe, Kansas, in 1983 with a degree in biology and agribusiness. According to a statement issued by the U.S. Navy, “Lt. Commander Shults was among the first cohort of women pilots to transition to tactical aircraft.”

Southwest has not yet released a statement naming the pilot in command of Flight 1380. Shults was identified by passengers onboard the flight and by photos taken on the plane.

Though each airline has their own proprietary checklists and quick reference handbook (QRH) for abnormal procedures, generally speaking, in the event of a rapid, uncontrollable cabin depressurization at altitude, the captain takes the controls, both pilots put on their oxygen masks, turn the passenger oxygen switch on and begin an emergency descent to a safe altitude (10,000 feet or the lowest safe altitude above that). Typically, the pilot monitoring talks to ATC during that phase. When that’s done, the pilot flying takes over the coms while the other checks in with the cabin crew.

For engine failures, common procedure is to disengage the autopilot, determine the source of the shutdown (fire, physical damage, etc.), either restart the engine (if safe and possible) or shut it down properly, and land the aircraft as soon as practical. As can be heard in recordings of ATC audio from the Southwest emergency, speed is adjusted as needed to mitigate any vibration or other issues caused by structural damage.

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Operational Blunders: Protecting Yourself
 
Rick Durden
 
 

Editor's note: This article originally appeared in the April 2016 issue of our sister publication Aviation Consumer. 

The day had started out so well. You flew out to meet with a client and wrapped up a big sale. On the way home you got some time in the clag and shot an approach to your non-towered home field. You broke out well above minimums and easily spotted the runway. But then, somehow, you didn’t handle the crosswind during rollout and went swerving off the runway into the grass. To make matters worse, just before you got the airplane stopped the nose gear hit a hidden storm-drain cover and collapsed.

You shut everything down and crawled out, pretty disgusted with yourself. Looking at the bent prop and nose damage, you remember that Part 830 of the NTSB regulations defines a reportable aircraft accident. This clearly isn’t enough damage to qualify, so you know you don’t have to report this to any federal agency. You know you have good insurance, so you’ll call your agent first thing and you’ll talk with the FBO about getting the airplane moved into your hangar where it will be protected from the elements until repairs can get started.

About then people start showing up, asking if you’re OK. Two of them show you FAA identification—they’re inspectors who were at the airport restaurant and saw the whole thing. They, very politely, say they’d like to talk with you about what happened at some point—and they’ll want to see your logbook and the airplane’s logs.

Three days later you meet with them, talk about the incident and they look through the logs and your certificates. All of your stuff is in order—flight review, medical, instrument currency. Your airplane has a current annual, but, whoops, somehow you’d let the transponder and pitot-static checks lapse—you’re in violation of FAR 91.411 and 91.413.

How can this happen? Can the FAA step in and inspect you and your airplane after an event that didn’t even qualify as a reportable accident? What can you do to protect yourself from winding up with a violation? Will your insurance company pay if you violated a reg?

We’ll answer all of these questions and take an in-depth look at the more common operational blunders pilots make, how the FAA responds, how to avoid bringing yourself to the FAA’s attention, what protection you can have in place should you bring yourself to the FAA’s attention and whether your insurance company is going to try to deny a claim if you bust a reg and have an accident.

Which Blunders?

The FAA was tasked by the Federal Aviation Act of 1958 to, among other things, scrutinize aviation for the purpose of safety. An FAA inspector has the authority to ask pilots and aircraft owners to produce their certificates and logbooks for inspection. Most often that comes about during a ramp check (although it’s unusual for the inspector to ask to look at logbooks), and it is normal any time there is an accident or an incident that comes to the attention of the FAA.

If you have an accident and report it to the NTSB (by regulation, that’s the agency to which aircraft accidents are to be reported), the NTSB then tells the FAA. Almost invariably an FAA inspector is assigned to get involved with the investigation. That inspector will ask to see all certificates and logbooks. Under the regs, the pilot and owner must make them available for review.

That means that you shouldn’t rush to call the NTSB if you have a fender-bender event with your airplane—and that includes a gear-up landing. If the event doesn’t meet the definition of an accident under Part 830 of the NTSB regs, there is absolutely no requirement to report it to the NTSB. The definition of an accident includes fairly severe damage—and gear-up landings almost never generate enough damage to be a reportable accident. In fact, the definition appears to have been created with an eye to not saddling the NTSB with investigating gear-up accidents. They don’t want to hear about those; they’re already plenty busy.

Unfortunately, if someone does get excited and call the NTSB (or FAA) after you clip a runway light, you can’t stop the inspector who is assigned to your incident from demanding your certificates and logbooks by pointing out the event wasn’t a reportable accident—you’re in the crosshairs. So, think before you make a phone call.

The most common way to come to the FAA’s attention is via the most common, non-fatal accident for general aviation airplanes—runway loss of control (RLOC). If you lose it in a crosswind, scratch the airplane and someone tells the FAA, you get to produce certificates and logbooks and have an FAA inspector ask you a lot of questions.

The second most common way to invite unwanted attention from the FAA is to make a mistake when ATC is involved—not follow a clearance, bust an altitude or enter Class B airspace without a clearance. Neck and neck with those blunders is inadvertently flying into a TFR.

A close third is to do something stupid with an airplane where people can see (and photograph) you. Coming up rapidly on the outside for ways of generating FAA attention is making a video of yourself doing something stupid with an aircraft and posting it on social media. The biggie on these is low flying/buzz jobs/scud running. Everyone has a cellphone camera. Not everyone thinks a low-flying airplane is cool—and a certain percentage of the population sees a low-flying airplane and thinks, “terrorist attack.” We’re serious; some people become terrified.

If you do a buzz job and someone complains to the FAA, the FAA is required to investigate. If there is a photo or video that helps identify your airplane, the FAA’s workload in proving a violation against you drops off dramatically. The FAA can, and will, subpoena the data from any GPS device in your airplane and use it against you in a violation action.

If you are one who feels the need to fly low, we suggest you do it where there are very few people who might see you.

We are aware of situations where pilots had decided to continue flying after their medicals had expired or they’d lost their medicals and were turned in because someone who knew about it got mad at them and called the FAA. Compliance with the FARs is almost entirely on the honor system—reduced to its essence, the FAA trusts you to do the right things when you fly. When a pilot violates that trust intentionally, the FAA will come down hard. Based on our experience and conversations with aviation attorneys and FAA inspectors, flying without a medical and falsifying logbooks are two effective ways to have the FAA lower the boom on yourself.

Violations and Catches

Under the Pilot’s Bill of Rights law, the FAA has to tell you when it is investigating you for a possible violation of an FAR. While you are required to present your certificates and logbooks, you do not have to speak with the FAA or provide a written statement—and if you do so, anything you say or write can be used against you in a violation action.

We strongly recommend that following any sort of an accident or incident, or if you receive notice that the FAA is investigating you, that you speak with an aviation attorney before you talk with the FAA.

The overriding element in deciding whether you should talk to the FAA if there is a risk that you were in violation of a regulation is whether that talk will help or hurt you. You must decide, as objectively as possible, if talking to the FAA can improve things for you.

In the past, the answer was often no, as the FAA often had the goods on you from radar data of an altitude bust, ATC tape of you not complying with a clearance or a photo of you flying under a bridge and smiling for the camera.

As of last summer evaluating the “can I make this better” question changed for what we think is the better. The FAA changed its policy on pilot enforcement—it wants more matters resolved at the FSDO level, not elevated to an enforcement action to be handled by FAA lawyers. FAA Order 8000.373, issued June 26, 2015, sets out the new FAA policy of having well-intentioned pilots who inadvertently violate a regulation go through retraining and education rather than nailing them with a violation and suspension of their certificates. That, of course, doesn’t apply to the pilot who intentionally flew under the bridge after saying something along the lines of “Y’all watch this.”

We think that is great. For some years the FAA has gradually been encouraging FSDO inspectors to have pilots who made an honest mistake go through retraining to help prevent future mistakes. We think that where it’s been applied it’s worked. We’re glad to see that it is now official FAA policy.

The catch is that in order to take advantage of the policy, the pilot has to talk with the FAA during the investigation. He or she has to discuss what happened so the FAA inspector can determine if the pilot made a mistake or meant to violate a reg and whether the pilot has a constructive attitude toward safe operations.

That means that if you don’t talk and the inspector thinks you violated a reg, it’s likely the matter is going to get kicked upstairs to the attorneys for an enforcement action. Therefore, not talking can hurt you. If you do talk, the inspector has the choice of resolving the whole thing by sitting down and talking with you about how to avoid it in the future, having you take some dual to make sure your skills and judgment are up to snuff or elevating it to an enforcement action. Your demeanor and attitude can and will affect the inspector’s decision.

We think the new policy means that if you think you made an honest mistake—and your attorney objectively agrees with you—it’s probably better to talk with the FAA inspector during an investigation. If you buzzed a crowded beach, telling the inspector that you’re sorry and won’t do it again won’t help you and is an admission that you were the one flying the airplane.

An Incident is Traumatic

A huge caution from us—do not talk with the FAA inspector the day of your incident/accident or right away upon receiving the letter telling you that you’re being investigated.

Whether you realize it or not, your adrenaline level is spraying out of your ears and you are not going to be entirely rational or put your best foot forward in the conversation.

Following the most minor paint-scrape airplane incident, even the coolest pilot in the world is going to be mortified that he or she dinged an airplane—that pilot would rather have totaled the family car—it’s a huge point of pride.

For the next 24 hours, if you ask that pilot the sum of two plus two, she or he is likely to say, “Thursday,” and not have a clue that the answer makes no sense.

That means that if an inspector approaches you following an incident or accident and wants to talk with you, politely say that you will talk in the next day or so, but not today. Some inspectors come across with the bad-cop routine and claim that you have to talk. You don’t. Get the inspector’s phone number and professionally and politely repeat that you will call in the next day or so.

For an investigation letter from the FAA, call your aviation attorney and, with him or her, make a decision about talking to the FAA, but don’t make the call to the FAA for at least 24 hours.

Almost invariably, if you talk to the FAA the day of the incident, you will say something that doesn’t make sense, is completely inaccurate or both. Later, you’ll be faced with trying to correct your comment and the FAA may accuse you of making inconsistent statements—and lying to a federal official is a felony. Martha Stewart didn’t go to the slam for cooking the company books; she went for lying to investigators.

If the FAA asks for a written statement, discuss it with your lawyer, keep it short and to the point (pilots have a tendency to get themselves into trouble by saying too much) and then review and revise it with your lawyer before sending it in. You want it to be 100 percent accurate and you want to express it well.

Press

You couldn’t get the gear down despite everything. You made a beautiful gear-up landing. No one was scratched—and we don’t know of anyone hurt in a gear-up landing of a civilian airplane since WWII so long as the pilot kept the engine running at least until very short final. However, the press was alerted, ran live coverage of breaking news of aircraft occupants in mortal danger and your miracle landing and now wants to interview you.

Our recommendation is to politely decline or just make yourself unavailable. Trust us, you will not come across as the coolest pilot ever—your hair will be messed up from your headset, it’s impossible to answer stupid questions quickly and concisely and the reporter will decide which parts of the video get shown on the news. You will not only look like a dolt, there’s a chance you’ll say something the FAA can latch on to and investigate beyond a simple mechanically induced gear-up event.

NASA/ASRS Form

Any time you think you may have violated a regulation or if you have an incident in which you damage an airplane, file an Accident Safety Reporting System (ASRS) report with NASA (http://asrs.arc.nasa.gov) immediately. There is absolutely no downside to doing so. The FAA cannot find out who filed it from NASA. You do not implicate yourself if the FAA investigates the event. If you are found to have committed a violation—so long as it wasn’t on purpose and didn’t involve what the NTSB defines as an accident—when you show the FAA that you filed an ASRS report within 10 days of the event, you will not be subjected to the penalty associated with the violation.

The ASRS report is one of the best protections available to a pilot who inadvertently violates a regulation.

Insurance

In the example at the beginning of the article you were flying IFR apparently in violation of two FARs, but they had nothing to do with why you damaged your airplane. Can your insurance company deny coverage because of the violation? No—with almost no exceptions.

While pilots often claim that aircraft insurance companies do everything they can to keep from paying claims, the reality is just the opposite. We talked with Jon Doolittle, principal of Sutton James aviation insurance brokers, about denials of coverage. When we brought up the subject, he expressed surprise, as he said it is something that is rarely seen in the aviation world. He told us that he cannot recall a single denial of coverage of a claim within his agency in the last decade.

Doolittle explained that violation of an FAR is almost never grounds for denial of coverage. Unless the violation was causally related to the accident, an insurance company would have a hard time convincing a court that it didn’t have to pay a claim under its policy. Also, it’s expensive for an insurance company to litigate a denial of coverage claim.

According to Doolittle, his experience has been that even where an insurer can rightfully deny a claim—such as where the pilot had lied about his time or ratings on his application, or the airplane was way out of annual—the company will usually pay the claim and then never insure the pilot again.

The bottom line is twofold: If you crash and it turns out you violated a reg somewhere in the process, your insurer is almost certainly going to pay the claim; but if you do something that affects whether the insurer would cover you in the first place, such as lie on the application or don’t bother to have your airplane annualed or renew your medical, the chances of a coverage denial do go up.

Protective Measures

What can you do in advance to protect yourself from the unpleasant things discussed above?

Enroll in the AOPA Pilot Protection Plan. The annual fee for the basic service includes unlimited consultation with Legal Service Plan staff and a specified list of number of hours of representation by an aviation attorney who is on the LSP list of attorneys. The Plus Level plan provides coverage geared toward professional pilots.

As far as we’re concerned, the Pilot Protection Plan is inexpensive insurance for pilots for legal and medical issues. We do note that you can’t enroll after you’ve had your incident or notification of investigation and expect coverage—just as you can’t buy insurance after an accident and expect coverage.

Take regular, frequent dual, especially on crosswind landings. It sounds very basic and it is—recurrent training dramatically reduces your accident risk. The data we’ve seen indicates that staying current in the FAA WINGS program dramatically reduces a pilot’s risk of being involved in an accident. Professional pilots fly frequently, yet they take recurrent training—it’s a major part of the reason their accident rate is low.

Learn about crash survival and the equipment you should have with your for survival. We recommend the nonprofit foundation Equipped to Survive (www.equipped.org) for further information.

Don’t do anything dumb. Make sure you check for TFRs before every flight.

Tempted to make a low pass down the runway at a fly-in so the 40 or 50 people standing on the ramp can see how cool you are? Avoid temptation. The FAA has said that group of people makes the ramp a congested area—if you are not taking off or landing, you’ve got to be 2000 feet away horizontally and 1000 feet above them. One of them may not like what you’ve just done and make a call to the FAA to complain. Suddenly you’re being investigated for violation of the minimum altitude regulations.

Conclusion

Inadvertently violating a reg doesn’t mean your insurance isn’t going to pay if you have an accident or that you’re going to get a violation. However, protect yourself by joining AOPA’s Pilot Protection Plan and taking regular recurrent training.

If something does bring you to the FAA’s attention, resist the temptation to talk to anyone about the incident until you have spoken to an attorney and had time to focus your thoughts.

Rick Durden is an aviation attorney, a CFII, holds an ATP with type ratings in the Douglas DC-3 and Cessna Citation and is the author of The Thinking Pilot’s Flight Manual or, How to Survive Flying Little Airplanes and Have a Ball Doing It, Vols. 1 & 2.

This article originally appeared in the April 2016 issue of Aviation Consumer magazine.

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AERO: EASA Announces Streamlined Regulations
 
Jason Baker
 
 

At the Aero Expo this week in Friedrichshafen, Germany, EASA officials renewed their pledge to simplify certification rules for the European industry, including major changes to the rules governing flight schools. Besides simplifying the rules on balloon and glider operations, the agency is actively working on decluttering its rule books, both in an effort to make compliance simpler, but also to give the industry a better chance to counter its rising age demographics and dwindling numbers.

Major changes are expected to the current ATO (Approved Training Organization), which makes it difficult for smaller flight schools to provide training outside of the "professional" pilot training scope. In the future there are plans to establish "Declared Training Organizations" (DTO), reducing the regulatory burden and allowing for easy transition for flight schools. The move is expected to lower cost and increase completion rates for aspiring pilots while boosting smaller training outfits abilities to train and certify pilots. Ambitiously, the agency is moving to launch the program within summer of 2018. 

For aspiring instrument pilots, there will soon be a BIR (Basic Instrument Rating) again, tailored for private single- and multi-engine rated pilots. The BIR will be split up into three modules: (1) CORE Module, (2) Approaches & Arrival and (3) Enroute Instrument Rating, which can be completed by DTOs. Pilots holding the BIR are likely to be limited to higher approach minima.

Change options to the previous "national" license known as LAPL are currently on the table. The proposal would split the pilot certification into two modules, allowing local flights and different restrictions to people who wish to fly alone and local and those who wish to continue on toward the Part FCL license. The argument here is that one of the EASA jurisdictional states currently has such a system. With this option, the agency acknowledges handing the writing of regulations back to industry players. While EASA admits to being challenged by increasing demand to provide simple and easy-to-follow regulations for both pilots and manufacturers, EASA is moving toward more direct exchange with the industry, rather than holding the rulebook up.

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