ULM Pro! Continued … and not quite the end …
For those who have not followed the episodes of the ULM-Pro "telenovela", I invite you to read the previous editorial on this subject, "ULM Pro: for or against", with its origins, its twists and turns and above all the federation's positions.
The latest news on this subject is that the main bodies consulted (as far as we know the federation, the SNPPAL, the GIPAG and the FNAM) have had to hand in "their homework" on the draft order like good little schoolchildren. But this "consultation" is true to the nature of this whole file: long, laborious and, let us say it, not very respectful of those taking part.
We naively believed (we are entitled to be optimistic) that this consultation would be coordinated as to its arrangements and open to everyone. Instead, the draft order, whose new wording we did not know, was sent to the various bodies asking them to consult their own members! It is absurd: the federation's positions are known, and putting forward yet another version of the text without bothering to take our comments into account, and asking us what we think of it, only creates confusion and ambiguity and wastes time and a great deal of energy.
Moreover, while the positions of the federation and those of the SNPPAL are often convergent, and I want to make clear that as president I have always valued my exchanges with the SNPPAL, the presence in this "consultation" of the GIPAG and the FNAM, which are clearly hostile to our regulation and "fantasise" about a competition that does not exist, is nonsense. Look instead at drones! It is like inviting confectioners to a seminar on fighting diabetes, and we are waiting for the day when the federation is consulted on a reform of maintenance workshops... but let's move on. What next?
The DGAC will collate all the feedback over a few weeks and one day (generally without notice) we will be summoned to discuss the summary version of the order (which will have been leaked on social networks the day before), being asked what we think during long working sessions. Of course we will be told that everyone's opinions, confectioners included, had to be taken into account, that the DGAC had to make trade-offs, and so on and so forth, and that is how this subject has been "dragging on" for 5 years and risks ending up like the air-display text: a long, incoherent, unsuitable text that has carried so much dross of legal formalism that the original intention has been completely lost.
You will find the federation's "homework" attached. But if we had to state again our main comments on this subject (if they agree to listen to us), they could be summed up in three main demands.
The first and main one is that simple messages must be sent. Beyond the inevitable drafting of an order, it is unthinkable to send this document out as it stands, asking club presidents to deal with it and drowning them in regulatory obligations. The text is complicated. We absolutely must return to the spirit that prevailed when the MALGH was created: the DGAC organises civil aviation, but the heads of our organisations are not airline executives. Had we been able to coordinate the message (as in 2019 for the new microlight regulation, or as with the delegation of the theory exam), a climate of trust would obviously have prevailed. That is not the case, and although the federation supports the intentions of this project, it is impossible to understand how it will end...
The second demand is to be respected in the dialogue. Two examples are particularly telling: the medical and the beacons.
For four years we have spent dozens of hours and meetings convincing the DGAC not to apply the aeroplane medical examination (class 2), explaining that the sports system was appropriate. We got satisfaction, but the text proposes an examination that looks suspiciously like a class 2 without saying so. We ask that the current sports system be sufficient for those who hold a licence. It is for the DGAC to devise the system it wants for non-members. Let us not forget that the BEA's request comes mainly from events that took place outside the federation's structures.
The beacons: we agreed that (single-person, non-certified) beacons should be compulsory in inhospitable regions (the Guianan forest, for example). This was the subject of long discussions and an agreement, but "behind the scenes" the text proposes extending the obligation to all flights. Why discuss for hours and say yes, only to propose a text that goes back on the agreement and asks for our opinion?
The last demand is essential, and is the main complaint about the proposed draft (which is far from the first). The text does not draw a sharp enough distinction between clubs that give trial flights below 8% of hours (excluding training, BIA, open days and air displays) and the others. It is even quite hard, on first reading, to see the real benefit. Yet putting obligations on "small clubs" ends up putting them in a rut, just as the air-display text ended up discouraging club initiatives.
But let us say it again: in regulatory matters, the DGAC is sovereign. It is a great shame to write a text on microlights while depriving itself of the federation's expertise, but it is above all very trying to make us believe we are being listened to when we are not.
Let's stay optimistic: we can still get it right!
FFPLUM's observations on the draft amendments to the orders of 1991 and 1998 and on the creation of an order on the conditions of use of microlights.
