MPL – From “competency” to “wallet” based training

Conveniently flying under most radars (in this time of holidays), this 3rd of December, an amendment to Regulation (EU) No 1178/2011 was drafted by DG MOVE Petrova Irina (on behalf of the Commission) and fast-tracked to vote today by Member States within the ‘EASA Committee’.
If approved, part of it could be detrimental to the job market as follows.

Context and motives

Adopted in 2006, Multicrew Pilot Licence (MPL) credit could be given to now-retired Lufthansa's (LH) Capt. Dieter Harms notably, known as the "father of the MPL".
Aimed at answering inhouse airline-oriented pilot needs, as of nov. 2012, Capt. Harms assessed:

"Be assured, MPL will continuously grow.
The recovery from the current crisis will augment this trend
, provided that the international airline training and regulating community is able to facilitate a globally harmonised and standardised implementation."_source

Comes today, LH got more "MPL growth" than they bargained for, unwilling to process or complete its 800 MPL pilots conversion course from its training school (both ATO & TRTO) with no recovery in sight.

EASA to the rescue

First, lest we forget, MPL programs are at pilots' expense.
Air Arabia case in point, pilots fund their training like regular ATPL... except for €142,5k including TR to which is added a €27,5k LT (Line Training - p2f here) "security" cheque given back upon successful completion, tantamount to a down payment refunded with equivalent provided labour (the airline would reimburse only the netted sum hadn't a pilot finished LT).
As far back as 2008, the AAIB itself suggested something was off since "training organisation[s] pa[y] the airline[s] for [their] involvement in the training, enabling [them] to generate revenue through their training department" (incident report we shall detail another time).

Too busy reaping profits, EU AOC holders should have deemed deterrent enough to comply with regulation stipulating:

"the [MPL] licence [holder] shall be restricted to that specific operator until completion of the airline operator’s conversion course"

...which is why they decided it was decided to assume HR mismanagement responsibility, rationalize recruitment policies and bear resulting financial burden to hastily help airlines stuck with pilots help unfortunate pilots stranded with airlines worldwide by amending regulation
(blessed by ‘light’ EASA impact assessment rating)

The proposal

A thorough look at the amendment draft and annex reveals:

"(6) [...] There are cases where, due to the fault of the operator, some MPL holders cannot complete that operator’s conversion course and are consequently not able to work neither for that operator nor for another operator. The restriction on exercising MPL privileges elsewhere puts those MPL holders at a disadvantage without it being justified by safety reasons. Pilots who change operator are required to complete the new operator’s conversion course despite the fact that they have taken a conversion course on the previous operator. Moreover, any operator’s conversion course must take full account of the level of experience of the pilots joining that operator. It is therefore necessary to remove that restriction. MPL requirements are thus also aligned with the ICAO standards".


MPLs were built on the link between pilots and operators, giving tacit guarantee to the former they would later join the latter. That "restriction" will be waived. Even though:

  • operators turned their training dpt. from investment to cash cow,
  • operators weren't forced to queue MPLs beyond their needs,
  • "operators' fault" ensued, having failed duty to uphold and enforce regulation,

...pilots will foot the bill again, not working for the airline they paid and having to complete (fund?) the conversion course from whatever other operator will accept them at their discretion. Worst :

  • ​Lifting this restriction will incentivize ATOs to work with airlines that purposefuly have no job to offer, with the sole intention to generate profit.
  • Unblocking the operator-link restriction will flood the already saturated list of unemployed pilots, putting on the same footing the unemployed MPL pilots who followed the “fast track” and the ATPL pilots that followed the “normal track.”

Under the pretense of helping the few (stranded pilots) at the expense of the many (future MPLs and pilots at large), the EASA proposed to pervert regulation to ease operator's accountability and feed pilots' job insecurity. Glad no one noticed... yet.

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SDG – DG MOVE study on EMPL

Finalized this december 4th by Steer Davies Gleave's (SDG) associate Rosie Offord, expected for summer 015 as we were directly told by DG MOVE last May 22th, their "study on employment and working conditions in air transport and airports" is now available.

Though not primarily about it, this "investigation" is the closing chapter of answer n°1 of MEP Steinruck's questions where three neither-exhaustive-nor-conclusive "pay-to-fly" occurences emerge:

  • Page 21: Pay-to-fly is acknowledged in published literature (e.g. Atypical employment study, Ghent University) as an issue however stakeholders did not specifically comment in this area.
  • Page 159: 7.149 Pay-to-fly schemes are schemes that require pilots to contribute financially to an airline “in order to be allowed to fly and thus gain requisite flight experience”. Junior pilots without significant amounts of flight (type rating) experience are particularly vulnerable to such practices, although it is not clear how prevalent this is, or precisely which airlines are offering these schemes.
  • Page 163: 7.173 Training opportunities are broadly considered by the industry to have increased across all professions by all stakeholders except the worker representatives [...]. Pay-to-fly is acknowledged in published literature (e.g. Atypical employment study, Ghent University) as an issue however stakeholders did not specifically comment in this area.

Unfortunately for whatever decision European Commissioner for Transport Violeta Bulc will make (and European pilots at large), SDG missed:

  1. the exhaustive list of "precisely which airlines are offering these schemes" available on the internet for more than a year, based on...
  2. the extensive number of legally binding contracts gathered during that time span (also publicly available).

Between the lines

Despite the fact that we tried to forward aforementioned documents during the summer and unlike the Atypical employment study that preconized p2f "should be prohibited, not only in the European Union, but globally", SDG's stance on the matter could be summed up as:

"Yes, junior pilots pay to work, but as we're unsure how many and airlines refused to confess, the abuse may carry on".


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EC – decisive p2f answers

As reported three days ago, a p2f-dedicated meeting occured today dec.9th at 14h00 (Brussels local time) on DG Tran premises to present and engage in Q&A which, for the record, unfolded in accordance with the following canvas :

The dice are cast.

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Frontrunning: december 6

  • As expected, DGAC's lax initial ATO renewal decision officially backfired this Dec. 4th with SAT bankruptcy. 7 employees, 49 students and several hundred thousand euros in debt left in the wild. No DGAC officials to be held accountable.
  • French AGEPAC released pilot employment statistics update this Dec. 5th; slight improvements overall notably :
    • 53% working as airline pilots (45% on JAR25).
    • 2 to 3 years necessary for 50% of a class to find an employment.
    • 30% can't maintain IR/ME ratings with their jobs, 6% have an activity not related to the aeronautics.
  • Key meeting to be held wednesday 9th between the ECA and EC DG Tran in Brussels on potential backing of anti p2f proposal.
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School demise to drag students in limbo

The list could go on, :

  • Dutch Stella Aviation in a series of bankruptcies ending in april 2014;
  • in the UK amidst CAA warnings, Cabair in february 2012, formerly bankrupt as Cabair College of Air Training
  • in France, the EPAG (Ecole de Pilotage Amaury de La-Grange) in april 2013,
  • the ESMA (École supérieure des métiers de l’aéronautique) -or rather ESMA-HNA- twice bankrupt if not for Chinese investors, De Heerd Investments Limited (in 2006) then Hainan Group (in august 2013, also 48% Aigle Azur shareholder);
  • and in a lesser extent the SEFA (Service de la formation aéronautique) that merged into the ENAC (French Civil Aviation University) in january 2011 which currently operates "at industrial minimum".

This 6th of november, Sud Aviation Training (SAT) confirmed the trend in France, entering a one month receivership period at the end of which either a settlement or bankruptcy will seal the fate of the 49 students pilot group... and their estimated joint €500k.

Accountability - the 500,000€ question

With the student group willing to recoup their stakes (should SAT go out of business), the question arose: who is liable to refund its members?

Before answering "the school", let's consider the audit report that sanctioned SAT's first fiscal year : fullscreen

Out of 20 items (of which 3 were not applicable at the time of the report), one learns SAT failed to display compliance of 14 of them with regulation !

While some ORA (Organisation Requirements applicable) violations appear mild at first glance (like ORA ATO 120 and flight time not being logged in hundredth of hour), all of them fell under level 2 findings, reportedly:

"[...] established by the DGAC when any non-compliance is detected by the applicable requirements of Regulation (EC) No 216 2008 and its implementing rules, procedures and manuals in the organization or in the terms of the license or certificate, which could lower safety or hazard flight safety"_ref

DGAC - Paved with good intentions

Following this audit, the French Aviation Authority decided to revoke ATO accreditation give SAT a 3 months probation period to change its ways, concluding :

"Numerous discrepancies were found during the audit, asserting a lack of both professional maturity and enforcement in established procedures. The multiplicity of aforementioned discrepancies would be such as to put ATO certification into question. However [...] new Head of Training [...] firm will to improve [!]".

Changes must have been conclusive since SAT still operated to this day EXCEPT ORA.GEN.210 (a), financial viability, that proved non-existent.
Sources close to another ongoing legal dispute involving SAT confirmed:

"[...] SAT had a negative balance sheet of 140,000€ by the end of its first year [...]"

In other words, the DGAC tolerated deviations to rescue a business when ultimately said business was bound to leave its "clients" on the hook in what probably ended up as a ponzi scheme (a money sink, new entrants' money covering other participant's liabilities).

What scenario will unfold? Will DGAC bureaucrats man up should SAT bankruptcy occur? Will the students be offered a solution/recover their investment provided it hasn't vaporized? We're not holding our breath.

edit Dec 6th: and sure enough...

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Frontrunning: October 28


  • June 9: previously covered French National Assembly question met answering over state sponsored elite ENAC pilot training's relevance. School arguing EPL program already at industrial minimum, with further tightening to trigger "long term damaging loss of [both] expertise [and] national credibility at European level". (Assemblée Nationale)
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P2F baron & the FBI

With now more than a year under our belt on p2f (5 months after the official campaign kicked in), we gathered enough information to expose the enablers.

Since most media are quick to report the trees for the forest like the Germanwings 4U9525 crash (outing copilot Andreas Lubitz as an outright psychopath without questioning our industry)*, today is our turn to focus on the "trees" to sort the bad apples out, starting with:

Founded in September 1995 with CEO Jean-Marc René Bollinger, former Continental Airlines pilot (picture above), and headquartered Miami FL --like Stephane Hoinville's EagleJet (and former spearhead Gulfstream International)-- , this company offers services such as Cockpit and Cabin Crew training for which, as of 2015, the pilot training offer could read as follows:

fullscreen english translation

Ludicrous commercial deception aside, one learns WAS has allegedly delivered "over 2000 pilots to airlines worldwide including Air Gabon, Air Madagascar, Asiana Airlines, China Southern Airlines, Hainan Airlines, Hong Kong Airlines, Royal Air Maroc, TAAG (and many more)" with a training for which:

"there is nowadays in France a lot of polemic going on about [...]"

The catch? After a "line training [...] at the candidate's expense" (pay-to-fly - p2f), you are supposedly entitled to an employment "official letter" to secure an employment? interview (example given of Hong Kong Airlines)!

The man behind this program...

In light of such business innovation, is it fair to assume our entrepeneur's character would reflect on him? Fast backward July 8th 2006.

That Saturday afternoon, an Air France flight 95 was supposed to leave from Miami International Airport to France, but police were summoned to the airport after they received a call from a man who said his wife, a Lebanese citizen, was a threat to the safety of the flight.

A few minutes before it was scheduled to take off, that man (with their 17-month-old daughter) went to the Air France ticket counter and said that his wife, who was onboard, planned to blow up the plane, saying at first that she was angry about the arrest of a Lebanese citizen in a terrorist plot, and that she had said that "les américains allaient voir ce qu'ils allaient voir".

All 400 passengers onboard were evacuated. Investigators found the woman, who was traveling to Lebanon, and questioned both her and her husband.
FBI agents said that during the interview, they found out the woman never made any type of threat and instead arrested her husband, Jean-Marc Bollinger.
It was determined that the woman wanted a divorce (she showed bruises that she claimed were from her husband hitting and pushing her) alleging he abused her and wanted to go to Lebanon with the couple's daughter, but that Mr Bollinger refused, making up the story about the threat to try to keep his wife from leaving on the flight, as he later confessed.

French Bollinger was arrested and charged with criminal mischief and filing a false police report, avoiding several years in jail.
Incidentally, the mishap is said to have cost Air France $15,000 in operating costs while the plane was delayed and searched (no word as to whether his wife took another flight).


Seq No. Charge Charge Type Disposition

  • ID: 66145180
  • DOB: 9/14/1959
  • Court Case No: F-06-022316
  • State Case No: 13-2006-CF-022316-0001-XX
  • Date Filed: 7/10/2006
  • Date Closed: 10/17/2007
  • Warrant Type: N/A
  • Assessment Amount: $0.00
  • Balance Due: $0.00
  • Stay Due Date: N/A
  • Hearing Date: N/A
  • Hearing Type: N/A
  • Court Room: REGJB - JUSTICE BUILDING, ROOM No.: 2-3
  • Court Address: 1351 N.W. 12 ST
  • Previous Case: N/A
  • Next Case: N/A
  • Defense Attorney: MAULTASCH, RANDY
  • Bfile Section: F021
  • File Location: SCANNED
  • Box Number: N/A
  • Probation Start Date: N/A
  • Probation End Date: N/A
  • Probation Length: N/A
  • Probation Type: N/A
  • Defendant in Jail: N
  • Defendant Release To: HARVELL/ILM
  • Bond Status: DISCHARGED
  • Bond Issue Date: 8/24/2006
  • Bond Amount: N/A
  • Names / Aliases: N/A your pilot "provider"?

There you have it. While the picture above is probably the closest thing pilots will ever witness to a p2f felon behind bars for abject labour law discrepancies profiteering, that such a "colorful" profile could -and still does?- provide pilots to airlines (simultaneously preying on his kin) is beyond belief.
From there, with an added value of "zero", the need for intermediaries and brokers is anyone's guess (particularly after such blatant displays of integrity and candor). Sure, pilots are screened against criminal records, though perhaps it is time we come to realise criminals/psychopaths are not necessarily where we're led to believe.

* Except for these articles in The Atlantic, The Conversation, Boulevard Voltaire and excellent Global Research, notably.

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Enter Air “training offer” – survey

Van: "Renata Lasota" <>
Onderwerp: Enter Air training offer - survey
augustus 2015

Dear Pilot,

We are pleased to inform that we are planning to launch new training program soon. Therefore, we would like to carry out a survey on the basis of which we will prepare an offer which would meet expectations of the candidates interested.

If you are interested in performing training with us, please fill the questionnaire attached and send it back together with your up-to-date CV with a photo, a copy of your license and a copy of your passport to the address: till: 31.08.2015

On the basis of the questionnaires received, we will prepare an offer which will be suitable for the highest number of candidates. The program will be ready in autumn, and the start date and place of the training has been initially planned for October, Warsaw, Poland.

Please bear in mind that filling in the application does not oblige you to undertake the training. The survey concerns preparing a training program and it is not a job offer. [CockpitSeeker: emphasis added]

We are looking forward to your response!

On behalf of Enter Air Training Department,

Renata Lasota

Flight Crew Training & ATO Specialist
Enter Air Ltd.
Okęcie Business Park
ul. 17 Stycznia 45B, 02-146 Warsaw, Poland


Enter Air Sp. z o.o. Al. Krakowska 106; 02-256 Warszawa, zarejestrowana przez Sąd Rejonowy,
XIII Wydział Gospodarczy dla M. St. Warszawy pod numerem KRS 0000339408,
kapitał zakładowy 3.120.000 PLN, NIP: 701-020-69-59, REGON: 142051272

UWAGA! Niniejsza korespondencja ma charakter ściśle poufny i przeznaczona jest wyłącznie do wiadomości adresata. Jakiekolwiek jej rozpowszechnianie, czytanie, kopiowanie lub korzystanie przez osobe inna niż adresat, bez jego wyraźnej zgody jest wzbronione i jako naruszenie tajemnicy korespondencji może stanowić podstawę do pociągnięcia do odpowiedzialności.
ATTENTION! This information contains strictly confidential or privileged information. It is intended only for the addressee. Any distribution, reading, copying, or use of this communication by anyone other than the addressee without his explicit consent is prohibited and may give rise to liability.

At a time we thought pilots barely have a choice (in the aviation industry), it turns out EnterAir proved us wrong!
Would you rather pay to work with or without a Type Rating with them? Hmmm...

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Banks, schools & the training scam

With the MSM (mainstream media) catching up to industry fact that the pilot-shortage narrative might not be that simple after all, this July 21th both CNN and CNBS (in a lesser extent - UAE media totally disqualify) ended up suggesting "finding a first job can be tough".

Today we will cover the bank "angle" (pun intended) and prove flight schools contractually oblige newly trained pilots to engage in p2f to fake employment-record-improvements to secure more loans for more students for more profit.

ABN AMRO - weak safeguards amidst "confusion"

Being "the only Dutch bank to offer loans to trainee pilots" in an economy where "pilots [...] have been unable to earn enough to pay back the debts because of the economic downturn and the arrival of budget airlines [...] which pay far less than flag carriers", it was only a matter of time before issues arise.

Sure enough since August 2011, a group of 40 pilots triggered court cases (still ongoing) for failure in the bank's duty to oversee and implement adequate loan provisions (after having sought fair settlement on debt restructuring). ABN AMRO reportedly assumed:

"the market is improving and a shortage of pilots is on the cards"

...soundbite that doesn't add up with Mr F.C. Schoenmakers' confidential letter to numerous Dutch flight schools (Stella, CAE and EPST) :

English translation*

"[...] we shall further tighten the criteria [...] to the granting of credit for students of the training institutes. The reason for this is the rising number of unemployed prospective commercial pilots".

A few months later in December 2013, Mr Schoenmakers became "immediately available" on the job market...

CAE OAA & EPST - in for a penny, in for a pound

The only Dutch loan provider tightening loan criteria with the addition of new measures (as of January 1st 2013) among which:

"As soon as the number of students on the waiting list of your training institute is higher than 10 [...] A new student will only be eligible for a loan when two students have been placed".

it became paramount for flight schools to "place" their pilots so as to not diminish their cash flow student number. Where? CAE OAA (CAE Oxford Aviation Academy), sister company of CAE --already involved in p2f with Ryanair-- and EPST (European Pilot Selection and Training) have one clear solution:


... the kind of "job offer" where:

  1. a fee of £100 is chargeable for Stage 2 of the assessment process (non-­refundable).
  2. A fee of £150 is chargeable for Stage 3 (also non-refundable).
  3. The pilot must self-fund Type, Base and Line Training including VAT at a cost of £38,400.
  4. Living expenses during this time will meet neither salary nor compensation.
  5. The pilot must set his own limited company and get hired through the intermediary agency CAE Parc Aviation (another CAE sister company), because let's face it, you didn't think the airline would later hire you directly, did you?

No, not Ryanair, just EasyJet's take on modern day slavery "pay-to-fly" of course, and to top it all, you can't escape the rape program since according to the foreword translation*:

"You are contractually obliged to participate in placement"

Our readers can now simultaneously guess how those EPST students were "placed" and what that ABN AMRO's "improving market" and "shortage of victims pilots" really is.

Verdict - banks raise, schools bluff, pilots fold

Conveniently dropping the excuse that Type Rating and Line Training are just training (what we have been saying for years) to count those "opportunities" as "placement", flight schools found the perfect mean to defraud banks and bypass any of their criteria based on job finding. Banks unable (unwilling?) to tell the difference become (willful?) accomplice by perpetuating schools' scam, loading pilots with more debt for short term profit, with no incentive to dig deeper since real safeguards would impede their conducting business too.

In this poker game of lies and deception, pilots have the worst possible hand: they no longer decide to pay-to-work or not, they are now forced to, by contract.

*All Dutch translations from a sworn certified translator for the English and Dutch language at the district court of Amsterdam.

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