General Aviation Pilot Licensing Review - Acceptable Means of Compliance (AMC) and Guidance Material (GM) to the UK Balloon Regulation

We asked for feedback on a proposal to amend the Acceptable Means of Compliance (AMC) and Guidance Material (GM) to the UK Balloon Regulation.

The consultation ran from 25 March 2025 to 6 May 2025. To help with the contextual understanding of the consultations, draft implementing rules were included for reference purposes only as per the Opinion and Instruction Documents (OID) submitted to the Department for Transport (DfT).

The implementing rules provided for reference had already been the subject of consultation in Phase 2 of the project. Stakeholders were reminded that while the legislative drafting process continued, the draft implementing rules should not be taken as the final wording of UK law as all amendments to legislation are subject to a drafting process by Government.

We received a total of eleven (11) responses to the consultation. We received full support for the crediting of coaching time.

The amendments/new AMC and GM for BFCL.130 received mixed support. Whilst most supported the changes to allow FI(B) to conduct training for student pilots outside of an ATO/DTO setting, some felt that the burden to keep paperwork was too much for an individual. Full support was given towards removing the tethered rating and including it within initial licence training. Strong support was given on the amendments to the syllabus although two were not comfortable with the 5,000 ft flight. Full support was given to the amendments for BFCL.135

We received strong support for the new AMC for BFCL.150(e) with regards to gaining a mixed balloon class, as well as strong support for the amendments/new AMC for BFCL.160 regarding recency. We did receive a couple of comments regarding referencing SERA.5005 rather than including the wording from SERA.5005. This has been done to future proof the AMC. If SERA.5005 changes in the future, then it is automatically incorporated instead of the CAA having to amend AMC to reflect any changes.

The new and amended AMC to support the separation of the Commercial Operation rating into two individual ratings, BFCL.215 (commercial non-passenger operation rating) and BFCL.220 (commercial passenger operation rating), received some support. The comments received related to the regulation change itself and were therefore not relevant to this consultation.

The new AMC for BFCL.315 was fully supported as were the amendments to the AMC for BFCL.330, with the exception of the 5,000 ft flight as previously expressed.

The new and amended AMC for BFCL.415 and the new AMC and GM for BFCL.470 were all fully supported. One respondent felt that we should restrict the number of Senior Examiners issued rather than issue to all FE’s with more than 1000 hours. This is already in the regulation itself (BFCL.470 -The CAA will appoint, where required, Senior Examiners (Balloons)).

We acknowledge the responses and thank the responders for their suggestions.

The need to consult with interested parties on the development of rules that could have important social implications is set out in the Basic Regulation. The consultation process is also inherent in UK law and consultation is widely used to support this principle.  

Conclusion

The CAA has now amended/implemented all of the proposed AMC and GM into Part-BFCL.