Commercial Solo Time Requirement

[Aviatard]

What possibly could be the justification for needing anyone to "supervise" it. You're out of radio range so how would it even be supervised?

Sorry Mr. Beef, I missed this post. Supervision doesn't mean you're listening on radio and monitoring every move the student is making. It's more about making sure the student has a reasonable plan for the flight, weather is appropriate for the trip and the like.

[photofly]

Here are some other ambiguities in the CPL cross-country requirements:

Can you break the journey overnight?
Can you break the journey up over several days, for weather?
Can you break the journey up over several days, for sightseeing?
Do the legs have to be consecutive flights in your logbook?
What if you have a mechanical defect - can you continue the trip in a different aircraft?
Or must you wait for the first one to be repaired?
Can you make other flights while waiting for the repair?
What if the repair takes a week - can you go home (or somewhere else) and then pick up the trip where you left off, or do you have to wait with the aircraft?
What if the repair takes six months? Can you still continue the flight?
If you decided to continue in a different aircraft, does it have to be the same type? Or even the same class?

[Bede]

In general the TATC gives considerable deference to the Minister's interpretation of his own regulations.

No they don't. The TATC attempts to interpret to ensure consistency with it's prior decisions (stare decis doesn't technically apply, but for all intents and purposes). TC policies have no bearing on the decision making process.

Take a look at the Auld decision released recently.

[7ECA]

Take a look at the Auld decision released recently.

Gosh, isn't that a slap in the face for the TC inspectors...

Guess we'll be seeing a re-write of 602.01 pretty soon, darn shame it isn't the catch all it used to be.

[digits_]

Take a look at the Auld decision released recently.

Gosh, isn't that a slap in the face for the TC inspectors...

Guess we'll be seeing a re-write of 602.01 pretty soon, darn shame it isn't the catch all it used to be.

They already did, it is now 602.01.1

Application — Remotely Piloted Aircraft

602.01 This Subpart does not apply in respect of remotely piloted aircraft.

SOR/2019-11, s. 15

Previous Version
Reckless or Negligent Operation of Aircraft

602.01.1 No person shall operate an aircraft in such a reckless or negligent manner as to endanger or be likely to endanger the life or property of any person.

SOR/2019-11, s. 15

[Aviatard]

Transport Canada has come back with an answer ...

*drumroll*

... it depends on whether the instructor who signs off the PTR is willing to accept these fights as legitimate entries. So, basically a non-answer.

Sigh.

[ahramin]

Photofly, as long as it meets the requirements in the CARs, I'd say yes to all. My flight involved backtracking, an aircraft swap, and 5 days in between legs and was accepted without question.

[digits_]

Transport Canada has come back with an answer ...

*drumroll*

... it depends on whether the instructor who signs off the PTR is willing to accept these fights as legitimate entries. So, basically a non-answer.

Sigh.

? That's a crystal clear answer. Just like all the other training: it only counts if an instructor signs of your PTR.

[photofly]

All it does is move the question along the line: now the question is, is an instructor permitted to enter solo time that he/she didn't supervise into a PTR, for the CPL requirements? And we're no further forward.

I asked Licencing. They pushed me off to an Operations inspector, who told me that the solo time must be done with reference to an instructor. The intention is that the dual time with the instructor identifies what the student needs to work on, and the solo time is used by the student to bring their flying up to CPL standard.

There are lots of unanswered questions, but I"m going to stop asking them, in case I get answers I don't like.

Photofly, as long as it meets the requirements in the CARs, I'd say yes to all. My flight involved backtracking, an aircraft swap, and 5 days in between legs and was accepted without question.

I agree with you, but that is not the response given in evidence by a TC inspector at a tribunal hearing. That it was accepted "without question" is evidence more that nobody looked, than that they looked and approved.

[digits_]

I'm curious, do you happen to recall which tribunal hearing that was? Would be nice to read the summary/decision.

[ShawnR]

Take a look at the Auld decision released recently.

Where can I find this? I googled variations but no luck.

[digits_]

Take a look at the Auld decision released recently.

Where can I find this? I googled variations but no luck.

https://decisions.tatc.gc.ca/tatc/tatc/ ... 2/index.do

There was a topic about this before. It's the one where a helicopter pilot landing at a restaurant gets written up by a new TC inspector "because he could have driven his car, just like everybody else" and the judge (is it a judge at this level?) gives the inspector a can of whoopass.

[digits_]

All it does is move the question along the line: now the question is, is an instructor permitted to enter solo time that he/she didn't supervise into a PTR, for the CPL requirements? And we're no further forward.

An instructor has to certify the candidate has followed XX hours of groundschool. In a case of self study, how do you know it actually happens? It's the same thing. There is no requirement defined to supervise self study of ground school, there is no requirement specified to supervise the solo CPL flight time.

[photofly]

Self study has the same issue, if you ask me, and I'd want to see copious evidence of the self-study having been done to consider asking TC if it counted as groundschool. Overall, I don't think that helps.

Requirement to supervise solo CPL flight time: I can see myself making an exception for the cross country - after all, a cross country trip is hard to argue with. But A TC inspector says the TC intepreration is that there is a requirement to supervise, and that answer will have to be good enough, at least for me. You can take it up with the tribunal yourself, if it comes to it. I personally don't have any doubt, given the ambiguity, with whom the Tribunal will side.

Here is the decision about interpreting a cross country:
https://decisions.tatc.gc.ca/tatc/tatc/ ... 2/index.do

Here is the relevant comment:

Under cross-examination, Mr. Milligan said that there is no definition of "flight" in the Canadian Aviation Regulations (CARs) but stated his view that a flight, for the purposes of Standard 421.26(4)(b)(ii), has to take place in a single day. His view was that a cross-country flight should be a series of consecutive flights. Normally he would expect to see three legs flown on the same day, unless a person was going away on an extended trip. He said his interpretation was the industry standard.

Now in this case, the decision didn't really hinge on when you could break the trip, but on whether you could return to base in between the legs. Nor do I know what Mr. Milligan would understand by "an extended trip". But this is just evidence, that someone, somewhere, in TC will take a stricter view of things than we might like, and one would then have to fight for a re-interpretation.

[digits_]

Thanks! Intersting read.
The decision did specify that a trip could be split over multiple days to wait out bad weather though.

It would be absurd to think that a pilot would not meet the standard if he or she chose to shut the engine down and stay awhile at one of his or her stopover points during a solo cross-country, or if he or she had to overnight at one of the stopover points due to unexpected bad weather, or chose to do an extended trip.

[photofly]

Yes - that's what the Member said. But it's not what the Inspector said, and you're dealing in the first instance with the inspector.

[5x5]

I'm confused a bit - the decision posted related to a PPL cross country and wouldn't apply to a CPL. I agree that a PPL should, and I think in almost all cases does, happen in one day and certainly under supervision. A PPL student typically doesn't have the skill or experience to venture very far on their own.

A CPL on the other hand can happen over numerous days and frequently is part of a longer trip that covers much more than the 300 mile minimum. The whole idea is to gain experience and a CPL student should be able to manage the planning details of overnighting and in-flight weather and everything else involved with an extended trip. I've never seen or heard any kind of objection to this.

[photofly]

I’m confident that somewhere there’s an inspector who doesn’t agree with you.

[Aviatard]

Dredging this up again. I had a conversation with another TC inspector that I happened to run into. The answer: no, the time doesn't count unless it was authorized by an instructor. So, to sum up:

- the time counts
- it doesn't count
- it depends on whether you can get an instructor to sign off on the times
- it depends on who you ask

Rules are difficult.

[rotorspeed]

So if we assume the cross country is supervised, not really a big deal since you'll be doing trainng at the school. Is it possible to be finite about just pic building. I remember back in the day people would rent a plane for a period and fly to places like California from BC to build pic time. It would be hard for an instructor to supervise all that, plus if you had to do it at the school how would you do longer flights over days to build time