ATPL Validation with PC12 PPC and IFR renewal

FA28 guy · Post by **FA28 guy** » Wed Mar 24, 2004 1:02 pm

Just found out that if you have an ATPL and renew your IFR with a PPC on a single engine like a PC12 TC sends you back a Commercial Licence. That's because it's a group 3 IFR instead of a group 1make the ATPL not valid. Any body got any ideas or stories.

Panama Jack · Post by **Panama Jack** » Wed Mar 24, 2004 1:36 pm

Really? I can't figure out why that would be???

401.34(1) Subject to subsection (2), the holder of an airline transport pilot licence - aeroplane may exercise the privileges of a private pilot licence - aeroplane and a commercial pilot licence - aeroplane.
(amended 2001/03/01; previous version)

(2) The holder of an airline transport pilot licence-aeroplane endorsed with a Group 1 instrument rating may, while engaged in providing a commercial air service by means of an aeroplane of a class and type in respect of which the licence is endorsed with a rating, act as
(amended 2001/03/01; previous version)

Further:

401.47 The holder of a licence endorsed with an instrument rating may exercise

(a) the privileges of the licence under IFR in accordance with Part VI, Subpart 2, Division VII in respect of the group of aircraft endorsed on the licence; and

(b) the privileges accorded by a VFR OTT rating.

As far as I can read, they should not revoke your ATP (which is what they are doing). Yes, you don't have ATP privledges anymore according to the CAR's, however, you are still an ATP. What they've done seems equivalent (to me at least) of them revoking any non-current type ratings from your license:

(4) Experience

An applicant shall have met the training requirements for the issue of a Commercial Pilot Licence - Aeroplane that is not restricted to daylight flying and completed a minimum of 1500 hours total flight time of which a minimum of 900 hours shall have been completed in aeroplanes. The total flight time shall include a minimum of:
(amended 2000/09/01; previous version)

(a) 250 hours pilot-in-command flight time in aeroplanes which shall include where applicable, a maximum of 100 hours pilot-in-command under supervision flight time completed in accordance with Section 421.11. The pilot-in-command and/or pilot-in-command under supervision flight time shall include a minimum of 100 hours cross-country flight time of which a minimum of 25 hours shall have been by night;

(b) 100 hours night flight time as pilot-in-command or as co-pilot of which a minimum of 30 hours shall have been acquired in aeroplanes;

(c) 200 hours cross-country flight time as co-pilot in an aeroplane required to be operated with a co-pilot or, 100 additional hours cross-country flight time as pilot-in-command which may have been part of the 250 hours pilot-in-command flight time specified above; and

(d) 75 hours instrument flight time of which a maximum of 25 hours may have been acquired in approved instrument ground trainers and a maximum of 35 hours may have been acquired in helicopters. Instrument ground time shall not be applied toward the total 1500 hour flight time requirement.

(5) Skill

(a) Within the 12 months preceding the date of application for the licence, an applicant shall demonstrate in a multi-engined aeroplane with no central thrust configuration and fitted with instruments and equipment suitable for IFR flight in controlled airspace, familiarity with and the ability:
(amended 1999/03/01; previous version)

(i) to perform both normal and emergency flight procedures and manoeuvres appropriate to the aeroplane in which the flight test is conducted; and

(ii) to execute all manoeuvres and procedures set forth in Division XIV for issue of a Group 1 instrument rating.

(b) For initial issue of the Airline Transport Pilot Licence - Aeroplane Category, the Minister shall only endorse a Group 1 Instrument Rating on the licence.
(amended 1999/03/01; previous version)

Under 5(a) remember, you are not applying for a license, rather simply for the renewal of a rating. These are two separate issues.

Ireton · Post by **Ireton** » Wed Mar 24, 2004 1:45 pm

Well put forward PJ, I was about to start quoting the same myself.

I had a discussion with a friend who flies the PC12 who said the same thing about not being able to hold a commercial licence, but didnt believe it, thinking of those same regs. Apparently though, at this company, the folks who only fly the PC12 all hold commercial licences.

Doc · Post by **Doc** » Wed Mar 24, 2004 1:53 pm

But you can hold an ATPL and fly an Apache!!!!! Only in Canada!

Cap'n P8 · Post by **Cap'n P8** » Wed Mar 24, 2004 2:10 pm

Question,

If they do send you back a CPL. Will you automatically get the ATPL back as soon as you do your next Group I ride, seeing as how you have already held an ATPL, or is it more complicated than that?

Just asking 'cause it took me something like three or four months to receive mine the first time around!

FA28 guy · Post by **FA28 guy** » Wed Mar 24, 2004 2:23 pm

If you hold the single for more than 2 tears you will have to redo the exams and reaply. The system is crazy I think the commputer automaticaly reissues a commercial with a group 3. I'm sure TC will look at it some day

Panama Jack · Post by **Panama Jack** » Wed Mar 24, 2004 3:36 pm

I agree with the problem FA28 guy. It really is inconsistant and, at least the way I read it (I'm not a lawyer), Transport is not following the regulations as they are written (someone is mis-interpreting them). I wonder whether this is just a problem at a Regional Office or nation wide?

A scary prescident. By this logic, I could have my ATP revoked and reissued a Commercial License simply because I am a First Officer. Furthermore, they could pull my type ratings from airplanes I've last flown years ago (since I didn't qualify for them lately on PPC's).

Of course, the other solution is to find a guy with a Seminole or Duchess and do a Group 1 renewal ride, but why should you have to???

I would pursue the issue if I were you FA28 guy (but then again I am in a cranky, irritable, arguementative mood today). Go see Cat Driver for some counselling. He'll coffee you up and give you lots of advice.

FA28 guy · Post by **FA28 guy** » Wed Mar 24, 2004 3:48 pm

First this is not happening to me I'm lucky enough to have access to a few nice twins. Also I don't fly a PC12. This has happened to everybody that has renewed there IFR rating with a single engine PPC. I think It happens because the computer sees that it's a group 3 IFR renewal and has code not to issue or renew an ATPL unless its a group 1. The problem is buy renewing the IFR on a single even a PC12 the ATPL standards or a twin IFR are not met and you are as good as your last renewal in this case group 3. anyway bearskin pilots in this area are having the problem. You still keep your type rating just not multi IFR. Are we having any fun yet?

Dockjock · Post by **Dockjock** » Wed Mar 24, 2004 4:24 pm

I agree it sucks, but I don't see how it is in contravention to the regs. They clearly state that in order to hold an ATPL, you must have a Group I IFR. With a ride on the PC12 you get a group 3 therefore no current group I.
This happened to me from a Caravan PPC renewal. I still had 6 months left on my group I validity, did the ride and essentially had my group I "revoked". I discussed this with transport and the reason that happened is because you cannot hold 2 different classes of license at the same time (ie. group I valid to x, group 3 valid to y and so forth).
You can choose to NOT have your PPC ride count as an instrument renewal, but this typically increases training costs for your company due to the reduced validity period of your IFR and is usually not done (unless you are regularly flying a twin as well in which case no problem).

Frustrating? Yes. Against the CARs or wrong interpretation by TC? Unfortunately not.

oldtimer · Post by **oldtimer** » Wed Mar 24, 2004 5:31 pm

this is the way it has been for many years and you would think TC would change things. Many moons ago, I renewed my IFR in a Cessne 337 Huff Puff and that droped my down to a Senior Commercial. Now, the Senior Commercial is no more so I would have dropped to a Commercial. This is what the SC licence was all about. If an Air Carrier had transport category airplanes, such as a Canso that was flown VFR only, the chief pilot required an ATR but with no instrument rating, no ATR. hence the Senior Commercial. I dropped to a SC till I renewed in a Navajo and got my ATPL back just by asking. Once an ATPL, always an ATPL unless you let the Group 1 IFR or medical lapse. Didn't bother me cause I was flying a single privatley so a SC was good enough. When the company upgraded, I renewed to Group 1 but stayed SC till I needed it and they gave it back to me. This was over a period of 7 or 8 years. Mind you this was before the CARS. Some might say even before the wheel, but that's another story.

FA28 guy · Post by **FA28 guy** » Wed Mar 24, 2004 5:41 pm

Oldtimer (i'm probably as old as you are) The SC had the same exams as the old ATR that's why you didn't have to redo the written. The commercial doesn't have that advatage therefore if the exam expires by more than 2 years from going to a commercial the ATPL exams have to be redone the same as expiring an IFR rating or instructor rating for more than 2 years. That what I find crazy.

oldtimer · Post by **oldtimer** » Wed Mar 24, 2004 6:29 pm

FA28 guy. Don't tell me your the same age as the pile of dirt outside your window!!! Because I am.(63). You were right about the exams, I never thought of that. I thought that once an ATPL, always an ATPL but I guess that sounds too reasonable. Stupid idea that accomplishes nothing. TC teaches their people to be like computers. No reasoning, Black is black and that is all there is to it. Imagine, some dumb pilot would actually have the nerve and hutspa to come to US!!! TRANSPORT CANADA!!! YOUR GREAT WHITE FATHER!!! with some scatterbrained idea that acually makes sense. The nerve of some people. Does that sound close?

ndb · Post by **ndb** » Wed Mar 24, 2004 7:27 pm

This is pure and unadulterated communism.

To get your ATPL back, the idiots at Transports are going to ask you to write the SARON/SAMRA again, as well do a group 1 ride, because you only have a commercial.

However, if you just let your instrument rating lapse entirely (no group 3 ride) you would still have an ATPL, just without instrument privileges. Then all you would do to get your full ATPL back would be a group 1 ride - no written exams required.

But in the first case, where you've kept up a (single-engine) instrument rating, you're punished for keeping current by Transport into writing the ATPL exams again.

Nothing those crazy bastards do surprises me any more.

jimmyjazz · Post by **jimmyjazz** » Wed Mar 24, 2004 7:34 pm

If you read it thouroughly (pertinent part is in pj's post) it says for initial issuance of an ATPL only group1 ratings will be endorsed and they must have completed a ride in a non centreline thrust multi within the previous 12 months(so if you have a valid group1 but it's in the second year of validity you'd need to do a multi ride before issuance). They then go on to describe the duties you may perfom if your ATPL no longer has a group1 rating. While an instrument rating is requiered to keep an ATPL valid group1 is only requiered for the initial. If transport is pulling A's because you are now flying a Caravan or Pilatus that is wrong and easily proven it's one of the first things I've been able to find a clear answer on in the cars and in the standards. I would definetly argue this point with TC.

Cat Driver · Post by **Cat Driver** » Wed Mar 24, 2004 7:45 pm

O.K :

I have had enough of you guys bad mouthing the regulator.

Unless you cease and desist such ravings I will be forced to lay a complaint to the administrator of Avcanada that you are stealing my place on Avcanada.

I mean after all I would think I should have something left to show for all those years beavering away outthinking aircraft.

Cat

ahramin · Post by **ahramin** » Wed Mar 24, 2004 7:57 pm

This is crazy. Arm yourself with a copy of the CARs and fight this. There is nothing in the CARs that states that you have to renew your ATPL, so how can it lapse, other than the recency requirements which are the same for all licences. The skill requirement for the ATPL is required to issue it. Once it has been issued you have it plain and simple.

The first time it is issued it must be endorsed with a Group 1 instrument rating. This does not mean that the endorsement is part of the licence.

Are you required to write the exams every year? Of course not. Because it is required for the initial issue of the ATPL. By the same token there is no need to meet the skill requirements every year.

This is the result of a computer program which has been improperly programmed. We call it a bug. The bug is there because of an error in the Requirements Specifications. So just because the software engineers did not think this all the way through does not mean you just roll over and let TC flout the CARs.

I just went through CAR IV to check all this so if i have missed anything someone please point it out.

1. The ATPL is a licence, like the commercial or private.

2. Once a licence is issued it does not need to be renewed. Recency requirements (CAR 401.05) apply as do medical requirements (CAR 404.03) equally for all licences but a licence does not need to be renewed.

3. The instrument rating is an endorsement on a licence. Period. It is necessary for the initial issue of the ATPL, but just like the written exams, is not re-required afterwards.

ahramin

FA28 guy · Post by **FA28 guy** » Wed Mar 24, 2004 8:21 pm

The stupid thing is if you let the IFR rating expire completely since Transport is not reisuing the Licence or chaging it to a group 3 it stays as an ATPL. I had an old friend just renew his instructor rating but since his licence didn't say group 3 it stayed as an ATPL so it only goes to commercial if you stay current on a single engine. but expired is ok. (I still think 2 engines is better than one)

ahramin · Post by **ahramin** » Wed Mar 24, 2004 8:33 pm

Madre de Dios FA28, Tom did my multi ride. You're not old, you're antediluvian.

Like i said, it is not an interpretation, it is a computer bug. But i cannot say i am surprised that everyone is just bending over and taking it. Losing your ATPL to a computer bug is probably mild compared to what some of us are accepting from the both industry and TC.

ahramin

Cat Driver · Post by **Cat Driver** » Wed Mar 24, 2004 8:41 pm

Ahramin :

If these guys are old, where does that put me?

Cat

ahramin · Post by **ahramin** » Wed Mar 24, 2004 8:53 pm

Well ., at first i thought quondam or superannuated, or in your more lucid moments venerable. But as i know what you look like i can say with veracity that there is only one phrase which accurately describes you:

Well Marinated.