ATPL: Multi-engine "class" rating?

[MRFarhadi]

Hey y'all,

Hope you're doing great.

In my ICAO to TC ATPL-A conversion process, I have come to a rather odd situation here and I probably need some wisdom

I have already did a Group 1 Multi-engine IFR flight test a couple of months ago for the purpose of ATPL-A issuance after doing all the 3 necessary written exams. An agent contacted me today and told me that I would need "another" checkride for a "Multi-engine Class Rating" under 428 schedule 7 which is totally separate from the Multi-IFR flight test I have already performed (428 schedule 8 ).

Is this true? I thought I would only need to comply with 421.34 ATPL issuance and this guy wants me to get a multi-engine class rating on top of that.

I'm kinda stuck here, and would greatly appreciate your help on this!


Kindest and wamrest,

[ruffdeezy]

If you don't qualify to convert your multi rating then you need to do a multi VFR test and then the multi IFR test
You cannot jump to a group 1 instrument rating from nothing but most examiners don't look at this

[DanWEC]

I'd politely ask for the written reference and a second opinion, as the CARS only outlines a requirement for a MIFR ride for an ATPL conversion as far as I remember. Granted, that part of my internal meat drive is about 10 years old.
By that logic you'd have to do every preceding license and rating down to ppl.
Did you do some sort of cadet program?

[MRFarhadi]

I'd politely ask for the written reference and a second opinion, as the CARS only outlines a requirement for a MIFR ride for an ATPL conversion as far as I remember. Granted, that part of my internal meat drive is about 10 years old.
By that logic you'd have to do every preceding license and rating down to ppl.
Did you do some sort of cadet program?

I did, around 8 years ago. Got my PPL, CPL, IR, ME, and two type ratings before getting my ATPL from an ICAO contracting state.
I politely asked about a reference, and the guy told me 421.38 (3) is the reference and if I don't agree, he can right away give me a refusal and that's all I truly understand that TC is the authority and they're the guys who interpret the law, but I have yet to see what would CARs say on this.

If you don't qualify to convert your multi rating then you need to do a multi VFR test and then the multi IFR test
You cannot jump to a group 1 instrument rating from nothing but most examiners don't look at this

I believe you're refering to 421.46 (2)(c)(i)(A). If so, doing a Multi-rating checkride doesn't make you legal to fly an IPC as a PIC until a Canadian license is already issued for you. This will cascade all the way to the very first license/rating you'd need to obtain, which the conversion process was established to prevent this very thing from happening. Correct me if I'm wrong, and I just wanna get down to the root of this issue.

[Big Pistons Forever]

If the OP already has a ICAO Multi Engine rating from a contracting state then CAR 421.38(3) (c) (i) 0r (ii) should apply.


(3) Multi-engine Class Rating - Requirements
(a) Skill
An applicant for a multi-engine class rating shall successfully complete a flight test as pilot-in-command of a multi-engine class aeroplane, in accordance with Schedule 7 “Flight Test for the Issuance of a Multi-Engine Class Rating – Aeroplane” of Standard 428 - Conduct of Flight Tests.
(amended 2012/02/19)


(c) Credits for Foreign Applicants
The holder of a pilot licence - aeroplane category, issued by a Contracting State shall be considered to have satisfied the skill requirements as set forth above, provided that the applicant:
(amended 1999/03/01)

(i) has acquired a minimum of 50 hours flight time as pilot-in-command in multi-engine aeroplanes during the 12 months preceding the date of application for the rating, or
(ii) has met the prescribed standards, of the State concerned, for issue of a multi-engine class rating during the 12 months preceding the date of application for the rating.

If the OP doesn't meet those requirements then yes they would have to do a ME Rating Flight test

[DanWEC]

I've done instruction for people doing conversions and was always under the assumption only a MIFR ride was required, so I just looked it up to refresh myself....

Under the section "Licensing for Foreign pilots" under ATPL, as well as the supporting 421.34 which it references, only a MIFR ride is mentioned.

You're doing an ATPL conversion, not individual or domestic ratings- those are what would be supported by 421.38. Very strange attitude as well from your point of contact. I'd request a review or even a TATC panel before shelling out $5-10k for a ME rating, though it is an incredibly easy one to do, just pricey.

Perhaps someone else here can give more info before ruffling feathers. I just know the way we've done them before, maybe they used to just slip through.

[MRFarhadi]

...
If the OP doesn't meet those requirements then yes they would have to do a ME Rating Flight test

Does anywhere in CARs explicitly mention the necessity of having a ME rating to be issued an ATPL-A? All the applications and requirements are set forth in 421.34.

[digits_]

You're doing an ATPL conversion, not individual or domestic ratings- those are what would be supported by 421.38. Very strange attitude as well from your point of contact. I'd request a review or even a TATC panel before shelling out $5-10k for a ME rating, though it is an incredibly easy one to do, just pricey.

I don't think anyone here, inluding TC, is claiming he needs to do a ME rating. They are claiming he needs to do a ME flight test. That won't cost 5 or 10k.

[TeePeeCreeper]

You're doing an ATPL conversion, not individual or domestic ratings- those are what would be supported by 421.38. Very strange attitude as well from your point of contact. I'd request a review or even a TATC panel before shelling out $5-10k for a ME rating, though it is an incredibly easy one to do, just pricey.

I don't think anyone here, inluding TC, is claiming he needs to do a ME rating. They are claiming he needs to do a ME flight test. That won't cost 5 or 10k.

That’s exactly how I interpret it as well.

TPC

[DanWEC]

Ok, I was posting that quickly... Ride only not training for rating, (Dead easy but still what....over a grand I assume.) but I still don't see how it's written that it's a requirement.

MIFR ride is written explicitly in the conversion section and it's the only one. It seems arbitrary to ask for a ME ride when the conversion covers everything else as a blanket.
I didn't go through with a fine tooth comb recently but that's always been my understanding.

Same info on some FTU sites, though far from official of course.

[digits_]

...
If the OP doesn't meet those requirements then yes they would have to do a ME Rating Flight test

Does anywhere in CARs explicitly mention the necessity of having a ME rating to be issued an ATPL-A? All the applications and requirements are set forth in 421.34.

No, but it specifies:

(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)
(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.

I suppose you could interpret that as (i) is more the VFR stuff, and (ii) is what you experience on a multi ifr ride. But I admit that's a very loose interpretation and I don't really agree with it, it's way too vague.

MIFR ride is written explicitly in the conversion section and it's the only one.

Which conversion section are you referring to? Contrary to for example the ME or CPL sectionm the ATPL section does not specify any credits for foreign applicants: https://tc.canada.ca/en/corporate-servi ... ars#421_34

[DanWEC]

MIFR ride is written explicitly in the conversion section and it's the only one.

Which conversion section are you referring to? Contrary to for example the ME or CPL sectionm the ATPL section does not specify any credits for foreign applicants: https://tc.canada.ca/en/corporate-servi ... ars#421_34

Those sections apply if you're looking specifically at individual ratings. This is a totally different animal- it's a blanket ATPL foreign licence conversion.

Take a look here and you'll see where I'm coming from, scroll down to ATPL if it doesn’t land on it:

https://tc.canada.ca/en/aviation/licens ... ts#airline

Why would they ask for a ME ride? It doesn't say, but is it assumed because you need one to do the MIFR ride? Why not then also a PPL ride? You need one to do a ME ride, and it doesn't say anything about that either, yet it's not required. So like I say, it's strangely arbitrary, and isn't written in black and white, and I know for a fact many people haven't had to do it. Strange.

[digits_]

MIFR ride is written explicitly in the conversion section and it's the only one.

Which conversion section are you referring to? Contrary to for example the ME or CPL sectionm the ATPL section does not specify any credits for foreign applicants: https://tc.canada.ca/en/corporate-servi ... ars#421_34

Those sections apply if you're looking specifically at individual ratings. This is a totally different animal- it's a blanket ATPL foreign licence conversion.

Take a look here and you'll see where I'm coming from, scroll down to ATPL if it doesn’t land on it:

https://tc.canada.ca/en/aviation/licens ... ts#airline

Why would they ask for a ME ride? It doesn't say, but is it assumed because you need one to do the MIFR ride? Why not then also a PPL ride? You need one to do a ME ride, and it doesn't say anything about that either, yet it's not required. So like I say, it's strangely arbitrary, and isn't written in black and white, and I know for a fact many people haven't had to do it. Strange.

I see. Seems like it just refers to 421.34 for every regulation. As I mentioned above, I think it comes down to satisfying 5 (a) (i). One could argue a multi ifr test only satisfies 5 (a) (ii). Perhaps that's a recent policy change?

421.34
(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)
(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.

[MRFarhadi]

The content of a group 1 MIFR test are available in 428 Schedule 8 and TP9939E. Both normal and emergency procedures, appropriate to the Multi-engine aircraft category, are exercised, making the use of a 428 Schedule 7 "Multi-engine class rating flight test" completely redundant and unnecessary to require.

[digits_]

The content of a group 1 MIFR test are available in 428 Schedule 8 and TP9939E. Both normal and emergency procedures, appropriate to the Multi-engine aircraft category, are exercised, making the use of a 428 Schedule 7 "Multi-engine class rating flight test" completely redundant and unnecessary to require.

Then why would the cars list both requirements separately?

There are many more emergencies and exercises that are executed on the multi engine class rating flight test, that are not demonstrated on a MIFR ride. Stalls, slow flight, steep turn, more single engine work, single engine go arounds.

[MRFarhadi]

Kinda getting speculative here, reading in between the lines of regulations. But, I can only surmise, by reading the following, that there's only one test to be performed for such conversion, with no mention to the currency of ME time of the applicant:

4. Meet the skill requirement by successfully completing a flight test in a multi-engine aeroplane (excluding centre-line thrust) suitably equipped for instrument flight rules (IFR) flight in controlled airspace.
Read CARs Standard 421, section 421.34, para. (5) to learn more.

Reference: https://tc.canada.ca/en/aviation/licens ... ign-pilots

[digits_]

Kinda getting speculative here, reading in between the lines of regulations. But, I can only surmise, by reading the following, that there's only one test to be performed for such conversion, with no mention to the currency of ME time of the applicant:

4. Meet the skill requirement by successfully completing a flight test in a multi-engine aeroplane (excluding centre-line thrust) suitably equipped for instrument flight rules (IFR) flight in controlled airspace.
Read CARs Standard 421, section 421.34, para. (5) to learn more.

Reference: https://tc.canada.ca/en/aviation/licens ... ign-pilots

That document tries to summarize the rules, but are not the regulations. The text refers to the paragraphs mentioned.
Ask yourself how you've satisfied 421.34 (5) (a) (i).


I do think that the TC inspector you dealt with is wrong with quoting 421.38 (3), that seems irrelevant to me. Not a nice situation to be in, that's for sure.

[MRFarhadi]

Kinda getting speculative here, reading in between the lines of regulations. But, I can only surmise, by reading the following, that there's only one test to be performed for such conversion, with no mention to the currency of ME time of the applicant:

4. Meet the skill requirement by successfully completing a flight test in a multi-engine aeroplane (excluding centre-line thrust) suitably equipped for instrument flight rules (IFR) flight in controlled airspace.
Read CARs Standard 421, section 421.34, para. (5) to learn more.

Reference: https://tc.canada.ca/en/aviation/licens ... ign-pilots

That document tries to summarize the rules, but are not the regulations. The text refers to the paragraphs mentioned.
Ask yourself how you've satisfied 421.34 (5) (a) (i).


I do think that the TC inspector you dealt with is wrong with quoting 421.38 (3), that seems irrelevant to me. Not a nice situation to be in, that's for sure.

As per explicit language of 421.34 (5) (a) (i), does this make Two flight tests, one under 428 Schedule 7 to comply with the first clause, and another under 428 Schedule 8 to satisfy the second clause, mandatory for everyone? Even for those who have 50 hours of ME time in the past 12 months.

p.s. Yeah. I feel sick to the stomach with the kind of unprofessional behavior I'm dealing with. I'm out here speculating, while the only communication I receive is [heresay] "You have to do it because I say so, and that's that."

[digits_]

What does your CFI / examiner say about all this? They usually have other contacts at TC that could possibly intervene.

[MRFarhadi]

Called him the day the agent told me all of this, he said just a Group 1 ME-IFR flight test suffices.

[ruffdeezy]

There is no 'conversion' of a foreign ATPL, if you meet the requirements then you get it
in order to get it you have completed CPL training requirements and have the experience and tests done
to do a multi IFR test - you have to hold a multi rating, if you don't have a canadian licence, then you need to meet the conversion requirements of flight test or 50 PIC within past year - this covers most people since most get a test every year.
but as said, since the CAR's have so many grey areas - most examiners just give the test and don't bother looking at what the history is for foreign licence holders.

[digits_]

to do a multi IFR test - you have to hold a multi rating,

That's how it's usually done, but it's not defined in the standards as a requirement.

[MRFarhadi]

Hey folks,

Dorval office got in talks with Ottawa and ...
*Drum Beats*
They said the ME flight test is *NOT* necessary. They issued the license right away, et voilla!

Kindest wishes to everyone who helped me through this and anybody who commented here.

Best,

[digits_]

Hey folks,

Dorval office got in talks with Ottawa and ...
*Drum Beats*
They said the ME flight test is *NOT* necessary. They issued the license right away, et voilla!

Kindest wishes to everyone who helped me through this and anybody who commented here.

Best,

Very nice to hear. Thank you for reporting your findings back as well!

How did you get them to review your file again? Did you just keep bugging the same person?

[DanWEC]

Hey folks,

Dorval office got in talks with Ottawa and ...
*Drum Beats*
They said the ME flight test is *NOT* necessary. They issued the license right away, et voilla!

Kindest wishes to everyone who helped me through this and anybody who commented here.

Best,

Glad to hear it!

That's always how I had proceeded with conversions. Happy you were able to push back. I'm genuinely a little concerned at the obstinate and omnipotent attitude of your contact if your description is true- that's not what we need in those roles. If inclined you can submit service feedback through the TC website. I'd encourage it actually.