TC will not issue me an ATPL-H, because of aircraft type.

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Gilles Hudicourt
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Gilles Hudicourt »

CropDuster wrote:Not all military aircraft have civilian certification
This one does:

http://easa.europa.eu/system/files/dfu/ ... 012012.pdf

But not yet in Canada
CropDuster wrote: As many of you may know military pilots are just that, military pilots. Different flying, different rules, different equipment.
From TC's letter:
Further to your ATPLH application received August 21, 2014 I have reviewed your application and logbooks and find you meet all the requirements to hold the Airline Transport Pilot License Helicopter License.
The OP meets all of TC's requirements. He did his ride in an EH-101, which has a civilian Type Certificate in Europe, in the US and elsewhere, but not in Canada.

He is not asking for an EH-101 Type rating on his licence, just for an ATPL(H).
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by PilotDAR »

People who wear our uniform, and step up to defend us wherever, and whenever get a bit of a "let" from me. I sure would not have the nerve to disallow the application as described, from a person whose fellow members are getting attacked in our own country!

There are people in our society who care for everyone else, and take a personal risk doing it. Military, police, fire, ambulance, and others. They should get the benefit of any grey zone our society has to offer. We don't weasel word these people, we step up in some small way for them.....
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Cat Driver »

Maybe these morons in T.C. do not think the military pilots are trained well enough to be civilian pilots?
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by CID »

This one does:

http://easa.europa.eu/system/files/dfu/ ... 012012.pdf

But not yet in Canada
Umm...sort of misleading. The links you provided in the last two posts basically re-enforce the fact that these really are military helicopters with no civil airworthiness certifications beyond a couple of special instances. The link above is related to a single serial number that was to be delivered for civil service. That helicopter now resides in a museum in the UK. That makes that type certificate about as useful as toilet paper.

http://www.airliners.net/search/photo.search?id=2259477

The other two type certificates you eluded to were for two serial numbers. One as a civil demonstrator and the other for the aforementioned Japanese public service. More toilet paper. Furthermore, none of those foreign type certificates are for the specific model flown by the Canadian Forces which is the CH-149. Not the -500 or the -510 or the -300.
Maybe these morons in T.C. do not think the military pilots are trained well enough to be civilian pilots?
That's not really the point is it? TCCA cannot(one of those Cs is "civil") issue a civil authority for an aircraft that has no civil type certificate in Canada. And that's a good rule. Civil airworthiness authorities set standards for aircraft for a reason and it's just not wise to "willy nilly" accept experience on an aircraft that hasn't been demonstrated to meet those standards. I'm not saying the fellow in question here doesn't have a good reason to have HIS experience considered but it would take some effort in the way of an MOU or other agreement between TCCA and the DTA to make it happen.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by PilotDAR »

it's just not wise to "willy nilly" accept experience on an aircraft that hasn't been demonstrated to meet those standards.
I see it differently. It's not will nilly to accept experience if it's an accepted military aircraft type. The military has its own very appropriate design standards, which I would think are at least equivalent to civil standards. An accepted military "public service" aircraft (as opposed to a military experimental aircraft) has got to be every bit as good. We're not sending our soldiers flying as passengers in unproven aircraft.

It would be willy nilly, were ATPL credit being given for flying experience on an amateur built aircraft of completely unproven compliance.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Cat Driver »

Exactly PilotDar:

I can maybe understand ISIS not giving due respect and acknowledgment to the flying skills of Canadian military.

I do not understand why any Federal employee would discriminate against the competency of their own military pilots.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by CID »

Pilot DAR, I would think that you would understand that the prescribed level of safety for normal operation of military aircraft is not the same as for civil aircraft. There are no "CFR 25" fighter jets and military operations are not bound to civil operating rules. The DTA (Canadian Military Director of Technical Airworthiness) only considers civil airworthiness standards in their fleet of aircraft that were originally designed under civil rules. It wasn't always like that but they found that they lost a great deal of money if they applied military modification and operation standards to civil airframes.

It's often impossible for aircraft designed primarily for military applications to be type certified by civil airworthiness authorities and the tiny percentage that can be, require a great deal of modification as evidenced by the EH-101/AW-101 history.

I liken this issue to having a driver apply for a license in Canada when his/her driving experience is exclusively in Malaysia. Apples and oranges.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Whiskey25 »

A couple of things I noted reading through the posts....

1. Having flown the Aurora, I believe there are quite few similarities with the L188. In fact I am sure that other pilots have had the L188 endorsed on the ATPL with only Aurora experience. BPF - I can tell you that without a doubt your L188 experience would be appreciated on an Aurora Sqn, at least by me

2. When I flew the Aurora there were 3 levels of command. Aircraft Commander allowed you to sign out the aircraft for training or ferry flights thus allowing junior pilots (as little as 5-700hrs) to gain much needed aircraft command experience without the added pressure and risk (ie low level tactical flying) of an actual mission. The next level of Pilot Command was the Patrol Aircraft Captain; at this level you were experienced enough to command the aircraft in all tactical missions and you should have all the qualifications to be a mission commander.

Both of the previous levels of AC are always held by pilots and are achieved over the course of 2 years with timelines and objectives that must be met to advance. Prior to being upgraded to each level, you must pass an intensive review board and flight test (the first one focussing on the aircraft and the second focussing on operations). Pilots or Navigators are appointed by the Commanding Officer to the position of Mission Commander and it should be based based on ones leadership ability and experience. The Mission Commander has more responsibility than the AC in some ways as his job doesn't end on shutdown. He or she is responsible and accountable for the mission effectiveness as well as 20-40 people while on deployment; essentially representing the Commanding Officer of the Sqn.

3. TC not recognizing a certain military A/C type isn't new. Every CF-18 pilot I've known had to go for a IFR ride in a rented twin of some sort in order to meet the requirements of the ATPL. Certain military aircraft are/were maintained to civil standards or have equivalent civilian types - King Air, Challenger, Airbus, even the Buffalo and Aurora making it a lot easier.

4. I do wish TC would make exceptions for certain things on a case by case basis though. I have over 700 instructional hours and held an A2 Instructional Category in the military (I believe that's equivalent to Class ll), but I can't get any credit because my rating expired more than 2 years ago. I like instructing and would like to do it for fun; I'm not asking to skip all the training, but I would like to do an accelerated (ie less expensive) course and be credited if I can demonstrate the ability.

W
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Gilles Hudicourt »

CID wrote:
This one does:

http://easa.europa.eu/system/files/dfu/ ... 012012.pdf

But not yet in Canada
Umm...sort of misleading. The links you provided in the last two posts basically re-enforce the fact that these really are military helicopters with no civil airworthiness certifications beyond a couple of special instances. The link above is related to a single serial number that was to be delivered for civil service. That helicopter now resides in a museum in the UK. That makes that type certificate about as useful as toilet paper.

http://www.airliners.net/search/photo.search?id=2259477

The other two type certificates you eluded to were for two serial numbers. One as a civil demonstrator and the other for the aforementioned Japanese public service. More toilet paper. Furthermore, none of those foreign type certificates are for the specific model flown by the Canadian Forces which is the CH-149. Not the -500 or the -510 or the -300.
There is nothing misleading. They are certified civilian in all of Europe and the USA. They have an unrestricted type certificate. The number of civilian actual airframes is irrelevant, it just means no one ordered any. If a US civilian operator wanted to order some today and operate them with 30 passengers, they could. The certification was done, approved.

In the past, Lockheed had gone through the FAA Type Certification process for the C-141 Starlifter, as the L-300. No civilian operator ever ordered any and the single airframe that was used to obtain Type Certification was later given to NASA. The number of Civilian L-300 built is irrelevant.

So the OP did his skills test in an Airframe that has a civilian Type Certification according to FAR and JAR 25, the same as Canada's.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by CID »

Gilles, read the type certificate for the -300. It's for a single serial number. Even if they made a second one they'd have to get it added to the type certifcate and again it's irrelevant because it's not even the same model as the Canadian Forces use.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Big Pistons Forever »

CID wrote:Gilles, read the type certificate for the -300. It's for a single serial number. Even if they made a second one they'd have to get it added to the type certifcate and again it's irrelevant because it's not even the same model as the Canadian Forces use.
I disagree with your assessment. The Griffon is recognized as a Bell 412 for the purposes of a type rating on a License, even though this model was equipped to a Military specification, has a unique to it model number and there is not one civil Bell 412 that is the same.

I think it is an entirely reasonable to apply to TC requesting that the Cormoront be designated as a AW101 for the purposes of licensing on the basis of the Civil type certificate issued to Augusta Westland for the AW101. TC will consider the request and either grant it, which solves the OP's issue, or deny it; in witch case the OP is going to have to do a ride on an approved helicopter.

Where is the downside of this course of action ?
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Big Pistons Forever »

Whiskey25 wrote:
4. I do wish TC would make exceptions for certain things on a case by case basis though. I have over 700 instructional hours and held an A2 Instructional Category in the military (I believe that's equivalent to Class ll), but I can't get any credit because my rating expired more than 2 years ago. I like instructing and would like to do it for fun; I'm not asking to skip all the training, but I would like to do an accelerated (ie less expensive) course and be credited if I can demonstrate the ability.

W
Holding an ATPL gives you the same credits as you would get with a valid RCAF A2 rating. You basically have the course requirements cut in half. The downside is you have to start as a Class 4 under this route, while you go straight to a Class 3 if you had the A2 qual.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Whiskey25 »

Sorry for the threadjack R901
Holding an ATPL gives you the same credits as you would get with a valid RCAF A2 rating. You basically have the course requirements cut in half. The downside is you have to start as a Class 4 under this route, while you go straight to a Class 3 if you had the A2 qual.
BPF do you have a reference, I don't recall seeing that one before. Not too concerned about being a Class 4

Never mind... found it. Back to your regular scheduled AvCanada...
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by CID »

Big Pistons, no issues there. TC has already stated that it would be OK if his time was on a helicopter with a TCCA type certificated counterpart. The helicopter in question doesn't have a TCCA civil counterpart.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by trampbike »

CropDuster wrote: As many of you may know military pilots are just that, military pilots. Different flying, different rules, different equipment.
You do realise that we still have to know, and have to comply with the civilian rules most of the time?
If I go fly IFR into Vancouver airspace, let me tell you they are not about to cut me any slack because I'm military...


CropDuster wrote: Just the same as if a civilian pilot wanted to walk into military operations with out training...
Quite different I'd say.


CropDuster wrote:Makes any sense?
No
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by PilotDAR »

Pilot DAR, I would think that you would understand that the prescribed level of safety for normal operation of military aircraft is not the same as for civil aircraft.
Ah, I do understand, the prescribed level of safety in the aircraft design standard is not the same. But not the same may not be better than, or less than, just different. We're not asking to operate the helicopter in a civil operating environment, we're asking that the qualified pilot of that type be credited the flying experience in it. I surely agree that there would be aircraft system and operational differences, but I don't accept that they would be so vast that the military qualified pilot could not find their way through the sky safely in the civil variant or similar. The applicant is not asking for a type endorsement on the non existent civil type, just the license to be endorsed upon qualification, on whatever type, following additional type training.

I liken this issue to having a driver apply for a license in Canada when his/her driving experience is exclusively in Malaysia. Apples and oranges.
Not so good an analogy. It is important to distinguish operating environment form vehicle being operated. This discussion focuses upon vehicle type, rather than operating environment as the basis of the applicant experience. If a soldier was trained to full competence driving one of those really cool big 6x6 trucks on our highways, would consider that experience to meet the requirements for a provincial driver's license? I sure hope so! The Malaysian license applicant could have type experience, but the environment experience might not be as applicable. That should get a review.

All that said, I stand by my suggestion that our military members deserve the benefit of the regulatory grey zone, when total experience is not is question.....
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by CID »

PilotDAR, good discussion.

With respect to "level of safety" you go higher or lower not "different". Different would imply an "equivalent safety" which is a term often used in aircraft certification for systems that don't fit perfectly with the definitions in the standards and guidance material. In Canada, the US and Europe (to name a few regions with civil airworthiness authorities) military aircraft do not need to meet the level of safety of civil aircraft. Know what the prescribed action for an electrical failure on an Alpha Jet is? Eject. Know any civil aircraft that could be certified like that?

The closest thing that we can compare to military aircraft in this context is the CL215/CL415. In operations other than fire-fighting they operate in the utility category and in fire-fighting mode they operate in the restricted category because in that configuration they can not meet the prescribed level of safety for normal or transport categories.

My Malaysian example was carefully selected. Here's why. In Malaysia, they drive on the left side of the road. The driver sits on the right hand side of the car. The cars themselves are not obliged to be safety tested....ever and the rules for performance, safety and environmental protection are more lax than in North America and Europe. The operating environment is largely uncontrolled by the authorities. You never encounter snow or ice but the sky opens up daily with heavy rains. So my analogy is a little deeper than the "conditions". You would be driving a car that was produced under completely different operational and safety requirements, in traffic that is not commensurate with North American traffic.

With respect to what our military "deserves", I tend to agree and as stated earlier, TC does provide some credit for helicopters with a Canadian civil counterpart. The issue is that this one the CH-149 doesn't so the inherent thing to pursue is an alleviation but that doesn't solve the problem of what type TC puts on his licence. They simply can not put a non type certificated type on the license. And no, Gilles, just because it's type certificated in another country doesn't help. Try to get an EMB-135 on your Canadian license....

The only way TC could even entertain such a thing is if they could strike up a special MOU between TCCA and the DTA for this case. It's not out of the question but it may just be easier for this fellow to buy some time on a type certified model or a military machine with a civilian counterpart.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Gilles Hudicourt »

CID, the OP does not want a EW101 type rating, just a Canadian ATPL, that TC is on record that he qualifies for.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Big Pistons Forever »

Gilles Hudicourt wrote:CID, the OP does not want a EW101 type rating, just a Canadian ATPL, that TC is on record that he qualifies for.
He doesn't qualify for it because he does not meet the requirements with respect to the skills test. If you are a CF 18 driver you can't use your last instrument RCAF ticket renewal ride on it as a means to meet the skill test requirement for the ATPL(A). I would say that TC is just being consistent here.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Cat Driver »

The skills level required by T.C. to get the ATPL is low enough that a pilot can start flight instruction right out of school and put in the required time in light single engine airplanes and a light twin and never actually fly in true IMC.

Having flown with many pilots over the past sixty years I will take a military trained pilot over a T.C. qualified pilot every time...all else being equal.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by CID »

Gilles, let's try this from another perspective. Let's say you are an FAA licensed pilot with an ATPL and you have the required experience, training, medial etc to have your ATPL "converted" but the only airplane you've ever flown is an EMB-135. Can the ATPL list the EMB-135 as a rated type? No. The EMB-135 is not type certificated in Canada so TCCA considers it no more than a collection of beer cans in tight formation.

In reality, they give it a bit more credit as they allow this beer can formation to fly in our airspace under the airworthiness agreements with various civil authorities.

They would likely still give the fellow the ATPL with some non-transport category, non-high performance single and multi aircraft.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Gilles Hudicourt »

Transport Canada issued ATPLs to a bunch of British pilots after these pilots made their skills test in a TC certified non flying tin box set on hydraulic jacks and whose instruments and the view outside its windows were computer generated but that had a TC issued registration and a TC "type certificate".

Yet the highly skilled and experienced SAR Cormorant driver is denied the same because his heavy tri engine IFR REAL helicopter, the most sophisticated in Canada, built to meet JAR 25 certication standards and that is type certificated in EASA (all of Europe), the USA and Japan, does not have a type certificate in Canada.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by CID »

Gilles, apples and oranges. The guidance material has provisions for granting TCCA ATPLs to foreign pilot with ATPLs under recognized airworthiness authorities. The British pilots you mention seem to be type rated on a civil airline that has a corresponding Canadian type certificate....not a military helicopter that doesn't. So what's your point?

That the British pilots were able to meet the requirements developed under the regulations?

Maybe next time Canada buys a military helicopter they should insist on the OEM obtaining a civil type certificate for the type or at least a comparable variant. That is if we have an extra few million to finance that.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by Cat Driver »

Yet the highly skilled and experienced SAR Cormorant driver is denied the same because his heavy tri engine IFR REAL helicopter, the most sophisticated in Canada, built to meet JAR 25 certication standards and that is type certificated in EASA (all of Europe), the USA and Japan, does not have a type certificate in Canada.
Gilles, using common sense does not work with people who have a cult like beliefe in the Canadian system.
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Re: TC will not issue me an ATPL-H, because of aircraft type

Post by CID »

Or you can be like some others here who work outside the regulations, get caught and spend a couple of decades complaining.
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