CPL skill test

[maxgolstreet]

I need help guys. I am going to complete my CPL training and I will have at the end 180 hrs. I know that I need 200 hrs to apply for the CPL license, but can I take a skill test with 180 hrs?, then do my IR and then apply for CPL with 200 hrs total.

I found an old thread in this forum about that, but I would appreciate your fresh recommendations.

[pudoc]

If you're training in the UK, Yes.

[packo1848]

Max,

Just done exactly that myself, and now on the IR, the only effect it has on the IR is the hours of training required. You would have to sit the 55hr hour IR as oppose to 45hr with a CPL issued. If you have access to some nice cheap flying it may work out cheaper to fly 20 hours extra hour building rather than another 10 in a twin/simulator (depending on how your school breaks it down). For me it broke roughly even, so I elected to shorten the time scale and get on with the 55hr course.

[BigGrecian]

If you're training in the UK, Yes.

Not in accordance with EASA Part FCL you can't.

There's a thread about this on the Examiner section of this website :

FCL 1030 - Pre-Requisites for EASA Skills tests (http://www.pprune.org/flying-instructors-examiners/514911-part-fcl-1030-a.html)

[b.a. Baracus]

When did this come in? i.e. skills tests carried out before / after which date?

[BigGrecian]

Was effective 17th September 2012 when the CAA implemented the EASA regs ( from http://www.caa.co.uk/docs/2330/Webrevisedv%20May12_17%20Sept_EASA_quickguide__v2.pdf )

Hence why there is a declaration on the application form which the examiner has to sign saying you meet licence issue requirements.

However some examiners and schools have been slow on the uptake, leading to some license issue problems.

[pudoc]

Not in accordance with EASA Part FCL you can't.

There's a thread about this on the Examiner section of this website :

FCL 1030 - Pre-Requisites for EASA Skills tests

Well me and I personally know about 50 people who have. My examiner never had an issue with it, neither did theres. No issues with license issue either from CAA. The only thing was I couldn't apply for the CPL license before 200 hours, but the test I did at 175.

Unless this has changed in the past 6 months. Or, the examiners didn't really know about this, which is likely as the CAA and EASA change things every 5 minutes and they can't keep up!

[2close]

There was an example very recently of an examiner refusing to test a candidate with <200 hours, despite having been recommended for test by the ATO.

You would think that this would be made crystal clear within CAP 804 for ALL to read AND understand without any ambiguity whatsoever.

There is no excuse for this, yet another example of shoddy regulation by those responsible. They have been told enough times by industry that CAP 804 is a mess - they should get it sorted!! :mad:

[BigGrecian]

There is no excuse for this, yet another example of shoddy regulation by those responsible

To be fair this regulations brings us closer to ICAO - in every other country I've flown in you have to meet license requirements at time of test.

[2close]

That's fair enough, BG, and it is about time that everyone was singing from the same hymn-sheet - my comment was related to yet another episode of ambiguity within the published document, for which there is no excuse.

Saying that, as a former CAA employee engaged in part in the checking of regulations pre-publishing I have personally witnessed us identifying errors to the legislators only to have our comments ignored and the regs being published with the ambiguities and 'loop-holes' in place.

Hence, I am not surprised! :ugh:

[Rishy]

I was told by my FTO recently (within the last month) that I do not need 200 hours total time before doing the CPL test, as long as all elements of the CPL course have been carried out. 200 hours is required for licence issue, but not for the test.

Moving onto the IR next, and will be in the same situation as packo1848 - will need to do the 55 hour course.

[BigGrecian]

I was told by my FTO recently (within the last month) that I do not need 200 hours total time before doing the CPL test,

They told you wrong.

Hence the point of this thread.

As some of the posts suggest the schools are behind on this and the exam cannot be conducted as it is clearly defined in Part FCL that you may not take the test. Examiners should, and are, refusing to test those who do not meet those requirments.

[2close]

Hi troops,

I have received it hot off the press this morning IN WRITING from CAA Policy that ALL requirements for licence issue MUST be met before a student can take a Skill Test.

Therefore, an applicant for a CPL(A) Skill Test MUST have 200 hours total time (plus all the other bits and pieces outlined in 1179/2011 Appendix 3).

:)

[Mickey Kaye]

Does this apply to PPL skills test as well?

[BigGrecian]

Does this apply to PPL skills test as well?

Yes in terms of the 45 hours total time, 25 dual, 10 solo etc.

See the reference in :

http://www.pprune.org/flying-instructors-examiners/514911-part-fcl-1030-a.html

[Mickey Kaye]

BG

Could you confirm that you are saying that the PPL skills test can no longer be part of the 45 hours eg the skills test cant be taken until the student has TT of 45 hours plus ten hours dual etc

Also if this the case are the CAA actually enforcing it?

[2close]

The EASA regs state that the requirements for licence issue must be met BEFORE the Skill Test can be taken - or at least, that is how they are being interpreted at Gatwick.

I would imagine that many instructors and examiners will interpret the requirements differently but you will run the risk of having a licence application returned from LSD FCL, should it land on the desk of one of the more 'officious' officers who goes through the paperwork and log book with a fine toothcomb.

Unfortunately, it is a lottery - some are more understanding and lenient than others and whilst this should never be the case with a regulator, it IS the case at Gatwick.

:rolleyes:

[b.a. Baracus]

In the case of flight test conducted and passed without the necessary experience for license issue and subsequently gaining sufficient experience? Please tell me they are not expecting the skills test to be taken again or something equally as ludicrous?

[Cirrus_Clouds]

Now to throw in a spanner in the works!

My FTO has had it writing from EASA that a student can sit a skills test without the full hours for CPL issue, with remaining hours can be built after the skills test before applying for licence. This was about 3 weeks ago!

EASA have also confirmed in writing of an "error" on a document created internally within EASA has been misinterpreted by examiners/staff etc, due to the admin person creating this document and wording it incorrectly; consequently causing this confusion.

I didn't progress with my CPL until EASA had confirmed back in writing the true facts.

And yes I've just sit my skills test and passed!

[2close]

CC,

Can you post the letter here, with ATO name removed of course; alternatively, PM me a copy and I will send it on to the Policy Officer at the CAA for comment.

I just love spanners!!! :)

[b.a. Baracus]

Yes a post of said letter would be useful.

More confused interpretations and mixed messages from CAA / EASA. Pardon my cynicism but I have not been impressed by what I have seen from EASA, inane Eurocratic bureaucracy pretty much sums it up in my opinion.

[BigGrecian]

My FTO has had it writing from EASA that a student can sit a skills test without the full hours for CPL issue, with remaining hours can be built after the skills test before applying for licence. This was about 3 weeks ago!

EASA have also confirmed in writing of an "error" on a document created internally within EASA has been misinterpreted by examiners/staff etc. due to the admin person creating this document and wording it incorrectly; consequently causing this confusion.

I call BS on this.

If they think differently an AMC would be issued.

Also even if they confirmed in writing it was a mistake - which is unlikely - as this is more like ICAO - then it's still law and we still have to abide by it.

The other states in EASA are applying this it's in their examiner briefings.

I think this is smoke and mirrors by the ATO to be honest but would love to be proved wrong.

[Cirrus_Clouds]

PM sent.

I haven't been dealing with this directly with EASA, my FTO has, so no copy of any correspondence - I'm only telling you what they have told me and they reinforced this during today when I discussed this with them.

Right now, I’m only caught in the middle and been told it's ok to proceed with training, which I am doing - as they have all in writing from EASA if any issues crop up.

To the poster above, you may call it BS, but you're not the one who has been dealing with EASA or also had a visit from a EASA representative confirming this directly with the FTO.

[BigGrecian]

but you're not the one who has been dealing with EASA or also had a visit from a EASA representative confirming this directly with the FTO.

No, but it's not my money on the line!

I also know in 5 other EASA states you must have the EASA licence issue requirements prior to test - because that's what Part FCL 1030 states!
I work with EASA on a daily basis and also been involved with a direct inspection from Cologne.

You on the other hand have a lot to loose, and more than just your money!

To be frank, I'm absolutely horrified that their word is enough - ask to see the correspondence - but then understand the correspondence itself is worthless if the AMC or GM hasn't been amended at : EASA - Acceptable Means of Compliance and Guidance Material (http://www.easa.europa.eu/agency-measures/acceptable-means-of-compliance-and-guidance-material.php)

Why not read the reference yourself and question them directly for the reference.

Remember as has been stated here some examiners are not conducting the tests when the applicant has less than the licence issue requirements - and the ATOs have nothing to loose - they've had your money after all - and then the applicant has been sent off to do 25 or so more hours hour building.

Don't say you weren't warned - I do hope your paying by credit card and can appeal the funds - but I guess you didn't get that in writing from the ATO either regarding their letter from EASA. :ugh:

I'm sorry for my frustration but you certainly won't be the first or last to be caught out by this.

PS their not called FTOs anymore - they're are called ATOs.

[2close]

I am completely in agreement with BG on this but I am not suggesting for one second that CC is incorrect in what he (assumption on gender;)) is stating has been reported to him by the ATO.

However, what BG states is absolutely correct; if there is nothing in black and white from EASA then any statements made are worthless and there lies the MAJOR problem.

It will be down to the competent authority, i.e. the UK CAA, as to whether or not the black and white regulations and AMC state one thing or the other and it will be their decision as to whether to issue the licence or not; and if they feel that the requirements for undertaking the Skill Test were not met at the time of taking the test then you can rest assured the application will come winging back to you with an instruction that you have to retake the test. Any pleas that 'we were told by EASA that...yada yada...' will simply fall on deaf ears.

As this appears to be gaining some momentum, I am taking the unprecedented step of copying the e-mail from the CAA below - these are the decision makers NOT EASA.

Dear (2close)

In reference to your email which has been forwarded to me for a response, I have set out clarification to your specific points below:

“I was informed on the weekend of a CPL Skill Test candidate at an ATO, who had fewer than 200 hours total time.

The examiner refused to conduct the test, stating that the regulations state that the CPL Skill Test candidate must have 200 hours total time before the Skill Test can be conducted.”

The examiner in this instance is correct. For applicants seeking a CPL (Modular route) licence, the requirements state that they must have completed all the training and relevant experience for the issue of the licence prior to the CPL skill test. The requirements were set out slightly differently under JAR FCL and when the text of Part-FCL was written (and throughout the consultation process) the requirement regarding the CPL experience is now stated for each of the CPL (integrated and modular) routes in Appendix 3 to Part-FCL. The implication for modular CPL applicants is that they must have all the CPL relevant experience requirements met prior to the skill test. The previous practice in the UK of completing the skill test prior to having the 200 total time, which was subject to interpretation under JAR FCL is now more defined under Part-FCL. Incidentally, while reviewing this issue with Flight Crew Standards, I consulted with the Heads of Training of ATOs outside the UK and they confirmed that the Part-FCL requirement of 200 hours before test was their interpretation under JAR, therefore the UK CAA was not necessarily aligned with other Member States. L&TS are currently drafting guidance information which will be disseminated by FCS to all flight examiners and by Approvals to all UK ATOs in the near future. Obviously there will be some individuals who find themselves unknowingly impacted by this clarification of the regulations and we will endeavour to provide this clarification whilst not disadvantaging any pilot currently undergoing their CPL modular training.

There you have it, in black and white from the people who make the decisions in the UK. Show this to your ATO.

Personally, if I was in your position I would not be happy until I had physically seen the correspondence from EASA. You are the one who stands to lose a lot, not them.

We are simply trying to help out to avoid future problems not to be difficult.

Best of luck with the remainder of your training.

:)

[b.a. Baracus]

As mentioned previously - what is the likely outcome of an individual who did not have the required experience for license issue, who had passed the skills test and subsequently gained sufficient experience for license issue?

if they feel that the requirements for undertaking the Skill Test were not met at the time of taking the test then you can rest assured the application will come winging back to you with an instruction that you have to retake the test

.... At considerable expense. Not an option for some. :uhoh:

Obviously there will be some individuals who find themselves unknowingly impacted by this clarification of the regulations and we will endeavour to provide this clarification whilst not disadvantaging any pilot currently undergoing their CPL modular training.

Does this mean the CAA may be sympathetic and allow a transitional period while the message is fully received and understood by ATOs / examiners and candidates etc?

We will see how this pans out but I hope it is met with some amount of common sense.

[2close]

BAB,

I can't say for certain but my (ample) gut feeling is that tests conducted to date will be honoured, owing to the ambiguity that appears to have pervaded this issue. It would be downright bl**dy minded to act in any other way.

I make this statement with the caveat that, it is a well known fact that you can ask the same question of four different people down at Aviation House and get four different answers so it would really be the luck of the draw as to whose desk the application landed on.

However, now that the issue has been well and truly flagged up, any future tests would indeed be on shaky ground and as soon as the Information Notice is sent out to ATOs and Examiners, that will firmly entrench the matter in concrete.

This situation has been created by nothing other than an inefficient misuse of the expertise that exists within the front-line industry coupled with atrocious document authoring by both EASA with Reg 1178/2011 and its Acceptable Means of Compliance together with that disgrace for a piece of authoritative literature, CAP 804, and the "competent" authorities should not be penalising individuals for their errors. It could all have been so easily avoided if the documents had been structured properly and if they had been submitted to industry for examination prior to release.

Apologies for the last paragraph rant.

:mad:

[BigGrecian]

I can't say for certain but my (ample) gut feeling is that tests conducted to date will be honoured, owing to the ambiguity that appears to have pervaded this issue. It would be downright bl**dy minded to act in any other way.

I have first hand experience of this.

They deny the application and send it back for a new signature in section 13 of SRG 1183 (http://www.caa.co.uk/application.aspx?catid=33&pagetype=65&appid=11&mode=detail&id=2615) - which if you read it specifically states that the applicant meets licence issue requirements.

If said examiner refuses to sign (which has happened) then it has to go through to the CFE and policy to be approved - which makes it a considerable delay = bad news if your waiting to start an IR and don't have a EASA PPL or waiting to apply for jobs.

This issue has been around since April time so I don't see how most wouldn't know. However I know of one school on the South coast which ignores this - and then the examiners refuse to test.

[spacemonkeys]

So my understanding after reading 2close's letter and CAP804 is that to follow the traditional route of cpl, me, IR. I would now need to have 175 hours before start of training to reach the 200 required for licence issue.

It seems to me that now it would be better to gain the 150 including night and 70 PIC.
Start with the Me 6 hour course (70 PIC Required),
Multi/IR 55hr course (10 basic 45 Procedural) PPL Required
Then finish with the CPL (I think with the IR this is only a 15hr course)

Actually thinking about it could you start at 124 as by the time you have the ME and IR sorted you would have 185, enough for the 150 cpl course requirement, then 200 by the end of the cpl course enough for licence issue?

Potentially saving enough from the hour building for an MCC or extra time in the twin?


Edit: Actually somewhere in those numbers you still need 100 PIC for CPL Licence issue

[2close]

Nearly there SM,

Unfortunately, FNPT II time cannot be logged.

Assuming the following start point and all completed in minimum hours.

150 hours TT; 100 hrs PIC

MEP CR - 6 hours + 1 hour Skill Test (157 TT; 101 PIC) - although no requirement for Skill Test if going straight on to IR(A)

IR(A) - 55 hours (40 FNPT II; 15 aircraft) + 2 hours Skill Test (174 TT; 103 PIC)

CPL(A) - 15 hours + 2 hours Skill Test (191 TT; 105 PIC)

Still 9 hours short. Personally, and this is merely my opinion, I would exchange 10 FNPT II hours for an additional 10 hours on the aircraft on the IR(A). 30 hours in the sim is more than enough to get to grips with the procedures but an extra 10 hours flying the actual aircraft is invaluable, especially if you've no complex time to start with. Of course, there would be extra costs but probably worth the outlay.

:)

[spacemonkeys]

Thanks 2close, that is probably the route I will go down.

However by the time I get to start the training the CAA should have sent out their notice to ATO's so it could all have changed again.

[spacemonkeys]

Are you sure FNPT II time can't be counted?

From CAP 804;

"8.2 STD time is creditable towards courses and licence issue but is not flight time and must not be recorded as such. STD time must be logged separately from flight time recorded in the log."

Under the CPL Experience requirements it only states that BITD can not be counted.

"(c) 10 hours of instrument flight instruction, of which up to 5 hours may be
instrument ground time in an FNPT I, or FNPT II or FFS. An applicant holding a
course completion certificate for the Basic Instrument Flight Module shall be
credited with up to 10 hours towards the required instrument instruction time.
Hours done in a BITD shall not be credited;"

Or am I just trying to look for loop holes now?

Cheers

[2close]

It is indeed a valiant effort SM and if it were my decision.......... :)

However...... :(

CAP 804

8.2 STD time is creditable towards courses and licence issue but is not flight time and must not be recorded as such. STD time must be logged separately from flight time recorded in the log.


EC Regulation 1178/2011 Annex I Appendix 3

EXPERIENCE

12. The applicant for a CPL(A) shall have completed at least 200 hours flight time, including at least:


So, the EC Reg is specific about a requirement for flight time and equally CAP 804 is quite specific that STD time is NOT flight time. Doh! :ugh:

You can complete 5 hours of the course on a FNPT II, thereby completing 20 hours on the aircraft but only 20 hours would count as flight time for licence issue.