reason for EASA CPL(A) modular 15 hour visual flight training requirement?

[akos.maroy]

Hi,

I'm a private pilot with just over 200 hours of experience, 8 hours on a multi engine (& complex) airplane, holding NVFR, SEP-IR, MEP & ME-IR ratings, with an ATPL Theory (all according to EASA) test behind me, and I'm considering getting a CPL.

Reading EU regulation No 1178/2011 for the requirements on a CPL modular training, I see in Appendix 3 Section E that I'm fit to go on a CPL modular training course, where I can get all my IR training time credited to the course among others.

But, paragraph 10(a) on flight training says (page 80 in the file found here: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:311:0001:0193:EN:PDF )


10. (a) Applicants with a valid IR shall be given at least 15 hours dual visual flight instruction.


I wonder, what is the rationale behind this?

I asked my 'usual' training organization, and they insist that indeed, there should be 15 hours of visual training, 5 of which is on a complex airplane (more on this later). I looked at their CAA approved training manual, this training covers the same topics are covered during my initial PPL training 3 years ago: traffic circuits, stalls, spins, turns, short cross-country flights. Moreover, 10 hours of this training can take place in 'any kind of powered aircraft', which literally would mean the same type I used for my PPL training (a Diamond DA-20)

Thus, I wouldn't be learning anything new during these 10 hours.

Does anyone know what the rationale behind this part of the regulation is?

I cannot think of anything else but subsidizing training organizations.


As for my FTO's insistence that I should also fly 5 hours with a complex plane during this training, even though I already have 8 hours on a ME complex plane, and the regulation lists 6 hours as a lower experience limit on ME planes for a CPL (paragraph 12(d)) - are they correct to require these 5 hours on their complex plane for this training?

for me, as I'd learn nothing new at all, and the insistence on the complex (hence more expensive) plane, it all seems like an attempt to get more money off me.


am I wrong? :)


with all fairness, I don't mind learning, and 200 hours is not that much of course. what would benefit me is to fly in a 'commercial-like' setting to large airports, and to experience how flying to & from these airports is done in real life. but this is something I wouldn't be getting during this training at all :(

[Rithalic]

How to operate an aircraft to a commercial standard and level.

[akos.maroy]

How to operate an aircraft to a commercial standard and level.

yeah, this would be my thinking, and there is a lot I could learn - but the training manual I saw at this FTO didn't contain anything of this sort. and it has been approved by the CAA :(

[Radix]

............

[BigGrecian]

CPL flying isn't that much different from PPL flying - the mentality is different though - have a read of standards document 3 at List of Flight Crew Standards Documents | Publications | About the CAA (http://www.caa.co.uk/standardsdocuments) and look at the aim - and it talks about demonstrating your ability to conduct a public transport flight, being commerically expeditious etc.

The 5 hours complex is mandatory as part of the CPL course - in Part FCL - appendix 3 Paragraph E part 11

11. At least 5 hours of the flight instruction shall be carried out in an aeroplane certificated for the carriage of at least
4 persons and have a variable pitch propeller and retractable landing gear

Thus, I wouldn't be learning anything new during these 10 hours.

This in itself proves how much you have to learn :O

Have a read of the 3 CPL diaries to help you:

http://www.pprune.org/professional-pilot-training-includes-ground-studies/108385-cpl-diary.html
http://www.pprune.org/professional-pilot-training-includes-ground-studies/176043-cpl-diary.html
http://www.pprune.org/professional-pilot-training-includes-ground-studies/377444-2009-cpl-diary-eft.html



Good luck on the CPL!

[akos.maroy]

CPL flying isn't that much different from PPL flying - the mentality is different though - have a read of standards document 3 at List of Flight Crew Standards Documents | Publications | About the CAA and look at the aim - and it talks about demonstrating your ability to conduct a public transport flight, being commerically expeditious etc.

thanks for the document. I looked at it, and I didn't find anything in it that were not part of my other tests already. in all my previous tests, be that PPL, NVFR, SEP IR, ME, ME IR, I had to go through the same tests: flight preparation, departure, flight with various tests during the flight & emergency procedures, and then arrival / landing. I didn't find a single outstanding part of this procedure, which would differ in a slightest way of these other tests. can you point one such aspect out?

The 5 hours complex is mandatory as part of the CPL course - in Part FCL - appendix 3 Paragraph E part 11


11. At least 5 hours of the flight instruction shall be carried out in an aeroplane certificated for the carriage of at least
4 persons and have a variable pitch propeller and retractable landing gear



indeed, but, it also says on part 9:


Applicants holding a valid IR(A) shall be fully credited towards the dual instrument instruction time.


and I did have at least 5 hours of training during my ME-IR training on a complex airplane. thus I think I should be credited for that, and not needing flight time during the CPL training on a complex plane.




Thus, I wouldn't be learning anything new during these 10 hours.

This in itself proves how much you have to learn


as I said I'd be happy to learn, and I do feel I need more training, especially in large-scale commercial environments - but the training manual at the FTO I saw contained nothing of that sort. it didn't even contain a single flight 'as flown in a commercial setting', that is, an IFR flight from one large airport to another. and the EU regulation also clearly says that this 15 hours of training should visual training, which basically makes any reasonable real-life-like training impossible.


Have a read of the 3 CPL diaries to help you:

CPL Diary?
CPL Diary
2009 CPL Diary at EFT



Good luck on the CPL!

thanks will do :)

[Tinstaafl]

Commercial flying isn't just 'one large airport to another'. In your previous training, how many of your flights involved maximising payload at the expense of flying with full tanks, including performance limiting airports? Consider dangerous goods/hazmat in the customer's baggage/freight? Planning the flight via the most expeditious route and not just what's easiest? Planning fuel stops that are cost effective and, as much as possible, don't inconvenience the pax? Making sure the airport is OK for public transport ops by day and night? Weight & balance, and runway performance, for all sectors? Flight & duty time limits?

All done in about 30 mins from initial request to planned?

Another aspect is in-flight performance in terms of proficiency & efficiency. At PPL level I didn't much care if the candidate flew in a manner that didn't account for pax. anxiety about flying ie were a bit rough or jerky or weren't as organised as they could be, as long as they adhered to aircraft limits. If a pax wouldn't want to fly with them again...so what? At the professional level pax handling and how you look to them while you go about your work is a factor. Pax are often nervous but you mustn't be the cause of that anxiety. Cool, calm & efficient is the go. Also, how bad was the weather in which you flew on your earlier training flights? At commercial level I expected my students, and expect my employees, to fly to the limit of VMC if a VFR flight as long as it can be done safely.

[akos.maroy]

I've done in the past most of what you describe above.

My main point is that the training manual I saw didn't include anything of the above. it simply included very basic aircraft handling activities that were already part of my PPL training.

as I already pointed our in my first post, I'd be eager to learn something new, but this this FTO, this would not be the case.


(I also wish people would read a complete post and comprehend it before responding. I guess this is a limitation of this medium [sigh] )

[Tinstaafl]

I read the complete post but, as happens in conversation, the topic can drift & expand. Comments weren't confined to just night flying but included other aspects of commercial training too.

You gave no indication in your previous posts about whether or not you had ever operated in the spirit of commercial ops, but your comments indicated that you thought there is little difference 'twixt PPLs & CPLs.

As for that specific school, perhaps they don't offer what you seek? I agree, on the face of it, that their syllabus doesn't seem to do much.

[Rithalic]

I think that I summed it up previously but let me expand.

Yes the course content may be similar if in fact the same.

But the standard of flying, cognitive process, SA, capacity, captaincy, decision making, pre-flight planning, forward planning, passenger comfort awareness, safety awareness etc and all around piloting will need to be higher.

That's not to say I haven't met a number of PPL holders that could fly circles around CPL holders but alas the course is the course.

Have a look at the tolerances allowed for the PPL and CPL skill tests and you'll start to get an idea of what I'm talking about.

http://www.caa.co.uk/docs/33/srg_lts_stds%20doc%203_V8_Sept2012.pdf

http://www.caa.co.uk/docs/33/srg_lts_Stds%2019_V7_Sept12.pdf

[2close]

The number of qualified PPL's that I fly with who are unable to maintain heading or hold altitude to within tolerance for the PPL let alone the CPL is somewhat disconcerting.

The tolerances for the CPL are more limiting than those for the PPL.

To say that you will not learn anything on the CPL course is very presumptuous; for one thing, we ALL learn and when practising we all (well, most of us) improve, whatever course we do, even refreshers and you may just find that you're not as good as you think you are - not YOU personally, just generally speaking. ;)

With nigh on 600 hours, with Complex sign-off, Night, IMC and FI(A) Ratings before CPL(A) I can still honestly say I learned a lot on the CPL(A) course. Thank you On Track!

:)

[Jet Simulation]

As pointed above, the tolerances are much narrower in a CPL course regarding heading, time and altitude. You are also expected to deal with partial panel situations and cruise climbs/ descents for pax comfort. There is a lot more memory item drills to do with engine failure/ fires compared to the PPL which with the greatest of respect is much more simplified.

The CPL course is very different however you seem to have done your training a very different way from the norm with your SEP IR and MEP IR done before your CPL and ATPL exams. This would have indeed giving you the idea of an overlap as you would have already done it before where as others who did it in the way flight schools offer, see it as building on the last bit of training one did.

One thing you will have to consider is general light aircraft GA flying is done on a more amateur level which was thought during the PPL with the primary understanding of flying safely. during the CPL training, yes safety is a priority however you are also trained to conduct flights in an expeditious manner. A simple example of this is you fly approach speeds in commercial flying and never stall the aircraft on the flair. In the PPL you are trained to hold the nose off the ground and "not let her land" to make sure you do not have a nose wheel landing and to land on the main gear first.

In general the CPL training gets you to a more refined standard of flying compared to a PPL where you are pushed to perform accurately as well as safely throughout. To make sure you meet the standard with a good chance of passing the test, the CAA have decided that a minimum of 15 hours is required in order to get a student up to the required standard and be comfortable as well as competent.