PPLs claiming P2 hours for SEP reval

[Broadlands]

For interest perhaps someone may know the history of P2 hours.

I have had a number of PPLs come to me asking me to sign their SEP based on experience, and after inspection of their log book noticed that some flights were put down as P2 and then added to the total in their log book. These were on the basis that they were not commander but were also a PPL. One pilot ended up being short and his SEP subsequently expired.

I advised that P2 is not an option for a PPL SEP as per CAP804. In cases where this occurred the pilot was also a glider pilot.

Glider pilots used to allocate their hours as P1 or P2 but with transition I think they will now have to put PIC or PUT.

My general question is if P2 hours used to be counted before the days of EASA and JAR (my license came in 2002) of which I have no knowledge. Some older pilots have said they always count flying with a friend as P2 so I would love to know where this originated from.

[Whopity]

You can only claim P2 on an aircraft certified for 2 pilots. It has never been any different. One thing that may well have caused confusion over the years, is the privilege of a licence holder which originates in ICAO Annex 1, to act as "co-pilot of any aeroplane". Different States have interpreted this in different ways and I have never seen any clarification. This carried all the way through to JAR-FCL: the privileges of the holder of a PPL(A) are to act, but not for
remuneration, as pilot-in-command or co-pilot of
any aeroplane engaged in non-revenue flights. This may be the basis on which people have incorrectly logged P2.

[S-Works]

Interestingly I have sat on my desk revalidation paperwork for a pilot who is flying for an 'airline' in the Cessna Caravan as a 'first officer'.

Over 400hrs logged as P2 on a single pilot aircraft. He seems to think that he only has 100hrs to go to get his ATPL on this basis.......

[Genghis the Engineer]

Interestingly I have sat on my desk revalidation paperwork for a pilot who is flying for an 'airline' in the Cessna Caravan as a 'first officer'.

Over 400hrs logged as P2 on a single pilot aircraft. He seems to think that he only has 100hrs to go to get his ATPL on this basis.......

Does that not depend upon company procedures? If they are set up as a 2-pilot operation within their authority approved procedures manual, then it is legally logged as P2 isn't it?

Quite a few of these nominally single pilot turboprops are operated that way I believe?


Not the same as logging P2 flying with your mate in a PA28 certainly.

G

[FlyingStone]

Over 400hrs logged as P2 on a single pilot aircraft. He seems to think that he only has 100hrs to go to get his ATPL on this basis.......

Actually, the requirements for ATPL goes to 500 hours in multi-pilot operations, which can be on single-pilot aircraft if CAA requirement is to require multi crew.

‘Multi-pilot operation’:
for aeroplanes, it means an operation requiring at least 2 pilots using multi-crew cooperation in either multi-pilot or single-pilot aeroplanes;

(b) Experience. Applicants for an ATPL(A) shall have completed a minimum of 1 500 hours of flight time in aeroplanes, including at least:
(1) 500 hours in multi-pilot operations on aeroplanes;

However, skill test must be done on a multi-pilot aircraft (e.g. not Cessna Caravan):

FCL.520.A ATPL(A) — Skill test
Applicants for an ATPL(A) shall pass a skill test in accordance with Appendix 9 to this Part to demonstrate the ability to perform, as PIC of a multi-pilot aeroplane under IFR, the relevant procedures and manoeuvres with the competency appropriate to the privileges granted.

[S-Works]

The last time I looked the UK CAA did not accept Cessna Caravan operations as either multi crew or airline.....

[foxmoth]

The last time I looked the UK CAA did not accept Cessna Caravan operations as either multi crew or airline
I did not think "airline" actually came into CAA definitions for licensing purposes?!

[Genghis the Engineer]

The statement there is "perform as PiC of a multi-pilot aeroplane".

If a company's authority-approved procedures demand that an aeroplane is operated multi-pilot, then it's an interesting question whether it's a multi-pilot aeroplane or not for the purposes of an ATPL skill test, when the certification may not require it.

In the meantime, another interesting dichotomy is that for something like a Caravan, which is certified for single pilot operations as an aircraft, even if it's required to be operated multi pilot by company procedures, a CPL/IR holder does not require ATPL TK passes to gain a type rating and fly as F/O on such an aeroplane.

Would they need ATPL TK to fly as PiC? I assume so, as they'd need to pass the ATPL skill test to have a co-pilot. Probably. Maybe.

Mind you, that implies that Captain Martin Crieff (http://www.comedy.co.uk/guide/radio/cabin_pressure/characters/) had passed the ATPL Skill Test, which is a little hard to believe, so maybe they don't.

G

[Broadlands]

I think Whopity has shed some light on the P2 issue (for PPLs anyway). Since doing my FE none of the PCs or revals have been simple. A steep learning curve.

[fireflybob]

But is not the POH/AFM the definitive document e.g "The minimum crew is one pilot"?

[FlyingStone]

If a company's authority-approved procedures demand that an aeroplane is operated multi-pilot, then it's an interesting question whether it's a multi-pilot aeroplane or not for the purposes of an ATPL skill test, when the certification may not require it.

Well, EASA is quite clear on this - aircraft needs to be certified to have a minimum two flight crew to qualify for ATPL skill test purposes.

‘Multi-pilot aircraft’:
for aeroplanes, it means aeroplanes certificated for operation with a minimum crew of at least two pilots;

[Journey Man]

Genghis is right.

I have had pilots working under me return to the UK having flown as C208B F/O and their hours were validated after I summarised their time and included a copy of the approved Ops B for the aircraft.

I believe the Cessna Mustang is probably a similar case.

[mad_jock]

you can do you mutlicrew experience on a SPA aircraft working under an AOC multicrew ops.

But you can't do your ATPL skills test on one, it has to be a MPA aircraft type which you are typed or in the process of being typed on.

[Genghis the Engineer]

So does the captain need an ATPL to command a part 23 aeroplane being fliwn multi-crew?

G

[mad_jock]

I don't know what part 23 is.


But if it is a SPA operated as multicrew they only need a CPL.

And they also don't need a MCC to be completed and the hours that are flown can be used to get a exemption for the MCC if they go on to fly a MPA type.

I know a few that went that route straight into the LHS of a multicrew aircraft completing there ATPL skills test at the end of their MPA type rating after doing there multicrew hours on a F406.

They line trained while waiting for the ATPL to be issued after getting the type entered on their CPL at Gatwick.

As for the original question. There is group of instructors and examiners out there that teach them to do it, then there is FAA logging input as well. The group are determined they are correct, 2 I know have been taken to task by others for this but continue to teach it (well this was the case 6 years ago when I last came up against it). Unfortunately they are also signing off people using P2 as valid as well and so long as the PPL stays within this group they continue to be signed off.

Power only they tend to be old ex CAA life PPL's and when you do get them into a plane after mucho arguing and abuse they turn out to be utterly dangerous both handling and standard exercises. There is another sub set who are glider pilots, they seem to have zero issues and problems and as always it is a pleasure to fly with them. They tend to appear in batches as examiners loose there authorisations or medicals and the group they used to sort out have to find another tame examiner to keep them legal.

One pilot I saw hadn't been legal to fly SEP since issued with a JAR ppl in 2001 and it was 2009. He had been signed off by experience and 1 hour with his tame examiner every two years and I suspect they were in a SLMG or TMG. In that period he had something like 26 hours logged as PIC and the rest out of 200 logged as P2. He had though in that time logged over 1000 hours as PIC in gliders. So after we did an hour running through the basic exercises with him put him through a skills test and signed him off and said nothing more about it as he was actually very competent handling even if he didn't seem to have a clue what he was doing at a controlled airfield which was his first one in that period that he had operated out of.

It tends to be PFA and gliding types who will do it. The gliding types IMHO its not a big issue, some of the PFA types though its a bit of an eye opener that there is such a sub culture operating. But that said obviously their activity's don't get highlighted in incident or accident stats otherwise there would have been a crack down on it. I suspect it will just be time while the old examiners drop out of the system before it eventually ends.

[Genghis the Engineer]

Cheers Jock.

(And part 23 is the next size range down from part 25 - so tends to include most turboprops, piston twins, and all but the smallest piston singles).

G

[Level Attitude]

So does the captain need an ATPL to command a part 23 aeroplane being fliwn multi-crew?But if it is a SPA operated as multicrew they only need a CPL.

And they also don't need a MCC to be completedThe rules say MJ is correct:
FCL.305 CPL — Privileges and conditions
(a) Privileges. The privileges of the holder of a CPL are, within the appropriate aircraft category, to:
(2) act as PIC or co-pilot of any aircraft engaged in operations other than commercial air transport;
(3) act as PIC in commercial air transport of any single-pilot aircraft subject to the restrictions specified in FCL.060 and in this Subpart;Not sure this is actually what EASA intended - probably another case of un-joined up rule making with their not realising that some aircraft that only need one pilot do, in fact, require two for certain operations.

Also seems strange to me that multi-crew might be required for a certain flight but that none of the pilots on board need to have been assessed in their MCC skills.


For the OPs original question I think whopity's answer is spot on:
During training the student will be told whether to log PIC or PUT.
Once qualified they may go and fly with a friend who will be PIC but they are now a qualified pilot also sitting behind a set of controls and probably 'taking part' in flying the aircraft. They know they are not PIC and that, obviously, they are not PUT but want to log something and they see in the rules that a PPL holder is allowed to log co-pilot (P2) - but do not know, don't check, or do not care (because they want to 'log hours') that the definition of co-pilot means that the flight must have required 2 or more pilots.

[mad_jock]

The MCC doesn't asses your MCC skills anyway its a turn up and tick the box course.

The operation of SPA as multicrew was the same under JAR nothing has changed. I presume it was the same before JAR.

If it wasn't so you would have real problems getting Captains for these type of operation. It would mean that you would either have to remove the ATPL requirements for the test to be done on a MPA type or they would have to go and do a type rating on a MPA type just so the could move seats on there current type.

The first one is never going to happen and the second one is utterly pointless.

The MCC as it stands is a load of nonsense anyway, it was never intended to be done as a stand alone course. It was meant to be a first type rating company addition to that training. Companys saw they could off load the expense under the rules so did so and now an industry has developed around the requirement for a tick in the box. We basically do it again as part of the company induction. Some have done the course straight after training then gone instructing for years then got there first multi crew type. It can be 2-5 years since they had anything to do with muticrew MCC type stuff.

We are not talking mass transport of people with these operations.

They are all semi specialist

king airs air-ambulance, nav aid calibration, survey work.

F406, survey work, calibration, fisheries protection.

In the main they actually carry a heavier load on crew cooperation than simple aircraft operation. They have a job to do which requires 3or 4 people working as a team onboard to get the task done. Which is something the standard MCC course doesn't touch.

And as they will be working under a AOC the CRM will be assessed to the same level as any other AOC operation that's multicrew. The ATPL as such doesn't add anything to the skipper.

You can kid yourself all you like but the job these guys do is by far harder than the A to B pax moving that the majority of pilots do.

[S-Works]

Well, I can tell you that the CAA have rejected this applicants request to have his multi crew time accreted towards the issue of his ATPL.

I will ask if I can post the contents of the email from CAA policy but the just is that as the aircraft he has been flying is only certificated as a Single Pilot Aircraft and it is only a local requirement for them to be operated multi crew the hours are not eligible. According to the CAA there interpretation is that the hours must be flown in an aircraft certified as a must pilot airplane.

[mad_jock]

It doesn't surprise me to be honest Bose-x

I presume it was the single turbine caravan?

All the people I know who got it were through UK AOC's

The planes had to have a muticrew fit as well, they weren't the standard factory aircraft.

The company I worked for that had them had two airframes that were allowed to log multicrew on and one that was only single crew. The multicrew pilots weren't allowed to fly it. And only the TREs were allowed to fly both.

The crew also had a multicrew IR rating for the aircraft type.

I haven't heard of anyone being allowed to log multicrew time on a single engine aircraft in fact add to that MEP as well.

[OhNoCB]

The company I used to work for had their ops manual etc approved for multi pilot ops on a single pilot MEP.

Allegedly this actually came about as a suggestion of the CAA, as before this the company operated with one pilot and a 'safety pilot' and the CAA found out that lots of the 'safety pilots' were logging the time anyway, so they told the company that they could get their approved to fly as a multi-crew operation and if they implemented the proper training etc they could have FOs log hours.

We were LPC/OPC'd with the company and received an MPA/IR rating for the single pilot airplane.

[S-Works]

I would suspect all of this was pre EASA when the UK had its discretion on these things.

[OhNoCB]

Know a few guys still doing it. They do both single and multi crew flights (mostly multi crew) and the CAA auditors have been trying to convince them to drop the single crew stuff as it would be safer to do it all multi crew.

[mad_jock]

No its still going on Bose.

As long as the machine is set up for muticrew and the SOP's are set up for it They are more than happy with multicrew ops.

Now if they would be willing to except hours obtained outside a UK AOC is a different story.

I can think of 4 current UK AOC holders that are flying SPA as multi crew and the pilots are logging multicrew time.

Gamma
Directflight
Atlantic
FRA.

[Genghis the Engineer]

BAS do it also under corporate operations with their Do228 and TwOtters.

G

[mad_jock]

forgot about them

Add in

Logan Air and Aurigny as well

[SpannerInTheWerks]

The minimum crew may be one pilot, but I suppose the question is if the aeroplane as being operated as multi-crew (in accordance with the Ops Manual and with CAA approval) then the second pilot can claim P2 time?

This from Bristol Flying Centre website:

Are the King Air and Citation Jet single pilot aeroplanes?

Yes, both the King Air and Citation Jet are single pilot aeroplanes. In Europe no jet can be operated public transport single crew therefore the Citation is a single pilot aircraft flown multi crew. The King Air is a turbo prop and can therefore be flown single crew however many operators are becoming 2 crew. In general terms a Captain for either aircraft will need 1500 hours total time, 500 hours multi and 50 hours on type. This is very much a general rule of thumb and will be dictated by the operators own requirements and those of their insurers.

[mad_jock]

Yes that's about it.

If the flight ops inspector waves his/her magic wand and deems your method of operating as multicrew and approves your manuals then the multicrew time can be logged.

The 500 hours multi is referring to multi engines not multicrew time.

The insurance requirements usually far outstrip any regulation type requirements.


Just in case any wannbies are tampering with themselves at the thought of going straight into the LHS of 1600 SHP turboprop with a CPL and a smile.

Its not normally an issue with hours acquired with a UK operator when applying for an ATPL. Rest of Europe it can get a bit sticky depending on the country they were acquired in eg Germany not a problem. Greece you might have a struggle on your hands. Outside Europe your basically stuffed.

[Rocket2]

If it helps the original question I used to log any time that I had an instructor with me as P2 (now corrected) as in my eyes, the instructor was ultimately in command (that goes for gliding & sep).

[Genghis the Engineer]

If it helps the original question I used to log any time that I had an instructor with me as P2 (now corrected) as in my eyes, the instructor was ultimately in command (that goes for gliding & sep).

Seldom correct.

Normally you'd be P/UT, unless they're just along for the ride, in which case you're PiC. P2 belongs in multi-crew operations.

G

[Rocket2]

Apologies - finger trouble - that's what I meant

[Pull what]

You can only claim P2 on an aircraft certified for 2 pilots. It has never been any different.

It has been different, one company who operated privately a single crew Citation 1 for a large industrial company had an agreement with CAA that all P2 hours would be counted as the companies insurance required it to be operated by two type rated pilots, not an uncommon agreement either

[Whopity]

It has been differentThere are exceptions to every rule however; all such exceptions should be documented and such documentation should identify what may be credited. Without that documentation the basic rule stil holds good.

[mad_jock]

I have seen someone have to remove 800 hours to logging multi crew time on a AOC single crew aircraft without the required approval.

Got all a bit messy as he had moved on to a multi crew bigger biz jet with min hour restrictions from the insurance company.

Luckily he had only gone for the ATPL when there was a slot for the LHS available. So at the time of discovery he could continue working but unfortunately he couldn't go LHS.

He had though flown uninsured for two years in a 10 mill jet.