mrspinx
8th Feb 2017, 20:24
Ladies and gents I am currently hours building to start a CPL A course this coming summer. There seems to be some confusion and conflicting info coming from different schools as to what my limiting hours are. Its either 70hrs P1 fixed wing for the multi engine piston rating or 100hrs P1 fixed wing towards the 200hrs total. The relevant IN is IN-2016/23 and the section of the CAP is CAP 804, Sect 4, Part L, Para 12. Please see below a copy of an email conversation with the CAA who have stated that the correct no is 100hrs P1.
I will not argue any further with them but, I am still not convinced by their answer. My doubts stem from the fact that 100hrs is of no use to anyone, by the time anyone who has completed EFTS (which is everyone) hits 100hrs P1 fixed wing then with the average of 60hrs from EFTS we already have enough hours to start a CPL A. If the accreditation was 100hrs P1 then that would be helpful. Surly we have not somehow managed to agree accreditation which is useless. I would appreciate your opinions/thoughts as to whether I am being an arse and misreading the CAP. I've replaced names in the emails to 'ME' and 'CAA'. please scroll to bottom.
CAA,
Thank you again for the reply. Whilst of course I accept your definition of the rules I still believe that whole segment of the CAP to be very ambiguous and open to interpretation. What you have pasted below makes sense except that subpara 'e' is missing, when that is included I believe it changes the context of the para.
To me the statement from para 'e' hours as PIC of other categories may count towards the 200hrs flight time" when related to subpara 'a' which states the applicant for a CPL A shall of completed at least 200hrs flight time, including at least: 100 hours as PIC, of which 20 hours of cross-country flight as PIC .
To me from that statement there is no distinction made between PIC heli or PIC Aero simply that 100hrs PIC is required.
Again I am not trying to be awkward but you should be aware that schools are interpreting the above the same way I am and added clarity is needed.
Kind Regards,
ME
From: Customerservices <[email protected]>
Sent: 08 February 2017 15:45
To: ME
Subject: RE: Customer ref no
Dear Mr ME
The 100 hours PIC credit for the helicopter hours can only be counted to wards the total flight time of 200 hours and not towards the specific requirements to be done in aeroplanes:
(a) 100 hours as PIC, of which 20 hours of cross-country flight as PIC, which shall
include a VFR cross-country flight of at least 540 km (300 NM), in the course of
which full stop landings at two aerodromes different from the aerodrome of
departure shall be made;
(b) 5 hours of flight time shall be completed at night, comprising 3 hours of dual
instruction, which shall include at least 1 hour of cross-country navigation and 5
solo take-offs and 5 solo full stop landings; and
(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;
(d) 6 hours of flight time shall be completed in a multi-engine aeroplane, if a multiengine
aeroplane is used for the skill test
I hope this helps
Regards
CAA
Licensing Support & Examiners Officer
Licensing Support and Examiners
Civil Aviation Authority
Tel: 01293 573700
Follow us on Twitter: @UK_CAA (http://twitter.com/UK_CAA)
Please consider the environment. Think before printing this email.
Following the referendum on EU membership there will be no immediate change to civil aviation regulation nor the CAA's role in the EU and the European Aviation Safety Agency.
Any future changes will depend on the outcome of the UK's negotiations on exiting the EU. We will be working closely with the Department for Transport in assisting the UK Government in the months ahead as discussions progress.
https://attachment.outlook.office.net/owa/[email protected]/service.svc/s/GetFileAttachment?id=AQMkADAwATYwMAItOThlMy1hYzhlLTAwAi0wMAo ARgAAA7TdK0BBWOlLkBAh4tQ%2FiTYHAGzBuc%2BJ87pOlSQ2VkNgPGMAAAI BCQAAAGzBuc%2BJ87pOlSQ2VkNgPGMAAVJp5jkAAAABEgAQAGCGTwWCSHRJi NrBs%2F9AHx8A&X-OWA-CANARY=guqcXodFb0q_DCb_hzY4lUAgDdFkUNQYYZvlojdsZeBIASjuGe2L_ mEufDzBgvGBO7YqTFoFuVc.&token=e66efbd6-bf15-4821-b4ce-d360ccfa8c90&owa=outlook.live.com&isc=1
https://attachment.outlook.office.net/owa/[email protected]/service.svc/s/GetFileAttachment?id=AQMkADAwATYwMAItOThlMy1hYzhlLTAwAi0wMAo ARgAAA7TdK0BBWOlLkBAh4tQ%2FiTYHAGzBuc%2BJ87pOlSQ2VkNgPGMAAAI BCQAAAGzBuc%2BJ87pOlSQ2VkNgPGMAAVJp5jkAAAABEgAQAIVxfxWC7nNIv 1UvRcI937o%3D&X-OWA-CANARY=SQJ6dQrSvkaykqKGe74_2sBIP89kUNQYGkZeQuZdnwaVgQgLnbVSx 7rjkvewQX-1PWlkqazwZW8.&token=e66efbd6-bf15-4821-b4ce-d360ccfa8c90&owa=outlook.live.com&isc=1
From: ME
Sent: 08 February 2017 15:25
To: Customerservices
Subject: RE: Customer ref no
CAA,
Thank you very much for the quick reply it is very much appreciated. I think confusion still exists. I am happy that the IN 2016/023 allows me to take 100hrs PIC helicopters across towards the 200hrs total. The confusion lies within the CAP 804 Sect 4, Part L, Para 12 which simply states that "100hrs PIC is required, of which 20hrs must be cross country" there is no mention of Aeroplanes simply that 100hrs PIC is required. I therefore believe my original question still stands in that can my 100hrs PIC heli count towards the 100PIC as stated in that paragraph.
I do not mean to be awkward but simply wish to be 100% certain as to what is required before I spend a substantial amount of money. As a current aviator PIC is PIC, whatever the type, and is more about captaincy than the type of aircraft flown. If I am required to to complete an extra 30hrs PIC flying Aeroplanes it is going to be of little benefit to me and at substantial added cost.
I look forward to hearing from you,
Kind regards,
ME
Sent from Samsung tablet.
-------- Original message --------
From: Customerservices <[email protected]>
Date: 08/02/2017 13:58 (GMT+00:00)
To: ME
Subject: RE: Customer ref no
Dear Mr ME
Thank you for your email.
In 2016/023 does state that a QMP (H) can count 100 hours flown in helicopters PIC towards the 200 flight time required for the issue of the CPL (A), which means that you need 100 hours PIC on aeroplanes for CPL issue- 70 hours PIC aeroplanes for MEP issue: http://publicapps.caa.co.uk/docs/33/InformationNotice2016023.pdf
You need to have a minimum of 150 hours to start the CPL modular course.
I hope this answers your query.
Regards
CAA
Licensing Support & Examiners Officer
Licensing Support and Examiners
Civil Aviation Authority
Tel: 01293 573700
Follow us on Twitter: @UK_CAA (http://twitter.com/UK_CAA)
Please consider the environment. Think before printing this email.
Following the referendum on EU membership there will be no immediate change to civil aviation regulation nor the CAA's role in the EU and the European Aviation Safety Agency.
Any future changes will depend on the outcome of the UK's negotiations on exiting the EU. We will be working closely with the Department for Transport in assisting the UK Government in the months ahead as discussions progress.
https://attachment.outlook.office.net/owa/[email protected]/service.svc/s/GetFileAttachment?id=AQMkADAwATYwMAItOThlMy1hYzhlLTAwAi0wMAo ARgAAA7TdK0BBWOlLkBAh4tQ%2FiTYHAGzBuc%2BJ87pOlSQ2VkNgPGMAAAI BCQAAAGzBuc%2BJ87pOlSQ2VkNgPGMAAVJp5jkAAAABEgAQALbkoPofrR9Ah hE8BbeYDjg%3D&X-OWA-CANARY=guqcXodFb0q_DCb_hzY4lUAgDdFkUNQYYZvlojdsZeBIASjuGe2L_ mEufDzBgvGBO7YqTFoFuVc.&token=e66efbd6-bf15-4821-b4ce-d360ccfa8c90&owa=outlook.live.com&isc=1
https://attachment.outlook.office.net/owa/[email protected]/service.svc/s/GetFileAttachment?id=AQMkADAwATYwMAItOThlMy1hYzhlLTAwAi0wMAo ARgAAA7TdK0BBWOlLkBAh4tQ%2FiTYHAGzBuc%2BJ87pOlSQ2VkNgPGMAAAI BCQAAAGzBuc%2BJ87pOlSQ2VkNgPGMAAVJp5jkAAAABEgAQAJNQdfEkqGBGl Ng4KxM71ew%3D&X-OWA-CANARY=guqcXodFb0q_DCb_hzY4lUAgDdFkUNQYYZvlojdsZeBIASjuGe2L_ mEufDzBgvGBO7YqTFoFuVc.&token=e66efbd6-bf15-4821-b4ce-d360ccfa8c90&owa=outlook.live.com&isc=1
From: ME
Sent: 08 February 2017 13:25
To: Customerservices
Subject: Customer ref no
Sir/Madam,
I am a QMP (H) about to start hours building to achieve a CPL A by the end of the year. I have spoken to a number of different ATOs and there seems to be some confusion as to the interpretation of IN-2016/23 AND CAP 804 Sect 4, Part L, Para 12 (e) which states that a CPL (H) holder can count 100hrs PIC towards the requirement for a CPL A. A colleague of mine has already contacted yourselves asking a similar question and was informed that the intent of IN-2016/23 para 3.1 was to treat QMP (H) the same as CPL (H) with regards to CAP 804 Sect 4, Part L, Para 12 (e). For clarity, before I begin my hours building, could you please confirm that I can take 100hrs PIC helicopters across to satisfy the requirement in CAP 804 Sect 4, Part L, Para 12 (a) and my limiting hours will therefor be 70hrs PIC Aeroplanes for the MEP rating and 200Hrs total with regards to building hours.
I look forward to your reply and appreciate any assistance.
Kind Regards,
ME
************************************************************ **********
I will not argue any further with them but, I am still not convinced by their answer. My doubts stem from the fact that 100hrs is of no use to anyone, by the time anyone who has completed EFTS (which is everyone) hits 100hrs P1 fixed wing then with the average of 60hrs from EFTS we already have enough hours to start a CPL A. If the accreditation was 100hrs P1 then that would be helpful. Surly we have not somehow managed to agree accreditation which is useless. I would appreciate your opinions/thoughts as to whether I am being an arse and misreading the CAP. I've replaced names in the emails to 'ME' and 'CAA'. please scroll to bottom.
CAA,
Thank you again for the reply. Whilst of course I accept your definition of the rules I still believe that whole segment of the CAP to be very ambiguous and open to interpretation. What you have pasted below makes sense except that subpara 'e' is missing, when that is included I believe it changes the context of the para.
To me the statement from para 'e' hours as PIC of other categories may count towards the 200hrs flight time" when related to subpara 'a' which states the applicant for a CPL A shall of completed at least 200hrs flight time, including at least: 100 hours as PIC, of which 20 hours of cross-country flight as PIC .
To me from that statement there is no distinction made between PIC heli or PIC Aero simply that 100hrs PIC is required.
Again I am not trying to be awkward but you should be aware that schools are interpreting the above the same way I am and added clarity is needed.
Kind Regards,
ME
From: Customerservices <[email protected]>
Sent: 08 February 2017 15:45
To: ME
Subject: RE: Customer ref no
Dear Mr ME
The 100 hours PIC credit for the helicopter hours can only be counted to wards the total flight time of 200 hours and not towards the specific requirements to be done in aeroplanes:
(a) 100 hours as PIC, of which 20 hours of cross-country flight as PIC, which shall
include a VFR cross-country flight of at least 540 km (300 NM), in the course of
which full stop landings at two aerodromes different from the aerodrome of
departure shall be made;
(b) 5 hours of flight time shall be completed at night, comprising 3 hours of dual
instruction, which shall include at least 1 hour of cross-country navigation and 5
solo take-offs and 5 solo full stop landings; and
(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;
(d) 6 hours of flight time shall be completed in a multi-engine aeroplane, if a multiengine
aeroplane is used for the skill test
I hope this helps
Regards
CAA
Licensing Support & Examiners Officer
Licensing Support and Examiners
Civil Aviation Authority
Tel: 01293 573700
Follow us on Twitter: @UK_CAA (http://twitter.com/UK_CAA)
Please consider the environment. Think before printing this email.
Following the referendum on EU membership there will be no immediate change to civil aviation regulation nor the CAA's role in the EU and the European Aviation Safety Agency.
Any future changes will depend on the outcome of the UK's negotiations on exiting the EU. We will be working closely with the Department for Transport in assisting the UK Government in the months ahead as discussions progress.
https://attachment.outlook.office.net/owa/[email protected]/service.svc/s/GetFileAttachment?id=AQMkADAwATYwMAItOThlMy1hYzhlLTAwAi0wMAo ARgAAA7TdK0BBWOlLkBAh4tQ%2FiTYHAGzBuc%2BJ87pOlSQ2VkNgPGMAAAI BCQAAAGzBuc%2BJ87pOlSQ2VkNgPGMAAVJp5jkAAAABEgAQAGCGTwWCSHRJi NrBs%2F9AHx8A&X-OWA-CANARY=guqcXodFb0q_DCb_hzY4lUAgDdFkUNQYYZvlojdsZeBIASjuGe2L_ mEufDzBgvGBO7YqTFoFuVc.&token=e66efbd6-bf15-4821-b4ce-d360ccfa8c90&owa=outlook.live.com&isc=1
https://attachment.outlook.office.net/owa/[email protected]/service.svc/s/GetFileAttachment?id=AQMkADAwATYwMAItOThlMy1hYzhlLTAwAi0wMAo ARgAAA7TdK0BBWOlLkBAh4tQ%2FiTYHAGzBuc%2BJ87pOlSQ2VkNgPGMAAAI BCQAAAGzBuc%2BJ87pOlSQ2VkNgPGMAAVJp5jkAAAABEgAQAIVxfxWC7nNIv 1UvRcI937o%3D&X-OWA-CANARY=SQJ6dQrSvkaykqKGe74_2sBIP89kUNQYGkZeQuZdnwaVgQgLnbVSx 7rjkvewQX-1PWlkqazwZW8.&token=e66efbd6-bf15-4821-b4ce-d360ccfa8c90&owa=outlook.live.com&isc=1
From: ME
Sent: 08 February 2017 15:25
To: Customerservices
Subject: RE: Customer ref no
CAA,
Thank you very much for the quick reply it is very much appreciated. I think confusion still exists. I am happy that the IN 2016/023 allows me to take 100hrs PIC helicopters across towards the 200hrs total. The confusion lies within the CAP 804 Sect 4, Part L, Para 12 which simply states that "100hrs PIC is required, of which 20hrs must be cross country" there is no mention of Aeroplanes simply that 100hrs PIC is required. I therefore believe my original question still stands in that can my 100hrs PIC heli count towards the 100PIC as stated in that paragraph.
I do not mean to be awkward but simply wish to be 100% certain as to what is required before I spend a substantial amount of money. As a current aviator PIC is PIC, whatever the type, and is more about captaincy than the type of aircraft flown. If I am required to to complete an extra 30hrs PIC flying Aeroplanes it is going to be of little benefit to me and at substantial added cost.
I look forward to hearing from you,
Kind regards,
ME
Sent from Samsung tablet.
-------- Original message --------
From: Customerservices <[email protected]>
Date: 08/02/2017 13:58 (GMT+00:00)
To: ME
Subject: RE: Customer ref no
Dear Mr ME
Thank you for your email.
In 2016/023 does state that a QMP (H) can count 100 hours flown in helicopters PIC towards the 200 flight time required for the issue of the CPL (A), which means that you need 100 hours PIC on aeroplanes for CPL issue- 70 hours PIC aeroplanes for MEP issue: http://publicapps.caa.co.uk/docs/33/InformationNotice2016023.pdf
You need to have a minimum of 150 hours to start the CPL modular course.
I hope this answers your query.
Regards
CAA
Licensing Support & Examiners Officer
Licensing Support and Examiners
Civil Aviation Authority
Tel: 01293 573700
Follow us on Twitter: @UK_CAA (http://twitter.com/UK_CAA)
Please consider the environment. Think before printing this email.
Following the referendum on EU membership there will be no immediate change to civil aviation regulation nor the CAA's role in the EU and the European Aviation Safety Agency.
Any future changes will depend on the outcome of the UK's negotiations on exiting the EU. We will be working closely with the Department for Transport in assisting the UK Government in the months ahead as discussions progress.
https://attachment.outlook.office.net/owa/[email protected]/service.svc/s/GetFileAttachment?id=AQMkADAwATYwMAItOThlMy1hYzhlLTAwAi0wMAo ARgAAA7TdK0BBWOlLkBAh4tQ%2FiTYHAGzBuc%2BJ87pOlSQ2VkNgPGMAAAI BCQAAAGzBuc%2BJ87pOlSQ2VkNgPGMAAVJp5jkAAAABEgAQALbkoPofrR9Ah hE8BbeYDjg%3D&X-OWA-CANARY=guqcXodFb0q_DCb_hzY4lUAgDdFkUNQYYZvlojdsZeBIASjuGe2L_ mEufDzBgvGBO7YqTFoFuVc.&token=e66efbd6-bf15-4821-b4ce-d360ccfa8c90&owa=outlook.live.com&isc=1
https://attachment.outlook.office.net/owa/[email protected]/service.svc/s/GetFileAttachment?id=AQMkADAwATYwMAItOThlMy1hYzhlLTAwAi0wMAo ARgAAA7TdK0BBWOlLkBAh4tQ%2FiTYHAGzBuc%2BJ87pOlSQ2VkNgPGMAAAI BCQAAAGzBuc%2BJ87pOlSQ2VkNgPGMAAVJp5jkAAAABEgAQAJNQdfEkqGBGl Ng4KxM71ew%3D&X-OWA-CANARY=guqcXodFb0q_DCb_hzY4lUAgDdFkUNQYYZvlojdsZeBIASjuGe2L_ mEufDzBgvGBO7YqTFoFuVc.&token=e66efbd6-bf15-4821-b4ce-d360ccfa8c90&owa=outlook.live.com&isc=1
From: ME
Sent: 08 February 2017 13:25
To: Customerservices
Subject: Customer ref no
Sir/Madam,
I am a QMP (H) about to start hours building to achieve a CPL A by the end of the year. I have spoken to a number of different ATOs and there seems to be some confusion as to the interpretation of IN-2016/23 AND CAP 804 Sect 4, Part L, Para 12 (e) which states that a CPL (H) holder can count 100hrs PIC towards the requirement for a CPL A. A colleague of mine has already contacted yourselves asking a similar question and was informed that the intent of IN-2016/23 para 3.1 was to treat QMP (H) the same as CPL (H) with regards to CAP 804 Sect 4, Part L, Para 12 (e). For clarity, before I begin my hours building, could you please confirm that I can take 100hrs PIC helicopters across to satisfy the requirement in CAP 804 Sect 4, Part L, Para 12 (a) and my limiting hours will therefor be 70hrs PIC Aeroplanes for the MEP rating and 200Hrs total with regards to building hours.
I look forward to your reply and appreciate any assistance.
Kind Regards,
ME
************************************************************ **********