Part 61 gotcha for Chief Pilots/AOC holders and syndicates.
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Part 61 gotcha for Chief Pilots/AOC holders and syndicates.
It was my understanding pre CASR Part 61 that a pilot completing induction training with an AOC holder could be trained / considered competent to operate a type within a group (class) by the Chief Pilot. The Chief Pilot didn't necessarily need to hold an instructor rating provided the pilot held the appropriate design feature endorsements. An example might be a pilot with say Cessna 210 experience could be "checked out" by the Chief Pilot to fly a C182RG. Under CASR 61.385 (general competency) the Chief Pilot NOW needs to hold an instructor rating with at least a grade 2 training endorsement. The same story with syndicates, no longer could an experienced member "hold the hand" of a new member to gain experience, this now must be completed by an appropriately rated flight instructor. Refer 61.385, 61.1165(e). CAO 40 didn't specify how this was to be done or what qualifications were required, it just said you needed to know how to operate the aircraft and hold appropriate design feature endorsements.
I can't remember the reference but there is somewhere in Part 61 that allows this, it was one of the few sensible things it seemed to introduce! As long as the Chief Pilot holds the correct piece of paper from CASA they're able to check their Pilots on the Aircraft they operate. It's not an Exemption as such, I just can't think of the correct term for it at this particular moment nor the actual reference.
Thread Starter
I can't remember the reference but there is somewhere in Part 61 that allows this, it was one of the few sensible things it seemed to introduce! As long as the Chief Pilot holds the correct piece of paper from CASA they're able to check their Pilots on the Aircraft they operate. It's not an Exemption as such, I just can't think of the correct term for it at this particular moment nor the actual reference.
It's a bit like the flight review - an instructor (grade 1 or 2) can conduct a flight review independently of a 141/142 cetificate holder provided they don't do any training! Now, if the pilot asks you to complete a flight review and their steep turns are safe, but untidy do you demonstrate one and provide guidance, then let them practice til they are tidy? No, this is considered instruction so you'll need a Part 141 certificate with all of the administrative stuff (POH, check lists etc for that aircraft type). Alternatively you tell them to go away and practice steep turns until they are tidy, then I'll look at them again or say they're untidy but safe so I'll just sign you off?
The philosophy seems to be you are considered suitable to judge what's safe (checking), but not how to train them to be safe unless you've got the weight of the subject aircraft in paper to support the training.
Without diving into the regs to clarify, by the sound of it I suspect you are getting a little confused.
If someone is licensed to fly the 210 in your example, you are licensed to fly the 182rg. The CP is not training you for any endorsements or ratings. They still have responsibilities under CAO 82 for check and training, and I do believe that teaching them your SOPs on the 182 is not considered "training" by way of the definition of "training".
Training in the sense of the defined word would be teaching someone without csu/rg ratings to operate an aircraft with such features.
If someone is licensed to fly the 210 in your example, you are licensed to fly the 182rg. The CP is not training you for any endorsements or ratings. They still have responsibilities under CAO 82 for check and training, and I do believe that teaching them your SOPs on the 182 is not considered "training" by way of the definition of "training".
Training in the sense of the defined word would be teaching someone without csu/rg ratings to operate an aircraft with such features.
Thread Starter
Without diving into the regs to clarify, by the sound of it I suspect you are getting a little confused.
If someone is licensed to fly the 210 in your example, you are licensed to fly the 182rg. The CP is not training you for any endorsements or ratings. They still have responsibilities under CAO 82 for check and training, and I do believe that teaching them your SOPs on the 182 is not considered "training" by way of the definition of "training".
Training in the sense of the defined word would be teaching someone without csu/rg ratings to operate an aircraft with such features.
If someone is licensed to fly the 210 in your example, you are licensed to fly the 182rg. The CP is not training you for any endorsements or ratings. They still have responsibilities under CAO 82 for check and training, and I do believe that teaching them your SOPs on the 182 is not considered "training" by way of the definition of "training".
Training in the sense of the defined word would be teaching someone without csu/rg ratings to operate an aircraft with such features.
Is the reg talking about a class rating or type rating? If it's a class rating (which is the case now for most GA aircraft) the pilot only needs to have the class rating in the licence and be satisfied that he/she is confident that they are competitent on the aircraft. Type ratings require specific training on the particular aircraft type.
Example would be that if a pilot had a class rating on a multi engine piston twin, and say had a lot of time in a PA31 and then wanted to fly say a PA34, the pilot could legally fly in the PA34 provided that the pilot was satisfied that he/she were competent enough to fly the PA34. How that competentcy is achieved is up to the pilot/operator to determine. Reading the POH and doing a flight with another pilot experienced on the aircraft might be all that is required, and that other pilot does not have to be an instructor.
I can't see how a syndicate would be drawn into this, they don't hold AOCs.
Example would be that if a pilot had a class rating on a multi engine piston twin, and say had a lot of time in a PA31 and then wanted to fly say a PA34, the pilot could legally fly in the PA34 provided that the pilot was satisfied that he/she were competent enough to fly the PA34. How that competentcy is achieved is up to the pilot/operator to determine. Reading the POH and doing a flight with another pilot experienced on the aircraft might be all that is required, and that other pilot does not have to be an instructor.
I can't see how a syndicate would be drawn into this, they don't hold AOCs.
Thread Starter
Is the reg talking about a class rating or type rating? If it's a class rating (which is the case now for most GA aircraft) the pilot only needs to have the class rating in the licence and be satisfied that he/she is confident that they are competitent on the aircraft. Type ratings require specific training on the particular aircraft type.
Example would be that if a pilot had a class rating on a multi engine piston twin, and say had a lot of time in a PA31 and then wanted to fly say a PA34, the pilot could legally fly in the PA34 provided that the pilot was satisfied that he/she were competent enough to fly the PA34. How that competentcy is achieved is up to the pilot/operator to determine. Reading the POH and doing a flight with another pilot experienced on the aircraft might be all that is required, and that other pilot does not have to be an instructor.
I can't see how a syndicate would be drawn into this, they don't hold AOCs.
Example would be that if a pilot had a class rating on a multi engine piston twin, and say had a lot of time in a PA31 and then wanted to fly say a PA34, the pilot could legally fly in the PA34 provided that the pilot was satisfied that he/she were competent enough to fly the PA34. How that competentcy is achieved is up to the pilot/operator to determine. Reading the POH and doing a flight with another pilot experienced on the aircraft might be all that is required, and that other pilot does not have to be an instructor.
I can't see how a syndicate would be drawn into this, they don't hold AOCs.
https://www.casa.gov.au/sites/g/files/net351/f/_assets/main/lib100268/general-competency-pilots.pdf
Thread Starter
The point I'm trying to make here is CASR 61.385 effectively creates a pseudo "type rating" for every type. If you've got experience in a broad range of types and were conversant with the procedures loading etc on a new type you might be able to argue in court that you met the general competency requirements, but you'd only be in court if there was an incident so that might be difficult. If you're not that experienced and sought assistance from a more experienced person they must hold an instructor rating for the "training" to be valid. If there was an incident the person "helping" the less experienced pilot gain experience would be dragged into the enquiry.
If you haven't read the references I quoted above you won't understand CASA's current stand in this regard.
If you haven't read the references I quoted above you won't understand CASA's current stand in this regard.
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Know a CP who applied for Reg 217 and put himself up as head of check and training, 15,000 hours not enough apparently.
CAsA required him to get an instructors rating, 400 hours of basic instructional experience, then multi-engine training approval, then 300 hours instructing under IFR in multi engine aircraft. The gentleman concerned would long be in his grave by the time he'd obtained all that. So I guess we are going to see a lot of 21 year olds with brand new grade ones and no experience doing C&T on high performance aircraft now. Still when you look at the experience levels of some of the CAsA FOI's struggling through type ratings on some very sophisticated machinery to become the anointed experts, one can only wonder when the next training accident will occur
Incidentally did I read somewhere that Qantas C&T's are going to be granted automatic instructors ratings?
I don't have a problem with that, but it sort of makes a mockery of all those kids who have stumped up the money got all the required ticks in the required boxes and put in the time and effort.
CAsA required him to get an instructors rating, 400 hours of basic instructional experience, then multi-engine training approval, then 300 hours instructing under IFR in multi engine aircraft. The gentleman concerned would long be in his grave by the time he'd obtained all that. So I guess we are going to see a lot of 21 year olds with brand new grade ones and no experience doing C&T on high performance aircraft now. Still when you look at the experience levels of some of the CAsA FOI's struggling through type ratings on some very sophisticated machinery to become the anointed experts, one can only wonder when the next training accident will occur
Incidentally did I read somewhere that Qantas C&T's are going to be granted automatic instructors ratings?
I don't have a problem with that, but it sort of makes a mockery of all those kids who have stumped up the money got all the required ticks in the required boxes and put in the time and effort.
Can anyone enlighten me on the 5 hours VFR and 10 hours IFR requirement for charter under part 61 on type that use to be part of the endorsement for commercial operators
Now if you have retract, constant speed, pressurisation on say a C421 then under the part 61 this entitles you to immediately fly say a Monave after a check out without having done the ICUS
Now if you have retract, constant speed, pressurisation on say a C421 then under the part 61 this entitles you to immediately fly say a Monave after a check out without having done the ICUS
61.385 mentions nothing about having to hold an instructor rating. Not sure where you are coming up with that? I don't think it is creating a "pseudo type rating". Type and class ratings are clearly defined.
By your logic, if a pilot friend asked you at the bar one night "hey, I've forgotten, what was the stall speed on (insert the plane we both fly)?" then you would be giving training!
61.1165e allows an instructor to obviously teach the general competency requirements of 61.385. If the list of privileges for an instructor didn't let them teach that stuff then that would be silly!
Yep you need an instructor rating to teach someone how to fly an aircraft that they are not allowed by regs to fly because of say, a design feature or the aircraft not being a type or class that they are licensed on, or to conduct a flight review.
I've had it clearly from casa that "training" (ie giving icus to) a pilot who is licensed to fly an aircraft we operate in our sop is not training that requires a flight instructor rating. The pilot has already been trained/reviewed/certified competent by an instructor already, hence why they are licensed to fly it. The operator still has to ensure they cut the mustard and are up to their standard.
It does get a little more complex though when you start having type ratings, OPCs, approved check and training etc all involved.
Thorny, just because he has 15,000 hours doesn't necessarily mean he knows how to check and train. Without any more details, this 15,000 hour guy might have 14,500 hours single, maybe some single turbine, have his 500 multi command, and maybe he has just put a jet on the AOC and wants to train people himself in that! All without ever being in a formalised C&T process himself.
By your logic, if a pilot friend asked you at the bar one night "hey, I've forgotten, what was the stall speed on (insert the plane we both fly)?" then you would be giving training!
61.1165e allows an instructor to obviously teach the general competency requirements of 61.385. If the list of privileges for an instructor didn't let them teach that stuff then that would be silly!
Yep you need an instructor rating to teach someone how to fly an aircraft that they are not allowed by regs to fly because of say, a design feature or the aircraft not being a type or class that they are licensed on, or to conduct a flight review.
I've had it clearly from casa that "training" (ie giving icus to) a pilot who is licensed to fly an aircraft we operate in our sop is not training that requires a flight instructor rating. The pilot has already been trained/reviewed/certified competent by an instructor already, hence why they are licensed to fly it. The operator still has to ensure they cut the mustard and are up to their standard.
It does get a little more complex though when you start having type ratings, OPCs, approved check and training etc all involved.
Thorny, just because he has 15,000 hours doesn't necessarily mean he knows how to check and train. Without any more details, this 15,000 hour guy might have 14,500 hours single, maybe some single turbine, have his 500 multi command, and maybe he has just put a jet on the AOC and wants to train people himself in that! All without ever being in a formalised C&T process himself.
Thread Starter
61.385 mentions nothing about having to hold an instructor rating. Not sure where you are coming up with that? I don't think it is creating a "pseudo type rating". Type and class ratings are clearly defined.
By your logic, if a pilot friend asked you at the bar one night "hey, I've forgotten, what was the stall speed on (insert the plane we both fly)?" then you would be giving training!
61.1165e allows an instructor to obviously teach the general competency requirements of 61.385. If the list of privileges for an instructor didn't let them teach that stuff then that would be silly!
Yep you need an instructor rating to teach someone how to fly an aircraft that they are not allowed by regs to fly because of say, a design feature or the aircraft not being a type or class that they are licensed on, or to conduct a flight review.
I've had it clearly from casa that "training" (ie giving icus to) a pilot who is licensed to fly an aircraft we operate in our sop is not training that requires a flight instructor rating. The pilot has already been trained/reviewed/certified competent by an instructor already, hence why they are licensed to fly it. The operator still has to ensure they cut the mustard and are up to their standard.
It does get a little more complex though when you start having type ratings, OPCs, approved check and training etc all involved.
Thorny, just because he has 15,000 hours doesn't necessarily mean he knows how to check and train. Without any more details, this 15,000 hour guy might have 14,500 hours single, maybe some single turbine, have his 500 multi command, and maybe he has just put a jet on the AOC and wants to train people himself in that! All without ever being in a formalised C&T process himself.
By your logic, if a pilot friend asked you at the bar one night "hey, I've forgotten, what was the stall speed on (insert the plane we both fly)?" then you would be giving training!
61.1165e allows an instructor to obviously teach the general competency requirements of 61.385. If the list of privileges for an instructor didn't let them teach that stuff then that would be silly!
Yep you need an instructor rating to teach someone how to fly an aircraft that they are not allowed by regs to fly because of say, a design feature or the aircraft not being a type or class that they are licensed on, or to conduct a flight review.
I've had it clearly from casa that "training" (ie giving icus to) a pilot who is licensed to fly an aircraft we operate in our sop is not training that requires a flight instructor rating. The pilot has already been trained/reviewed/certified competent by an instructor already, hence why they are licensed to fly it. The operator still has to ensure they cut the mustard and are up to their standard.
It does get a little more complex though when you start having type ratings, OPCs, approved check and training etc all involved.
Thorny, just because he has 15,000 hours doesn't necessarily mean he knows how to check and train. Without any more details, this 15,000 hour guy might have 14,500 hours single, maybe some single turbine, have his 500 multi command, and maybe he has just put a jet on the AOC and wants to train people himself in that! All without ever being in a formalised C&T process himself.
Thread Starter
Sunfish - having CASA create their own version of ICAO Flight Crew Licencing rules is like putting the rats in charge of the cheese factory!!
What user pays and airport privatisation started, part 61 will finish. RIP GA...
What user pays and airport privatisation started, part 61 will finish. RIP GA...
Last edited by roundsounds; 7th Feb 2016 at 01:06.
The info sheet supports the FOI's interpretation and guidance on how to satisfy the intent of 61.385.
The crunch comes when such matters are adjudicated on by a court, and it would be a brave person who relied on the info. sheets as legal interpretation documents.
Re. "Instructor's Ratings", the policy, embodied in the plain language drafts of the original Part 61, said that all present C&T, by whatever name, would AUTOMATICALLY get "Instructor's Ratings" limited to precisely what they were qualified for in the airline training department, CAR 217 organisation of whatever. It would be a change of name, not function.
The policy never was that an airline C&T could suddenly conduct basic flying training, unless he/she was otherwise qualified. It is the b###sh1t interpretations of the FOIs (most of then ex-GA/Mil) that have shafted the intent, and are now not differentiating between "instructors" at flying school level, and airline/CAR 217 level.
This is a problem generated entirely within CASA, as a result of the shambles of the final version of Part 61.
Tootle pip!!
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Guys,
A lot of hysteria here. Nothing has changed. CP can check anybody to line under CAO 82. You all used to have to do endorsements right ?? So for aircraft under 5700kg what you do is you still go to a suitably qualified Instructor and do a ground school, if required, and then enough flying, say 3-5 hours to pass a flight review in that type. Then you have the basics and hopefully wont scare the CP who doesn't have an instructor rating. It has never been the job of a CP to endorse you on type.
Leadsled I think you mentioned the thing about Part 61 that really annoys most people in that T & C approvals were not automatically turned into Flight Examiner ratings. That process is at the mercy of the individual FOI and costs thousands if you can convince them to let you do it. The CASA Impact Study said, "no appreciable cost to industry", which was one of the bigger stuff ups I have seen in recent history.
Groggy
A lot of hysteria here. Nothing has changed. CP can check anybody to line under CAO 82. You all used to have to do endorsements right ?? So for aircraft under 5700kg what you do is you still go to a suitably qualified Instructor and do a ground school, if required, and then enough flying, say 3-5 hours to pass a flight review in that type. Then you have the basics and hopefully wont scare the CP who doesn't have an instructor rating. It has never been the job of a CP to endorse you on type.
Leadsled I think you mentioned the thing about Part 61 that really annoys most people in that T & C approvals were not automatically turned into Flight Examiner ratings. That process is at the mercy of the individual FOI and costs thousands if you can convince them to let you do it. The CASA Impact Study said, "no appreciable cost to industry", which was one of the bigger stuff ups I have seen in recent history.
Groggy
Thread Starter
Extract from the CASA website:
"General competency requirement
What is the general competency rule?
Every pilot must abide by the general competency requirement, which is covered in Civil Aviation Safety Regulation 61.385. This regulation means that you are responsible for ensuring you are competent to fly a particular aircraft and conduct a particular kind of operation, even if you hold the necessary authorisations. That includes being competent in:
- operating the aircraft's navigation and operating systems
- conducting all normal, abnormal and emergency flight procedures for the aircraft
- applying operating limitations
- weight and balance requirements
- applying aircraft performance data, including take-off and landing performance data, for the aircraft.
Pilots should consider undertaking training from a qualified person before flying a type of aircraft they have not previously flown, even if they hold the relevant class or type rating.
Always apply prudent airmanship before flying an aircraft you are not familiar with or haven't conducted a kind of operation recently."
"General competency requirement
What is the general competency rule?
Every pilot must abide by the general competency requirement, which is covered in Civil Aviation Safety Regulation 61.385. This regulation means that you are responsible for ensuring you are competent to fly a particular aircraft and conduct a particular kind of operation, even if you hold the necessary authorisations. That includes being competent in:
- operating the aircraft's navigation and operating systems
- conducting all normal, abnormal and emergency flight procedures for the aircraft
- applying operating limitations
- weight and balance requirements
- applying aircraft performance data, including take-off and landing performance data, for the aircraft.
Pilots should consider undertaking training from a qualified person before flying a type of aircraft they have not previously flown, even if they hold the relevant class or type rating.
Always apply prudent airmanship before flying an aircraft you are not familiar with or haven't conducted a kind of operation recently."
roundsounds,
I can't see anywhere in 61.385, 61.1185 or any of the CAO 82 regs that states that a Chief Pilot would need to hold a G2 instructor rating.
The info sheets aren't legislation, they are merely advice/guidance material. The info sheet could be incorrect!
Check your PM.
I can't see anywhere in 61.385, 61.1185 or any of the CAO 82 regs that states that a Chief Pilot would need to hold a G2 instructor rating.
The info sheets aren't legislation, they are merely advice/guidance material. The info sheet could be incorrect!
Check your PM.
