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Old 13th Feb 2020, 16:33
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Join Date: Jul 2019
Location: London
Posts: 1
ATP(A) Integrated SPIC hours


I am wondering if anybody can actually provide a definitive answer into SPIC hours which can be logged by ATP(A) Integrated students. In particular, the Part-FCL Appendix 3 (A) (Page 1128) which lists flying training requirements seems to be slightly ambiguous to me:
(a) 95 hours of dual instruction, of which up to 55 hours may be instrument ground time;
(b) 70 hours as PIC, including VFR flight and instrument flight time as student pilot in-command (SPIC). The instrument flight time as SPIC shall only be counted as PIC flight time up to a maximum of 20 hours;
(c) 50 hours of cross-country flight as PIC, including 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;
(d) 5 hours flight time shall be completed at night, comprising 3 hours of dual instruction, which will include at least 1 hour of cross-country navigation and 5 solo take-offs and 5 solo full stop landings; and
(e) 115 hours of instrument time comprising, at least:
(1) 20 hours as SPIC;
(2) 15 hours MCC, for which an FFS or FNPT II may be used;
(3) 50 hours of instrument flight instruction, of which up to:
(i) 25 hours may be instrument ground time in a FNPT I, or
(ii) 40 hours may be instrument ground time in
From the above I understand that (b) mandates for 70 PIC hours, for which up to 20 hours of SPIC time can be counted as PIC. I.e. it means that at least 50 hours must be flown solo as part of the training, which is fine. For examples, in a most favorable scenario a student could fly exactly 50 hours VFR solo and then use 20 hours from IFR SPIC time to comply with total of 70 PIC hours.

But then (e)(1) states that at least 20 hours of IFR must be flown as SPIC. And this is where it gets confusing and questions appear:
  • Does the regulation mean that only a maximum of 20 hours of IFR can be logged as SPIC (and hence PIC) in logbook?
  • Or does the reg say that one can log more than 20 hours of SPIC in IFR, but only 20 hours of those can be counted in order to satisfy (b)?
Naturally, every student would want to log as much PIC time as possible, hence if it is possible to log more than 20 hours of SPIC and still comply with remaining clauses (i.e. dual time) then people would. So the ultimate overall question is:

Is it OK for an integrated ATP(a) student to log more than 20 hours as SPIC time (and hence increase total logbook PIC), but count only 20hr of those SPIC towards the 70hr PIC requirement of the regulation?
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