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Old 16th Jul 2008, 15:46
  #21 (permalink)  
 
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Altp For 1900d As A Commander

Bad news for the Comm 1900 captains.

The meeting held today has brought bad news for the guys with a comm flying as a captain on the 1900D...(C to follow soon).

As of today, any person caught flying a 1900D as a captain with only a comm, will be in contravention of the CAT''s / CAR'S.

It was debated for 90 mins on the subject and as the law is very very clear on the privalliges of a comm pilot / ATP and flying multi crew aeroplanes.

The 1900D is a factory certified multi crew aircraft,(9 seats or more), and above 5700kg, thus requiring a ALTP as the commander.

This has now come from the commissioner.

Some of the operators were informed of the commissioners decision and stance on this, this afternoon,

As there are people who do not like what has happened, you are at liberty to apply for an exemption from this law.

The unfortunate thing is, the whole industry new that this day was coming.
Some definitely did something about it, others carried on hoping that it would just go away.
As it is a law, zero grace can be given, except in the event of a exemtion from the commissioner.

Goffel.
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Old 16th Jul 2008, 15:58
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Great news for ATP captains!!!!!sorry for all the comm captains.
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Old 16th Jul 2008, 16:42
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So SACAA has decided to go in contravention to JAA and FAA. The aircraft is FAR 23 certified and SFAR41 as commuter aircraft catogory. So 2 crew are mandatory in part 135/121 operations, however the PIC does not require ATP overseas.

I do not mind as I am just starting out as FO anyway, busy with my ATP. However some SA companies will suffer due to PIC shortage. At least now there is clarity to the subject.

Last edited by Propellerpilot; 17th Jul 2008 at 09:11. Reason: correction
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Old 16th Jul 2008, 16:53
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well well well...... very interesting! this is a good move I think better for us with ATP's, but Solenta and Norse Air are going to kuk off!!!!! Loads of CPL's poling left seat there!
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Old 16th Jul 2008, 17:22
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That's really going to put some hyenas into the baby birds' nests.
Many thanks to G for keeping people posted.
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Old 17th Jul 2008, 06:45
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some clarity with facts

Here is the link to the actual FAA certification certificate for the B1900 C and D stating single pilot certification ( see page 39 )...

http://rgl.faa.gov/Regulatory_and_Gu...FILE/A24CE.pdf

Here is the link from the FAA library stating the B1900 series ( C and D ) can be tested as single pilot, ( read page 5... F (1)-(5).)
B1900C is certified under SFAR41 and the B1900D in the "Commuter Category"... ( see page 2...para 3 note 6 (f) )

http://www.airweb.faa.gov/Regulatory...87103D-C13.pdf

SA CAA Part 61.05.5 (5) (c)
(c) act as pilot-in-command in commercial air transport operations in any
aeroplane certified for single-pilot operation;
ICAO Annex 1, UK CAA, and JAR ( FCL 1.150 Priveleges and conditions ) note (3) allow a Commercial pilot to "act as pilot-in-command in commercial air transportation of any single pilot aeroplane; "

By adding a second pilot, does that change the aircraft certification ? NO.
Does it increase the safety margin ? YES

It defies logic that a 250hr Comm is allowed to fly a B1900D with 9 pax as a single pilot as P1, yet add one pax and suddenly this is unsafe and he now needs 1500hrs and an ATPL !? What if he has 9 pax and 1 ton of cargo, his TOW will still be well above 12500lbs (5700kg) yet he may still fly as P1 single pilot with a Comm ?^%*&^
What about B1900D Cargo aircraft - they don't have more than 9 seats ?
All SA 1900 operators operate the B1900 with 2 pilots, but the fact remains, it is still a single-pilot certified aircraft.

For an aircraft to be MCC certified, there is a huge amount of certification requirements, equipment fit, performance requirements ( JAA 2.1% FAA 2.4% 2nd stage climb etc ) The B1900 does NOT meet these, therefore never was, nor will it ever be, MCC certified.
You cannot test for ATPL under JAA on the B1900 as it is not MCC, it is a single pilot certified aircraft.

Obviously this interpretation of the law would adversely affect Operators, and pilots alike. What happens to those pilots already operating as Captain on the B1900 with a Comm and P1 rating, some of these guys have been doing this for years, the CAA has approved AOC's and Operations Manuals and logbooks and licences like this for years.
If it is decided that a B1900 Captain will now need an ATPL, after being told by the CAA many times, they consider it a single-pilot certified aircraft and a Comm Pilot CAN fly as a Captain, there would need to be a reasonable transition period for Operators and crew alike to meet this restriction. Until then, the status quo should remain.

The most important thing here is to reach a safe, sensible, legal agreement that complies with the law, and doesn't kill an industry already reeling from the effects of oil price increases, redundancies etc.
Just look at SAA's latest financial results..........
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Old 17th Jul 2008, 07:01
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i agree with the above post, it is not going to be easy now for the operators. what about the guys in the field now flying left seat without a atpl? does the CAA really expect one to call them home? what agreement was reached about a transition period if any?
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Old 17th Jul 2008, 08:43
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If the CAA has decided that the B1900, in commercial operations for hire or reward, should be a two crew operation with the Commander having an ATPL, then that would seem to be something which lies within its authority. A CAA of any country is entitled to err, if that is the apposite word, on the side of caution which is, in effect what the SA CAA has done.
(It might be relevant, especially in terms of FAA regulations, to remember that a CPL holder does not have to have an instrument rating for his licence to be valid.)
Arguments to the effect that because the FAA allow single crew/IFR/commercial operations in a B1900 (if they do) are somewhat disingenuous. South Africa has its own regulations and its CAA is perfectly entitled to make whatever changes it deems fit to what has, up to now seemed to have been more of a tendacious arrangement than a legal prerogative.

It is difficult to see how exemptions could be made. There hardly seems to be flexibility in determining which CPL holder is better qualified to fly such an aircraft single crew than another. One suspects that the easiest solution for the CAA will simply be not to grant exemptions at all. A period of grace would perhaps be a more realistic option but even that would be difficult to implement and there would inevitably be enormous clamour for extensions.
It is somewhat difficult to see that the CAA, in arriving at its decision has allowed itself any room for manouevre. From this then, must one conclude that the CAA does not seek room for such flexibility?
This is, of course, all very distressing for those pilots who find themselves in a position of some licencing awkwardness. It is also presumably a difficult time for the operators. Presumably and as of this morning, any insurance cover on B1900s will be automatically void when flown by a CPL for hire or reward?
It is true, however, to say that this matter has been bandied about for a long time. There has been opportunity for those in the flying positions in question to obtain their ATPLs. The writing has hardly just appeared on the wall as it did at Balthasar's Feast.
Therein perhaps lies a possible saving grace if one were to be sought. It seems obvious enough that the CAA have predicted the onslaught from operators and pilots that their decision will cause. It would be reasonable for the CAA to wish to draw a line under this matter as soon as possible. Suppose therefore that the CAA were to grant a temporary exemption to any Commercial Pilot who had, at the least, obtained a partial pass in his ATPL examinations and then set a reasonable time limit, six months or one year perhaps, for the completion of the licence. Such an action would ease the situation insofar as operators are concerned, possibly make life a little easier for the CAA and afford recognition to those pilots who, having seen which way the wind was blowing, had decided to do something about it?
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Old 17th Jul 2008, 09:23
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I completely agree with all said above. The fact remains the aircraft is over 5700kg(well over I may add....) I also agree with the fact that there are alot of very highly experienced captains flying 1900's for SA operators that do not have SACAA/ICAO ATPL licenses, but hold FAA/JAA atpl's instead. I feel desperately sorry for these pilots. What must be kept in mind is a lot of operators in SA have been getting away with murder, employing 1200-1300hr comm captains on the 1900(where 900hrs of the respective captains experience lies in the circuit, doing touch and goes in a TIRED old c150) and paying them less then half the market rate, because quiet frankly, they do not have the experience to be in that position, realizing that, the pilot accepts the salary on the grounds he/she 'needs the hrs'. What this does to the guys with the right amount of experience(not mentioning ATPL)is career threatening, suddenly experience means nothing, operators would rather employ inexperienced pilots, on the grounds that it is legal, and pay them peanuts!!!!!!! instead of the employing pilots with the right amount of experience and having to pay a little more. This law(having to hold an atp to command a 1900D)will STOP this abuse!!!!!!and companys will be forced to employ experienced pilots and pay the market rate. Having flown for quiet a few years, it is always drummed into a pilot,that if there are two conflicting laws, you always apply the most restrictive of the two, the aircraft may be a "single crew certified" aircraft, BUT its over 5700kgs as well, which law overides which???
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Old 17th Jul 2008, 09:36
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I have serious doubts but that, had such crew/s been flying with their levels of experience during a northern European winter, there would have been some very unfunny, fun and games.
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Old 17th Jul 2008, 09:50
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Solenta is 100% correct. I doubt that a captain with 3000hrs on type with only a CPL/IF will suddenly become a better or more qualified pilot when writing those SACAA ATP exams. However he will make himself more marketeble for true FAR25 aircraft if he does. So better do it now than when it changes to the new Part61 exams in January.

One thing uncertain however is, that voices I hear from oversees (JAA) state, that SFAR41 commuter hours are counted towards unfreezing of an ATP, but you can still have a CPL/IF captain flying the aircraft PIC.

My question is now, how big is the transition from a 1900 to a true FAR 25 aircraft (say a Dash8 or Canadair Jet) for the pilots ?
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Old 17th Jul 2008, 10:02
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The law says?????????????

Solenta.......please take out your 1900D Raytheon manual...go to Limitations...page 30.

I PILOT: All passanger seats in excess of nine (9) must be rendered nonoccupiable by "DO NOT OCCUPY" seat belt tube assembly...(anotherwords, more than 9 pax, now makes it a certified multi crew ???)

If you can convince the Commissioner that the 1900D is in actual fact a single crew operation with more than 9 pax's, then I am sure you will get an exemption.

If you cannot convince the Commissioner of such, I am pretty sure your exemption will be turned down.

The privilages of a commercial pilot is very clear in saying that one may act as a co-pilot in a certified multi-crew operation.

Yes, it does also say that a comm pilot may act as a commander on a certified single crew operation, regardless of weight..(a figure that was ommitted from version 8 of the up-dates.

But lets be fair, every operator of a 1900 has known for years that this little loophole would be closed, and in fact last year, the same month as we are in now, the same was debated and the industry was told that it would be clamping down....in other words, the operators have definitely had enough time to get ATP pilots to drive their machines.

If you start giving out exemptions for the 1900's, what is stopping the E120 operators asking for the same as the weight difference is not that much....or any other operators of a/c above 5700kg's.

I am pretty sure that there are going to be ATP pilots out there watching this whole debate with interest, just waiting for people to get exemption, then they will pounce on the CAA with a law suite as their jobs are being taken away from them by a comm pilot.

What is good for one, wil be just as good for the other.

The fact is, there are ATP pilots out there looking for jobs, but are not prepared to work for a comm pilot's salary....and rightly so...they studied, slaved and passed....so why accept the comm salary.

The fact of the matter is...it is a law....and an operator/pilot must obey the law of his country.

Goffel...(the above is my personal opinions only).
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Old 17th Jul 2008, 10:11
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Of course, man to man, a pilot with 3,000 hours on a B1900 and an ATPL is a better and more qualified pilot than one with a CPL and the same time.

He is better educated and he has demonstrated qualities of ambition, initiative and perseverance which the other has not!
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Old 17th Jul 2008, 10:21
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Quick question for Goffel: will p2 time on the 1900D now count in full or will it still be halved?

81
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Old 17th Jul 2008, 10:44
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One does get very confused with all this FAR stuff. Tendency arises then to let airmanship and common sense prevail.
Transitioning from a machine such as a B1900 to a Dash 8 piece of kit shouldn't pose too much problem so long as the electronic ergonomics of the cockpits are fairly similar. An FMS and its usual operation in an SOP can take a little getting used to as well.
Same goes, in principle, as between the B1900 and a baby jet but I think that most people with experience on a B1900 would need to cycle a little faster during the first few hours of conversion to the Canadair or a B737 for example.
There's a bit of a technique difference between flying an instantly responsive turbo prop and a oscillatorally (?) inclined jet.
Then there is that which seems to be never mentioned in South African aviation training terms. It's the hardest bit of the lot and it's called Line Training.
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Old 19th Jul 2008, 15:44
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Next talks on Tuesday

Unreal......the left hand does not agree with the right hand.....it is so enjoyable to see the likes of boffins arguing the facts (or no facts), of law and the little interpretations.
..
Good news for the 1900 comm pilots though.
..
Bad news for the 1900 ATP pilots looking for work...(and that there are genuinely a few who have been in contact).
..
Round number 6 starts on Tuesday morning....

Goffel.....sitting on the beach in Plett.
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Old 19th Jul 2008, 16:01
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Is it too much to conjecture that, in the middle of this hiatus, every SA CPL flying a 1900 'in command' has signed up for an ATPL examination date?
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Old 20th Jul 2008, 11:20
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Cavorting Spotty.....and to think that they got a discount on the exam fees....all you had to do was have a letter from your company saying that you were a poooooor 1900 D comm peeeeloooot and could not afford the fees.

This entitled you to 50% discount on the exam fees, the pass mark had been lowered to 65%, but could be lowered even more if you had flown the C model as well.

And now this has all been taken away due to round number 6....no more discount.

Eisch.
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Old 20th Jul 2008, 13:46
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At the risk of posting an unpopular post, a terror which usually does not act as a disincentive, one has to say this. The SA licence would seem to be accepted in most countries in the sub continent. Certainly, as far as one can determined, the SA ticket is highly revered south of the Sahara and one is constantly bumping into fellows hanging around downstairs at Waterfall Park, waiting for their treasured validations. That being the case and bearing in mind that African Africa, of such a term may be used, is considerbly bigger than Europe or JAR land, it seems that the SA CAA fees are remarkably low. Bearing in mind the territorial size of the land mass over which the SA licence reigns and balancing that versatility against a JAR licence, should not the SA CAA fees rise tenfold to reflect proportional representation?
Furthermore, is it not reasonable to expect that, if an experienced pilot writes a technical examination, his standard of knowledge might equally reasonably expected to be higher than a pilot with no such experience? Such a justified assumption should then logically lead to an increase in the pass mark required rather than a decrease?
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Old 20th Jul 2008, 14:49
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Bored Mr Cheetah?

Trawling for turds is most unbecoming.....
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