DanishPilot
19th Nov 1999, 14:34
Dear fellow PPRuNers.
(Also YOU with ATPL or just lucky ones holding multi pilot airplanes on their national licence.)
I will not just sit back and watch, so to do something about it I wrote this email to Mrs. Mengelberg-Thissen, head of JAA JAR FCL office, on [email protected]:
-----------------------------------------
Att.: Mrs. Mengelberg-Thissen,
Regarding Transition procedures.
--------------------------------------------------------------------------------------------------------------
Dear Mrs. Mengelberg-Thissen. I am a CPL/IFR ME Fz. ATPL pilot from Denmark. (More about my hours and status on www.danbbs.dk/~lohse/cv (http://www.danbbs.dk/~lohse/cv) )
I am writing to you to point out some aspects of the procedure in the transition from National certificates to JAR FCL which I find are unfair to a certain groups of pilots.
----------------------------------
Mainly, it is the matter of
* Losing the credit of ATPL ground school when changing to JAR FCL certificates/ratings, as applicable to some pilots
* The requirement for an MCC course for pilots who have vast experience in approved two-pilot environments, yet only on SPA
* The MCC and ATPL ground school issues above in reality locks pilots without ATPL/MPA rating to his/her licensing country, until the pilot redoes courses that he/she have already taken
* If a rating on an SPA can be restricted to "Co-pilot only" - how can it be a single pilot aircraft to this pilot, if he/she cannot fly it alone, not even private and/or VFR conditions ?
* In many countries, including Denmark, many SPA cannot be operated commercially with one pilot only. When flying commercially on these planes it is then NOT possible to fly them single pilot. In Denmark this is valid for planes approved for more than 10 pax seats, which many SPA are. Similar rules are in other JAR countries.
----------------------------------
Let me show some examples of scenarios and what the outcome PRESENTLY is:
Example 1:
Qualifications: Pilot with CPL/IFR Multi engine frozen ATPL 7000 hours total, 5000 command, 3500 hours in approved multi pilot environment on Metro, Citation 501 and other SPA. 0 hours in MPA
Need for courses: MCC course, ATPL 300 hours theory ground school and test if not reaching 500/1500 hours before JAR FCL conversion becomes necessary. Will lose all complicated types if the ATPL ground school is not taken.
Example 2:
Qualifications: Pilot with CPL/IFR Multi engine, frozen ATPL, 400 hours total, 50 hours in Shorts 330/360 MPA
Need for courses: No MCC. If reaching 1500 hours on MPA before JAR FCL conversion, then no ground school is required
Example 3:
Qualifications: Pilot with ATPL, 1500 hours total (captain on at least one MPA)
Need for courses: Proficiency check, show knowledge of JAR.
Example 4:
Qualifications: Pilot with CPL/IFR frozen ATPL, 2000 hours total, captains rating on King Air (Which is "only" a SPA)
Must go to another JAR country to fly as captain because of no other job options. Must go through JAR FCL, and thereby loses the rating, as ATPL theory is required to fly this "complicated" plane.
Need for courses: Must do ATPL ground school over again, now according to JAR, before this can be done.
----------------------------------
In the above, only example 2 and 3 seems fair. Example 1 and 4 are way out of proportion to actual qualifications and experience. How can an MPA (Shorts/Jetstream/DC-3/Citation500) pilot be better qualified than an SPA (Metro/KingAir/Citation501) pilot ?
Of course there has to be a limit.
What I urge you to change from present transition procedures could be as shown in the following examples:
One limit considered "too easy" could be "All pilots with national CPL/IFR Multi engine before JAR FCL implementation need not MCC nor to redo ATPL ground school if already completed, and if experience in approved multi pilot operations are documented". If this is "too easy" to present pilots, then how about
Qualifications: Minimum CPL/IFR multi engine, frozen ATPL, 500 hours total, 100 hours in CAA approved multi pilot environment
Need for courses: No MCC required, frozen ATPL theory will remain frozen to JAR FCL licence. Next flight test: Must demonstrate knowledge to JAR FCL.
Also, all approved and passed national ATPL theory courses within the JAR region should be transferrable, regardless of experience.
What is the reasonable argument for requiring to do again what has already been done ? Why does this not apply to ATPL holders then - they have gone through the same national ATPL theoretical courses !
----------------------------------
For you and the JAA board it is not difficult to state the requirements.
Neither is it a problem to the larger operators.
But to an unemployed pilot caught between national and JAR, a 3 week MCC course in the order of £3000 AND a 3 month / 300 hour ATPL ground school in the order of £6000, (a course which has already been done according to national rules), can be difficult to overcome financially, after spending £50000 or more already on the education to this point.
But the ground schools are happy for this new money making scheme.
£9000 and 4 months with no possibility to work at the same time. This is hard for those of us that thought we had that all behind us !
Please be fair and change the transition rules to a decent and respectful level, so JAR can provide the freedom over borders that it is here for, also in this transition period so hard for us all !
Thank you for reading this far - hope for your understanding.
Regards
Kåre Lohse
www.danbbs.dk/~lohse (http://www.danbbs.dk/~lohse)
-----------------------------------------
Write your local CAA or directly to Mrs. Mengelberg-Thissen, head of JAA JAR FCL office, on [email protected] or the address found on www.jaa.nl. (http://www.jaa.nl.)
JAR definitions:
MPA: Multi Pilot Aircraft - must be required multi pilot on aircraft certification
SPA: Single pilot aircraft - certificated for single pilot ops
MCC: Multi Crew Coordination course - required as noted in the letter above.
JAR rescources:
AMC FCL 1.220: List of what planes are SPA and MPA
JAR FCL 1 for the rest of the relevant information.
(Also YOU with ATPL or just lucky ones holding multi pilot airplanes on their national licence.)
I will not just sit back and watch, so to do something about it I wrote this email to Mrs. Mengelberg-Thissen, head of JAA JAR FCL office, on [email protected]:
-----------------------------------------
Att.: Mrs. Mengelberg-Thissen,
Regarding Transition procedures.
--------------------------------------------------------------------------------------------------------------
Dear Mrs. Mengelberg-Thissen. I am a CPL/IFR ME Fz. ATPL pilot from Denmark. (More about my hours and status on www.danbbs.dk/~lohse/cv (http://www.danbbs.dk/~lohse/cv) )
I am writing to you to point out some aspects of the procedure in the transition from National certificates to JAR FCL which I find are unfair to a certain groups of pilots.
----------------------------------
Mainly, it is the matter of
* Losing the credit of ATPL ground school when changing to JAR FCL certificates/ratings, as applicable to some pilots
* The requirement for an MCC course for pilots who have vast experience in approved two-pilot environments, yet only on SPA
* The MCC and ATPL ground school issues above in reality locks pilots without ATPL/MPA rating to his/her licensing country, until the pilot redoes courses that he/she have already taken
* If a rating on an SPA can be restricted to "Co-pilot only" - how can it be a single pilot aircraft to this pilot, if he/she cannot fly it alone, not even private and/or VFR conditions ?
* In many countries, including Denmark, many SPA cannot be operated commercially with one pilot only. When flying commercially on these planes it is then NOT possible to fly them single pilot. In Denmark this is valid for planes approved for more than 10 pax seats, which many SPA are. Similar rules are in other JAR countries.
----------------------------------
Let me show some examples of scenarios and what the outcome PRESENTLY is:
Example 1:
Qualifications: Pilot with CPL/IFR Multi engine frozen ATPL 7000 hours total, 5000 command, 3500 hours in approved multi pilot environment on Metro, Citation 501 and other SPA. 0 hours in MPA
Need for courses: MCC course, ATPL 300 hours theory ground school and test if not reaching 500/1500 hours before JAR FCL conversion becomes necessary. Will lose all complicated types if the ATPL ground school is not taken.
Example 2:
Qualifications: Pilot with CPL/IFR Multi engine, frozen ATPL, 400 hours total, 50 hours in Shorts 330/360 MPA
Need for courses: No MCC. If reaching 1500 hours on MPA before JAR FCL conversion, then no ground school is required
Example 3:
Qualifications: Pilot with ATPL, 1500 hours total (captain on at least one MPA)
Need for courses: Proficiency check, show knowledge of JAR.
Example 4:
Qualifications: Pilot with CPL/IFR frozen ATPL, 2000 hours total, captains rating on King Air (Which is "only" a SPA)
Must go to another JAR country to fly as captain because of no other job options. Must go through JAR FCL, and thereby loses the rating, as ATPL theory is required to fly this "complicated" plane.
Need for courses: Must do ATPL ground school over again, now according to JAR, before this can be done.
----------------------------------
In the above, only example 2 and 3 seems fair. Example 1 and 4 are way out of proportion to actual qualifications and experience. How can an MPA (Shorts/Jetstream/DC-3/Citation500) pilot be better qualified than an SPA (Metro/KingAir/Citation501) pilot ?
Of course there has to be a limit.
What I urge you to change from present transition procedures could be as shown in the following examples:
One limit considered "too easy" could be "All pilots with national CPL/IFR Multi engine before JAR FCL implementation need not MCC nor to redo ATPL ground school if already completed, and if experience in approved multi pilot operations are documented". If this is "too easy" to present pilots, then how about
Qualifications: Minimum CPL/IFR multi engine, frozen ATPL, 500 hours total, 100 hours in CAA approved multi pilot environment
Need for courses: No MCC required, frozen ATPL theory will remain frozen to JAR FCL licence. Next flight test: Must demonstrate knowledge to JAR FCL.
Also, all approved and passed national ATPL theory courses within the JAR region should be transferrable, regardless of experience.
What is the reasonable argument for requiring to do again what has already been done ? Why does this not apply to ATPL holders then - they have gone through the same national ATPL theoretical courses !
----------------------------------
For you and the JAA board it is not difficult to state the requirements.
Neither is it a problem to the larger operators.
But to an unemployed pilot caught between national and JAR, a 3 week MCC course in the order of £3000 AND a 3 month / 300 hour ATPL ground school in the order of £6000, (a course which has already been done according to national rules), can be difficult to overcome financially, after spending £50000 or more already on the education to this point.
But the ground schools are happy for this new money making scheme.
£9000 and 4 months with no possibility to work at the same time. This is hard for those of us that thought we had that all behind us !
Please be fair and change the transition rules to a decent and respectful level, so JAR can provide the freedom over borders that it is here for, also in this transition period so hard for us all !
Thank you for reading this far - hope for your understanding.
Regards
Kåre Lohse
www.danbbs.dk/~lohse (http://www.danbbs.dk/~lohse)
-----------------------------------------
Write your local CAA or directly to Mrs. Mengelberg-Thissen, head of JAA JAR FCL office, on [email protected] or the address found on www.jaa.nl. (http://www.jaa.nl.)
JAR definitions:
MPA: Multi Pilot Aircraft - must be required multi pilot on aircraft certification
SPA: Single pilot aircraft - certificated for single pilot ops
MCC: Multi Crew Coordination course - required as noted in the letter above.
JAR rescources:
AMC FCL 1.220: List of what planes are SPA and MPA
JAR FCL 1 for the rest of the relevant information.