FRTOL and Air/Ground

[Ryan5252]

Hi,

Quick question please. Can the holder of an FRTOL provide an air/ground service under the call sign 'Radio'? It is my understanding that they cannot (hence the 'Flight') but I am told I am wrong...

best
Ryan

[dan_vector]

Hi,

No you can't. LASORS section B paragraph B1.1 refers.

"The FRTOL does not entitle the holder to operate a radio station which is installed anywhere other than an aircraft"

[Whopity]

The privileges of the FRTOL are in the ANO Schedule 7
Flight Radiotelephony Operator’s Licence
Minimum age – 16 years
Maximum period of validity – 10 years
Privileges:
The holder of a Flight Radiotelephony Operator's Licence is entitled to operate
radiotelephony apparatus in any aircraft if the stability of the frequency radiated by the
transmitter is maintained automatically but is not entitled to operate the transmitter, or to
adjust its frequency, except by the use of external switching devices.A ground radio station needs a Station Licence (http://www.caa.co.uk/default.aspx?catid=8&pagetype=90), and to operate it you need a Certificate of Competence (http://www.caa.co.uk/applicationimages/pdficon_small.gif) issued by the CAA and countersigned by the licensee of the ground radio station.

[athonite]

Whopity, not sure it works that way in reality, if the pilot was issued with a UK PPL and FRTOL, the FRTOL like the PPL is issued for life, However, if you gain a higher licence CPL, ATPL your FRTOL runs for the period of the higher licence (ten years). Complete rubbish know, but I got into an argument with the CAA on this point, as I argued my FRTOL was for life!

[Whopity]

Over the years FRTOLs have been issued for various periods. At one point, the licence was issued for "life" to match the PPL validity, however; that was never in compliance with the ANO which has never indicated a validity period greater than 10 years. Like many others, I have one that was issued for "life" however when you read it, it actually states "for the lifetime of the pilots licence to which it is attached" and gives a number. At the end of the day, its a Court that you would have to convince of its validity, not the CAA, and no doubt there are a number of old licences out there with different wording that may still be legally valid. It always pays to read what is written on the licence.

[UV]

if you gain a higher licence CPL, ATPL your FRTOL runs for the period of the higher licence (ten years). Complete rubbish know, but I got into an argument with the CAA on this point, as I argued my FRTOL was for life!

Me too.
I also argued the point and eventually they re-issed me a lifetime RT Licence (on a lifetime PPL) which includes the wording, and I quote...

"IX> Validity. This licence shall remain in force for the holder's lifetime unless revoked suspended or varied"... End of quote.

So it can be done!

[athonite]

thanks whopity and UV, good points, but do I really need a lawyer before I fly, what is ridiculous, that while I have held onto my UK PPL, I've always considered my professional qualification a separate entity, the CAA don't. Infact they have been obstructive on putting my MEP, and FI on that rating. Having said that I technically flew for six months without a FRTOL and did a FI renewal without one, did the CAA have the balls to prosecute, absolutly, because they no they would be skating on thin ice, the whole thing was complete rubbish.

Just wish I had kept my brown ticket and original FRTOL and AFISO.

Incidently, whopity, you must know this, can UK PPL, still fly on the brown bus ticket, I say yes but you might know better!

Anyone with a UK PLL dont trade it in for a newer model, it's for life!

[chevvron]

I've got a brown card PPL in a plastic wallet issued in 1976 which is non - expiring, and my FRTOL says 'valid for the life of the licence attached and numbered below'

[BillieBob]

A UK PPL(A) will remain valid for the lifetime of the holder, as will an RT Licence attached to it. However, after 8 April 2015 it will be valid only on Annex II aeroplanes

[Whopity]

There are still PPLs flying on the "Credit Card" style licence issued during the 70s in a long plastic wallet, but as BB says, the lifetime bit won't cover EASA aircraft after 2015, but the FRTOL will be valid in them.

[Peter Gristwood]

A UK PPL(A) will remain valid for the lifetime of the holder, as will an RT Licence attached to it. However, after 8 April 2015 it will be valid only on Annex II aeroplanes

So do you need a new RT Licence for flying EASA aircraft if you keep the old CAA UK-PPL? Surely not.

[Jim59]

Can the holder of an FRTOL provide an air/ground service under the call sign 'Radio'?


The answer to this question is, at the moment, YES! However, the CAA don't like that fact and for some time 'suggested' that one has a Radio Operators Certificate of Competence to operate an AGCS. The Certificate used to be issued to holders of the FRTOL on request but more recently one has to pass a specific test (see CAP 452) and apply using form SRG 1413- but it is still free.

There is currently a CAA consultation open about a proposed change to the ANO to close this loophole. If the ANO is amended as proposed it will become a legal requirement to hold the Certificate of Competence to operate an AGCS with the exception that anybody may operate a ground radio for the purpose of avoiding immediate danger. Consultation closes on 14th October 2011. See:
Consultation - Proposal to Amend ANO - Radio Operators Certifcate of Competence | Consultations and Letters of Intent | CAA (http://www.caa.co.uk/default.aspx?catid=2159&pagetype=90&pageid=12337)

[Spitoon]

The answer to this question is, at the moment, YES! Absolute Rubbish!

The various certificates and licences set out the privileges associated with the bit of paper. A FRTOL, of whatever vintage or validity, has never conferred any privileges to routinely operate an AGCS radio station.

As has been pointed out, there was a time when you could simply request a Certificate of Competence for an AGCS ground station if you had a FRTOL but this stopped some years ago. I believe the argument was that just because someone knows how to operate a radio doesn't mean they know what to say/do to provide an AGCS.

What you have to do in order to operate an AGCS station after you get a Certificate of Competence has been set out in a CAP for years.

Having heard some complete tosh spoken by AGCS radio operators I agree with an earlier post (which has now been pulled) that an overhaul of the AGCS is long overdue.

[Jim59]

Absolute Rubbish!

The various certificates and licences set out the privileges associated with the bit of paper. A FRTOL, of whatever vintage or validity, has never conferred any privileges to routinely operate an AGCS radio station.



Spitoon,
I never said it did. What I said was that the holder of a FRTOL can legally operate a ground station because in fact right now anybody can operate an AGCS radio whether they have any relevant certificates, other qualifications, or radio licences or not. Only the ground station needs a licence - not its operator - for an AGCS. The CAA are proposing to change the law precisely because they consider that to be an unsatisfactory state of affairs.

The fact that the CAA have set up a system of certificates of competence does not make it a legal requirement to hold them if the legal basis to make them mandatory has never been enacted.

Whilst the FRTOL does not confer such a privilege - it does not remove it either!

P.S. I'm the licensee of a ground station and hold a certificate of competence.

[Whopity]

Only the ground station needs a licence - not its operator - for an AGCS. The CAA are proposing to change the law precisely because they consider that to be an unsatisfactory state of affairs. Another example of cost cutting and transferring responsibility from one Quango to another. There was no problem when the RA controlled things and the requirements were clearly written in the Schedule to the licence, which was legally binding. The CAA took it over, screwed it up and now has to change the law to regain control!

[2 sheds]

Jim

With respect, this is not quite what CAA publishes in CAP452:
5.1 International Radio Regulations require that all operators of radios utilising aeronautical frequencies, except those used solely for company use for Operational Control Communications (OPC), shall be in possession of a qualification recognised by the relevant government.
5.2 For frequencies approved for use to provide an air ground communication service, the necessary qualification is an Aeronautical Radio Station Operator’s Certificate of Competence. For offshore operations, individuals must be in possession of an Offshore Aeronautical Radio Station Operator’s Certificate of Competence.
5.3 In either case, the holder of the particular radio station licence, as issued by Ofcom, is responsible for ensuring that all individuals using the radio are in possession of the correct certificate (even when under training), and are competent in both the operation of the equipment and local procedures.

There was no problem when the RA controlled things and the requirements were clearly written in the Schedule to the licence, which was legally binding.
The major problem for AGCS, which I hope will be addressed at the same time as the change in legislation, is the specification of the responsibilites (or not) of an AGCS unit/operator.

2 s

[Jim59]

2 sheds

I don't disagree with your comments, however, international rules still need UK legislation to make them applicable to the UK (Europe excepted). The CAA writing what they have in CAP 452 does not have the force of law in the UK; that's why they are planning to make new law and add three new articles to the ANO. One is to prohibit unauthorised use of AGCS stations, the second to legalise the certificate of competence and the last to give the CAA power to regulate training and examinations.

[2 sheds]

Jim

Thank you for that. Without wishing to make a meal of it - as this point will shortly be covered by specific legislation anyway - I would have thought that if the Authority currently requires that the "necessary qualification" is an ARSOCOC (!), then this in effect is a directive from the CAA even if it is not currently enshined in law per se.

If it turns out that this requirement is not worth the paper on which it is written, it does not say much for the CAA's legal input - mind you, neither does the way in which AGCS is conducted.

Regards

2 s

[Mike Cross]

2 Sheds

If a criminal offence could be created by the stroke of a pen by an employee of a government agency I'd emigrate. The right to make law belongs rightly to Parliament.

CAA is not even part of the governemt of this country, they are an agency of DfT. Although they may draft the legislation, they cannnot and do not pass it.

[bingoboy]

I think the CAA are looking to make it law by putting it into the next ANO update which will be signed off by our gov. (prob just a formality)

The concern I have is that it will do nothing for safety.

An FRTOL should be the only CAA test that an A/G operator.

A section to remind them what they can and cannot do could be in the airfields flying order book.

[Whopity]

An FRTOL should be the only CAA test that an A/G operator. As already stated earlier in this thread a FRTOL has nothing to do with A/G operation, and the test does not cover the relevant aspects of A/G operation. A FRTOL(General), never issued in the lifetime of the CAA, did once include such a privilege of ground station operation.
A section to remind them what they can and cannot do could be in the airfields flying order book.There is no requirement for an airfield FOB!I think the CAA are looking to make it lawThe CAA are not empowered to make anything law, they can only make recommendations to government.

The current situation is an "own goal" for the CAA who have totally mismanaged the radio licensing delegated to them by the useless OFCOM!

[2 sheds]

Mike

2 Sheds

If a criminal offence could be created by the stroke of a pen by an employee of a government agency I'd emigrate. The right to make law belongs rightly to Parliament.

CAA is not even part of the governemt of this country, they are an agency of DfT. Although they may draft the legislation, they cannnot and do not pass it.
I do not disagree! What I was referring to was the internal legal advice within CAA.

Bingoboy
The concern I have is that it will do nothing for safety.

An FRTOL should be the only CAA test that an A/G operator.

A section to remind them what they can and cannot do could be in the airfields flying order book.
On your first point, I agree. As said before, it needs to be in addition to the CAA specifying the responsibilities of an AGCS operator.

Point 2 - An FRTOL, in my experience, is most certainly not a qualification to immediately work in AGCS. Operating communications on the ground and relating it to a changing airborne situation is a very different skill.

Point 3 - cross-referring to point 1. It needs to be specified by CAA, not be subject to local variations, and most importantly be clearly understood by pilots.


2 s

[Spitoon]

Some interesting posts. It's a few years since I had any detailed involvement in this stuff but at that time the radio station licensee had an obligation (fully supported in law, through the WT Act as I recall) to ensure that operators of the station were competent. The CAA provided some standards to be followed by operators and a simple means to show who was deemed to be competent (the C of C). Someone who didn't hold a C of C was likely to be placing the radio station licensee in contravention of the law. The upshot of all this was that the CAA never had much control of who was operating the radio station.

The standards that the CAA set are often published as CAPs rather than explicitly in law. The law tends simply to say 'In order to do X you you have to satisfy the CAA' and the way to satisfy the CAA is set out in a CAP. It's a slightly unusual way (when compared to other States) to do things but it has worked quite well for many years. It has allowed the CAA considerable latitude to vary what it takes to satisfy them - whether this is a good or bad thing who knows, but it certainly enables unusual situations to be handled within the existing regulatory framework.

From what Whopity says, it sounds like the conditions attached to the radio station licence have changed. If there is no similar control in the current licensing regime then Jim is probably correct that absolutely anyone can operate an AGCS station.

I guess this might lead one to ask a few other questions. Like, will the proposed new legislation make any difference to anything? I’m guessing that most AGCS operators trying to do it properly had a C of C anyway so the new law just makes this mandatory.

It might be more interesting to ask what an AGCS actually is. Or what does a pilot think he/she is getting from XXX Radio. And if the CAA now has some law to control who is operating a radio station, will they do anything about how the station is being used so as to ensure that the pilot gets what he/she is expecting?

[chevvron]

The FRTOL was once included, along with a valid ATCO licence or RAF Certificate of Competence, as a qualification for the issue of an A/G Certificate rather than take the written and practical exams. This privilege was withdrawn about 2007. It is still up to the radio station licence holder to sign an individual's c of c before that person may use the radio as an A/G operator.
One of the pages in CAP 452 emphasises the differences in phraseology between A/G and FISO phraseology; I have witnessed A/G operators using FISO 'words' eg 'land at your discretion' which they are not entitled to use and it could lead to confusion for the pilot as to exactly what type of service is being provided, so this is possibly one of the reasons for the CAA to review the system.