ATPL TK exams expiry - extensions?

[CrazyScientist]

Hello

I completed my ATPL exams in August 2015, and so have until this coming August (2018) to have my CPL/IR completed before the exam passes expire.

I was doing pretty well with my training in that I managed to complete about half my hour building and was about to start my IR in March of this year. Unfortunately, when it came to getting my Class 1 medical, I was grounded (unfit for Class 1 and 2) and have been since. I am currently going through very lengthy appeals processes.

My concern now is that even if I manage to successfully regain medical certification, I won't have much time left to finish my hour building and complete my IR then CPL before my exams expire.

Given the delay in completing my training (possibly putting me over the August deadline) will have been down to the extreme delays in getting my case assessed by the CAA (9 months to go through the initial assessment then the secondary review/appeal), I've been looking into the possibility of the licensing department at the CAA granting an extension to the normal 36 month deadline for completing the CPL/IR.

Does anyone have any experience with this? I've looked online, and it seems that the CAA used to grant extensions for various issues, including for more minor ones such as skill tests delayed due to weather or maintenance problems. I'd have thought that a 9 month (and counting) delay due to the inefficiency of the CAA would hold more weight.

However, the only cases I can find are pre-EASA. I'm just concerned that now it's a body higher than the CAA that makes the rules. Presumably it will be correspondingly more difficult for the CAA to grant exceptions to those rules?

I have been in touch with the FCL department over the phone, and the immediate reaction didn't suggest it would be impossible. I do need to write to the technical team though as it would be a matter of policy, and unfortunately I have to wait for the CAA to re-open next week. Would be great to get any feedback from those with experience in the meantime though!

Thanks

[rudestuff]

I doubt the CAA will grant an extension, but good luck. If you can get it sorted in the next few months you have plenty of time. Have you considered other options? If you are confident that you will get a class one back, depending on your circumstances you might be able to get an alternative medical, FAA class 3 for example, and tick off your hour building in the states. The CPL and IR need only take 25 hours in the UK.

[CrazyScientist]

Many thanks for your reply. Going abroad would be a desperate last resort and may not be feasible due expenses and wanting to do as many hours in the UK as possible (getting used to the environment I will be doing my CPL/IR in).

Even if the CAA stick to the suggested timescales in their appeals guidance document, it could take until April to get certified again. I'd then have four months to complete 54 hours PIC, the IR, and CPL. Not really doable in the UK's weather!

[paco]

I can tell you now - from EASA - no extensions, unless for operational reasons. That's what they tell us at all the meetings....

[rudestuff]

Sound like you’ve given up? 4 months should be easily achievable in summer. Simulators work in all weather, which leaves 15 hours IR and 15 hours CPL training. You might be reading too much into things, training in the UK is all very noble, but a plane is a plane, the laws of physics remain the same, so it’s only the charts that look a bit different and your radio work should be fine. Everything you need will be taught on the courses so hour building abroad is fine. A CPL test is just a bit of navigation, some instruments, some handling and some landings, all of which you’ve done for PPL. Course-wise, you need to average 15 minutes flight time per day. Only half needs to be VMC. So any weather excuse is nonsense.

Another thing to consider is doing an SEIR - shorter, cheaper and no need to do the MEP first. If time is short and you need to ‘save’ the atpls, it’s the best option. You can upgrade to MEIR after your exams expire.

[CrazyScientist]

Thanks for the continued input guys.

Paco, what would constitute operational reasons?

Rudestuff, I definitely haven't given up yet, just trying to narrow down viable options. I definitely will be doing the SEIR instead of MEIR with no intention to do the MEP course for now due to the reasons you mentioned and this has been my plan for a while. What you mention about hour building abroad is reassuring, I will definitely look into it but feel it could be close either way as I still need to get a medical sorted. But then maybe not every ICAO aviation authority is as inefficient as the UK CAA.

Council Van, the issues that have grounded me arose well after starting my ATPLs. So I would have passed the Class 1 had I applied before I started the ground school and then been grounded all the same later on.

[paco]

Operational reasons = an aircraft on the ground was the example we were given

[CrazyScientist]

Thanks Council Van.

Paco, thanks for the feedback. I'll temper my expectations but try my best to apply for an extension nonetheless. My main point is that, assuming my appeal is successful, the lengthy period I have been grounded will have been down to procedural irregularities in the assessment of my case (i.e. CAA's fault) as opposed to genuine medical circumstances (i.e. nobody's fault).

[paco]

Keep us posted.....

[CrazyScientist]

Will do. I have sent in a written request by email and received the automated response regarding high volumes of email etc etc.

They state up to 30 working days for a response from the technical team. The last time I wrote to this address was two years ago with a very simple question regarding the expiry date of my ATPL exam passes, and it took them about 65 days to respond.

[CrazyScientist]

Credit where credit is due. Got a reply after three hours.

It's not great news though, they've said they won't consider an exemption until June (2 months prior to my exams expiring) and to get back in touch then using the appropriate form. The form mentions operational reasons only as you discussed Paco, so I've sent another email asking if they'd possibly consider the delays due to the CAA Medical Department slowness to be 'operational' reasons. Will post back as soon as I hear more.

[parkfell]

Is there any history of anyone challenging the CAA through JUDICAL REVIEW?

[CrazyScientist]

As far as I'm aware, the hearing that is a part of the final appeal process when rejected for a medical certificate is something an applicant can attend in person only since the CAA were legally challenged by a user on these forums.

Link:

https://www.pprune.org/medical-health/540393-caa-medical-appeals.html

[Duchess_Driver]

Depends upon your outlook, but remember there is no requirement to actually have a valid medical whilst undergoing training. This therefore, means you can complete the training elements and then once the medical issue is resolved finish the hour building and skills tests.

Obviously, if at the end you don’t get the medical decision then that’s money down the drain.

Unlikely, I know, but different Countries have different standards and the, for argument sake, eyesight requirements under one authority may be less - depends upon the medical condition.

Years ago I went to the CAA and failed initial issue hearing. The doc gave me the work around which was to get a foreign CPL and then they’d assess me to renewal standards (which I met) even though it was an initial issue of a JAA certificate. Not sure that loophole is still open.

[RTN11]

Depends upon your outlook, but remember there is no requirement to actually have a valid medical whilst undergoing training. This therefore, means you can complete the training elements and then once the medical issue is resolved finish the hour building and skills tests.

Depending on his total hours at the moment, this probably wont help him, under EASA Part-FCL Appendix 3, requirements for the CPL are:

3. Before commencing the flight training the applicant shall:
(a) have completed 150 hours flight time;

So if he doesn't have 150 hours, he would need to fly dual to build time to start the CPL course, even doing the IR first this could still be a stretch. Then

12. The applicant for a CPL(A) shall have completed at least 200 hours flight time, including at least:

(a) 100 hours as PIC, of which 20 hours of cross-country flight as PIC, which shall include a VFR crosscountry
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;

So he would still then need to build up to at least 100 hours PIC in order to apply for the CPL, albeit this could be done post-test, but the application needs to be with the CAA before the 36 months on the exams expires, or they will reject the application and he will have to redo the exams and the CPL course.

Unless he could get some sort of approval to fly as PIC to build the hours with a safety pilot for medical reasons, then his only hope is an extension on the 36 month limit for the theoretical exams.

[rudestuff]

It's changed a bit - you now have to have completed all hour building BEFORE the skills test.

On the bright side, there are plenty of ways to command a plane without an EASA medical.

"Applicants for and holders of a CPL shall hold a class one medical."

You can do everything - (hour building, IR training IR test, CPL training) - except the CPL test itself. As long as you get a class one medical on the morning of the test, you should be good to go.

[RTN11]

Ah, ok I missed that change, I see it now on Appendix 3


SKILL TEST

13. Upon completion of the flying training and relevant experience requirements the applicant shall
take the CPL(A) skill test on either a single-engine or a multi-engine aeroplane.

Although worth noting that you could use some gliding hours if you have any:

(e) Hours as PIC of other categories of aircraft may count towards the 200 hours flight time, in the
following cases:
(i) 30 hours in helicopter, if the applicant holds a PPL(H); or
(ii) 100 hours in helicopters, if the applicant holds a CPL(H); or
(iii) 30 hours in TMGs or sailplanes; or
(iv) 30 hours in airships, if the applicant holds a PPL(As); or
(v) 60 hours in airships, if the applicant holds a CPL(As).

[CrazyScientist]

Thanks for the input guys.

I have considered doing courses "at risk" in order to get them out of the way and on the assumption I can get my medical certification back in time for when I submit the relevant license/rating application (I think you don't even need the medical for the actual test, only to be issued with the qualification). Unfortunately not only is the CPL out of reach due to the hour requirements pre-test, but so is the IR. I think I'm short by about 10 hours of PIC cross-country time (50 required before course)!

[rudestuff]

That last bit doesn't make any sense.

[CrazyScientist]

Sorry, I meant that the IR course requires 50 hours of PIC XC time to begin and I only have about 40.

[rudestuff]

So just go and get an FAA medical then fly as much as you like in the states on a 61.75 conversion.

You can get a sport pilot certificate in a few hours - you can fly up to 1320lbs with no medical - (just a US driver's licence can be got in a few hours) so a Piper cub would be ok.

Or can get a recreational certificate - and fly the usual 4 seaters (only one passenger day VFR) - with no medical.

Flights and accommodation will cost about £500.

[2close]

I have been through a Reg.6 appeal with the CAA on medical grounds and the 'impartial' board was made up of 2 x CAA executive directors. I am not questioning their professional judgement in any way but it is quite laughable that any professional body would even consider having their own executive directors form any impartial board. However honestly impartial the executive directors are it cannot help but stink of conspiracy.

Quis custodiet ipsos custodes?

As for judicial review, a lengthy and very expensive conference was held with legal counsel in London and we were informed of the huge costs involved in bringing an action for judicial review. Counsel was very confident of the merits of the case and even pointed out an alternative approach, aimed at discrimination. Following consultation with the CAA the considered verdict was they've got more money and time than us, they'll bury us in paperwork and bankrupt us in the process and by the time we get a judgement, EASA will be in charge and we'll have to start again in the European Courts. Project got canned!

[2close]

Can't you self certify to fly light sports aircraft in the UK, the hours of which count towards hour building?

The more realistic option is to stop any thoughts of potentially pouring good money after bad, until you have your Class One medical in your hand.

Resign yourself to the fact that you are probably going to have to retake your ATPLs. You will probably take a lot of pressure off yourself. Start studying now. You've done it before. You've probably still got your notes so you should only have to pay for brush-ups and exams.

Do your hour building at a leisurely pace and find yourself a good instructor to 'mentor' you to CPL standards. Burning holes in the sky is only good for that!

[CrazyScientist]

Thanks again for the continued advice guys.

I am considering all my options at the moment, including US based (although the most accessible spots seem to require FAA PPLs and Class 2 certificates).

The option that looks most promising for the time being is to self-certify as you suggested 2close. That would allow me to hold an NPPL, which allows me to hour build in a PA28 until 8th April 2018. That might just save my skin if my appeal is successful as I can continue to progress slightly while I wait for the CAA's decision. I'm just trying to find out if my current medical problems preclude me from taking this route. As far as I can tell, it shouldn't be an issue.

I actually started another thread in the medical forum looking for feedback. Similar to your experiences 2close, I've not heard anything positive about the way the CAA operate either in that thread or from others I've spoken to. It is very disheartening, but I will try my very best to get this sorted prior to my exams expiring. I do agree however that at this stage paying for and beginning either a CPL or IR course (subject to somehow meeting the hour requirements) is probably best put off.

Nothing further from the CAA yet in terms of getting an extension. Will update this thread as soon as I hear anything else.

[KayPam]

Why did you do your ground school before your hour building in the first place ?

I planned my training so that both ended at approx. the same time.

[CrazyScientist]

I had to balance the ground school with my academic studies, so the period I sat the exams in was the only time I could really do them unfortunately!