MR rating before CPL ME?

[MovingUp]

Some people are arguing about the interpretation of this piece of Part FCL:

This is Part FCL Appendix 3 to Annex 1, update June 2020

E. CPL modular course – Aeroplanes

GENERAL

1. The aim of the CPL(A) modular course is to train PPL(A) holders to the level of proficiency necessary for the issue of a CPL(A).

2. Before commencing a CPL(A) modular course an applicant shall be the holder of a PPL(A) issued in accordance with Annex 1 to the Chicago Convention.

3. Before commencing the flight training the applicant shall:

(a) have completed 150 hours flight time; including 50 hours as PIC on aeroplanes of which 10 hours shall be cross-country.

Except for the requirement of 50 hours as PIC in aeroplanes, hours as PIC in other categories of aircraft may account for the 150 hours of aeroplane flight time in any of the following cases:

(1) 20 hours in helicopters, if applicants hold a PPL(H);

(2) 50 hours in helicopters, if applicants hold a CPL(H);

(3) 10 hours in TMGs or sailplanes;

(4) 20 hours in airships, if applicants hold a PPL(As);

(5) 50 hours in airships, if applicants hold a CPL(As).

(b) have complied with the prerequisites for the issue of a class or type rating for multi- engine aeroplanes in accordance with Subpart H, if a multi-engine aeroplane is to be used on the skill test.



Some read that you need to comply with the prerequisite for MEP rating issuance (training completed) before commencing the flight training for CPL modular, others read that you need to fulfil the MEP prerequisites if a MEP is to be used for skill test (MEP training during CPL).

ATO quotations varies, and some national authorities seem perplexed? is it just badly written?

Any lights please, somebody on top of the ladder needs convincing...

Thanks in advance

[Whopity]

3. Before commencing the flight training the applicant shall:
(b) have complied with the prerequisites for the issue of a class or type rating for multi-engine aeroplanes in accordance with Subpart H, if a multi-engine aeroplane is to be used on the skill test.

The prerequisites are:
(a) Single-pilot aeroplanes
Applicants for the issue of a first class or type rating on a single-pilot aeroplane seeking the privilege to operate the aeroplane in multi-pilot operations shall meet the requirements in points (b)(4) and (b)(5).
Additionally, for:
(1) Single-pilot multi-engine aeroplanes
Applicants for the issue of a first class or type rating on a single-pilot multi-engine aeroplane shall have completed at least 70 hours as PIC in aeroplanes.
Quite clear, you need 70 hours PIC before comencing the flight training

[BillieBob]

I don't see the regulation as badly written, although I'm not quite so clear about the question. Para (b) applies only if the skill test is to be taken in a ME aeroplane but such training must be completed before any flight training for the licence is commenced. It would, perhaps, appear more sensible to require MEP training to be completed only before the ME phase of the CPL flight training is commenced. However, when this was the case pre-EASA, some training organisations were fiddling the figures and it looks as though they're at it again.

[MovingUp]

Thank you for your answers.

The question, maybe poorly laid, came as different quotations have been provided to CPL/ME candidates holding a PPL/SE with enough hours to start a CPL and ME rating.
Why some ATO's would quote ME rating (6 hours) followed by CPL/ME ( including 5 hours complex on Multi), and others quote CPL/ME ( including 6 hours Multi)?

A variation on the reading of Para (b)?

Looking at your answers, gentlemen, it seems you have differing opinions!

The plot thickens...

[Whopity]

Looking at your answers, gentlemen, it seems you have differing opinions!
Not really, we have two different courses, a ME Class Rating and a CPL Course, they are not combined, or if they are then the hours must reflect the requirements of both courses.

[BillieBob]

There is no problem in an ATO quoting a separate fee for each course or a single fee to cover both courses. Bear in mind that only the 6 hrs training for the MEP is required to be completed before commencing the CPL(A) flight training (i.e. there is no requirement for the skill test to be passed or for issue of the rating). The important thing is that all of the MEP training must be completed before the CPL(A) course flight training is commenced. It is not permitted, for example, to complete the SE element of the CPL course, then the MEP training, then the ME element of the CPL course.

[MovingUp]

So an ATO should not quote a CPL/ME (6 hours on Multi) trying to get this 6 hours to tick the box for both the MEP rating training requirement and the 5 hours complex of CPL requirement?
As BillieBob point it out, you should have accumulated at least 11 hours on ME by the time you are ready for CPL skill test on ME, my understanding of Appendix 3 (E) (3) (b).
I'm trying to ascertain if a 6 hours scheme (ready for CPL skill test on ME, no class rating before) is Part FCL compliant or are we facing a scam/mistake in the quotation?

[rudestuff]

The whole point of doing the MEP rating before your CPL is to AVOID having to do the CPL course in a MEP..
A CPL is a licence, so just do it in an SEP if you've already got the MEP rating.

[Fl1ingfrog]

The CPL course is just that and no more. You are not required to train on a MEP or hold a MEP rating as part of it.

You are required to do the CPL test on a complex aircraft. The test can be done on a single engine type but it must have a wobbly prop and up and down wheels. Many of the CPL schools do not have a complex single. They are very likely to have a light twin aeroplane for teaching the IR. They will encourage you to do the required hours in their twin/s to satisfy the CPL test complex requirement and to better utilise their multi. If it is your intention to do the IR afterward this has an arguable economic benefit to you also because, obviously, you are not required to do the multi engine course twice. Note: your not required to do the multi for the IR either, you can do it all on a single if you wish. Airlines, if that is where you are going, will require a multi-engine rating which is why the MEP inclusion has become a norm.

If you do not need a multi rating then find a school that can provide a complex single for the necessary 5 hours experience on type, as part of the CPL course, for the subsequent test.

[BillieBob]

I'm trying to ascertain if a 6 hours scheme (ready for CPL skill test on ME, no class rating before) is Part FCL compliant or are we facing a scam/mistake in the quotation?I don't know how many other ways I can put this - Such an arrangement is not compliant with the Regulation. The MEP and the CPL are two entirely different courses and both must be completed in full and in the correct order if the CPL skill test is to be completed in a multi-engine aeroplane. Under JAR-FCL it was possible to combine the courses but EASA have made it abundantly clear to the competent authorities that this is no longer the case.

[Edgington]

The prerequisites are:
Quote:
(a) Single-pilot aeroplanes
Applicants for the issue of a first class or type rating on a single-pilot aeroplane seeking the privilege to operate the aeroplane in multi-pilot operations shall meet the requirements in points (b)(4) and (b)(5).
Additionally, for:
(1) Single-pilot multi-engine aeroplanes
Applicants for the issue of a first class or type rating on a single-pilot multi-engine aeroplane shall have completed at least 70 hours as PIC in aeroplanes.
Quite clear, you need 70 hours PIC before comencing the flight training

The regulation says applicants for the issue of the rating, so you can start training even do your skills test. Just not send in the application form to add the rating to your licence until you have the 70 hours PIC. No doubt it will depend on the member state, but the Dutch allow it.

[Whopity]

Generally at ATO will ensure the applicant has the 70 hours as you have a time of 6 months from commencing the rating to making the application. Additionally it is a requirement for test that the applicant meets all of the requirements for licence or rating issue.