ATPL upgrade from MPL

[com304]

Is there any ATPL holder who was previously MPL (and hopefully PPL) holder?
I need to shed some light on multi-pilot restrictions once you get the ATPL. As per PART-FCL:

FCL.505.A ATPL(A) – Restriction of privileges for pilots previously holding an MPL Regulation (EU) No 1178/2011
When the holder of an ATPL(A) has previously held only an MPL, the privileges of the licence shall be restricted to multi-pilot operations, unless the holder has complied with FCL.405.A(b)(2) and (c) for single-pilot operations.

There is this word, "only" which makes it complicated to me. I held PPL before I became MPL, shall my ATPL be multi-pilot restricted or not? The point is, we are only two ATPL ex MPL pilots in my country. We both had PPL before even commencing MPL training. My buddy has his licence restricted, I don't....?

[awair]

What does your current license say: do you have SEP (Land) endorsed?

If so, you have Single-Pilot privileges.

Did you previously, as a PPL, have MEP (Land) endorsed?

If so, it should state MEP (Land) SP. While it may vary by Authority, I believe that MEP is now endorsed either SP or MP-only?

Send me a PM, for a “I'll show you mine, if you show me yours...”

[Arrow Flyer]

You haven't "only" held an MPL, you had a PPL first, so you shouldn't have lost single pilot privileges upon MPL issue.

Where and what exactly is the restriction on your buddy's licence?

[rudestuff]

That's a very interesting question, right up my street.

I presume the intent is to stop people doing single pilot ops when they do not meet the experience and test requirements of the CPL.

According to the CAA, if you hold an ATPL you can exercise all the privileges of the holder of a LAPL, PPL and CPL. By doing an MPL you end up with an ATPL without meeting the PPL or CPL experience or test requirements. Confusingly my license reads ATPL, CPL, PPL which kind of implies that each licence has its own privileges rather than each licence contains the privileges of the lower licences, so I'm assuming in your case your licence might read ATPL, MPL, PPL?

The whole thing is poorly worded because aren't all ATPLs restricted to multi pilot operations by definition?
Basically what they're saying is if you've got an MPL but nothing else you're multi pilot only: If you want a PPL or CPL you have to get one.

The $64,000 dollar question is: Does an ATPL have CPL and PPL privileges (a) inherently or (b) by virtue of the fact that CPL and PPL are printed on the licence?
Because if it's (a) then FCL.505 basically says that just having a PPL gives your ATPL single pilot privileges...

[BillieBob]

If you have never held a licence other than an MPL, you will never have demonstrated your ability to fly a single-pilot aeroplane and, consequently, you ATPL(A) will be restricted to multi-pilot operations only. In order to remove the restriction, you will need to have complied with the experience and training requirements detailed in FCL.325.A and to have passed the CPL skill test and the IR skill test in a single-pilot aeroplane. However, if you have previously held any licence other than a MPL (i.e. LAPL, PPL or CPL) then the ATPL should be issued without the restriction. What is not clear is why you should have to pass the CPL skill test to remove the restriction when a previously held LAPL is sufficient to prevent the licence being restricted in the first place.

It is not true to say that all ATPLs are restricted to multi-pilot operations - it's the other way around. You cannot act as PIC of a multi-pilot aeroplane unless you hold an ATPL but the privileges of an ATPL (except if restricted as above) include the privileges of a CPL, PPL and LAPL.

[African_TrouserSnake]

This is not true, check part fcl, you need to fulfill the 70hr PiC+cpl skilltest etc.

and realistically speaking, MPL trainees have 10ish solo hours in a single pilot airplane and 60dual, so ability to fly a single pilot aeroplane is demonstrated in that sense.

Realistically speaking, how would a hobby license such as ppl or lapl combined with an MPL demonstrate legal proficiency for SPO at a commercial level..... ppl isn’t professional flying...

[com304]

Thank you guys for your inputs.

awair, I'l make sure to PM you. I only had SEP land.

Arrow Flyer: His licence says "Multi-pilot operations only" just under ICAO English level and then again next to A320/IR/LVO/PBN in section XII. We both have same backgrounds and training, I was just lucky enough to meet ATPL requirements couplne months earlier.

I understand now that most probably my ATPL licence without this multi pilot restriction is correct. Let me rewrite my original question then. Can I do aerial works in a Cessna and be paid for that just like if I had CPL?

[African_TrouserSnake]

You’ve already posted your answer in the topic starting post, but since I am in a good mood I will chew you food for you...

from part-FCL:

When the holder of an ATPL(A) has previously held only an MPL, the privileges of the licence shall be restricted to multi-pilot operations, unless the holder has complied with FCL.405.A(b)(2) and (c) for single-pilot operations.

FCL.405.A
(b) The holder of an MPL may obtain the extra privileges of:
(1) the holder of a PPL(A), provided that the requirements for the PPL(A) specified in Subpart C are met;
(2) a CPL(A), provided that the requirements specified in FCL.325.A are met.
(c) The holder of an MPL shall have the privileges of his/her IR(A) limited to aeroplanes required to be operated with a co-pilot. The privileges of the IR(A) may be extended to single-pilot operations in aeroplanes, provided that the licence holder has completed the training necessary to act as PIC in single-pilot operations exercised solely by reference to instruments and passed the skill test of the IR(A) as a single-pilot.
Regulation (EU) 2018/1974.


FCL.325.A
Before exercising the privileges of a CPL(A), the holder of an MPL shall have completed in aeroplanes:
(a) 70 hours of flight time:
(1) as PIC; or
(2) made up of at least 10 hours as PIC and the additional flight time as PIC under supervision (PICUS).
Of these 70 hours, 20 shall be of VFR cross-country flight time as PIC, or cross-country flight time made up of at least 10 hours as PIC and 10 hours as PICUS. This shall include a VFR cross- country flight of at least 540 km (300 NM) in the course of which full-stop landings at two different aerodromes shall be flown as PIC;
(b) the elements of the CPL(A) modular course as specified in paragraphs 10(a) and 11 of Appendix 3, E to this Part; and
(c) the CPL(A) skill test, in accordance with FCL.320.


So: no, having a hobbyist PPL before obtaining a MPL doesn’t magically grant you the rights to commercial SPO as some kind of loophole in the system which circumnavigates the requirements of FCL.405.A(b)(2) and (c)....which ofcourse a monkey could’ve told you....

[rudestuff]

From part-FCL:

When the holder of an ATPL(A) has previously held only an MPL, the privileges of the licence shall be restricted to multi-pilot operations, unless the holder has complied with FCL.405.A(b)(2) and (c) for single-pilot operations.
The problem is that this quote (FCL.505) is at odds with FCL.405 to which it refers. Quite clearly the intent was more like - "When the holder of an ATPL(A) has not previously held a CPL..." ....except that they didn't write that..

When reading regulations they tend to be clustered, so if I'm looking for info regarding the MPL I would go to FCL.400. Key point to remember: 405 technically refers to an MPL wanting PPL or CPL privileges.

If I used to be an MPL pilot who's just been given my ATPL and I decide i want to remove this "multi pilot" condition - where would I go to look? FCL.500: because I've got an ATPL, which means that FCL.505.A would take precedence.

The problem is that FCL.505.A clearly offers the option NOT to be bound by FCL.405, purely by being poorly written.

[rudestuff]

So: no, having a hobbyist PPL before obtaining a MPL doesn’t magically grant you the rights to commercial SPO as some kind of loophole in the system which circumnavigates the requirements of FCL.405.A(b)(2) and (c)....which of course a monkey could’ve told you....
Well done, you made a good attempt at understanding the issue, but keep chewing!

[African_TrouserSnake]

Well done, you made a good attempt at understanding the issue, but keep chewing!


mate... I’ll do some more chewing due to your lack of deductive reasoning.

I can imagine you at your CAA’s office: “Yeah listen here, I previously held a balloon pilot license when I was 16, so according to part FCL505 I am eligible to fly commercial SPO, please remove my restriction m’am” good luck with that 😂


This thread is getting to an embarrassing loophole-in-the-system level... you might as well hold a drivers license or berry picking license, as FCL505 doesn’t specify what they refer to by ‘Only MPL’.

[rudestuff]

Exactly! It's badly worded, but it's there nonetheless. Which is why the original poster asked the question.