Lack of PIC time for CPL-A

[palegreendot]

Hi everyone,
I am trying to convert my ICAO CPL to Canadian CPL. In our country it is allowed to log both PIC and Dual recieved when acting as a pilot-in-command and getting flight instructions from a CFI, provided that he doesn't touch flight controls.
As far as I got from Transport Canada, only one person on board may log PIC time, in my case, a CFI. So, I am missing ~50 PIC hours to achieve enough experience for CPL-A. Also,

421.30 Aeroplanes - Requirements

(ii) following the issuance of a private pilot licence — aeroplane by Canada or another contracting state, have completed 65 hours of commercial pilot flight training in aeroplanes consisting of a minimum of:
(B) 30 hours solo flight time including:

• (I) ...a cross-country flight to a point of a minimum of 300 nautical mile radius from the point of departure and shall include a minimum of 3 landings at points other than that of departure; and
• (II) 5 hours solo flight time by night during which a minimum of 10 takeoffs, circuits and landings were completed.

...these conditions are not met. Can I just get a Foreign License Validation Certificate, go to a Canadian flight school and fly that 50 hours PIC+some night circuits and a cross country flight landing at 3 different airports?
Would TC consider that flight experience as a part of commercial flight training?

Thanks.

[rudestuff]

Which country are you converting from?

[Fred Kap]

My question is does TC count copilot times on the bigger jets as a PIC time for the fulfillment of ATPL time requirement? I have around 5000 TT as a copilot on Boeing 767 and Airbus 330. Having only an ICAO CPL license. PIC time @ pilot training school was less than 100 hrs.

[palegreendot]

Originally Posted by rudestuff

Which country are you converting from?

From Russia..

[+TSRA]

Hi everyone,
I am trying to convert my ICAO CPL to Canadian CPL. In our country it is allowed to log both PIC and Dual recieved when acting as a pilot-in-command and getting flight instructions from a CFI, provided that he doesn't touch flight controls.
As far as I got from Transport Canada, only one person on board may log PIC time, in my case, a CFI. So, I am missing ~50 PIC hours to achieve enough experience for CPL-A. Also,

421.30 Aeroplanes - Requirements

(ii) following the issuance of a private pilot licence — aeroplane by Canada or another contracting state, have completed 65 hours of commercial pilot flight training in aeroplanes consisting of a minimum of:
(B) 30 hours solo flight time including:

• (I) ...a cross-country flight to a point of a minimum of 300 nautical mile radius from the point of departure and shall include a minimum of 3 landings at points other than that of departure; and
• (II) 5 hours solo flight time by night during which a minimum of 10 takeoffs, circuits and landings were completed.

...these conditions are not met. Can I just get a Foreign License Validation Certificate, go to a Canadian flight school and fly that 50 hours PIC+some night circuits and a cross country flight landing at 3 different airports?
Would TC consider that flight experience as a part of commercial flight training?

Thanks.

Yes. When you get to Canada, or if you are here, go into the local TC office. They can issue you an FLVC on your current license, but because you're short hours to hold the Canadian equivalent, you'll only get an FLVC to a PPL level. That will let you build your PIC time to the minimum required to hold the license. Once you have the time, you'll then have to do the Canadian CPL flight test. You won't just automatically get the Canadian CPL as your FLVC would only be for the PPL. I did something very similar back in 2007 or 2008 when I moved back to Canada with a CPL from New Zealand. It's no big deal. Do the hours, do the flight test, and off you go.

[+TSRA]

My question is does TC count copilot times on the bigger jets as a PIC time for the fulfillment of ATPL time requirement? I have around 5000 TT as a copilot on Boeing 767 and Airbus 330. Having only an ICAO CPL license. PIC time @ pilot training school was less than 100 hrs.

Nope. Captain logs the PIC time, FO logs FO time. The TC view is that only the person who is in command can log PIC time. The FO, while making decisions, is not ultimately in command.

With that said, what TC does permit is a PICUS program (Pilot-in-Command Under Supervision).

It requires that the company build the program into its operations and training manuals, you can't just decide to do it on your own with your buddies. Then, by regulation, you're only able to credit 50% of the time to a maximum of 100 credited hours (so 200 hours flown), and it must be flown within 12 months of your ATPL application. You generally need a letter from the company along with some sort of record that is countersigned by the Captains you fly with when you submit your license application. However, not every Captain agrees to PICUS flying, especially where the company doesn't pay them for it. I don't agree with that sentiment, but I do understand it. So, if you need the time, be ready to fork out the money. You might be better to see if a bunch of guys want to go in and buy an inexpensive Cessna 150 with you, or something like that. It might be cheaper overall than renting 50 hours at the local club.

[rudestuff]

Have a look at getting an FAA certificate. The FAA will accept PIC time that has been flown dual.

Then have a look at AC 401-001

[Fred Kap]

Thank you for the responses.

[AlphaVictorFoxtrot]

Originally Posted by rudestuff

Have a look at getting an FAA certificate. The FAA will accept PIC time that has been flown dual.

Then have a look at AC 401-001

Having had a look at it, it has this fun bit in it:

Originally Posted by AC 401-001, 1.2 Applicability

(3) Holders of a FAA airman certificate issued on the basis of another foreign pilot licence are not eligible for conversion under this agreement.

So, no, no sneaking around the regs, unless you apply for an FAA license based on your hours (instead of as a conversion), but I would imagine that would involve a mountain of paperwork, especially coming from a place the US isn't too crazy about.

Speaking of paperwork, OP, make sure you have all your training paperwork from back home translated and notarized in Canada when you are doing this process. Email Transport Canada licensing to make sure you have a record of the exact things you'll need. If you can't get originals, you might also have to have notarized copies of them from back home as well.

(The joys of moving from a non-English-writing country are all very exciting)

[rudestuff]

Originally Posted by AlphaVictorFoxtrot

Having had a look at it, it has this fun bit in it:


So, no, no sneaking around the regs, unless you apply for an FAA license based on your hours (instead of as a conversion), but I would imagine that would involve a mountain of paperwork, especially coming from a place the US isn't too crazy about.

Speaking of paperwork, OP, make sure you have all your training paperwork from back home translated and notarized in Canada when you are doing this process. Email Transport Canada licensing to make sure you have a record of the exact things you'll need. If you can't get originals, you might also have to have notarized copies of them from back home as well.

(The joys of moving from a non-English-writing country are all very exciting)

Don't get confused between an "on the basis of" or part 61.75 certificate, which does not require a test - and a full FAA certificate, which does.

If the OP was going to train as required and take a Canadian test but lacked the PIC time, they could instead train as required and take the FAA written and flight tests. This would not be considered OTBO, but rather a stand alone FAA certificate which can be converted to TC easily.

[AlphaVictorFoxtrot]

Originally Posted by rudestuff

Don't get confused between an "on the basis of" or part 61.75 certificate, which does not require a test - and a full FAA certificate, which does.

I think we're saying the same thing - see my "unless the OP is actually applying for the license" bit ("certificate" would have been more clear in FAA land, but I always forget just how "different" the US regs are). Bottom line is, yes, the FAA certificate might be a better way to get to the Canadian license than a direct conversion. (With the big caveat that the OP would need appropriate entry visas for dealing with the FAA process, since I don't think they have offices outside the US)

I should, at this point, note that I don't know the full process for the FAA licensing, and how involved it is. I believe there's at least a couple of in-person visits to licensing offices involved... but there's a whole other forum for the US on here, where there might be more info.

[+TSRA]

Fred Kap - your inbox is saying it can't accept new messages. Here is my response to your PM as it applies equally to the OP:

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The first link you provided is for the crediting of co-pilot time towards the issuance of the ATPL - in other words, how a co-pilot can count their experience towards the licensing requirements. Back before 2014, a co-pilot could only count 50% of their experience. For example, in order to count 500 hours of co-pilot time, you'd have to fly 1,000 hours. Since 2014, you are allowed to credit 100%, or 1:1.

This has nothing to do with crediting of co-pilot time as PIC time. It is simply how to credit your time flown as a co-pilot towards the minimum experience levels. So, where you see in the standard "...or 200 hours as co-pilot..." that's what they're talking about. How to credit your experience against that sort of requirement.

The second link you provided is the Pilot-in-Command Under Supervision provisions. This is what permits a co-pilot to log their experience as PIC, but it's not that simple.

The big, massive caveat is described in paragraph 1): All air operators using large aeroplanes may institute programs of supervision to allow co-pilots to credit flight time as pilot-in-command time.

The emphasis on may is mine and is intentional.

This provision of the regulations - standards actually - means a co-pilot can only count their experience as PIC where the airline they are working for has a training program built to allow for it to happen. In all the airlines I have worked for, a co-pilot could only enter the program after they had completed their first year of service, had to have not failed a ride, and then only where the Captain specifically agreed before the flight that the hours would be counted as PICUS.

Not all air operators have a PICUS program and not all Captains agree to fly the flight as a PICUS flight. If you're unlucky to fly for an operator who doesn't have a PICUS program or you're flying with a Captain who refuses to help you out, you have to log the time as co-pilot.

Now, if the airline has a PICUS program, and if the Captain agrees to operate the flight under PICUS, then you can only count 50% of the flight time as PICUS (and you have to notarize it as PICUS time somehow, you can't just log it as PIC, because it's not, its PICUS). You also cannot count any more than 100 hours of PICUS towards the ATPL (so 200 hours flown), and you must log the time within the 12 months before you apply for the ATPL. Finally, you must submit to TC a summary of the hours flown under PICUS, the number of takeoffs and landings, and TC typically likes to see this form countersigned by each Captain you flew with, although not all programs require that from the Captain.

It's been my experience that most co-pilots only use PICUS if they have a few hours to clean-up - for example, they're short on their night PIC. If you're looking to build serious PIC time, it may be quicker and easier to rent a C172 and do a bunch of night cross-country flights, especially if you're itching to get your ATPL so that you can sit left seat in a 704 or 705 operation.

I know this is not the answer you're likely looking for, but Transport Canada holds the firm view that only one person can ever be in command, and if that's not you, then the best you can hope for is that the company you work for sees the value in allowing their co-pilots to do the duties of a Captain, while under supervision, for a couple of hours.

I know both Jazz and Encore have PICUS programs, as do most of the major charter airlines. But it is certainly worth asking the question in an interview, as you don't want to accept a job to then find out that the company doesn't have the program. Then you're definitely looking to rent again.