CL65 Type Rating Completion
 

Hello,

I did training with my previous company for a CL-65 type rating but left just before the ride. Is there somewhere I can finish the ride? I still have my training record. Thanks.

Well, it is a very grey area you're in, so my gut says not really, no. I'm speaking as a former ACP.

An ACP can conduct a PPC for the sole purpose of issuing a type rating, but they have to be authorized by Transport Canada beyond the ACP approval process - I make that sound like a bigger deal than it is. It's not, it's a tickbox on the application form. The gotchya for you will be in the interpretation of the ACP Manual, ACP Authorities, Subsection 5(b)(i) where it describes you needing to complete a recognized program of ground and flight training on the aircraft type by a TRTO (Type Rating and Training Organization - think, Flight Safety or CAE). While you may have the training records, what you perhaps don't have are training files from a TRTO. An air operator is not a TRTO. What you also don't have will be a valid and up-to-date nomination to the ride. Both the TRTO training files and a nomination would be required before you could challenge the flight test. Furthermore, while you have training files from an air operator, it has been my experience that Transport Canada considers training files to be the property of the air operator or training organization, NOT the pilot.

Complicating matters further, because you never finished a PPC, your training files are of relatively no use to any other air operator as they'd have to start you from scratch. While it is possible to transfer training from one operator to another, you must have completed the ride as a prerequisite. Another complication would be if the air operator sent you to a TRTO for the training. This complicates matters because while you received training from a TRTO, it was on behalf of an air operator, so it is extremely grey as to who legally holds the rights to those records. Like I said, TC has consistently taken the line that training records are company property.

For all these reasons, and were I to have the CL65 on my accreditation letter, I'd not agree to conduct a ride on you as it could put my own license on the line. It sucks, and another ACP may have a different interpretation, so I do suggest you seek a second opinion. Now, I am 2 years removed from my last ride and when I handed back my ACP credentials, so it is possible there have been minor changes in that time. However, Transport Canada sent me ACP Manual, Tenth Edition, which is the same as I was using when doing flight checks, so I doubt there has been such a major change as the wording of that section in the ACP manual.

Thank you for the detailed answer. If I can get a letter from TC for an exemption, could an ACP do a recommend and a ride sim at CAE or Flight safety?

Isn’t there a requirement to take the ride within a specified amount of time after completion of the training course?

There is! The current ACP Manual requires that a flight check be completed within 30 days of the recommending flight training event.

If the flight check is delayed and will take place beyond the 30-day period, the chief pilot or their designate can sign and date a letter attesting that additional training was provided and the training was considered sufficient to ensure the candidates competency to complete the flight check. It's my experience that instead of going down this route, most companies will just have the pilot complete an additional training session where a new nomination is provided rather than having the chief pilot sign a letter.

Almost anything is possible with lets and exemptions from TC. But before you even get FlightSafety or CAE to agree to leasing you a sim and an ACP for a day (which, do you know how much that will cost), you have to consider the path a TC Inspector will take to determine an exemption is warranted.

First, they'll have to ensure that all training per the CARs was completed. To do this, they'll likely contact the company you worked for and ask for their training Cross Reference List, which demonstrates where a particular training regulation or standard is covered in the training program. At the same time, they'll ask to ensure that any other company training as outlined in the COM and not described on the training forms was provided. All it takes at this point is for you to not have completed a single item of training, no matter how small. If you still had something outstanding that is trivial to flying an airplane, but nevertheless required by the company (think WHMIS), that would cause the company to say that your training was incomplete, and TC will not provide an exemption.

If, however, all is clean and complete, the inspector will come to the second step. They have to ascertain whether or not the marks you were provided and the comments written validate a ride nomination. This is a pretty steep gradient to overcome, sight unseen, especially if it's outside that 30 days I described above in answer to B2N2. Anyone who provides a nomination to a ride is validating that, in their professional estimation, you will pass that ride. There is a lot more in providing a nomination than just the grades on a page, but that could be handled through an interview.

Now comes the third and final step, and what I consider to be the largest stumbling block. The inspector will have to determine whether there is a public safety reason to provide you an exemption. In the case of pilot licensing, they have to consider the effect not granting an exemption will have. The only reason they grant exemptions is because public safety will be maintained or improved. For example, the reason they granted the COVID exemptions to pilot licensing was that without an exemption, the industry would have come to a grinding halt inside eight months, seriously harming the health, safety, and economy of the country. In the case of a type rating to an individual pilot they'll have to answer whether that fact that you don't have a CL65 type rating means that a medivac operation comes to a grinding halt, or the economy is disrupted because VIPs don't get to a meeting. You will have to provide a very strong argument that in providing an exemption to you, public safety is somehow improved. The fact that you simple want the type rating is insufficient and immaterial. Anyone with the valid credentials, training, and a pulse can obtain a CL65 type rating. So why should you be exempted from the normal process? I know that sounds harsh, but it's a huge question that you have to answer, ego aside.

I am reminded of a quote from, all places, Star Trek VI, where Spock says "What you want is irrelevant, what you've chosen is at hand." For whatever your reasons, you chose to leave a company before the PPC was complete. In almost every case I've been involved in as an instructor, check pilot, or standards pilot, that means you have chosen to turn your back on the training and qualifications you would otherwise have received were you to have stayed. That doesn't mean you can't ever have a CL65 type rating on your license, just that you chose not to have it at this time.

Now, if you can make a persuasive argument that the forms are legally yours or that the company willingly provided them to you, that you completed all the required company training (in addition to training not described on the forms), and that public safety is enhanced by you having the type rating, then maybe TC could find their way to providing you an exemption. I would actually be very interested to see what argument you develop, and I don't mean that facetiously. I mean it. I'd be interested to see what works, because every once in a while TC does surprise me.