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HoT matters

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Old 18th Feb 2019, 08:42
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HoT matters

Can an ATO continue if the HoT (voluntary part time) needs to leave the country due to working full time for another operator? To add, there are no full time instructors (all gone) and only one part time instructor, so potentially no one to delegate to.

After taking on the mantle, several abnormalities have been corrected, but I find myself in a precarious position trying to steer the correct path.

The only guidance I can find is the qualification required under Part Ora and the CAA Standards 55. Standards 55 states the the ATO must have sufficient FIs, which is obviously a serious issue.

Any help and guidance very welcome. I have a feeling I’m leaving myself wide open
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Old 18th Feb 2019, 14:13
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If an organisation is that small, does it need to be an ATO? If its not offering commercial training, maybe a DTO would be more relevant. Normally, the HoT may be transient as the day to day operation is under the supervision of the CFI. If you are doubling as the CFI then that would suggest in your absence, that there would be no supervision. As an ATO you will have an approved Operations Manual, what does that say?
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Old 18th Feb 2019, 14:59
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My preference would be to change from an ATO to DTO but the Directors have other ideas for the future, which has no way of happening.
The manual does state that training must be supervised, but without any instruction on certain days then that requirement is met because there is no training.
I am curious if there is a legal requirements though.
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Old 18th Feb 2019, 15:22
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ORA.GEN210 (c)
The organisation shall have sufficient qualified personnel for the planned tasks and activities to be performed in accordance with the applicable requirements.
If the part-time instructor is there when training is planned to take place, you comply.

ORA.ATO.110 (b)
The HT's responsibilities shall include:
  1. ensuring that the training provided is in compliance with Part-FCL and, in the case of flight test training, that the relevant requirements of Part-21and the training program has been established.
  2. ensuring the satisfactory integration of flight training in an aircraft or a flight simulation training device (FSTD) and theoretical knowledge instruction; and
  3. supervising the progress of individual students.
None of that requires the HT's attendance 24/7. provided you can show that you are achieving the above while overseas, you comply
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Old 18th Feb 2019, 18:43
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BillieBod
Thanks for your reply. On that basis we comply but it is questionable to say if we can provide adequate oversight of each student. To be fair to each student regardless if we comply, they need consistent and high quality training which I personally want to make sure they get.

As Whopity said, without providing commercial training, DTO would be the way to go.
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