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A Part 61 conundrum for Australian ATPL applicants

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A Part 61 conundrum for Australian ATPL applicants

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Old 3rd Jan 2016, 22:02
  #121 (permalink)  
 
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Just a minor point of order, Mach is only calling him "Dude" as that is his username - "fpvdude".So noted
Also, I am often PIC from the right seat - the quote and reference you provide (and ask us in a holy manner to "behold") does not support a suggestion that it "must" be done from the left seat, but, as you allude, CASA may have a different (incorrect IMO) view.
'Behold' because it seems contradictory to what CASA told Mach, at least in appearance to me. My point is that CASA have been heavily inconsistent on this matter.

I've also spent many hours in the right seat acting as PIC, but I suspect the test role referenced in the MOS to be a little bit different. A simple example is calling for checklists. Is CASA going to sit there and accept my demonstration of command decision making and leadership as I sit there awaiting the captain to instruct me to begin checklist X, normal or worse still, non normal? Thats perfectly fine if I'm in the right seat training someone, but I think its a stretch that CASA would agree with that type of scenario for a test designed to test my capabilities as a new Captain.

The list goes on. If CASA are happy for me to do the thing from the right seat, thats great for me. Makes it miles easier. But it also annoys me even further, because now what are they even testing? Can I operate as a copilot in an aicraft that I've been flying in for years for the low low cost of 5 figures? If you say 'You're being tested on multi crew team management' then really you're testing me on my ability as a C&T captain. When else do you sit in the right seat as PIC? Something not really within the scope of the test I thought. Kinda skips a few steps in the career chain.

Or maybe I'm entirely wrong. I just know the thing irks me.
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Old 4th Jan 2016, 04:15
  #122 (permalink)  
 
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Did anyone call CASA today ?
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Old 4th Jan 2016, 06:19
  #123 (permalink)  
 
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Folks,
Just a "small" point, but operating from the LHS as PIC is "the convention", but whether it is a requirement of a regulation is another matter entirely.

Indeed, some time ago, a thread was devoted to this subject, and nobody, as I recall, came up with a regulatory requirement for the PIC to be in the LHS in a side by side configuration.

As an airline IRE/TRE or equivalent, the PIC being in the RHS is the norm.

As to the subject in general, in the G.O.Ds, my SCPL flight test doubled as a Class B Instructor annual, or vice versa, take your pick. All conducted in a single engine aeroplane, in compliance with the Air Navigation Act, the ANRs and the ANOs, Chief Examiner of NSW Region version thereof.

Was very teed off when I lost my three digit license number for the ARN.

Tootle pip!!
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Old 4th Jan 2016, 08:14
  #124 (permalink)  
 
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You're probably not wrong leadsled. But as it relates to this test specifically, I think its going to cause issues for the reasons I listed.

The person sitting in the left seat has a certain role on my type, including calling for checklists and generally running the show. Those are our SOPs. They cannot be 'reversed'. CASA may say for the purposes of the the test I sit in the right but am "PIC".

Ok, but it seems a strange way for me to do the core element of the test, ie demonstrate the ability to run the show, show leadership etc whilst I conduct our SOPs which require me to be instructed on what checklist, normal or non normal I run. The only situation where I'm in the right really operating as PIC is when I was training people. But how does that correlate with the idea of the ATPL flight test, ie to test a candidates ability as a new captain?

Again, I'm all for doing it in the right, makes my life easier, but the whole thing looks a mess to me.
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Old 4th Jan 2016, 17:36
  #125 (permalink)  
 
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Soldat is your SOP and training so prescriptive -indeed so anal - that if the Captain fails to call for a checklist, or attempts to initiate the wrong procedure, or fails to respond correctly to an abnormal situation, the First Officer will sit there like a stunned mullet and do nothing?
What do you do if the captain slumps over the controls below 80 knots on takeoff? Not reject because that is not 'normally' what you do? What would you do if it happens above 80 knots but before V1 and you had two miles of runway in hand? What would you do if the takeoff was accelerate stop limited? Does your organisation not discuss and occasionally introduce these scenarios in recurrent training?
Or are all your Captains so perfect, so healthy that such mistakes, omissions and events are inconceivable?
I think that you worry too much about how this ATPL test will be conducted should you only have exposure to your type in the RHS. The few guys who are running these ATPL tests are experienced, practical and reasonable, though of course I can't speak for the culture within your Company C&T organisation. How would we brief your LHS pilot on the day? Simply to be more passive than usual but to provide normal callouts - a suitable support pilot can role play without stuffing the candidate up or totally bastardising the SOP.

Assuming that the appropriate training would be available, ie changing from RHS to LHS and given adequate line training etc, I ask myself - is this person 's skill, management and decision making up to the standard where an operator COULD upgrade him/ her to command? If so, good; if not, go away, get some more experience and training and come back when you have it.

Having just got to 1500 hours and having passed some theory is not an entitlement to an ATPL, though having said that, a guy I had the pleasure of training recently would pass the test in a heartbeat. Even with no airline background he would put some 10,000 hour pilots to shame, but at this stage of his young life he does not yet have the hours for ATPL.

For those who object to my use of 'entitlement' again (and I do apologise to those of gen Y who do not suffer from the entitlement syndrome) please review the privileges of an ATPL.
A pilot with one of these could legally hold direct entry command on an A380 flying anywhere in the world, in the worst possible weather. Not very likely, but that is what the licence permits.
Certainly there are those who have gone off to the likes of Lion Air and parlayed F/O time and an ATPL to very quick jet commands.

Last edited by Mach E Avelli; 4th Jan 2016 at 20:37.
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Old 4th Jan 2016, 23:03
  #126 (permalink)  
 
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Soldat is your SOP and training so prescriptive -indeed so anal - that if the Captain fails to call for a checklist, or attempts to initiate the wrong procedure, or fails to respond correctly to an abnormal situation, the First Officer will sit there like a stunned mullet and do nothing?
What do you do if the captain slumps over the controls below 80 knots on takeoff? Not reject because that is not 'normally' what you do? What would you do if it happens above 80 knots but before V1 and you had two miles of runway in hand? What would you do if the takeoff was accelerate stop limited? Does your organisation not discuss and occasionally introduce these scenarios in recurrent training?
Or are all your Captains so perfect, so healthy that such mistakes, omissions and events are inconceivable?
Of course not. But so what?

The Captain fails to call for a checklist, I call for it.
Attempts the wrong procedure, I identify the correct one.
Fails to respond correctly to an abnormal situation, I put forward the correct one.
If the Captain becomes incapacitated I use our incap SOPs, whatever the situation.

How are any of these situations relevant to whats being discussed? If I failed to do any of the above, I'm not suitable to operate as a First Officer. It has nothing to do with being in command. Unless you're suggesting the ability to meet the required competencies for FO automatically qualifies me to be the captain too? If so I state again, what's the point of this test.

Anyway I've made my point, no reason to go on endlessly. If I'm wrong then so be it. If CASA can assess my ability as a captain by watching me not be the captain, power to them. Makes my life easier.

Last edited by das Uber Soldat; 5th Jan 2016 at 00:01.
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Old 4th Jan 2016, 23:31
  #127 (permalink)  
 
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RHS ATPL flight test

Not sure about the legal technicalities in Aus, but to give yet another example from the more enlightened side of the ditch (which I'd bet will apply), it's acceptable to do a NZCAA ATPL flight test from the right hand seat of a qualifying sim/aircraft and this is routinely done by NZ airlines when issuing ATPLs to line FOs in advance of a command upgrade. A pilot can command an aircraft regardless of their seating position (they could even be in the jump seat), so I don't see why there is a debate?

As for the requirement to do a flight test - about bloody time - previous system was inappropriate. I'm sure NZCAA will be pleased the floodgates have been shut on TTMRA flight test dodgers.
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Old 5th Jan 2016, 02:29
  #128 (permalink)  
 
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A pilot with one of these could legally hold direct entry command on an A380 flying anywhere in the world, in the worst possible weather. Not very likely, but that is what the licence permits.

However he would also have to pass the type rating test and also have been given a command by someone with an AOC. How many checks does one need to do before they are deemed competent?

You could also argue that someone could pass an ATPL on a Metro then hold a command on a A380 and fly anywhere in the world.

What relevance would a ATPL test on a Metro have to commanding a A380?

The reality is that passing an ATPL flight test really has no bearing on anything as you are going to also have to pass a type rating and a command check by a AOC holder.

So in the end other that make it harder to be pilot and generate more money for CASA what does it all prove?
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Old 5th Jan 2016, 02:54
  #129 (permalink)  
 
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Well, let's reverse that argument. Teach people to fly, but have no test for PPL or CPL. After all the people who hire out aeroplanes to them, or employ them, are going to ensure that they are competent, right?
Let's adopt the same strategy for heavy truck drivers or bus drivers. If they can drive a car, they will be OK with a B double or taking your kids to school because the owners will ensure that it is so.
It is a fact of life - if you do not set a standard then test people to that standard the system will be abused.
So, for once it IS all about safety. I am no great lover of Big Brother, but CASA don't exactly make a profit out of this, so let's not wrongly accuse them of that motive.
It is just a shame that CASA did not save a lot of money by engaging NZ CAA as consultants on the whole Part 61 introduction.
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Old 5th Jan 2016, 03:52
  #130 (permalink)  
 
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So where is your data to show the level of risk that is mitigated by the formal final tests in the other examples you gave? How do you know it's not just self-perpetuating intuition?

Setting a standard and requiring it to be met does not inexorably entail a formal final test.

We all know people who've passed formal final tests but are nonetheless incompetent to fly/drive/sail/ride.

Let's reverse your argument. I reckon ATPL holders should be subject to another flight test before each and every flight in which the ATPL holder proposes to exercise the privileges of that licence. What is the safety objection to that requirement?

If you say the risk mitigated by that requirement is so vanishingly small as to not justify its cost and inconvenience, where is your data to prove that?

I note there are lots of people exercising the privileges of an ATPL who have never been the subject of a formal ATPL flight test. Why are they not considered 'unsafe'? Or is it that they are merely tolerated as being 'acceptably unsafe'? How 'unsafe' are they, compared with the pilots who have passed the formal ATPL test?
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Old 5th Jan 2016, 03:56
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Well, let's reverse that argument. Teach people to fly, but have no test for PPL or CPL. After all the people who hire out aeroplanes to them, or employ them, are going to ensure that they are competent, right?
Except no equivalent test exists for the PPL or CPL does it? The ATPL flight test however, does have an equivalent. The IPC. If you argue thats only the company ensuring competence and not the regulator, then you're arguing that a company should never be the arbiter of your competence and we should remove their ability to conduct the IPC/Renewals immediately.

Can your company ensure competence or not? Can't have it both ways.


Let's adopt the same strategy for heavy truck drivers or bus drivers. If they can drive a car, they will be OK with a B double or taking your kids to school because the owners will ensure that it is so.
Is the car or bus test more or less identical to the B double test? No. It tests entirely different things. IPC and the ATPL test are nearly identical.

It is a fact of life - if you do not set a standard then test people to that standard the system will be abused.
I agree. Which is why we do the ATP/sorry, IPC already. And the regulator has deemed 217 departments qualified to assess competency on their behalf. Now you argue they shouldn't?

So, for once it IS all about safety. I am no great lover of Big Brother, but CASA don't exactly make a profit out of this, so let's not wrongly accuse them of that motive.
It is just a shame that CASA did not save a lot of money by engaging NZ CAA as consultants on the whole Part 61 introduction.
They may have had good intentions, but there is a reason they've been forced into appointing a 20 something man task force to address the disaster than has been the part 61 implementation. There is a reason companies are increasing their minimum requirements, not decreasing them as was expected. I agree that consultation could have provided a vast improvement.
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Old 5th Jan 2016, 04:20
  #132 (permalink)  
 
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Let's adopt the same strategy for heavy truck drivers or bus drivers. If they can drive a car, they will be OK with a B double or taking your kids to school because the owners will ensure that it is so.
Or how about Trucks adopt the aviation system and get tested on every different brand of truck? Imagine that!

Unlike most other industries testing in aviation is perpetual. Most other transport doesn't do it neither does medicine.
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Old 5th Jan 2016, 05:49
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The ATPL air test is just a big fat waste of money , I really think that the test should be removed ,especially for someone that already has a large aircraft type rating.at a minimum you should be excempt from the test requirement if you hold a CASA Type rating on a >5700kg turbine aircraft-JT
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Old 6th Jan 2016, 21:37
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Did anyone talk to CASA on this recently i.e. In the last days-JT
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Old 7th Jan 2016, 00:19
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As an experienced pilot in GA who's hoping in the not to distant future to take the next step in my career (but who doesn't have a spare $30k sitting around to do an ATPL flight test), I find it frustrating to see that most of the airlines in Australia now require applicants to hold an ATPL, even for an FO position. I've just spent 5 minutes looking through the various airline websites, and Jetstar, Cobham, Network, Jetconnect, even RFDS, all require applicants to hold an ATPL. Why do I need to hold an ATPL licence to be an FO, or to fly as PIC in a King Air or a PC12? Surely the fact I have passes in all of the subjects will suffice?

I'm a realist. CASA will not remove the requirement for a flight test to gain an ATPL, and in all honesty, I don't think they need to. The previous system where you could meet all of the flight experience requirements by tooling around in a 210 in the outback wasn't right and needed to be changed but I feel that it may have gone too far.
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Old 7th Jan 2016, 00:57
  #136 (permalink)  
 
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The previous system where you could meet all of the flight experience requirements by tooling around in a 210 in the outback wasn't right and needed to be changed.
Any data to support that need? Or is it just intuition?

Are you able to nominate the ATPL holders who met the flight experience requirements by tooling around in a 210 and are now, consequently, unacceptably unsafe to hold an ATPL?

This is, after all, supposed to be an evidence-based and risk-based system, and we don't want unacceptably unsafe people holding ATPLs.
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Old 7th Jan 2016, 01:12
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You can twist my words how you like, but at no stage did I say that it was unsafe. In my opinion I don't believe that the previous system was perfect. I used a 210 as an example, but hell, if you wanted to, you could have flown all of the required hours in a 152, and as long as you had passed the exams, could now be issued an ATPL. How would the experience gained in flying a 152 apply to an operation where you are required to hold an ATPL? Like I said, in my opinion the old system wasn't perfect, however, the new system has gone too far the other way.
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Old 7th Jan 2016, 01:15
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Any data to support your opinion?

If your opinion is correct, it follows that the holders of ATPLs gained as a consequence of this kind of experience are not acceptably safe. Otherwise, what's the point of the change?
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Old 7th Jan 2016, 01:17
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Nope, no data. Just my opinion and experience in a non aviation related industry where the thought of being issued a licence to operate a piece of machinery without demonstrating competence by way of an assessment would be laughed at.

Genuinely curious then, how many countries in the world don't require a flight test for the issue of an ATPL?

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Old 7th Jan 2016, 01:39
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I have no idea. It would be interesting to find out, though, because I anticipate that the accident and incident rate of pilots from countries that have the test will not be statistically significantly different than pilots from countries that do.

If there are ATPL holders out there who:

- satisfied the experience requirements by tooling around in a 210 (or 152)
- did not have to do a flight test for the ATPL, and
- now exercise the privileges of the ATPL and meet all the recurrent requirements for doing so,

what would you conclude about the nexus between safety and the test/kind of experience?

It's a bit like asking: How many countries don't have the death penalty? The death penalty exists in some places as a consequence of intuition and politics, not any analysis of the extent, if any, to which the death penalty has a causal effect on crime rates.

Given that this is all supposed to be about safety, I'm trying to find out the data showing a causal connection between the ATPL test and safety or, to put that another way, data showing the existence and extent of the risk that is mitigated by the ATPL test.
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