A Part 61 conundrum for Australian ATPL applicants
It depends on whether the CPL test is an efficient and effective mitigation of a substantial safety risk. That's kinda the key point - the requirements should be based on data, risk assessments, causal links and cost/benefit, not intuition.
But you're being a bit naughty. The discussion was about the ATPL flight test, or lack of it. Your analogy about operating a piece of machinery without a licence test was not a valid one. The holder of an ATPL has done lots of tests, including the CPL flight test. And after they gain their ATPL they continue to do lots of tests.
If you think that the operators of the machinery called aircraft let anyone with a licence loose on them, just because they happen to have a licence, I'd suggest you think again.
But you're being a bit naughty. The discussion was about the ATPL flight test, or lack of it. Your analogy about operating a piece of machinery without a licence test was not a valid one. The holder of an ATPL has done lots of tests, including the CPL flight test. And after they gain their ATPL they continue to do lots of tests.
If you think that the operators of the machinery called aircraft let anyone with a licence loose on them, just because they happen to have a licence, I'd suggest you think again.
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Well regardless of your opinion that there is no safety case, it seems that 'world's best practice', is to conduct a flight test for applicants for an ATPL. The usual suspects on pprune seem to hold the FAA regs and Kiwi regs as some sort of Holy Grail of aviation regulations, and they both require an ATPL flight test. So when CASA make an attempt to bring the so called 'galapagos of aviation' in line with world's best practice, the same voices seem to chastise them again. Damned if they do, damned if they don't.
- 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?
- 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?
I think I can speak from personal experience, as the "test" I did was on a single engine aircraft for a SCPL -- it was, in fact, a Group B Instructor renewal.
Given the way CAR 217 operations and training are conducted, doing the test as required by CASR 61 (or any stand alone ATPL test) is irrelevant, and just a bureaucratic box ticking exercise.
Speaking from the point of view of an almost 25,000H pilot, with about 15+ years as PIC (including T+C) on seriously heavy metal, on a variety of ATPL/ALTP/licenses.
Tootle pip!!
The usual suspects on PPRuNe seem to hold the FAA regs and Kiwi regs as some sort of Holy Grail of aviation regulations, and they both require an ATPL flight test.
Being a bit disingenuous, are you not.
If candidates could do the test here, as per the US ( in a light twin) or under the slightly more onerous NZ rules, this thread would not exist.
I didn't say there was no safety case, wishiwasupthere.
I said I wanted to see it.
I said I wanted to see it.
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Being a bit disingenuous, are you not.
If candidates could do the test here, as per the US ( in a light twin) or under the slightly more onerous NZ rules, this thread would not exist.
If candidates could do the test here, as per the US ( in a light twin) or under the slightly more onerous NZ rules, this thread would not exist.
As the supply of suitable applicants dries up airlines will have no choice but to drop the requirement for the ATPL on day of joining and incorporate the test into their training programs.
Even though it is not the best way of attracting the best candidates, and certainly saves little or no money in training, some misguided airline HR departments may try to import pilots via the 457 visa route.
If they attempt this, disadvantaged local pilots as a collective group will need to smack them down with the widest possible lobbying, publicity and, if necessary, legal process. Or just wait it out until the error of their ways becomes self evident when they tally up the cost of bringing people in from overseas and inducting them to our strange ways, only to have half of them bugger off home when they realise the grass is not so green here after all.
Back to the ATPL debate; having had time in more than one CAR 217 organisation I do not accept this is a guarantee of quality training or checking.
In a former role, I was quite amazed at how bad some pilots from this system could be. Only a few, but enough to cast doubts on placing absolute trust in operators to uphold standards. Some of the training I received in these systems was excellent, some of token value only and some just plain bloody worthless.
The same goes for flight schools and independent ATOs authorised to renew instrument ratings. Two pilots that I had assessed as unsuitable as F/Os (in the days when we had co pilot ratings) went out and next day got command ratings in a Duchess or Seneca. If someone who is type rated and current on type can't meet co pilot standards in a relatively automated aircraft with the assistance of a reasonable Captain, how come they are OK single pilot IFR in a light twin? Did all it really take was an hour's dual to get them up to speed, then an hour to meet all the elements of the test? Hmmm.
This admittedly happened about 15 years ago and was well covered up at the time, but some readers here know what I am referring to. A highly experienced Captain who had years of service with a very respected airline, paired with a F/O (who was also within the 'umbrella' of the CAR 217 system) nearly replicated the Papa India disaster. Events leading up to the incident, and the incident itself were uncannily similar.
So, no - time under CAR 217 or a history of IR renewals in a bugsmasher twin does not automatically an ATPL make.
Even though it is not the best way of attracting the best candidates, and certainly saves little or no money in training, some misguided airline HR departments may try to import pilots via the 457 visa route.
If they attempt this, disadvantaged local pilots as a collective group will need to smack them down with the widest possible lobbying, publicity and, if necessary, legal process. Or just wait it out until the error of their ways becomes self evident when they tally up the cost of bringing people in from overseas and inducting them to our strange ways, only to have half of them bugger off home when they realise the grass is not so green here after all.
Back to the ATPL debate; having had time in more than one CAR 217 organisation I do not accept this is a guarantee of quality training or checking.
In a former role, I was quite amazed at how bad some pilots from this system could be. Only a few, but enough to cast doubts on placing absolute trust in operators to uphold standards. Some of the training I received in these systems was excellent, some of token value only and some just plain bloody worthless.
The same goes for flight schools and independent ATOs authorised to renew instrument ratings. Two pilots that I had assessed as unsuitable as F/Os (in the days when we had co pilot ratings) went out and next day got command ratings in a Duchess or Seneca. If someone who is type rated and current on type can't meet co pilot standards in a relatively automated aircraft with the assistance of a reasonable Captain, how come they are OK single pilot IFR in a light twin? Did all it really take was an hour's dual to get them up to speed, then an hour to meet all the elements of the test? Hmmm.
This admittedly happened about 15 years ago and was well covered up at the time, but some readers here know what I am referring to. A highly experienced Captain who had years of service with a very respected airline, paired with a F/O (who was also within the 'umbrella' of the CAR 217 system) nearly replicated the Papa India disaster. Events leading up to the incident, and the incident itself were uncannily similar.
So, no - time under CAR 217 or a history of IR renewals in a bugsmasher twin does not automatically an ATPL make.
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If a 457 visa pilot is needed because CASA have made such a expensive requirement for a ATPL that would really suck. On the 457 subject , personally I think they should all be cancelled. -JT
If they attempt this, disadvantaged local pilots as a collective group will need to smack them down with the widest possible lobbying, publicity and, if necessary, legal process.
Back to the ATPL debate; having had time in more than one CAR 217 organisation I do not accept this is a guarantee of quality training or checking.
In a former role, I was quite amazed at how bad some pilots from this system could be. Only a few, but enough to cast doubts on placing absolute trust in operators to uphold standards. Some of the training I received in these systems was excellent, some of token value only and some just plain bloody worthless.
The same goes for flight schools and independent ATOs authorised to renew instrument ratings.
In a former role, I was quite amazed at how bad some pilots from this system could be. Only a few, but enough to cast doubts on placing absolute trust in operators to uphold standards. Some of the training I received in these systems was excellent, some of token value only and some just plain bloody worthless.
The same goes for flight schools and independent ATOs authorised to renew instrument ratings.
You've seemingly to me gone to great lengths to entirely avoid the arguments that are being put to you by myself and others regarding the evidence and logic behind an ATPL flight test.
Neville wrote : "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?".
Its a valid question. How on earth does the test conducted in this environment possibly relate or have any bearing at all on the level of safety of an applicant? Think about what that person needs to go through to attain such a position in addition to the differences in the operation.
Lead wrote "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? "
Where is your evidence? Or answers to his follow up questions? "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?"
So, no - time under CAR 217 or a history of IR renewals in a bugsmasher twin does not automatically an ATPL make.
Its an extra test, identical to ones we already undergo, conducted by the same people who do our existing testing. It is absolutely pointless and redundant.
Last edited by das Uber Soldat; 7th Jan 2016 at 22:59.
What was the official reason REX and Skywest used for the 457 visas ?
Very same thing could happen again with the ATPL. People can't afford to get the license or want the airlines to pay, Airlines require the ATPL, they claim they can't get anyone so the government could open the doors to foreign pilots because Australians aren't qualified and foreigners bypass all CASA bureaucracy and expense. Effectively killing the industry in one easy step.
Das Uber's right. What is the point of an ATPL flight test when you get tested on everything anyway and you are at the behest of an AOC holding who is also tested by CASA?
Last edited by neville_nobody; 8th Jan 2016 at 00:20.
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Well let's not let that happen again. As a professional aviation community lets get together and pressure CASA to remove the test requirement, starting here on PPRUNe. JT.
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Uber etc.
The individual examiner/ATO is responsible for conducting the test to the standard required by the Manual of Standards. You may not be aware of this as you won't have read the MOS but there is much more in the test than the IPC.
If you are an airline pilot you might be aware that there is much more to command than instrument proficiency. And if you are a pilot next time you're near a bunch of passengers tell them you dispute the Commonwealths right to require a test for the ATPL.
Just my thoughts.
Sherm
The individual examiner/ATO is responsible for conducting the test to the standard required by the Manual of Standards. You may not be aware of this as you won't have read the MOS but there is much more in the test than the IPC.
If you are an airline pilot you might be aware that there is much more to command than instrument proficiency. And if you are a pilot next time you're near a bunch of passengers tell them you dispute the Commonwealths right to require a test for the ATPL.
Just my thoughts.
Sherm
Hear! Hear! Sherm! 
Now, what will we do about all those people who currently exercise the privileges of an ATPL without having done an ATPL flight test?
I reckon that each and every safety brief from cabin staff should include a declaration of whether the PIC has or has not passed an ATPL flight test, and offer pax the option to disembark if they don't like the answer.
Surely that's what should happen, in the interests of safety. Surely.
Now, what will we do about all those people who currently exercise the privileges of an ATPL without having done an ATPL flight test?
I reckon that each and every safety brief from cabin staff should include a declaration of whether the PIC has or has not passed an ATPL flight test, and offer pax the option to disembark if they don't like the answer.
Surely that's what should happen, in the interests of safety. Surely.
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This is supposed to be a mature discussion..... So when laws came in to increase standards and tests for doctors, teachers, nurses etc you'd have opposed them because there would be some who hadn't been trained to the new standard?
Alas, it's way past your bedtime and level of comprehension.
Alas, it's way past your bedtime and level of comprehension.
Not at all, Sherm. I'd merely require that all those lower standard nurses and doctors to be identified so that we'd know who the 'unsafe' ones are.
The individual examiner/ATO is responsible for conducting the test to the standard required by the Manual of Standards. You may not be aware of this as you won't have read the MOS but there is much more in the test than the IPC.
If you are an airline pilot you might be aware that there is much more to command than instrument proficiency. And if you are a pilot next time you're near a bunch of passengers tell them you dispute the Commonwealths right to require a test for the ATPL.
If you are an airline pilot you might be aware that there is much more to command than instrument proficiency. And if you are a pilot next time you're near a bunch of passengers tell them you dispute the Commonwealths right to require a test for the ATPL.
There is very little difference. Don't take my word for it though! I've got some time so lets go on a journey of discovery together!
Appendix K.1 ATPL Aeroplane category rating flight test
1. Flight test requirements
1.1 An applicant for an air transport pilot licence with aeroplane category rating flight test must
demonstrate her or his competency, in the units of competency mentioned in clause 3, by
performing manoeuvres in an aeroplane, within the flight tolerances specified in tables 2 and 5 in
Section 1 of Schedule 8 of this MOS.
1. Flight test requirements
1.1 An applicant for an air transport pilot licence with aeroplane category rating flight test must
demonstrate her or his competency, in the units of competency mentioned in clause 3, by
performing manoeuvres in an aeroplane, within the flight tolerances specified in tables 2 and 5 in
Section 1 of Schedule 8 of this MOS.
Table 2: Aeroplane general flight tolerances – professional level
1. Applicability
1.1 The flight tolerances in this subsection apply to the following licences and ratings:
(a) commercial pilot licence;
(b) multi-crew pilot licence;
(c) air transport pilot licence;
(d) pilot instructor rating;
(e) instrument rating;
(f) private IFR rating;
(g) flight examiner rating;
(h) aerial application rating;
(i) low-level rating;
(j) aircraft type rating
1. Applicability
1.1 The flight tolerances in this subsection apply to the following licences and ratings:
(a) commercial pilot licence;
(b) multi-crew pilot licence;
(c) air transport pilot licence;
(d) pilot instructor rating;
(e) instrument rating;
(f) private IFR rating;
(g) flight examiner rating;
(h) aerial application rating;
(i) low-level rating;
(j) aircraft type rating
What about demonstrated competencies?
The ATPL requires C2, C3, C5, NTS1, NTS2, IFF, IFL, RNE, MCO, CIR, IAP2, IAP3
The IPC requires NTS1, NTS2, IFF, IFL, CIR, IAP2, IAP3
hmm, those look like some differences!
C2.1 – Pre-flight actions and procedures. Can I read the MEL? A NOTAM? Its possible I've been assessed on this so far.
C3.1 – Operate radio equipment. I wont even answer this one.
2.1 RNE.1 – Operate and monitor radio navigation aids and systems. I'd be impressed if you could pass an IPC yet fail this guy.
2.2 RNE.2 – Navigate the aircraft using navigation aids and systems. Refer above.
2.1 MCO.1 – Operate effectively as a crew member. Possibly the only actual point of difference. Yet everything in MCO I'd argue is required regardless despite its omission from the IPC for a successful attempt. Certainly in an OPC this material is looked at and assessed. There is nothing new here, no 'new standard' beyond what has been required in the past.
This 'much more' you refer to as being in the ATPL test vs an IPC (let alone an OPC) is starting to look 'much more' like SFA.
This is supposed to be a mature discussion..... So when laws came in to increase standards and tests for doctors, teachers, nurses etc you'd have opposed them because there would be some who hadn't been trained to the new standard?
Secondly, if one of these doctors who hadn't been subjected to these increased standards and testing wanted to operate on you, would you have allowed it? If no, then you argue that anyone not subject to the increased testing hasn't met the required competencies, isn't safe and shouldn't be operating/flying. This almost certainly includes you. Are you and 99.9% of Airline Captains not competent Sherm?
If yes, then whats the point of the test? Clearly you see no evidence sufficient to alter your opinion of the competency of the person involved. Which leads directly to lead balloons core point. Where is the evidence that the introduction of this test will have a material affect on the safety of those exercising the privileges of the ATPL?
Or is that past your 'level of comprehension'.
Last edited by das Uber Soldat; 8th Jan 2016 at 23:53.
Pilots are already being tested every 3-6 months anyway so what does another expensive test prove? You can fly a single engine ILS? Which you will be doing again in another 3 months?