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IMC rating - post PPL minimum hours

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IMC rating - post PPL minimum hours

Old 7th Dec 2014, 15:04
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IMC rating - post PPL minimum hours

Folks,

To get an IMC rating issued, CAA states:

Restricted Instrument Ratings (IMC / IR(R)) | Private Pilots | Personal Licences and Training
The course consists of a minimum of 15 hours, all dual instruction, with a written examination and skill test. The pilot must have completed 25 hours post-PPL flying before the rating can be issued.

I have NPPL(SSEA) and about 30 P1 hours flown post license issue. Does it mean I need to do another 25 hrs after I finish the conversion training and get my PPL? Or do the NPPL hours count towards the IMC requirements?

Thanks!
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Old 7th Dec 2014, 17:15
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Hello! Not sure about your NPPL P1, but when I did my IMC in 2010 the rating training itself counted towards the 25 hours, so I only had ten hours to polish off after the IMC test (which I did by bashing out a trip to France, bien sur) before I could apply to the CAA to put the rating in my licence.

I guess my point is you don't have to do 25 hours before your start the IMC training! Hope that made sense.
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Old 7th Dec 2014, 17:30
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I don't think you can do an IMC with an NPPL, unless there have been changes.

As far as I know you would have to upgrade the licence, which may not be too different to the extra hours you mention?

BB
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Old 7th Dec 2014, 17:52
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The original poster is in the process of 'upgrading' to a PPL. The question (s)he's asking is whether or not the 30 hours P1 they have accrued using their NPPL count towards the 25 hours post-PPL flying that you need before the IR(R) can be issued.

I don't actually know the answer to this question... It's a good one!
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Old 7th Dec 2014, 18:03
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Originally Posted by stevelup
The original poster is in the process of 'upgrading' to a PPL. The question (s)he's asking is whether or not the 30 hours P1 they have accrued using their NPPL count towards the 25 hours post-PPL flying that you need before the IR(R) can be issued.

I don't actually know the answer to this question... It's a good one!
If the regulations specify "post PPL" then I would suggest that any flying "post NPPL" are not going to count as by definition they are not post PPL and therefore do not meet the wording of the regulation.

Therefor you will need to find an additional regulation/CAA directive etc etc that specifically addresses this issue by providing relief from the regulation and allows those hours to be counted.
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Old 7th Dec 2014, 18:34
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Cap 804 says:-
a) Experience
i) 25 hours total experience as pilot of aeroplanes following PPL issue and which

may include the training for the IMC Rating / IR (Restricted).
ii) 10 hours as Pilot in Command of aeroplanes to including 5 hours as Pilot in Command of aeroplanes on cross-country flights.
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Old 7th Dec 2014, 19:44
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Your existing hours are acceptable.
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Old 8th Dec 2014, 18:21
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Your existing hours are acceptable.
bose,
Do you have a reference to support that statement?
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Old 8th Dec 2014, 20:29
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I am Head of Training of a Uk ATO. FE, CRE, TRE which includes the privilege of teaching and examining for the the UK IMCr or IRR if we want to use the correct term.

I have questioned this previously and received condfirmation from CAA policy in writing that any flying hours in aeroplanes count regardless of the licence on which they were flown. The IMCR is a national rating and thus the CAA have total control over what is acceptable for it. That discretion is filtered down to the Instructor and the Examiner.

Guys, why do we have to try and make more difficult than it is by making up rules that don't exist? The whole point of the IMCr is to improve safety and it's meant to be accessible. The fact that it's a national rating means the Eurocrats have not managed to get there hands on it. Let's enjoy that......
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Old 9th Dec 2014, 18:16
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It is obviously very sensible to count post NPPL or LAPL hours, but If the CAA really mean that why don't they change the wording in CAP 804 and the SRG1125 form? Both of these documents very clearly state that the hours are post PPL

In form SRG1125 you need to fill in a box annotated as "Total experience as pilot of aeroplanes (following valid application for issue of PPL)." If a candidate listed hours flown since the issue of an NPPL in this box it could be seen as "false representation" which is a very serious matter, as the form goes on to make clear.

"It is an offence to make, with intent to deceive, any false representations for the purpose of procuring the grant, issue, renewal or variation of any certificate, licence, approval, permission or other document. Persons doing so render themselves liable, on summary conviction, to a fine not exceeding the statutory maximum (currently £5000, or in Northern Ireland £2000) and on conviction on indictment to an unlimited fine or imprisonment for a term not exceeding two years or both.".
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Old 9th Dec 2014, 19:06
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A PPL is a PPL regardless of weather its an NPPL, EASA PPL, LAPL or an ICAO PPL. You need to have an appropriate licence on which to include the rating but as longs as the hours flown were in the correct class of aircraft then they all count towards the total. Which in the case of the IMC is Aeroplanes.

If we were to use your argument Dobbin then an CPL or an ATPL holder would be ineligible to get an IMCr.....

Really guys, why are you making this difficult?

Dobbin, thanks for pointing out the fraud statement on the paperwork, but as Head of Training I understand my obligations for signing paperwork just fine!!!
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Old 9th Dec 2014, 19:36
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I'm not having a go at you Bose, I'm just saying that the CAA could (should) make it clearer. I doubt the CAA would define "PPL" as including the NPPL, LAPL etc in any other context.
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Old 9th Dec 2014, 19:57
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Dobbin, the difference here is that you are surmising. I am posting from a position of already having established the answer from the policy unit at the CAA.

Pose the question to them yourself if you have any doubt.
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Old 9th Dec 2014, 20:23
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I don't doubt what you are saying.

Nevertheless, I bet there are IR(R) candidates who have taken these documents at face value and flown additional pointless hours. A small change in the wording would avoid this.
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Old 9th Dec 2014, 20:24
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I have already written to the CAA to propose that ‘following PPL issue’ should be amended to ‘following issue of a pilot licence’ or similar.

The experience has to be gained in aeroplanes, so there should be no need to be any more specific.
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Old 16th Dec 2014, 15:22
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UPDATE

I have now had an official reply from the CAA.

It is agreed that the 'following PPL issue' experience prerequisites also apply to experience gained since NPPL / LAPL(A) issue (as bose-x posted).

A suitable change of wording will be included in the next CAP 804 amendment.
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Old 16th Dec 2014, 22:02
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Good work!
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Old 16th Dec 2014, 22:07
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With all due deference to bose-x I would suggest that, until the wording in CAP 804 is changed, ‘following PPL issue’ is what the CAA would expect/accept.

Unless the CAA refuse to accept the pass in the test (because it was done before all experience requirements were met) there shouldn't be a cost penalty to having an application rejected - However the applicant would be mighty miffed.
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Old 17th Dec 2014, 06:39
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With all due deference to bose-x I would suggest that, until the wording in CAP 804 is changed, ‘following PPL issue’ is what the CAA would expect/accept.
Not so. No need for such scaremongering, Level Attitude, CAA ISP have confirmed the policy, so there is no reason to doubt that The Hub have also been informed.
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Old 17th Dec 2014, 07:51
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I established this several months ago and have not had any issue with candidates getting paperwork processed.

As Beagle says, there really is no need for scaremongering nor making out the CAA to be the Bogeymen. I watch them make very pragmatic decisions on a daily basis.

CAP804 is guidance not law, if you don't like or understand it then you can contact the CAA and seek clarification or change. Both Beagle and I do it on a regular basis and the CAA are very responsive.

Perhaps those always seeing the negative side should actually speak to the CAA before they post so quickly in the negative?
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