ATP(A) Integrated SPIC hours

[wigbam]

Hi,

I am wondering if anybody can actually provide a definitive answer into SPIC hours which can be logged by ATP(A) Integrated students. In particular, the Part-FCL Appendix 3 (A) (Page 1128) which lists flying training requirements seems to be slightly ambiguous to me:

(a) 95 hours of dual instruction, of which up to 55 hours may be instrument ground time;
(b) 70 hours as PIC, including VFR flight and instrument flight time as student pilot in-command (SPIC). The instrument flight time as SPIC shall only be counted as PIC flight time up to a maximum of 20 hours;
(c) 50 hours of cross-country flight as PIC, including a VFR cross-country flight of at least 540 km (300 NM), in the course of which full stop landings at two aerodromes different from the aerodrome of departure shall be made;
(d) 5 hours flight time shall be completed at night, comprising 3 hours of dual instruction, which will include at least 1 hour of cross-country navigation and 5 solo take-offs and 5 solo full stop landings; and
(e) 115 hours of instrument time comprising, at least:

(1) 20 hours as SPIC;
(2) 15 hours MCC, for which an FFS or FNPT II may be used;
(3) 50 hours of instrument flight instruction, of which up to:

(i) 25 hours may be instrument ground time in a FNPT I, or
(ii) 40 hours may be instrument ground time in

From the above I understand that (b) mandates for 70 PIC hours, for which up to 20 hours of SPIC time can be counted as PIC. I.e. it means that at least 50 hours must be flown solo as part of the training, which is fine. For examples, in a most favorable scenario a student could fly exactly 50 hours VFR solo and then use 20 hours from IFR SPIC time to comply with total of 70 PIC hours.

But then (e)(1) states that at least 20 hours of IFR must be flown as SPIC. And this is where it gets confusing and questions appear:

• Does the regulation mean that only a maximum of 20 hours of IFR can be logged as SPIC (and hence PIC) in logbook?
• Or does the reg say that one can log more than 20 hours of SPIC in IFR, but only 20 hours of those can be counted in order to satisfy (b)?

Naturally, every student would want to log as much PIC time as possible, hence if it is possible to log more than 20 hours of SPIC and still comply with remaining clauses (i.e. dual time) then people would. So the ultimate overall question is:

Is it OK for an integrated ATP(a) student to log more than 20 hours as SPIC time (and hence increase total logbook PIC), but count only 20hr of those SPIC towards the 70hr PIC requirement of the regulation?

[flybyschool]

In my humble opinion... this is more a theoretical question than a practical one

From what my HT explains me... any SPIC hour above the 20 you mention... are a waste

My point is, doing an integrated training, you must follow the school’s approved manuals... so you just cannot decide; “Iwant more SPIC hours”
you will just complete the ones in your particular ATOs training manuals

hope it helps.

[wigbam]

Hi Alex, thanks for your input. First of all I totally agree with you that the students should simply follow the program of their ATOs. But this question was meant to be precisely from the view point of the ATO. What is the legal standing of SPIC hours in regards to logbook from the EASA Part-FCL's point-of-view?

You mentioned that your Head of Training was of an opinion that "any SPIC hour above the 20 you mention... are a waste". Yep, that is precisely what I heard from other people too and I guess it might have been implied from Part-FCL Appendix 3 (A) (b), but this is exactly the question I wanted to bring - how all of those requirements are to be interpreted? Only 20 hours of SPIC are allowed to be logged as PIC during the whole course? Or more than 20 hours can be logged as PIC, but only 20 hours of those will count towards that particular constraint (70 hour PIC time).

To be pedantic, let's say a student has 19:30 hours of SPIC time already logged as a part of ATP(A) integrated course and then makes another SPIC flight of 02:30. Should the time logged then be split into 00:30 PIC and 02:00 DUAL? That log entry wouldn't make much sense.

[BillieBob]

You can include any amount of SPIC in your logbook but any above 20 hours cannot be counted as PIC for any licensing purpose and is, therefore, pointless. What you write in your personal logbook is entirely up to you, provided that you include the minimum requirements of Article 228 of the ANO (assuming that you are UK-based).

[wigbam]

BillieBob , thanks, in that case, following my earlier example where a SPIC flight would exceed the 20 hour limit should the time logged indeed be split into PIC and DUAL for such a flight?

[flybyschool]

I agree with BillieBob

if you fly SPIC, you will log it in your logbook but when it comes to present it to the authorities to issue your license... only 20 will be counted towards the min needed

in other words, you can fly 100 SPIC hours but only 20 will be used for meeting the min criteria to be issued the license.

that’s why I called it a “waste” to do more than 20.
we received a logbook with 58 hours SPIC from an integrated training from another school...

[BillieBob]

@wigbam: I say again, "What you write in your personal logbook is entirely up to you" There is no 'correct' way of recording excess SPIC time, nobody cares how you do it.

[wigbam]

Originally Posted by flybyschool

in other words, you can fly 100 SPIC hours but only 20 will be used for meeting the min criteria to be issued the license.

Thanks again Alex, that indeed was my understanding as well.

Originally Posted by BillieBob

@wigbam: I say again, "What you write in your personal logbook is entirely up to you" There is no 'correct' way of recording excess SPIC time, nobody cares how you do it.

Is that so? There are a few airlines looking for low-hour pilots with 100 PIC hours. Hence by not caring and not logging more time as SPIC or logging just the minimum 20 required for licensing purposes a student might end up with the mandatory minimum of 70 PIC hours in the logbook and be at disadvantage or have some explaining to do later.

[VariablePitchP]

Very off topic but just some advice. Yes it is called SPIC by your school and the books, but just google that acronym. It’s an incredibly offensive racial slur used in the Americas. For interviews etc you m may want to not abbreviate it just in case the interviewer doesn’t quite catch what you are referring to... As for using it on a flight deck, definitely not advised!!

[BillieBob]

@wigbam: SPIC is not PIC; up to 20 hours, it may be counted towards the minimum PIC requirements for licence issue by graduates of a CPL or ATPL integrated course, but has no value beyond that. An airline is highly unlikely to accept any amount of SPIC as counting towards its requirement for minimum PIC time.

[wigbam]

BillieBob, yeah, I am totally with you regarding the licensing part of SPIC vs PIC and 20hr limit, thanks for clarifying that.

​​However I still believe it would be more advantageous for a student to have logged as much IFR time as possible as SPIC even if some would not consider it as "true" PIC. Some might do and again even the regulation says it should be "at least" 20 hour SPIC. So I don't see why it would be harmful to have more. Ultimately my reasoning is that dual time is less PIC than SPIC you if know what I mean ​​. And for wannabes every edge and perceived advantage sometimes can make a difference.

[wigbam]

Originally Posted by BillieBob

You can include any amount of SPIC in your logbook but any above 20 hours cannot be counted as PIC for any licensing purpose and is, therefore, pointless. What you write in your personal logbook is entirely up to you, provided that you include the minimum requirements of Article 228 of the ANO (assuming that you are UK-based).

This is no longer the case as far as I understand. There was a Commission Implementing Regulation (EU) 2019/1747 which changed this requirement (I would have posted a link, but for some reason PPRuNe treats me as having 0 posts , so just search for this reg).

Before 15/10/2019 Part-FCL part A of Appendix 3, point (b) in point 9 used to state:

70 hours as PIC, including VFR flight and instrument flight time as student pilot in-command (SPIC). The instrument flight time as SPIC shall only be counted as PIC flight time up to a maximum of 20 hours;

Which meant that students had to do at least 50 hours PIC alone time in the aircraft. The above mentioned amendment changed this as follows:

(60) in part A of Appendix 3, point (b) in point 9 is replaced by the following:
‘(b) 70 hours as PIC, of which up to 55 hours may be SPIC. The instrument flight time as SPIC shall only be counted as PIC flight time up to a maximum of 20 hours.’;

So effectively, now students need only 15 hours of proper PIC alone time in the aircraft. This was quite a silent, but significant change in regs which went mostly unnoticed.

[what next]

Hello!

Originally Posted by VariablePitchP

For interviews etc you m may want to not abbreviate it just in case the interviewer doesn’t quite catch what you are referring to...

You just pronounce it "es - pee ay see" (each letter individually, just like most acronyms in aviation are supposed to be pronounced) and all will be well. Anyway, if we have to omit every word from our speech that might mean somthing nasty in another language or culture not many words would be left...

[Field Required]

I can't believe how little flying is actually done on an integrated course for it to A) take so long and B) cost so much. Robbed!