Odd ATPL Theory question...

[Unusual Attitude]

Hi all, looking for some assistance here with a slightly odd ATPL theory question.

So back in the Early 2000’s I did my ATPL’s and gained a JAR CPL, which then became an EASA CPL and now a CAA CPL but never added a full IR so effectively lost my ATPL theory credits.

Currently I get by flying my light twin around for business and pleasure using my CPL/Multi/IR(R) however I’m planning to upgrade that to a full IR using the CB-IR route which looks like I will only need to re-do 4 ATPL theory exams as I currently hold a valid CPL. This part all makes sense, it gets weird from here.

Further to the above, I’m now also considering a career change to fly for a living, though I will hold a CPL/Multi/IR, I wont have a FzATPL due to expired ATPL theory credits and will therefore need to regain these in order to be able to hold a multicrew type rating.

In order to gain a FzATPL from this situation does anyone have any clue what I will need to do with regards exams? The CB-IR route seems to grant me reduced theory requirements for gaining an IR given I already have a CPL, however I’ve no idea if these count in any way with regards credits towards a FzATPL? Is anyone please able to clarify the requirements here as I’m struggling to find a solid answer.

All answers greatly appreciated!

[paco]

Just do the ATPL theory - it includes the full IR. CPL/IR upgrade to atp means another 12 exams anyway.

[Unusual Attitude]

Thanks for that, so in essence the CB-IR route is in reality a dead end for multi crew flying resulting in the need to sit the full set of ATPL exams all over again? (excluding VFR comms I believe?)

Reagrds

UA

[paco]

The flying is one thing, the theory is another. If you did the ATP you wouldn't have to do it.

[Genghis the Engineer]

I agree with Paco, if you want to do public transport multi-crew flying, you need the recent ATPL TK.

If you don't want to do flying under an AOC - e.g. private operator business jets, even if it's multi-crew, technically you don't need them but,an individual recruiter may prefer still to go for somebody who does have them.

G

[rudestuff]

Originally Posted by Unusual Attitude

Thanks for that, so in essence the CB-IR route is in reality a dead end for multi crew flying resulting in the need to sit the full set of ATPL exams all over again?

What makes you think you have to do the ATPL exams again? ATPL exams have no expiry date. The requirement is to have passed them, which you have.

[paco]

You require an IR for them to stay valid for 7 years after the date of its expiry - he never added one.

[rudestuff]

Originally Posted by paco

You require an IR for them to stay valid for 7 years after the date of its expiry - he never added one.

True - if you want an ATPL. The ATPL exam validity is determined by what you use them for. For a LAPL or PPL they're only valid for 24 months. CPL or IR they're valid for 36 months, ATPL is a rolling 7 years. However they can also be used to satisfy the theory requirements for FI and a first MP type rating - which have no expiry.

[Unusual Attitude]

Originally Posted by rudestuff

True - if you want an ATPL. The ATPL exam validity is determined by what you use them for. For a LAPL or PPL they're only valid for 24 months. CPL or IR they're valid for 36 months, ATPL is a rolling 7 years. However they can also be used to satisfy the theory requirements for FI and a first MP type rating - which have no expiry.

That's very interesting.

I was under the impression that to add a Multi crew type I would in fact have to redo the ATPLs, hadn't noted the lack of a timeline on that requirement?. I already have a CPL so don't need them for that, I can gain an IR via the CB-IR upgrade route so don't need them for that either, just purely the need to add a multi crew type for airline flying was my thinking.

Will do some digging thanks.

[Unusual Attitude]

So looking at CAP 804 Section 4 part H it states the following:"have passed the ATPL(A) theoretical knowledge examinations in accordance with this Part; and..."

Since it states "in accordance with this part" I went through the rest of CAP 804 regarding theoretical knowledge, mainly part 1 but also Section 4, Part A, paragraph 3 that also refers to Part-FCL.025 (c)(2)

After looking through that lot there isn't anything to challenge the statement that you merely need to have "passed" the ATPL theoretical knowledge at some point, there is however this little gem in FCL.035 "Crediting of flight time and theoretical knowledge:"

"(5) Notwithstanding point (b)(3), the holder of an IR(A) who has completed a competency-based modular IR(A) course or the holder of an EIR shall only be credited in full towards the requirements for theoretical knowledge instruction and examination for an IR in another category of aircraft when also having passed the theoretical knowledge instruction and examination for the IFR part of the course required in accordance with FCL.720.A.(b)(2)(i)."

So I get that's to stop anyone doing the CB-IR and using that theory to claim IR theoretical compliance for a multi crew type however it does state that you can actually do that if you have already "passed" the IFR part of theory examinations with no mention of time limit.

FCL.720.A.(b)(2)(i). merely loops back to the original statement of:"(3) have passed the ATPL(A) theoretical knowledge examinations in accordance with this Part; and..."

So in theory, it looks like you can actually add a multi crew type with expired ATPL theory as long as you have "passed" all the exams at some point, you certainly cant use them for issue of a CPL or IR or also to then upgrade to a full ATPL which would mean you are stuck forever as an FO on a multicrew type!

I spend a lot of time reviewing industry / contract law in my day job and it never fails to amaze me what a mess of vagueness the CAA / EASA documents are....!

Regards

UA

[selfin]

The CAP 804 document hasn't been maintained for nearly a decade. Current consolidated versions of the retained EU Aircrew Regulation and associated implementing rules, along with the delegated act that deals with foreign conversions and validations, are available from UK CAA here. The AMC/GM was adopted by UK CAA in ORS 9. Some derogations or exemptions from Part-FCL will still be found in ORS 4.

The version of FCL.035 point (b)(5) you cited has been amended to refer instead to FCL.720.A point (a)(2)(ii)(A). You can disregard FCL.035 point (b)(5) which refers to crediting across aircraft categories, eg aeroplane to helicopter. The requirements in FCL.720.A point (a) apply to single-pilot high-performance non-complex aeroplanes regardless of any provision in FCL.035.

As rudestuff points out, neither FCL.025 nor any other rule imposes a validity period on the ATPL exams for the purpose of FCL.720.A point (b), viz the requirement to have passed the ATPL(A) exams before starting training for the initial unrestricted MPA TR.

[rudestuff]

You'll have plenty of time in the cruise to study when it comes to upgrade time!

[Unusual Attitude]

This is true! I do however see most job ads state FzATPL required so not having that would be somewhat limiting I suspect.

I'm now trying to get my head around what I would need to do theory wise if I just took the pain and did all the exams again. In the old days it was 13 of the 14 exams required with the only credit for having a CPL being VFR comms. Looks like now possibly 3 are credited of the 13 as a CPL holder with Human Performance, Met and Comms not required though I'm struggling to find confirmation of this anywhere.

[rudestuff]

No one gives a **** about frozen ATPLs. ATPL theory credits are required by regulation. It's a prerequisite to starting a first multi pilot type rating. They don't need to be current. You Meet that requirement.

[richpea]

Originally Posted by Unusual Attitude

This is true! I do however see most job ads state FzATPL required so not having that would be somewhat limiting I suspect.

I guess the thing to remember is that FzATPL isn't an actual thing, it's just a shorthand to describe the situation of holding a CPL, IR and ATPL theory credits on your license.