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Multi-Pilot without ATPL(H) possible? (EASA-land)

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Old 17th November 2013 | 09:58
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wmy
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Multi-Pilot without ATPL(H) possible? (EASA-land)

The question rose if it is possible to operate a Agusta 109 multi-pilot according EASA with both pilots only having a CPL(H)?

FCL.720.H says:
Unless otherwise determined in the operational suitability data established in accordance with Part-21, an applicant for the issue of the first helicopter type rating shall comply with the following experience requirements and prerequisites for the issue of the relevant rating:
(a) *Multi-pilot helicopters. An applicant for the first type rating course for a multi-pilot helicopter type shall:
(3) have passed the ATPL(H) theoretical knowledge examinations.
As the 109SP is not a multi-pilot helicopter type, i'd like to assume, that if both pilots have their MCC course and a CPL(H) they are ready to fly the ship multi-pilot?

any expert advise is greatly appreciated!

walter
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Old 17th November 2013 | 10:28
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You can operate a single pilot aircraft "multi crew" e.g. to fit in with the customer's requirement for two pilots. The issue arises when the "co-pilot" tries to claim the flight time.
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Old 17th November 2013 | 11:00
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wmy
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yes, that's exactly what we are seeking. A legal (of course...) way to write the copilot hours so that they will be countable for a future ATPl(H). That means, those hours have to be multi-pilot hours according EASA.FCL.

During my research, i got two main answers:
  • To operate a ME-Helicopter below 3175kg/9seats with a multi-pilot crew all you need is a CPL(H), a MCC course and an AOC where the multi-pilot operation is described.
  • Same as before, but both pilots need a frozen ATPL(H).

However, in EASA.FCL, there is no clear reading about this...
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Old 17th November 2013 | 11:06
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You would have to declare the 109 a multi pilot helicopter as per your ops manual and subsequently fly it with two crew at all times.
Now the co could log the hours but the aircraft could not be flown single pilot ever again unless you change the ops manual again.
Check with your CAA whether the Captain has to be ATP now...
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Old 17th November 2013 | 11:22
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Would be possible that the operator could get into ops manual that depending on the kind/condition of the flight the aircraft can be flown both single or multipilot? (let’s say: VFR Day- single vs IFR or VFR Night- Multipilot or Flight with the pax-multi vs MX flight- single)
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Old 17th November 2013 | 20:25
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wmy
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Thanks Aucky,

even if it's CAA's "Interpretation" of EASA.FCL, it gives a good overview, what to expect from my Authority. I'll check with them...

Still, i'm quite curious how CAA comes to the conclusion that
Choosing to operate a single pilot helicopter with 2 pilots as a policy of the owner/operator of the helicopter does not make it a multi-pilot operation; as flying the aircraft multi-pilot is not required by the operating rules in such a case
If i read the mentioned EASA.FCL definition of "multi-pilot aircraft" in 0.10, it says
for helicopters, it means the type of aircraft which is required to be operated with a co-pilot as specified in the flight manual or by the air operator certificate or equivalent document.
So, it does not state, that it's up to the authority to decide, which operation or based on what criteria(s) an operator has to decide to operate a helicopter as multi-pilot helicopter. If it would be (up to the authority), shouldn't there be at least a list of operations which are eligible to be flown multi-pilot???

Last edited by wmy; 17th November 2013 at 20:51.
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Old 17th November 2013 | 20:46
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As far as I know ... It's on you to decribe in SOPs (and OM...and what is accepted by CAA) which operations you are going to fly MP, which SP.

Off course, MCC concept must be described in your OM (how you do that) and all pilots must hold MCC (IR or VFR) certificate.

JR
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Old 17th November 2013 | 21:22
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Fixed wing world it seems to be slightly different.

You don't need to have a MCC in fact quite a few use it to get an exemption.

The aircraft doesn't require to be MPA from as soon as its being used unless it has a mod which means that the SPA stuff isn't reachable by a single crew eg the second altimeter can't be adjusted.

there are three inspections that need to be passed.

1. The aircraft that its equipped to be MPA.

2. OPs manuals and SOP's are multicrew.

3. Training is to be multi crew along with line checks, OPC/LPC etc.

A lot of it is in the hands of your ops inspector some don't like crew being qualified SPA and MPA on the same type. Some will let you. Some will say you need a MCC as part of initial training others don't require it.

There are shall we say some experts out there in getting the manuals together and all the boxes ticked. And it can be a bit involved.

Once you have it both pilots can log the time and the co-pilot can log PICUS as well (make sure you define that in your manuals).

I don't think its possible to do unless your on an AOC. Or if it is I have never heard of it.

Oh and you can be PIC without an ATPL.
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