Commercial Solo Time Requirement

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Commercial Solo Time Requirement

Post by Aviatard »

I searched and didn't find this exact topic.

Before the FTU bashing begins, accusing me of wanting to rip the poor student off and soak him for extra charges, this guy has his own airplane. If he has to re-do some flights, the FTU won't get a penny.

Student stopped by to ask about the solo flight time requirements for the commercial pilot licence. He has his own aircraft and wants to be able to count a number of flights he's done toward the 30 hours of solo flight time for the commercial, including the 300 nm cross country requirement. He did not get an instructor authorization before making these flights, and I think this is going to be a problem for counting the time.

CARS 421.30(4)(a)(ii) says:
following the issuance of a private pilot licence — aeroplane by Canada or another contracting state, have completed 65 hours of commercial pilot flight training in aeroplanes consisting of a minimum of:
(A) 35 hours dual instruction flight time, under the direction and supervision of the holder of a Flight Instructor Rating — Aeroplane,
...
(B) 30 hours solo flight time including:
(I) 25 hours solo flight time emphasizing the improvement of general flying skills of the applicant which shall include a cross-country flight to a point of a minimum of 300 nautical mile radius from the point of departure and shall include a minimum of 3 landings at points other than that of departure;


So what is solo flight time? CARS 400.01(1) says this:
solo flight time means, with respect to the flight time necessary to acquire a permit, licence or rating,
(a) in the case of a pilot, the flight time during which the pilot is the sole flight crew member


and this:
training flight means a dual instruction flight or a solo practice flight that is conducted under the direction and supervision of a flight instructor

CARS 426.22(5) says:
A person who is appointed as Chief Flight Instructor for a flight training unit identified in subsection (1) shall be responsible for:
(k) ensuring that all solo training flights are properly authorized by a flight instructor and acknowledged by the trainee;


Finally, CARS 426.56 says this:

A daily flight record shall include the following information:
...

(f) flight instructor’s authorization;
(g) trainee’s acknowledgement;


So, my contention is that in order for the solo flights to be counted toward the 30 hours solo flight training requirement, the flights would have had to be entered in a Daily Flight Record, authorized by an instructor, and acknowledged by the student. It's not enough to just write them in a pilot training record and call it a day.

I'm sure you can find examples where people did just that, and TC accepted their licence application. I don't believe this would survive an audit though. If a TC inspector were to ask to see the Daily Flight Records for these flights, they wouldn't exist.

Student has contacted TC for an opinion but has yet to hear back. So I throw it to you, avcanada hive mind. What do you say?
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Re: Commercial Solo Time Requirement

Post by C.W.E. »

If there is a matching entry in the aircraft journey logs then the flight is genuine.
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Re: Commercial Solo Time Requirement

Post by Aviatard »

C.W.E. wrote:
Sat Oct 05, 2019 7:03 am
If there is a matching entry in the aircraft journey logs then the flight is genuine.
Agreed. There isn't a question of whether the flight happened. The issue is whether it was properly authorized as a solo training flight.
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Re: Commercial Solo Time Requirement

Post by Big Pistons Forever »

I would suggest the main issue is around what would go in the PTR for those flights. As per the CAR’s the intent of the solo flights is for “the improvement of general flying skills”. So what did the student do that could be reasonably considered to have met the intent ?

Remember the CFI or his/her delegate has to certify each page of the PTR. If I were the CFI, I do not think I would want to do that for this individual based solely on what he said.

ps; good job on the CAR’s research !
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Re: Commercial Solo Time Requirement

Post by Beefitarian »

That's kind of scary. I suspect the guy was just ignorant of needing to get permission. I understand Aviatard being reluctant to just sign off since I would definately not want to anger TC or worse get a reputation as being willing to sign things off leading to future TC. Battles.

I hope he gets someone at TC that is in a good mood and co-operative. They might just be ok with it though I kind of doubt it.
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Re: Commercial Solo Time Requirement

Post by digits_ »

Hmmm good points, however:

- CARS 421.30(4)(a)(ii) does not specify who should supervise the solo time. For dual, a flight instructor rating is required. Who supervises the solo time? The solo time definition does not include the requirement for solo time to be supervised except for student pilot permit holders
- CARS 421.30(4)(a)(ii) requires flight training, not training flights. Flight training is not defined in the cars.

This leads me to believe that the instructor is not responsible to supervise solo flight time for the CPL. Just like ground school can be self study (with no proof other than the student's word), the solo flight time could be self study as well if you wish.

If those hours are flown outside of an FTU environment, a daily flight record requirement would not apply.
Just like, when a student starts at FTU A and continues at FTU B, FTU B has no requirement to log old flights at FTU A in its daily flight record.
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Re: Commercial Solo Time Requirement

Post by photofly »

The solo time is part of the flight training requirement for the CPL, and therefore needs to be supervised by an instructor. It cannot be done "freestyle". If done through an FTU it must be entered on the DFR. Either way TC requires that it must be included in a Pilot Training Record.

If the AP feels that the time being claimed by the applicant doesn't meet the requirements (for instance the solo time was not properly supervised) then they should contact their regional licensing officer for advice. TC may be more permissive than a strict interpretation of the rules appears to allow, and could permit an instructor to "adopt" the flights into a PTR after they've been made.

However once the flights are entered into a PTR, there is no requirement for an AP to undertake an investigation of how they were done. The AP is allowed to rely on the documents presented to them. The applicant is the person who formally guarantees they meet the requirements.

An authorized person cannot refuse to accept a licensing application: if the fee is paid, an application must be accepted. If an application doesn't meet the requirements then the minister may refuse to issue the Aviation Document under 6.71(1)(b) of the Aeronautics Act, and then has to send a formal notice of that decision under 6.71(2) of that Act. The decision is then appealable to the TATC under 6.72(1). In general the TATC gives considerable deference to the Minister's interpretation of his own regulations.
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Re: Commercial Solo Time Requirement

Post by digits_ »

photofly wrote:
Sat Oct 05, 2019 11:44 am
The solo time is part of the flight training requirement for the CPL, and therefore needs to be supervised by an instructor. It cannot be done "freestyle".
Not supervised does not automatically mean "freestyle". Which CARs would be violated if my student in his own airplane told me he flew his 300 NM last weekend because the weather was good. He shows me his logbook and all requirements check out. I have no reason to doubt him. He enters it in his PTR and I sign the page a couple of weeks later as well. Why would this not count?
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Re: Commercial Solo Time Requirement

Post by photofly »

I like to think it would count. A 300nm cross country is a 300nm cross country: if the student made a flight of that distance then the requirement is met.

But - the rule that would be violated, if you have to push the point, is that the flight wasn't completed under supervision. It was a 300nm cross country, but it wouldn't count as flight training. Compare it with the requirement for the Instrument Rating, which needs 50 hours of cross-country PIC. It's not training time, and can be done without referring to an instructor for supervision. This is different.

I think you could argue that the level of supervision required for the CPL solo time is quite small, given that the flights are done using only the privileges of a licence that the applicant already holds: the PPL. But the solo hours do have to emphasize the improvement of general flying skills. It is still "training time", not just PIC time. You can't ignore that. People are not permitted to train themselves for licences, they need an instructor.


You know what? Now I'm looking at the requirement and the way it's worded:

There's "35 hours dual instruction flight time, under the direction and supervision of the holder of a Flight Instructor Rating — Aeroplane," - and - "30 hours solo flight time including:". Not "30 hours solo flight time under the direction and supervision of..."

So now I'm not sure. I will make some enquiries...
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Re: Commercial Solo Time Requirement

Post by Kejidog »

Good day. I am sort of in the same situation. I bought my plane to acquire my PPL. having owned it for over 3 years now I am thinking of getting a commercial licence to move on perhaps to instructing in my spare/retirement time. I have over 350 hours of flying and am feeling that i want to more training.

I have made many trips 300 nm plus trips from home to Ontario and Quebec. I am wondering how and why 1 or another of these trips would not qualify? The flight was planned, executed, and logged by myself. And I even made it back home as well. I don’t see how having not been “signed off” by anyone on the ground really makes a difference in the eyes of transport. I even have a CloudAhoy track to prove it. Lol. I wouldn’t fudge my logs to pad hours as i am flying for fun and enjoyment. Especially my journey log as that is what all my maintenance is based on.

I have yet to talk to anyone about this but i have looked at the standards and believe i meet several already. Why couldn’t say a freelance instructor look at my logs and simply authorize them based on my tracking info , journey log and even photos taken along the route.
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Re: Commercial Solo Time Requirement

Post by digits_ »

photofly wrote:
Sat Oct 05, 2019 12:54 pm

You know what? Now I'm looking at the requirement and the way it's worded:

There's "35 hours dual instruction flight time, under the direction and supervision of the holder of a Flight Instructor Rating — Aeroplane," - and - "30 hours solo flight time including:". Not "30 hours solo flight time under the direction and supervision of..."
Yes that's one of the points I am trying to make.

The other is that the car definition of solo time specifically says that supervision is required for student pilot permit holders.
As far as I know, solo time is only required for a PPL license or CPL license. This strongly hints that supervision is not required for licensed pilots solo time.
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Re: Commercial Solo Time Requirement

Post by Beefitarian »

I have to say it would not surprise me in the least for TC to demand I do a specific 300nm trip. Never mind I have flown thousands of miles. "Sorry we want you to do one assigned by an instructor." Or who knows what.

I'd just suck it up and go but I don"t blame anyone with more patience trying to get them to accept a trip they already did. Since either you have successfully flown a 300nm trip or you have not. What possibly could be the justification for needing anyone to "supervise" it. You're out of radio range so how would it even be supervised?
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Re: Commercial Solo Time Requirement

Post by Aviatard »

Good points. Once again there is no argument that the flights were done. I don’t think this is someone who invented some bogus time and is trying to get away with it. The only question is whether they need a sign out by an instructor.

I noted the difference, as photofly points out, in the wording of the dual and solo time requirement. I’m having trouble figuring out how you can do flight training but not do a training flight as defined by 400.01: a solo practice flight that is conducted under the supervision of an instructor. It would be crystal clear if the CAR had the same wording for both dual and solo.
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Re: Commercial Solo Time Requirement

Post by digits_ »

Note that for a PPL, the requirements are to:
(a) An applicant shall have completed a minimum of 45 hours private pilot flight training in aeroplanes under the direction and supervision of the holder of a Flight Instructor Rating - Aeroplane. A maximum 5 of the 45 hours may be conducted on an approved aeroplane simulator or flight training device.
(amended 1998/09/01)
My emphasis

This supervision requirement is only specified for the dual part of the experience requirements for the CPL.

Note, that the full definition of solo time is:
solo flight time means, with respect to the flight time necessary to acquire a permit, licence or rating,

(a) in the case of a pilot, the flight time during which the pilot is the sole flight crew member, and

(b) in the case of a student pilot permit holder, the flight time during which the holder is the sole occupant of an aircraft while under the direction and supervision of the holder of an instructor rating for the appropriate category of aircraft; (temps de vol en solo)
PPL holders can accumulate solo flight time without supervision.

There are no requirements for training flights, nor any reference to training flights, so the definition in that case is irrelevant.
Training flights are mentioned in different parts of the CARS, usually in the case of "If training flights are happening, ....." or "no training flights are allowed, ...." which then means if dual flights or solo flights under supervision are happening, then certain rules get triggered.
That does not mean every flight training hour counts as a training flight.

A solo flight without supervision is not a training flight.
That does not mean a solo flight without supervision doesn't count towards flight training.
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Re: Commercial Solo Time Requirement

Post by photofly »

I’m afraid the answer lies with TC’s licensing officers, it’s not something that can be argued to a conclusion here.
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Re: Commercial Solo Time Requirement

Post by digits_ »

photofly wrote:
Sat Oct 05, 2019 4:15 pm
I’m afraid the answer lies with TC’s licensing officers, it’s not something that can be argued to a conclusion here.
Fair enough. From that point of view: how would they know if the solo flights were done under supervision of an instructor or just by the student themselves? If the instructor signs off the PTR because he deems the requirements to be met, nothing should prevent the student from getting his CPL.
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Re: Commercial Solo Time Requirement

Post by photofly »

Right. An Authorized Person (who acts for the Minister) is not required to investigate the paperwork: unless it’s facially flawed, it can be taken as accurate. The application for the licence is signed by the applicant who certifies they meet the requirements, on pain of being eaten by crocodiles, or some-such.
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Re: Commercial Solo Time Requirement

Post by Beefitarian »

Weird stuff just happens too often. Sometimes it depends who you talk to at a government office. They are just not 100% consistent.

Income tax is odd like that too. Some people write things off and others get told no way.

My opthamologist claims he has re-attatched retinas on several commercial pilots who brought forms from their company and had no issue. He sent a report to Transport for me and they said it was not good enough.
I don't know if all the other ones were through corporate offices and delt with in a different region or what? He just kept sending things for me until they eventually accepted it. Super frustrating.

Maybe all the other pilots with detatched retinas never told Transport, but I find that hard to believe.
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Re: Commercial Solo Time Requirement

Post by ShawnR »

There is another thread that touches on this somewhere here but here is my story. .

With regards to the CPL xcountry ...

I am working on my CPL. I have a few X-countries in my book but one in particular exceeds the requirement for the CPL. I asked at the local office if it counts and they told me yes but would not put it in writing. ..? But, in the meantime, I had emailed TC and they got back to me and said no, must be completed after you started your CPL training.
Then after this transpired, I was chatting with a pilot, older guy like me, who just completed his CPL and TC took his past x countries as acceptable.
So, it seems to be who at TC reads your application....
Can I do it again? Yes. Do I want to spend another $800 or more if I don't have to?.., no.

Frustrating. You (I) won''t know till you submit your application, I think.
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Re: Commercial Solo Time Requirement

Post by Beefitarian »

I am a really bad example for this specific thing though. I flew from coast to coast one year but that year was almost thirty years ago so I would just go do a new one.

Having said that, in my opinion, if a person flew 300 nautical miles within a year of applying it should just count, there should be no question.
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Re: Commercial Solo Time Requirement

Post by Aviatard »

Beefitarian wrote:
Sat Oct 05, 2019 3:22 pm
What possibly could be the justification for needing anyone to "supervise" it. You're out of radio range so how would it even be supervised?
Sorry Mr. Beef, I missed this post. Supervision doesn't mean you're listening on radio and monitoring every move the student is making. It's more about making sure the student has a reasonable plan for the flight, weather is appropriate for the trip and the like.
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Re: Commercial Solo Time Requirement

Post by photofly »

Here are some other ambiguities in the CPL cross-country requirements:

Can you break the journey overnight?
Can you break the journey up over several days, for weather?
Can you break the journey up over several days, for sightseeing?
Do the legs have to be consecutive flights in your logbook?
What if you have a mechanical defect - can you continue the trip in a different aircraft?
Or must you wait for the first one to be repaired?
Can you make other flights while waiting for the repair?
What if the repair takes a week - can you go home (or somewhere else) and then pick up the trip where you left off, or do you have to wait with the aircraft?
What if the repair takes six months? Can you still continue the flight?
If you decided to continue in a different aircraft, does it have to be the same type? Or even the same class?
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Re: Commercial Solo Time Requirement

Post by Bede »

photofly wrote:
Sat Oct 05, 2019 11:44 am
In general the TATC gives considerable deference to the Minister's interpretation of his own regulations.
No they don't. The TATC attempts to interpret to ensure consistency with it's prior decisions (stare decis doesn't technically apply, but for all intents and purposes). TC policies have no bearing on the decision making process.

Take a look at the Auld decision released recently.
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Re: Commercial Solo Time Requirement

Post by 7ECA »

Bede wrote:
Sun Oct 06, 2019 6:12 am
Take a look at the Auld decision released recently.
Gosh, isn't that a slap in the face for the TC inspectors...

Guess we'll be seeing a re-write of 602.01 pretty soon, darn shame it isn't the catch all it used to be.
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Re: Commercial Solo Time Requirement

Post by digits_ »

7ECA wrote:
Sun Oct 06, 2019 4:33 pm
Bede wrote:
Sun Oct 06, 2019 6:12 am
Take a look at the Auld decision released recently.
Gosh, isn't that a slap in the face for the TC inspectors...

Guess we'll be seeing a re-write of 602.01 pretty soon, darn shame it isn't the catch all it used to be.
They already did, it is now 602.01.1 :lol:
Application — Remotely Piloted Aircraft

602.01 This Subpart does not apply in respect of remotely piloted aircraft.

SOR/2019-11, s. 15

Previous Version
Reckless or Negligent Operation of Aircraft

602.01.1 No person shall operate an aircraft in such a reckless or negligent manner as to endanger or be likely to endanger the life or property of any person.

SOR/2019-11, s. 15
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