Commercial Solo Time Requirement

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digits_
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Re: Commercial Solo Time Requirement

Post by digits_ »

Aviatard wrote: Thu Oct 31, 2019 2:46 am Dredging this up again. I had a conversation with another TC inspector that I happened to run into. The answer: no, the time doesn't count unless it was authorized by an instructor. So, to sum up:

- the time counts
- it doesn't count
- it depends on whether you can get an instructor to sign off on the times
- it depends on who you ask

Rules are difficult.
Can you ask him for a reference to a CAR that requires that?
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photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

Unless you want to go to court over it, it's best to follow the Inspector's interpretation.
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digits_
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Re: Commercial Solo Time Requirement

Post by digits_ »

photofly wrote: Thu Oct 31, 2019 7:45 am Unless you want to go to court over it, it's best to follow the Inspector's interpretation.
Or apply at a different region. Or even the same region. Chances are that the inspector you spoke to is not the same inspector that would approve your application. If I had the time, I'd certainly try that before spending a few thousand dollars on unnecessary (re)training.
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photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

Inspectors don’t see or approve applications. An application is approved by a Authorized Person, on behalf of the Minister, and goes to the licensing officer at the TC regional office for examination. But the AP is the person with the responsibility to check the form is correctly completed, and it is on the Applicant’s honour - they sign the form - that the requirements are met.

You can lie through your teeth and claim as much solo time as you like, there’s no process to reject an application if the solo time was, or wasn’t, supervised.
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Aviatard
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Re: Commercial Solo Time Requirement

Post by Aviatard »

photofly wrote: Thu Oct 31, 2019 9:01 am But the AP is the person with the responsibility to check the form is correctly completed, and it is on the Applicant’s honour - they sign the form - that the requirements are met.
The AP is responsible for making sure that the requirements are met. It says so in the AP manual. So if you TELL me up front that you're not sure if some of your flights should count, then I'd look into that. That's how I got into this mess in the first place.
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digits_
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Re: Commercial Solo Time Requirement

Post by digits_ »

Aviatard wrote: Thu Oct 31, 2019 2:37 pm
photofly wrote: Thu Oct 31, 2019 9:01 am But the AP is the person with the responsibility to check the form is correctly completed, and it is on the Applicant’s honour - they sign the form - that the requirements are met.
The AP is responsible for making sure that the requirements are met. It says so in the AP manual. So if you TELL me up front that you're not sure if some of your flights should count, then I'd look into that. That's how I got into this mess in the first place.
In your case, why not just check if the instructor signed of the PTR? If so, you are in the clear.

Or do you happen to be the instructor as well?
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As an AvCanada discussion grows longer:
-the probability of 'entitlement' being mentioned, approaches 1
-one will be accused of using bad airmanship
photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

Right. But if the documentation is complete and consistent, you don't, for instance, have to start calling up the instructor whose name appears in the PTR and enquire about the circumstances of the dual flight.
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rotorspeed
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Re: Commercial Solo Time Requirement

Post by rotorspeed »

Does PTR have to show all pic flights or do they go by loGkbook again were talking the time building
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photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

The 65 hours of dual and solo have to be entered in a PTR.
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photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

Reading the CPL flight test guide, I see the recommendation for the CPL flight test requires an instructor to certify that “the above named candidate meets the minimum experience requirements of section 421.14 of the Personnel Licensing and Training Standards” so really this matter should have been settled prior to the flight test.
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Aviatard
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Re: Commercial Solo Time Requirement

Post by Aviatard »

digits_ wrote: Thu Oct 31, 2019 3:01 pm In your case, why not just check if the instructor signed of the PTR? If so, you are in the clear.

Or do you happen to be the instructor as well?
I'm not the instructor. The flights were done at another FTU. The flights weren't entered in the PTR, so there's no sign off by an instructor.
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Re: Commercial Solo Time Requirement

Post by AirFrame »

I self-studied my private groundschool, which was questioned by my FTU when I went to learn to fly. I told them I wasn't paying for a groundschool course when i'd already studied it myself and passed all the practise exams. They asked me some questions about some obscure things to see if I knew my stuff, and I did... So they signed off my approval for writing the written.

For solo time, since the intent is for the student to show development as a pilot, how about sitting down and talking to the pilot about the flying he/she has done? See what they've done, where they've been, ask them what they've learned along the way. If it's someone who has bought a Cessna 150 and only ever flies it 20 minutes away for a hamburger, except for that one trip >300mi once when they scared themselves silly in bad weather, then no, you probably don't want to sign that off. But if it's someone who has flown multiple aircraft types over the years, owns his/her own airplane now, and has done other "development" like learning tailwheel, aerobatics, formation, has pursued Instrument or Multi rating, has done multiple long trips cross country, etc. then yeah, they probably have learned quite a bit in that time, and they're likely a better candidate than someone who has been confined to an FTU for 25 solo hours and the FTU's "standard" cross country route that everyone does.

What's the end goal? Better pilots? Or people who are better at checking off items on a list?
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Oh_Matron
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Re: Commercial Solo Time Requirement

Post by Oh_Matron »

A friend of mine had a issue with an AP not signing him off for his CPL. This reply isn't really regarding the X-country, rather how an AP can refuse to sign something, even when the person has records to prove they meet the standard.

He started his PPL at FTU-A, but moved to FTU-B, where he spent a good chunk of change and got his PPL.
He rented a few times after getting the PPL, so people knew him there.

He then had an opportunity to go with a freelance instructor, and he built his hours up and met all standards and was signed off by his instructor.
All happy, with records in hand, he went to the AP of FTU-B and asked them to review his paperwork and sign him off.
The AP refused because my friend didn't use FTU-B to do the training! My friend had all the records and the instructor would have met the AP to prove that he had met the requirements. The AP still refused.
Thankfully, my friend went to FTU-A, who charged him a small fee, but signed him off with no issue.

An AP seems to have a lot of power in these circumstances
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ahramin
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Re: Commercial Solo Time Requirement

Post by ahramin »

Can't you just submit the whole package to TC without having it signed by an AP? Unless you are in a hurry to get the licence right away, is there a need to go through an AP?
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CpnCrunch
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Re: Commercial Solo Time Requirement

Post by CpnCrunch »

ahramin wrote: Fri Nov 15, 2019 5:15 pm Can't you just submit the whole package to TC without having it signed by an AP? Unless you are in a hurry to get the licence right away, is there a need to go through an AP?
Yes, that's what I did for mine, as I used a freelance instructor for most of it. I used an FTU for some of the training, and their AP was happy to sign me off. However, upon reviewing my file he said he couldn't sign off because one of my landings was a T&G and their SOPs for the CPL x/c say they have to be full stop. My interpretation of the CARs was that it didn't matter, and I sent it off to TC without it being signed by an AP, and it was all fine.

Note that you do still need each page of your PTR signed off. I don't think TC will give you your license if you don't get that done.
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photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

CpnCrunch wrote: Fri Nov 15, 2019 5:24 pm However, upon reviewing my file he said he couldn't sign off because one of my landings was a T&G and their SOPs for the CPL x/c say they have to be full stop. My interpretation of the CARs was that it didn't matter, and I sent it off to TC without it being signed by an AP, and it was all fine.
You should remind the AP that they act on behalf of the Minister, not on behalf of any particular flight school.

The CPL X-C requirements do not include full-stop landings, and the FTU SOPs are irrelevant. Your AP should know this. I would have written a letter to the licensing officer at the regional office in question asking him or her to clarify the requirements for the AP's benefit.
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photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

AirFrame wrote: Fri Nov 01, 2019 6:54 am What's the end goal? Better pilots? Or people who are better at checking off items on a list?
The end goal is people who meet the requirements listed in the regulations; there's no other fair way of doing it.
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Re: Commercial Solo Time Requirement

Post by OldInstructor »

Although I can not provide any current information I have a great deal of experience reviewing applications and making determinations on what solo was acceptable. The standards to not provide guidance for each circumstance. An applicant who holds a private pilot licence with an instrument rating with endorsements on numerous high performance singles and twins with more then a 1000 logged hours much of it on long cross country flights out of the country need not fly additional hours under an instructors supervision. The PTR starts when the individual decides they want the commercial licence. Training received prior to that point for other purposes need not be entered. The application would require the PTR and the pilots logbook to confirm the commercial requirements have been met. I also found that in cases such as this the applicant did require some solo practise. Steep turns and forced approaches come to mind immediately.
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