Commercial Solo Time Requirement

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Aviatard
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Re: Commercial Solo Time Requirement

Post by Aviatard »

Transport Canada has come back with an answer ...

*drumroll*

... it depends on whether the instructor who signs off the PTR is willing to accept these fights as legitimate entries. So, basically a non-answer.

Sigh.
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Re: Commercial Solo Time Requirement

Post by ahramin »

Photofly, as long as it meets the requirements in the CARs, I'd say yes to all. My flight involved backtracking, an aircraft swap, and 5 days in between legs and was accepted without question.
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digits_
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Re: Commercial Solo Time Requirement

Post by digits_ »

Aviatard wrote:
Wed Oct 09, 2019 4:46 am
Transport Canada has come back with an answer ...

*drumroll*

... it depends on whether the instructor who signs off the PTR is willing to accept these fights as legitimate entries. So, basically a non-answer.

Sigh.
? That's a crystal clear answer. Just like all the other training: it only counts if an instructor signs of your PTR.
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photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

All it does is move the question along the line: now the question is, is an instructor permitted to enter solo time that he/she didn't supervise into a PTR, for the CPL requirements? And we're no further forward.

I asked Licencing. They pushed me off to an Operations inspector, who told me that the solo time must be done with reference to an instructor. The intention is that the dual time with the instructor identifies what the student needs to work on, and the solo time is used by the student to bring their flying up to CPL standard.

There are lots of unanswered questions, but I"m going to stop asking them, in case I get answers I don't like.
ahramin wrote:
Wed Oct 09, 2019 11:09 am
Photofly, as long as it meets the requirements in the CARs, I'd say yes to all. My flight involved backtracking, an aircraft swap, and 5 days in between legs and was accepted without question.
I agree with you, but that is not the response given in evidence by a TC inspector at a tribunal hearing. That it was accepted "without question" is evidence more that nobody looked, than that they looked and approved.
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Re: Commercial Solo Time Requirement

Post by digits_ »

I'm curious, do you happen to recall which tribunal hearing that was? Would be nice to read the summary/decision.
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Re: Commercial Solo Time Requirement

Post by ShawnR »

Take a look at the Auld decision released recently.
Where can I find this? I googled variations but no luck. :oops:
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Re: Commercial Solo Time Requirement

Post by digits_ »

ShawnR wrote:
Thu Oct 10, 2019 6:03 am
Take a look at the Auld decision released recently.
Where can I find this? I googled variations but no luck. :oops:
https://decisions.tatc.gc.ca/tatc/tatc/ ... 2/index.do

There was a topic about this before. It's the one where a helicopter pilot landing at a restaurant gets written up by a new TC inspector "because he could have driven his car, just like everybody else" and the judge (is it a judge at this level?) gives the inspector a can of whoopass.
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As an AvCanada discussion grows longer:
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-one will be accused of using bad airmanship

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Re: Commercial Solo Time Requirement

Post by digits_ »

photofly wrote:
Wed Oct 09, 2019 5:27 pm
All it does is move the question along the line: now the question is, is an instructor permitted to enter solo time that he/she didn't supervise into a PTR, for the CPL requirements? And we're no further forward.
An instructor has to certify the candidate has followed XX hours of groundschool. In a case of self study, how do you know it actually happens? It's the same thing. There is no requirement defined to supervise self study of ground school, there is no requirement specified to supervise the solo CPL flight time.
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As an AvCanada discussion grows longer:
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photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

Self study has the same issue, if you ask me, and I'd want to see copious evidence of the self-study having been done to consider asking TC if it counted as groundschool. Overall, I don't think that helps.

Requirement to supervise solo CPL flight time: I can see myself making an exception for the cross country - after all, a cross country trip is hard to argue with. But A TC inspector says the TC intepreration is that there is a requirement to supervise, and that answer will have to be good enough, at least for me. You can take it up with the tribunal yourself, if it comes to it. I personally don't have any doubt, given the ambiguity, with whom the Tribunal will side.

Here is the decision about interpreting a cross country:
https://decisions.tatc.gc.ca/tatc/tatc/ ... 2/index.do

Here is the relevant comment:
Under cross-examination, Mr. Milligan said that there is no definition of "flight" in the Canadian Aviation Regulations (CARs) but stated his view that a flight, for the purposes of Standard 421.26(4)(b)(ii), has to take place in a single day. His view was that a cross-country flight should be a series of consecutive flights. Normally he would expect to see three legs flown on the same day, unless a person was going away on an extended trip. He said his interpretation was the industry standard.
Now in this case, the decision didn't really hinge on when you could break the trip, but on whether you could return to base in between the legs. Nor do I know what Mr. Milligan would understand by "an extended trip". But this is just evidence, that someone, somewhere, in TC will take a stricter view of things than we might like, and one would then have to fight for a re-interpretation.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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Re: Commercial Solo Time Requirement

Post by digits_ »

Thanks! Intersting read.
The decision did specify that a trip could be split over multiple days to wait out bad weather though.
It would be absurd to think that a pilot would not meet the standard if he or she chose to shut the engine down and stay awhile at one of his or her stopover points during a solo cross-country, or if he or she had to overnight at one of the stopover points due to unexpected bad weather, or chose to do an extended trip.
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As an AvCanada discussion grows longer:
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photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

Yes - that's what the Member said. But it's not what the Inspector said, and you're dealing in the first instance with the inspector.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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Re: Commercial Solo Time Requirement

Post by 5x5 »

I'm confused a bit - the decision posted related to a PPL cross country and wouldn't apply to a CPL. I agree that a PPL should, and I think in almost all cases does, happen in one day and certainly under supervision. A PPL student typically doesn't have the skill or experience to venture very far on their own.

A CPL on the other hand can happen over numerous days and frequently is part of a longer trip that covers much more than the 300 mile minimum. The whole idea is to gain experience and a CPL student should be able to manage the planning details of overnighting and in-flight weather and everything else involved with an extended trip. I've never seen or heard any kind of objection to this.
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photofly
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Re: Commercial Solo Time Requirement

Post by photofly »

I’m confident that somewhere there’s an inspector who doesn’t agree with you.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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Re: Commercial Solo Time Requirement

Post by Aviatard »

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.
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rotorspeed
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Re: Commercial Solo Time Requirement

Post by rotorspeed »

So if we assume the cross country is supervised, not really a big deal since you'll be doing trainng at the school. Is it possible to be finite about just pic building. I remember back in the day people would rent a plane for a period and fly to places like California from BC to build pic time. It would be hard for an instructor to supervise all that, plus if you had to do it at the school how would you do longer flights over days to build time
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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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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.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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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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 »

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.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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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:
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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.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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.
---------- ADS -----------
  
Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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