ATPL Time Rejected??

[Turbine dog]

Thanks for the replies! I haven't actually submitted my application yet. The thread title may be a bit misleading lol. I tried to catch audience attention. The thing is...I have literally the exact mins in every category, and just want to get an idea if I have missed anything, or potentially logged something incorrectly. I want to make sure this goes smoothly and I have no issues. It has also been interesting hearing why other pilot's ATPL applications were rejected lol.

[feel-x]

What do you mean "logged the rest of them properly"?
If I file vfr, I'm logging vfr. If I file ifr, I'm logging instrument time. The weather on that particular day is almost irrelevant to the flight rules being operated under. You can file ifr on a day without a cloud in the sky...it's still instrument flying, still instrument time.

Unfortunately (also) that's not how instrument time is defined in the CARs. I don't see any ambiguity or "grey area" about it.

The regulation about what you're supposed to record in your logbook says "whether VFR or IFR". So far, so good. But the licensing requirements are for a certain amount of "instrument time", which isn't the same thing at all.

A PPL requires "5 hours of instrument time". Nobody will argue that if the instructor files an IFR flight plan and the student flies for 5 hours in clear air that this requirement has been met. I cannot fathom why anyone thinks the ATPL requirement for "75 hours instrument flight time" can be satisfied that way either.

What the CARS say:

DIVISION VIII - AIRLINE TRANSPORT PILOT LICENCE
421.34 Aeroplanes - Requirements
(4) Experience
d) 75 hours instrument flight time of which a maximum of 25 hours may have been acquired in approved instrument ground trainers and a maximum of 35 hours may have been acquired in helicopters. Instrument ground time shall not be applied toward the total 1500 hour flight time requirement.

Subpart 1 — Interpretation

Interpretation

101.01 (1) In these Regulations,
instrument time means

(a) instrument ground time,

(b) actual instrument flight time, or

(c) simulated instrument flight time; (temps aux instruments)

Both simulated or actual are instrument flight time

IFR flight means a flight conducted in accordance with the instrument flight rules; (vol IFR)

IMC or instrument meteorological conditions means meteorological conditions less than the minima specified in Division VI of Subpart 2 of Part VI for visual meteorological conditions, expressed in terms of visibility and distance from cloud; (IMC ou conditions météorologiques de vol aux instruments)

there is no place in the CARs that says instrument flight time must be in IMC condition, it's their definition, not mine,
and on a personnal note, try flying without your instruments on an IFR flight plan, specially in the flight levels.... the ATC won't like you.....

[goingnowherefast]

Bombing around in CAVU on a IFR flight plan does not build the skill, compared to flying hard IMC.

Makes little to no difference... Autopirate on, push some buttons, who cares if you can't see out side.

Most pre-ATPL jobs are flying planes that don't have an autopilot. A 4 hour day with 5 approaches in solid IMC is much easier with a autopilot.

[digits_]

Thanks for the replies! I haven't actually submitted my application yet. The thread title may be a bit misleading lol. I tried to catch audience attention. The thing is...I have literally the exact mins in every category, and just want to get an idea if I have missed anything, or potentially logged something incorrectly. I want to make sure this goes smoothly and I have no issues. It has also been interesting hearing why other pilot's ATPL applications were rejected lol.

If you are sure everything is correct, just go for it. If you do need an hour here or there to make them happy, they'll give you a chance to correct it (even though technically I don't think they have to).

[Redneck_pilot86]

What do you mean "logged the rest of them properly"?
If I file vfr, I'm logging vfr. If I file ifr, I'm logging instrument time. The weather on that particular day is almost irrelevant to the flight rules being operated under. You can file ifr on a day without a cloud in the sky...it's still instrument flying, still instrument time.

Unfortunately (also) that's not how instrument time is defined in the CARs. I don't see any ambiguity or "grey area" about it.

The regulation about what you're supposed to record in your logbook says "whether VFR or IFR". So far, so good. But the licensing requirements are for a certain amount of "instrument time", which isn't the same thing at all.

A PPL requires "5 hours of instrument time". Nobody will argue that if the instructor files an IFR flight plan and the student flies for 5 hours in clear air that this requirement has been met. I cannot fathom why anyone thinks the ATPL requirement for "75 hours instrument flight time" can be satisfied that way either.

What the CARS say:

DIVISION VIII - AIRLINE TRANSPORT PILOT LICENCE
421.34 Aeroplanes - Requirements
(4) Experience
d) 75 hours instrument flight time of which a maximum of 25 hours may have been acquired in approved instrument ground trainers and a maximum of 35 hours may have been acquired in helicopters. Instrument ground time shall not be applied toward the total 1500 hour flight time requirement.

Subpart 1 — Interpretation

Interpretation

101.01 (1) In these Regulations,
instrument time means

(a) instrument ground time,

(b) actual instrument flight time, or

(c) simulated instrument flight time; (temps aux instruments)

Both simulated or actual are instrument flight time

IFR flight means a flight conducted in accordance with the instrument flight rules; (vol IFR)

IMC or instrument meteorological conditions means meteorological conditions less than the minima specified in Division VI of Subpart 2 of Part VI for visual meteorological conditions, expressed in terms of visibility and distance from cloud; (IMC ou conditions météorologiques de vol aux instruments)

there is no place in the CARs that says instrument flight time must be in IMC condition, it's their definition, not mine,
and on a personnal note, try flying without your instruments on an IFR flight plan, specially in the flight levels.... the ATC won't like you.....

It doesnt seem like much of a gray area to me. Navigating on radials, shooting simulated approaches, etc is all still instrument time. I don't see how some people are coming up with other interpretations. How would anyone verify if you were in a cloud or not on a flight a year ago? Should I be video recording every flight, or sitting with a stopwatch to count when I am in cloud and when I am not?

[photofly]

"Simulated instrument flight time" means wearing a hood or other view-limiting device. You simulate instrument conditions by wearing one.

The idea that "navigating on radials" time counts for anything is hilarious. Can I credit "pressing direct on the GPS while severe VFR" towards my PPL instrument time too? I don't think so.

Why should whether anyone can verify your instrument time be relevant? The presumption is that pilots are honest about their experience.

[JBI]

Woah, don't shoot the messenger! I was only passing on what licensing officers had mentioned to me. If all of your IFR flights have the same amount of instrument time as flight time in the log book, I think that there will be issues in getting your ATPL processed.

I don't have an opinion on what TC's interpretation should be - just what I was told on how it is. Now that the ATPL is signed off, I don't need to worry about it. Just trying to help out.

[feel-x]

"Simulated instrument flight time" means wearing a hood or other view-limiting device. You simulate instrument conditions by wearing one.

The idea that "navigating on radials" time counts for anything is hilarious. Can I credit "pressing direct on the GPS while severe VFR" towards my PPL instrument time too? I don't think so.

Why should whether anyone can verify your instrument time be relevant? The presumption is that pilots are honest about their experience.

I can see what you are saying, but unfortunatly TC is a paperwork hell, and in legislation, it's not what you or the other guy believes, but it's what is actually written in the law that matter... I checked everywhere but I didn't find any definition of simulated...
Again, when you file IFR you should fly IFR, no matter what is the weather, no matter if the controller give you some hold or a direct destination, you must fly looking at your instrument, if you want to fly VFR you file VFR.... I know some TC guy may be painful, but if you really want to loose your time, i'm pretty sure that their believes doesn't worth a lot in front of a judge, but black ink on white paper signed by the "queen" may be a better source....

[photofly]

Woah, don't shoot the messenger!

I'm not. I agree with your interpretation, that "75 hours hood and cloud time" is what is required, not "75 hours instrument flight plan time". From what has been written in this thread, TC does too.

Again, when you file IFR you should fly IFR, no matter what is the weather, no matter if the controller give you some hold or a direct destination, you must fly looking at your instrument

I hope you don't mean that. If you filed IFR and you're in VMC in classes C to G, you had bloody well be looking out the window for VFR traffic.

[feel-x]

I hope you don't mean that. If you filed IFR and you're in VMC in classes C to G, you had bloody well be looking out the window for VFR traffic.

you are right! it is still PIC responsability to avoid VFR traffic, but you still cannot do like that guy doing a scenic tour on IFR, just because it was VMC.... and for traffic some pilot might be the old school see and avoid type, but radios and tcas (or soon to be ads-b... I hope) can give you some info... even VFR you might be suprise by a last minute traffic that fly in some weird altitudes... but usually, when you are controlled, ATC will have you and traffic around on radar, Usually... If you are uncontrolled, get your timer if you want, I will estimate the time!

[AuxBatOn]

I am starting to understand why we need such expansive, detailed rules and regulations...

You need to look at the intent of the rule. In this case, the 75 hours is to make sure you had enough experience in your career so far to fly on the dials without outside visual cues (so you don't kill yourself and your 16 passengers and cree members when you actually have to do it). When you are on an IFR flight plan, at 28,000 ft, you still have those cues that help you make sense of the instruments (even if you don't directly look outside). This is NOT the intent of the rules to log these hours towards the ATPL.

The rules themselve may not be explicit on the requirements for simulated instrument time but they sure are implicit: look at the definition of safety pilot.

[CubanCloudRider]

Thanks for the replies! I haven't actually submitted my application yet. The thread title may be a bit misleading lol. I tried to catch audience attention. The thing is...I have literally the exact mins in every category, and just want to get an idea if I have missed anything, or potentially logged something incorrectly. I want to make sure this goes smoothly and I have no issues. It has also been interesting hearing why other pilot's ATPL applications were rejected lol.

if you have PICUS, make sure you logged it in the PIC column and you have a sheet with all the information tc needs. If you logged the picus time in the copilot column, then 1503 is not adequate as the picus time is 50% of copilot time. So you would have to log more time, depending on how much picus you want to claim towards the allowed 100. Say your logbook shows 1503, and you want to claim 50hrs pic using picus, that means you flew 100hrs as copilot to count as 50hrs picus. If you logged these under the copilot column then you will be 50hrs short of your 1500 total time required, so you'd have to wait until your logbook says 1553 total time. I hope that makes sense.
Good luck.

[Panama Jack]

RE: "Instrument time"

I find some of interpretation of "Instrument flight time" by some members to be show a lack of understanding of the bigger picture of how Transport Canada works and the requirements for holding an ATP.

I do agree that the CAR's could do a much better job at making the requirements clearer. Out of the haze comes some of the self-serving interpretations and unintentional errors which one or two of you have also made.

As a member state of ICAO, Canada has a mandate to implement commonly-agreed upon practices and rules. These are contained in the ICAO Standards and Recommended Practices (SARPS) which are grouped in different Annexes. Annex 1- Personnel Licensing, establishes a common standard for Student Pilot, Private Pilot, Commercial Pilot, Multi-Crew Pilot, Airline Transport Pilot, Glider Pilot and Balloon Pilot licenses as well as Instrument and Instructor Ratings. Whether you apply for a licence in Canada, the United States, Peru, Germany, Kenya or Thailand you will quickly notice that there is a common age, knowledge, experience, and medical fitness requirement amongst all of these countries, despite their different cultural backgrounds. The reason is that their national regulations closely mirror the SARPS.

In the case of an Airline Transport Pilot Licence, and more specifically, the "instrument time requirement", Annex 1 states:

2.6.3.1 Experience
2.6.3.1.1 The applicant shall have completed not less than 1 500 hours of flight time as a pilot of aeroplanes. The
Licensing Authority shall determine whether experience as a pilot under instruction in a flight simulation training device is
acceptable as part of the total flight time of 1 500 hours. Credit for such experience shall be limited to a maximum of 100 hours, of which not more than 25 hours shall have been acquired in a flight procedure trainer or a basic instrument flight trainer.

2.6.3.1.1.1 The applicant shall have completed in aeroplanes not less than:
a) 500 hours as pilot-in-command under supervision or 250 hours, either as pilot-in-command, or made up by not less
than 70 hours as pilot-in-command and the necessary additional flight time as pilot-in-command under supervision;
b) 200 hours of cross-country flight time, of which not less than 100 hours shall be as pilot-in-command or as
pilot-in-command under supervision;
c) 75 hours of instrument time, of which not more than 30 hours may be instrument ground time; and
d) 100 hours of night flight as pilot-in-command or as co-pilot.

This 75 hours of instrument time looks identical to what the CARs require of ATP applicants. But what exactly is it?

When we look at the Definitions section of ICAO Annex 1, we find the following for "instrument time":

Instrument time- Instrument flight time or instrument ground time.

It goes further to explain:

Instrument flight time- Time during which a pilot is piloting an aircraft solely by reference to instruments and without external reference points.
Instrument ground time- Time during which a pilot is practising, on the ground, simulated instrument flight in a flight
simulation training device approved by the Licensing Authority.

Some of you may have also noticed that Transport Canada and the Federal Aviation Administration have been trying to harmonize regulations, which makes sense for a lot of reasons. Many Canadian pilots also get their FAA Certificate based on the IPL agreement that greatly simplifies conversions.

In the United States, §61.159 Aeronautical experience: Airplane category rating states that you must have:

(4) 75 hours of instrument flight time, in actual or simulated instrument conditions, subject to the following:

(i) Except as provided in paragraph (a)(4)(ii) of this section, an applicant may not receive credit for more than a total of 25 hours of simulated instrument time in a flight simulator or flight training device.

(ii) A maximum of 50 hours of training in a flight simulator or flight training device may be credited toward the instrument flight time requirements of paragraph (a)(4) of this section if the training was accomplished in a course conducted by a training center certificated under part 142 of this chapter.

(iii) Training in a flight simulator or flight training device must be accomplished in a flight simulator or flight training device, representing an airplane.

Again, very similar to the Canadian requirement and in reflection of ICAO Annex 1. However, not that they specify "instrument conditions." Instrument conditions usually means "Instrument Meteorological Conditions" vs. "Visual Meteorological Conditions." It has nothing to do with the Flight Rules (VFR, CVFR, SVFR, or IFR) that you are operating under. It is common practice for the airlines to operate exclusively under Instrument Flight Rules (IFR) however, that does not mean that they don't spend a substantial amount of time operating in Visual Meteorological Conditions (VMC). In fact, the regulations require pilots to keep a look-out for traffic avoidance when operating an IFR in VMC, and even make provisions for a visual approach when on an IFR flight plan in VMC.

Clear enough? Hopefully this will help you understand the mindset of Transport Canada. I can also tell that, at least outside of Canada, many prospective employers frown when they see that the amount of Instrument Time is pretty close to your Total Time. I am an >10,000 hour pilot, currently working scheduled airline and Low Visibility Procedure- LVP (up to Cat IIIB qualified) and yet my total "Instrument Time" between "Actual IMC" (that is the way the column states it in my VIP Pilot Centre logbook) and "Hood" time is less than 7% of my Total Time. Mind you, I don't see much point in precisely logging Instrument time anymore, but they days which I do, it tends to typically be not more than 0.2 or 0.3 as we go up or down through a layer or shoot an IFR approach in the soup. Try not to get too creative on interpreting the ways to log time, lest your credibility gets questioned.

Now, I am not sure that you would want to argue a case to Transport Canada that you have plenty of time operating under Visual Flight Rules, in IMC conditions (under sole reference to instruments). It would be interesting and be sure to post your experiences here on AvCanada!

[Redneck_pilot86]

"Simulated instrument flight time" means wearing a hood or other view-limiting device. You simulate instrument conditions by wearing one.

The idea that "navigating on radials" time counts for anything is hilarious. Can I credit "pressing direct on the GPS while severe VFR" towards my PPL instrument time too? I don't think so.

Why should whether anyone can verify your instrument time be relevant? The presumption is that pilots are honest about their experience.

Of course it counts. If you are being trained in how to navigate on a radial, while wearing a hood, it is instrument time. I don't mean just flying along, but dedicated training is absolutely Instrument time. That is what the bulk of my instrument flying training entailed for my PPL. Maybe you were born knowing how to intercept a radial, but the majority of us were taught. Just because it is essentially a useless skill for the modern magenta-line pilots, doesn't mean it isn't instrument flying.

[photofly]

Of course it counts. If you are being trained in how to navigate on a radial, while wearing a hood, it is instrument time.

That is not in dispute. But It's the fact that you're wearing a hood that makes it count towards the instrument flight requirements, not, as was suggested, the fact that you're following following a radial, nor the fact that you're receiving training in a skill whether that be useful for flying or otherwise.

Frankly you could be juggling bean bags or playing the flute in the cockpit and it would count towards your instrument flight time requirements, just as long as you were wearing a hood at the time.

[ragbagflyer]

Transport took issue with my lack of route information; they didn't reject my application and make me reapply, but I did have to add more information to my logs. Truth be told I wasn't even aware of CAR 401.01, that requires personal logs to list the point of departure, destination, and all intermediate stops. However that isn't practical over thousands of hours of float flying, and a lot of those stops along the way don't even have names. They were satisfied with me adding all the route info for all the recent IFR flying I'd done, and were civil about the whole thing. Helicopters are exempt from having to enter all the stops between departure and destination but apparently aeroplanes are not.

My advice to the float/bush pilots would just be to list departure and destination and state "multiple stops" in the remarks section if there's more then 4 or 5 stops. It did take them about 12 weeks to come back and say they wanted more info which was a little annoying, but once I sent back my log books with the additional info it was processed almost immediately.

For the info of all...

Personal Logs
401.08 (1) Every applicant for, and every holder of, a flight crew permit, licence or rating shall maintain a personal log in accordance with subsection (2) and with the personnel licensing standards for the documentation of
(a) experience acquired in respect of the issuance of the flight crew permit, licence or rating; and
(b) recency.
(2) A personal log that is maintained for the purposes referred to in paragraphs (1)(a) and (b) shall contain the holder’s name and the following information in respect of each flight:
(a) the date of the flight;
(b) the type of aircraft and its registration mark;
(c) the flight crew position in which the holder acted;
(d) the flight conditions with respect to day, night, VFR and IFR;
(e) in the case of a flight in an aeroplane or helicopter, the place of departure and the place of arrival;
(f) in the case of a flight in an aeroplane, all of the intermediate take-offs and landings;
(g) the flight time;
(h) in the case of a flight in a glider, the method of launch used for the flight; and
(i) in the case of a flight in a balloon, the method of inflation used for the flight.

[JeppsOnFire]

Redneck pilot:

As others have repeatedly stated - the intent is 'without external reference'.

Why is it different. Let me say this: I have done enormous amounts of line training. The common factor I see is when the weather is down, the trainees often keep that auto pilot on until 200 feet/runway visual. When the weather is good, they'll hand fly the last 10 miles to touchdown.

Now stop and think, both are flights are on IFR flight plans. Why the difference in operating procedures if it doesn't matter if weather it's IFR or VFR out the window?

[Gear Jerker]

On another note...

I've recently heard of an issue which I didn't think was an issue.

Company A: Navajo, flown mostly 2 crew, FO has a PCC, logs copilot time. Counts toward ATPL total time?

Company B: Navajo, flown mostly single pilot, all pilots have single pilot and multi crew PPC's, but the odd time fly 2 crew. Copilot time counts toward ATPL total time?

I wasn't aware of any rules here... when a company has multi crew SOP's and a COM, both of which are approved by TC, if an operational flight is conducted multi crew with both crew members appropriately licensed/trained, then whether or not an aircraft is designated single pilot in its type certificate is irrelevant, yes?

[lownslow]

Gear Jerker, you are correct. So long as two crew operation is approved there is just a letter TC will ask for from your CP or delegate.

[Gear Jerker]

Thanks lownslow!

Will it depend on the case/licensing officer, or is it a requirement that they have this letter?