Page 1 of 2

If only the rules were changed.

Posted: Sun Aug 19, 2007 6:41 pm
by Cat Driver
I am looking at buying a new Husky on Whipline Amphib floats for a friend.

Would love to do float ratings on it but because of the idiotic requirement of five solo take offs and landings for the rating I can't even think of paying the extra insurance penalty that would be required.

So it will stay private registered and I won't be able to use it for float ratings.

Why do they require five take offs and landings solo?

There is no solo for the multi engine rating or for the IFR rating.

Posted: Sun Aug 19, 2007 9:45 pm
by . .
i guess you already know how to take off and land from runways for the ifr and multi.

Posted: Mon Aug 20, 2007 8:11 am
by Cat Driver
i guess you already know how to take off and land from runways for the ifr and multi.
Using that logic wherein a check ride is required to determine that the candadate has demonstrated to a designated flight test examiner that the person meets the minimum skills level to safely operate the airlpane before being allowed to solo, why not require the same for the float rating?

Changing the requirement from five solo take offs and landings to an independant check ride before solo does not degrade safety, it enhances safety.

And the financial savings on the insurance policy to the school is signifigant.

For instance using the Husky as an example I can get hull insurance for 4% of hull value.

To insure the same airplane for solo flight during training the cost rises to 10% of hull value.

That is a difference of $15,000.00 per year.

How many float plane ratings would I have to do to make enough profit after operating expenses to pay that $15,000.00 before I even break even?

Remember, it is the schools their instructors and the students who are forced to pay for this added insurance cost.

Please convince me that this is a well thought out policy by TC aided and abbetted by ATAC.

The truth is all those salaried people in TC and ADAC are not in the least affected by their policies that in cases such as this serve no useful purpose safety wise.

Posted: Mon Aug 20, 2007 8:22 am
by Lurch
Shoot Cat does this mean you won't be doing float ratings?

I have been saving my pennies for the spring :cry:

Lurch

Posted: Mon Aug 20, 2007 9:10 am
by Cat Driver
Shoot Cat does this mean you won't be doing float ratings?
I can not see how I could justify insuring the airplane for flight training under a FTU OC.

Posted: Mon Aug 20, 2007 11:14 am
by twotterflogger
I feel your pain, and frustrations Cat.

Long before I left for the dark Continent I toyed with the idea of using my 180 to give out float ratings...
A few years ago, I figured that I needed some multi time, and some friends decided to take the bait, and the trade was ''15 hours in my 180 on floats with myself as an instructor all at my expense, for 15 hours on your twin (solo, as I met the insurers minimum reqs) at their expense'') Worked out great, except that PSA wanted to limit my coverage to liability only for the 5 solo circuits needed to meet TC antiquated regulations.
There was no way that I could justify the potential liability resulting in the lost of my bird.

I've been writing to TC for the last 2 years about reviewing it's policy on supervised solo's for the seaplane endorsement. I fully understand the insurance company's fears.
Let's face it, 7 hours of dual in ANY seaplane is a joke. There's no way you could even come close to mastering docking in 7 hours, let alone, teach the very basics of glassy water landings, cross-wind landings, operational concerns, survival skills etc, etc...

Would you feel comfortable sending out someone with only 7 hours of dual with you solo? I have a feeling that your line of thought is similar to mine.... ''Only ready for solo when I think your ready, and if it takes 30 hours of dual with me, than ''tough shit'' kind of thing''
However despite that kind of responsible attitude, the insurers wouldn't change their stance....
I'd be happy to send you my correspondences with our Honourable Mr Preuss about this issue, but I think I burnt them in a drunken fit of anger. :evil:

Posted: Mon Aug 20, 2007 11:29 am
by Cat Driver
I'd be happy to send you my correspondences with our Honourable Mr Preuss about this issue, but I think I burnt them in a drunken fit of anger.
If you can find them I would like to read them.

I could accept the fact that Preuss is just another political animal lacking in any identifiable understanding of how to manage anything, much less civil aviation, it is his lack of a moral compass and his distain for the rule of law that gets me frustrated....

.....and to make it even worse is the fact that Harper and Cannon are either ignorant of how morally corrupt Preuss is or they do not have the power to remove him.....maybe Preuss has something on them that they do not want made public???

Anyhow this stupidity in their policies is just one more indication of how badly managed aviation really is under the present regime in Ottawa.

I also have no sympathy for the FTU owners, because they get the regulation they are content to accept.

Posted: Mon Aug 20, 2007 11:57 am
by Doc
My good Cat, this may be an issue for the insurance companies to take up with Transport Canada. It would make a lot of sense coming from them, as it (a float accident with a student pilot) would represent a very large loss for them....that and there is, as you pointed out, there is no reason for the requirement....and no sweat off their asses to change it?

Posted: Mon Aug 20, 2007 12:35 pm
by Cat Driver
that and there is, as you pointed out, there is no reason for the requirement....and no sweat off their asses to change it?
The problem with getting any changes made by transport Doc is inertia on the part of TC.


Dictionary.com Unabridged (v 1.1) - Cite This Source
in·er·tia /ɪnˈɜrʃə, ɪˈnɜr-/ Pronunciation Key - Show Spelled Pronunciation[in-ur-shuh, i-nur-] Pronunciation Key - Show IPA Pronunciation
–noun 1. inertness, esp. with regard to effort, motion, action, and the like; inactivity; sluggishness.
2. Physics. a. the property of matter by which it retains its state of rest or its velocity along a straight line so long as it is not acted upon by an external force.
b. an analogous property of a force:
The decision makers at TCCA have no intrest other than protecting the status quo, they not only do not care about their client ( the working sector of commercial aviation. ) they have no real understanding of the meaning of accountability except to their own insular world.

It is almost impossible to get them to change anything, why should they it does not benefit them.

The only way to deal with these issues if find ways to circumvent them and get things done outside of their jurisdiction.....or be like them and just hold the law in contempt and do what ever it takes to attain your own goals.

Re: If only the rules were changed.

Posted: Tue Aug 21, 2007 10:29 pm
by good_idea
[quote="Cat Driver"]I am looking at buying a new Husky on Whipline Amphib floats for a friend.


There is no solo for the multi engine rating or for the IFR rating.

There is a flight test for the multi and IFR.

Solo time ... lol I guess. No flight test for the floats. Same rule applies to night ratings... the student needs at least 10 take offs in the 5 solo hrs required

Posted: Wed Aug 22, 2007 7:41 am
by Cat Driver
So with that comment good-idea can you give me a reasonable argument to support solo T.O.&L's for the float rating that would be more important than an independent check ride?

Or is it better to keep the solo T.O.&L's so people like me are unable to teach float ratings due to the insurance cost?

I guess it is better to have flight instructors who in many cases dont know jack shit about float flying teaching because they are blessed by TC?

Posted: Wed Aug 22, 2007 8:55 am
by Big Pistons Forever
You have to pass a flight test with a designated examiner in the USA for the issue of a float rating. This seems like a reasonable solution as most insurance policies have a clause that provides coverage for flight tests.

BTW a friend of mine tried to get a float rating from a friend in his airplane. The owner signed off the aplication for a rating form including the 5 solo TO and landings eventhough he was always in the airplane. The fed enforcement guys tried to play both pilots against
each other.

To my friend they said rat on the airplane owner for fraudulently attesting to solo time on the recommend form and they will not go after him for flying an airplane as PIC without liability insurance ( i.e. during the "solo" portion of his float training). At the same time they went after the aircraft owner to flip on the student, promising each no enforcement action if the
flipped on the other. It was not a pretty scene and they were playing hardball, so I would caution anyone to be very carefull about doing float training without a actual solo portion.

Posted: Wed Aug 22, 2007 9:34 am
by Hedley
One must wonder about the motivation of Transport to brutally enforce such an arbitrary regulation of nebulous value.

Perhaps if Transport feels that the solo takeoffs and landings are that vitally important to the "public interest", they could reasonably step up to the plate and offer subsidized hull and liability insurance for operators for this?

Posted: Wed Aug 22, 2007 12:48 pm
by good_idea
Cat Driver wrote:So with that comment good-idea can you give me a reasonable argument to support solo T.O.&L's for the float rating that would be more important than an independent check ride?

Or is it better to keep the solo T.O.&L's so people like me are unable to teach float ratings due to the insurance cost?

I guess it is better to have flight instructors who in many cases dont know jack shit about float flying teaching because they are blessed by TC?
Just having an instructor rating doesn't allow you to endorse someone for floats; 50hrs on floats as well is required.

Catdrinver, I think your frustration is misplaced... you should be frustrated by the insurance companies that don't understand jack shit about flying. You are teaching someone floats and then obviously trust there capabilities enough to take YOUR airplane solo. In my books for an individual to trust someone with their own personal property is pretty serious. To this day other than my brother no one has ever sat in the drivers seat of even my car.

Getting back to the TC requirements. I don't see why 5 solo TO&LD is a bad idea. After a new pilot solos, their first couple of hours are spent in the circut just solidifying the TO and Landing for the future

Posted: Wed Aug 22, 2007 2:43 pm
by Cat Driver
Catdrinver, I think your frustration is misplaced... you should be frustrated by the insurance companies that don't understand jack shit about flying.

Well good-idea I work with the underwriters for the express purpose of limiting risk by setting up training standards that results in lower premiums....the insurance adjusters may not know how to fly but risk assesment is how they make money.
Getting back to the TC requirements. I don't see why 5 solo TO&LD is a bad idea
You are entiteled to your own opinion, however from my perspective the cost of insuring low hour pilots in float planes should be born by the pilot sector after they pass a check ride, not the people doing the training.

Can you deny that an independent check ride to determine that the candidate meets the test standards for the issuance of a float plane rating trumps allowing five solo take offs and landings?
Just having an instructor rating doesn't allow you to endorse someone for floats; 50hrs on floats as well is required.
Having 50 hours of float flying is a joke as far as being sufficient experience to teach float flying.

But hey, that is your government bureaucrats setting out the standards so I guess you Canadian pilots get what you deserve.

Posted: Wed Aug 22, 2007 4:11 pm
by Cat Driver
You have to pass a flight test with a designated examiner in the USA for the issue of a float rating. This seems like a reasonable solution as most insurance policies have a clause that provides coverage for flight tests.


The training industry would be better served in Canada if the same requirement was put in place and the five solo take offs and landings dropped as a requirement.
BTW a friend of mine tried to get a float rating from a friend in his airplane. The owner signed off the application for a rating form including the 5 solo TO and landings even though he was always in the airplane. The fed enforcement guys tried to play both pilots against each other
.

How did enforcement become involved in this?
To my friend they said rat on the airplane owner for fraudulently attesting to solo time on the recommend form and they will not go after him for flying an airplane as PIC without liability insurance ( i.e. during the "solo" portion of his float training).
This is intimidation and entrapment, such tactics would not be condoned in a court of law.
At the same time they went after the aircraft owner to flip on the student, promising each no enforcement action if the flipped on the other.
Once again, entrapment and pure slimy tactics by TCCA enforcement.
It was not a pretty scene and they were playing hardball, so I would caution anyone to be very careful about doing float training without a actual solo portion.
And even more important, remember when you are approached by TCCA enforcement do not ever talk to them on any level without a lawyer present. TC has some of the most untrustworthy people one could ever imagine being in positions of power, therefore never ever offer any answers to their questions because the odds are you will regret it.

One of the inspectors who was active in enforcing these issues here in the Pacific Region is one of the most untrustworthy lying S.O.B.’s I have ever dealt with.

I would love for him to try and do me over again because I would give him the best lesson in hard ball that piece of human garbage ever had.

Posted: Wed Aug 22, 2007 5:00 pm
by altiplano
What happens if someone has a PPL done all on floats and wants to get checked out on a land plane? Is there the same 5 t/o & landing solo requirement? The same dual requirement?

Posted: Wed Aug 22, 2007 7:16 pm
by TC Guy
There has been change in the wind about the "5 take-off and landing" policy within TC for a while now. It was recommended by an internal study some years ago.

There were some interesting recomendations -- one of them being that the solo requirement being removed.

For whatever reason, it never went beyond that point.

-Guy

Posted: Thu Aug 23, 2007 7:19 am
by Cat Driver
Maybe someone in ATAC or TC has an intrest in selling high insurance programs?

I'm willing to bet there were more float plane " solo " flights with the instructor riding along than true solo in the past several decades since this stupid rule came out anyhow.

Posted: Thu Aug 23, 2007 3:54 pm
by Cat Driver
We keep arguing about these issues with no changes in the system taking place, so I have written the following to G. Preiestley to see if he will respond and what he will have to say on this issue.

**********************************************



Glenn K Priestley
Vice President
Fixed Wing Air Taxi, and Flight Training
Air Transport Association of Canada
255 Albert Street
Suite 1100
Ottawa, Ontario
K1P 6A9
Tel: 613-233-7727 extension 309
Fax: 613-230-8648
http://www.atac.ca



For many years the sea plane rating has required five take-offs and landings solo to acquire the rating.

For many years I and many others in flight training have tried to get this requirement changed to the requirement of a flight and oral test by a designated flight test examiner.

It has been many years since I have worked in Canada as a pilot, having been forced to work overseas due to TCCA in the Pacific Region having denied me the right to teach flying in Canada.

However I am about to retire from flying overseas and am involved in a new project that will require us to purchase a new Husky amphibian float plane and I would like to use it for giving bush pilot training and float plane ratings. However this requirement for five take-offs and landings will require the airplane be insured to reflect the requirements of five solo take-offs and landings for the students resulting in an insurance premium to expensive to even consider insuring it for sea plane rating training.

I have in the past attempted to get this requirement changed through Jim Dow in TCCA in Ottawa and through my Regional TCCA office, I was unable to even get a intelligent response never mind any indication that they were willing to consider making the change from solo to a check ride.

My reason for writing to you is due to a discussion taking place on Avcanada in the flight training forum where I see that TC is still attempting to penalize instructors who they think are still riding in the airplane as safety pilot and signing it out as solo.

If this requirement is to remain in place I personally will not be to inconvenienced as I can just use the airplane privately registered and teach outside of TCCA's area of regulation and just teach advanced flight training to licensed pilots with float plane ratings. As both you and Jim Dow are aware I personally do not even need a valid pilots license to give this kind of training, I would effectively be just another consultant.

I will be posting this e-mail to you on Avcanada for the perusal of the members and readers of Avcanada and we will with much anticipation await your reply to this issue.

Please feel free to discuss this with Jim Dow and possibly include his opinion if he has one in your answer.

Looking forward to your thoughts on this issue.

. .

290 Deer Lane

Nanaimo B.C.

V9T 4Y2

250 758-3693

Posted: Thu Aug 23, 2007 4:20 pm
by CD
A discussion from an earlier time on rule changes...

TC - laws, regs, PPCs and Changes

Posted: Fri Aug 24, 2007 1:54 pm
by good_idea
Cat Driver... this seems to be your pet peeve... we'll let you fight it out. Sometimes the rules suck but...

Have you picked up the Husky? Maybe when I'm around you can take me for a ride. :)

Posted: Fri Aug 24, 2007 3:06 pm
by Cat Driver
Cat Driver... this seems to be your pet peeve... we'll let you fight it out. Sometimes the rules suck but...
My pet peeve????

Quite franlkly I could personally care less what TC's policies are with regards to flight training as it it really does not affect the type of flight training I do.

The co.ksuckers in TC flight training in the Pacific Region have made sure I can't teach under a FTU regardless of what their policies say, so as I said it does not matter to me if they ask for 500 hundred solo take offs and landings to get a rating on floats.

You gotta really admire them for making sure some of us who should be teaching can not.

TC's gets away with stupid policies because they know no matter how stupid they are the sheep in Canada will just shrug their shoulders and say " sometimes the rules suck but...."

Obviously you have not had to deal with TC very much or you would be more concerned with their attitude towards the industry.

We have not ordered the Husky yet however we will probably order one soon, if we can get the right deal.

Posted: Fri Aug 31, 2007 11:41 am
by trey kule
You know, one of the things about insurance companies, is they want to write insurance. They just dont want to take extraordinarily bad risks.

which tells me that the training that is being done for a float rating at present is not coming up with a pilot that can be trusted to do a few circuits as PIC.

perhaps, Cat, this is an issue you should be addressing rather than trying to change insurance companies policies or asking TC to change.

If TC should drop the requirement I can not see how that will result in a safer product. And until the insurers see it differently through experience, I dont see a change there.

You may want to sit down with an insurer and explain how your training differs from the indsutry standard to put our a pilot qualified to go solo safely. Interestingly enough, you did not make mention of operators who should consider a float rating as an asset, when the training organization does not deem them fit for solo due to insurance or whatever.

Posted: Fri Aug 31, 2007 1:55 pm
by Cat Driver
Shinet Side Up wrote :
A little off the topic here, but just out of curiosity Cat, if TC isn't going to cooperate on this matter to make it workable. Is there possibility of dealing with the insurance company on this matter?
As the requirements now stand where instructors can solo pilots in around six hours of dual I would very much doubt is any underwriter would consider that to be an acceptable risk, therefore the higher premium.
I mean if those we elect to govern us and regulate such things as insurance companies to we all get a fair shake, it then falls to us to deal with things ourselves. TC isn't going to change its requirement, there might be the possiblity of convincing an insurance broker (however unlikely, we're at the archetypal rock and hardplace here) that the students you turn loose solo are as safe as when they're with an instructor. Possibly with your own inhouse testing program - a student doesn't get to do their 5 splash and dashes until you possibly have your own designated examiner have a look at them, one of course that you might have to get them to approve of... and you see how this might be a long and onerus process, but not one without possiblity.
The government has zero input into how an underwriter asseses risk, the underwriters are businessmen who live it the real world, government are another group all together and accountability is not in their realm of understanding.

As to your suggestion that I personally could do something in this area of training I am afriad that would not be possible because TC here in the Pacific Region have made it very clear that I will not be doing any instructing under any FTU OC.

They refused to accept any training done by me and the school that I was working under had to terminate me as the owner was told that if I were on his payroll he could look foward to some real touch audits, so he had to let me go.

About a year later I attempted to work under another FTU OC and the owner who I have known for years told me flat out that he could not hire me as he did not want TC to ruin his business.

So there really is not much that I could do as I am blackballed in the training industry by TC and I can't see it changing.


Trey K wrote :
You know, one of the things about insurance companies, is they want to write insurance. They just dont want to take extraordinarily bad risks.

which tells me that the training that is being done for a float rating at present is not coming up with a pilot that can be trusted to do a few circuits as PIC.

perhaps, Cat, this is an issue you should be addressing rather than trying to change insurance companies policies or asking TC to change.
As I have already stated Trey, there is nothing I can really do as I can not work in the FTU operated side of flight training due to my issues with TCCA.
If TC should drop the requirement I can not see how that will result in a safer product. And until the insurers see it differently through experience, I dont see a change there.


It may not result in a safer product across the board but it would allow us who can teach float plane flying to give ratings without having to pay the very high premium for the solo requirements.....
You may want to sit down with an insurer and explain how your training differs from the indsutry standard to put our a pilot qualified to go solo safely.
There is no need for me to sit down with the insurers to explain how my training produces a superior pilot as they already know that and have issued very low cost insurance based on my training with restrictions written in the policy clearly outlining the limitations time wise that the insured pilots must abide by to have the policy remain valid. However this is outside of the FTU sector of aviation.
Interestingly enough, you did not make mention of operators who should consider a float rating as an asset, when the training organization does not deem them fit for solo due to insurance or whatever.
I am unable to comment on whether or not any given flight training organazation in Canada turns out a safe product in the sea plane end of flight training.....however judging by the standards set up at present for determining the experience level for flight instructors to teach sea plane flying would you insure them?

How in hell can some pilot with a couple of hundred hours and a sea plane rating with only fifty hours on sea planes be good instructors.....?