Important - CPL(A) Modular Training Requirements

[Tony Pike]

After consultation with the UK CAA it has been determined that the previous JAR-FCL 1 requirements for undertaking the CPL(A) Modular Skill Test are NO LONGER applicable under EASA Part-FCL.

Under JAR-FCL 1, a modular student could commence a CPL(A) course with 150 hours total time, complete the course in the minimum required 25 hours and thereupon taken the CPL(A) Skill Test with 175 hours total time. The student would then progress on to MEP Class Rating and ME IR(A) training, at the conclusion of which s/he would have the required 200 hours (total time) for ME CPL(A) / IR(A) issue.

THIS IS NO LONGER THE CASE

Under EASA Part-FCL, the requirements for CPL(A) are as follows and ALL requirements MUST be met before the Skill Test can be taken:

EASA EC Regulation 1178/2011 Annex 1
Appendix 3
E. CPL modular course ? Aeroplanes

GENERAL

1. The aim of the CPL(A) modular course is to train PPL(A) holders to the level of proficiency necessary for the issue of a CPL(A).

2. Before commencing a CPL(A) modular course an applicant shall be the holder of a PPL(A) issued in accordance with Annex 1 to the Chicago Convention.

3. Before commencing the flight training the applicant shall:

(a) have completed 150 hours flight time;

(b) have complied with the prerequisites for the issue of a class or type rating for multi-engine aeroplanes in accordance with Subpart H, if a multi-engine aeroplane is to be used on the skill test.

4. An applicant wishing to undertake a modular CPL(A) course shall complete all the flight instructional stages in one continuous course of training as arranged by an ATO. The theoretical knowledge instruction may be given at an ATO conducting theoretical knowledge instruction only.

5. The course shall comprise:

(a) theoretical knowledge instruction to CPL(A) knowledge level; and

(b) visual and instrument flying training.

THEORETICAL KNOWLEDGE

6. An approved CPL(A) theoretical knowledge course shall comprise at least 250 hours of instruction.

THEORETICAL KNOWLEDGE EXAMINATION

7. An applicant shall demonstrate a level of knowledge appropriate to the privileges granted to the holder of a CPL(A).

FLYING TRAINING

8. Applicants without an IR shall be given at least 25 hours dual flight instruction, including 10 hours of instrument instruction of which up to 5 hours may be instrument ground time in a BITD, an FNPT I or II, an FTD 2 or an FFS.

9. Applicants holding a valid IR(A) shall be fully credited towards the dual instrument instruction time.

Applicants holding a valid IR(H) shall be credited up to 5 hours of the dual instrument instruction time, in which case at least 5 hours dual instrument instruction time shall be given in an aeroplane. An applicant holding a
Course Completion Certificate for the Basic Instrument Flight Module shall be credited with up to 10 hours towards the required instrument instruction time.

10. (a) Applicants with a valid IR shall be given at least 15 hours dual visual flight instruction.

(b) Applicants without a night rating aeroplane shall be given additionally at least 5 hours night flight instruction, comprising 3 hours of dual instruction, which shall include at least 1 hour of cross-country navigation and 5 solo take-offs and 5 solo full stop landings.

11. At least 5 hours of the flight instruction shall be carried out in an aeroplane certificated for the carriage of at least 4 persons and have a variable pitch propeller and retractable landing gear.

EXPERIENCE

The applicant for a CPL(A) shall have completed at least 200 hours flight time, including at least:

(a) 100 hours as PIC, of which 20 hours of cross-country flight as PIC, which shall include a VFR crosscountry flight of at least 540 km (300 NM), in the course of which full stop landings at two aerodromes different from the aerodrome of departure shall be made;

(b) 5 hours of flight time shall be completed at night, comprising 3 hours of dual instruction, which shall include at least 1 hour of cross-country navigation and 5 solo take-offs and 5 solo full stop landings; and

(c) 10 hours of instrument flight instruction, of which up to 5 hours may be instrument ground time in an FNPT I, or FNPT II or FFS. An applicant holding a course completion certificate for the Basic Instrument Flight Module shall be credited with up to 10 hours towards the required instrument instruction time. Hours done in a BITD shall not be credited;

(d) 6 hours of flight time shall be completed in a multi-engine aeroplane.*

(e) Hours as PIC of other categories of aircraft may count towards the 200 hours flight time, in the following cases:

(i) 30 hours in helicopter, if the applicant holds a PPL(H); or
(ii) 100 hours in helicopters, if the applicant holds a CPL(H); or
(iii) 30 hours in TMGs or sailplanes; or
(iv) 30 hours in airships, if the applicant holds a PPL(As); or
(v) 60 hours in airships, if the applicant holds a CPL(As).

* The UK CAA has filed a derogation with EASA removing this requirement if the CPL(A) is to be taken on a SEP.

You CAN undertake the IR(A) before the CPL(A), which will count towards the 200 hours total time requirement, with the exception of Simulator time, which does not count towards the experience requirements.

[TomA320]

Re: Important - CPL(A) Modular Training Requirements

Does this mean you need 200hrs total time before doing the skills test or does it mean 200 hours total time before getting a CPL Licence?

[Tony Pike]

Re: Important - CPL(A) Modular Training Requirements

200 Hours total time plus all other requirements for licence issue met BEFORE the Skill Test.

This is direct in writing from CAA Policy and not my personal interpretation.

[TomA320]

Re: Important - CPL(A) Modular Training Requirements

That's annoying, so the experience level has been increased by 25 hours? Didn't it used to be 175 hours before the Skills Test? 150 hours PPL and hour building then 25 on top of that for the CPL course.

[Tony Pike]

Re: Important - CPL(A) Modular Training Requirements

That was the old UK CAA interpretation of JAR-FCL which, apparently, was not common practice in other JAA member states which even back then implemented the 200 hour rule; therefore, this is no surprise to them.

CAA Policy has stated that an Information Notice (or similar) will be prmulgated in the near future to all ATO's and Flight Examiners informing them of the new requirements.

There is an alternative:

Assuming the following start point and all completed in minimum hours.

150 hours TT; 95 hrs PIC

MEP CR - 6 hours + 1 hour Skill Test (157 TT; 96 PIC) - although no requirement for Skill Test if going straight on to IR(A)

IR(A) - 55 hours (40 FNPT II; 15 aircraft) + 2 hours Skill Test (174 TT; 98 PIC) - FNPT II time is not logged.

CPL(A) - 15 hours + 2 hours Skill Test (191 TT; 100 PIC) - 10 hours credit for Basic Instrument Flight Module on IR(A)

Still 9 hours short. Personally, and this is merely my opinion, I would exchange 10 FNPT II hours for an additional 10 hours on the aircraft on the IR(A). 30 hours in the sim is more than enough to get to grips with the procedures but an extra 10 hours flying the actual aircraft is invaluable, especially if you've no complex time to start with. Of course, there would be extra costs but probably worth the outlay. Alternatively, do 10 hours hour building on a complex SEP before the MEP CR and IR(A) and stick with the 40 hours FNPT II option.

[HeloDriver]

Re: Important - CPL(A) Modular Training Requirements

Tony,

Thanks for all this.

If one is a CPL(H) looking to also get a CPL(A), are there any PIC hours accredited towards 100 PIC for licence issue, or do you still have to gain 100 PIC Aeroplane hours. I only ask because I cant get any answers from the CAA.

Regards.

HD

[KASUNDEL]

Re: Important - CPL(A) Modular Training Requirements

Hi Tony,

Just another clarification -

If you are under the hood & act as PIC while training for IR - Can the hours be logged as PIC/Dual both?

Thanks.

[Tony Pike]

Re: Important - CPL(A) Modular Training Requirements

100 hours of PIC time for a CPL(H) holder can be counted towards the CPL(A) 200 hours flying experience requirements, under para (e) (ii) below.

The best thing to do would be to e-mail me your (A) and (H) experience and I can take a look - something the CAA should be capable of doing.


EC Regulation 1178/2011 Annex I Appendix 3 states:

EXPERIENCE

12. The applicant for a CPL(A) shall have completed at least 200 hours flight time, including at least:

(a) 100 hours as PIC, of which 20 hours of cross-country flight as PIC, which shall include a VFR cross-country flight of at least 540 km (300 NM), in the course of which full stop landings at two aerodromes different from the aerodrome of departure shall be made;

(b) 5 hours of flight time shall be completed at night, comprising 3 hours of dual instruction, which shall include at least 1 hour of cross-country navigation and 5 solo take-offs and 5 solo full stop landings; and

(c) 10 hours of instrument flight instruction, of which up to 5 hours may be instrument ground time in an FNPT I, or FNPT II or FFS. An applicant holding a course completion certificate for the Basic Instrument Flight Module shall be credited with up to 10 hours towards the required instrument instruction time. Hours done in a BITD shall not be credited;

(d) 6 hours of flight time shall be completed in a multi-engine aeroplane.

(e) Hours as PIC of other categories of aircraft may count towards the 200 hours flight time, in the following cases:

(i) 30 hours in helicopter, if the applicant holds a PPL(H); or

(ii) 100 hours in helicopters, if the applicant holds a CPL(H); or

(iii) 30 hours in TMGs or sailplanes; or

(iv) 30 hours in airships, if the applicant holds a PPL(As); or

(v) 60 hours in airships, if the applicant holds a CPL(As).

[Tony Pike]

Re: Important - CPL(A) Modular Training Requirements

ALL training for the IR is PUT and ZERO is counted as PIC.

The only exceptions are students on integrated courses where some time can be counted as PICUS - I don't think that applies here.

Furthermore, FNPT II time does not count towards experience requirements for licence issue, e.g. if you had 200 hours total time but this included 40 hours FNPT II for an IR, this would NOT count towards the 200 hours required for the CPL(A) issue and a further 40 hours of actual flight would be required before the CPL(A) Skill Test could be taken.

Also, any time entered into a log book on N registered aircraft claimed as PIC as safety pilot for the PIC acting as the sole operator of the aircraft controls and carrying out IF practice would also not be counted as this is not recognised in EASA 'land'. Both pilots can claim the time under FAR's but not under EASA Part-FCL.

All good stuff, innit?

[KASUNDEL]

Re: Important - CPL(A) Modular Training Requirements

Hi Tony,

"ALL training for the IR is PUT and ZERO is counted as PIC."

I was training for IR in the US for FAA IR ( in a EASA Approved FTO) thinking that i could convert my IR to EASA later and the Instructor confirmed to me that all the training which i received for IR can be logged as PIC/Dual ...

So according to your comment - this means that even after obtaining a FAA IR i would have to follow up extra hours for IR to get the EASA CPL..

This is going to be really messy cos I have already posted all of those hours on the log book as PIC/Dual.

[Tony Pike]

Re: Important - CPL(A) Modular Training Requirements

Sorry Kas,

I missed this so apologies for the delay in replying.

The problem is between the EASA and FAA differences.

The FAA recognises certain training flights as P1S (Pilot in Command Under Supervision).

EASA (especially the UK CAA) will NOT recognise these hours as PIC time and will recognise them as PUT only. If you are on a training course you are Pilot Under Training, end of argument!

Additionally, the FAA permits two pilots in a Single Pilot Aircraft to claim PIC where one is acting as PIC under the hood in SIMULATED instrument conditions and the other is acting as a VFR Safety Pilot. Under EASA Regulations, ONLY the handling pilot can claim the time - the Safety Pilot gets 0.

If you do not meet the EASA requirements for licence issue at the time that the Skill Test is taken (and the CAA will check your log book, especially if you have N registrations in it) not only will they refuse to issue your licence they will also require you to retake the Skill Test.

I suggest you maintain 2 x log books, 1 for the USA and 1 for EASA. Same flight details, just different categories for claiming time.

Bit of a pain but could save a lot of heartache at a later date!

[FoxtrotSierra]

Hi there,

Old post, same problem.

I have also done a FAA IR(A) on my FAA PPL(A). The latter one is converted to EASA and I will convert the FAA IR after my EASA ATPL exams to then continue training towards a PART-FCL (UK CAA) fATPL(A).
I obviously need to meet the 100h PIC requirement before my CPL Skill Test and was counting on my PICUS time logged under FAA rules during my IR training, which were 43 hours.
This was an "approved course of training" as under Part 141 (Federal Aviation Regulation). I got the mail from the CAA with the statement that this training hours are not recognized as PIC, because they fall under PUT time in EASA regulations.
You mentioned that hours during instrument training can be SPIC (Student Pilot In Command) on integrated courses. My Part 141 Course was integrated, so I am looking at coming to a mutual agreement, that these hours will get recognized to some extent towards the 100 PIC for the CPL, as they were part of an course of integrated training, even though it was in the US.

I was really counting on my 43h FAA "PICUS" during my timebuilding here in Spain. I hope to get that sorted, in order to not have to fly 43 hours more...
Technically this is almost as the instructor was acting as a safety pilot, cause I had my PPL while during training to learn to fly under IFR, at least this is how the FAA looks at it. Also I was the sole manipulator of the controls at every moment.

Any more thoughts on this ? Any advice is appreciated !

Thank you !

[zachbrown]

Hey FoxtrotSierra
your post is a bit older and I'm in pretty much the exact same position as yourself.

I even have PIC under Supervision during my MEP training in FAA USA too.

How did this end up for you, were you able to get some of those flights counted?

Thanks!