ATP SEL to ATP MEL...Aug 1

[FlingWing]

That's not quite true. Suggest reviewing it again.

Which part? Following those decision trees, it would seem that I'm okay to just take the written now despite having an ATP in a different category, but the §61.165(c)(2) definitely says otherwise.

"(2) After July 31, 2014, successfully complete the airline transport pilot certification training program specified in §61.156;"

In fact, I guess one could actually read that to mean that you must complete that program, and your completion must occur after July 31. That obviously doesn't seem to be what they meant. It would be more clear if they had said something about needing to complete the program if the practical test was being administered after July 31.

 

[RussR]

Must be a mistake in the tree, because it doesn't match the regulations. As I said, I confirmed this situation with AFS-800. I'll bring this to their attention and report back.

Not sure why you think it doesn't match the regulations. From 61.155d,

(d) An applicant who successfully completes the knowledge test for an airline transport pilot certificate prior to August 1, 2014, must successfully complete the practical test within 24 months from the month in which the knowledge test was successfully completed. An applicant who passes the knowledge test prior to August 1, 2014, but fails to successfully complete the practical test within 24 months must complete the airline transport pilot certification training program specified in §61.156 and retake the knowledge test prior to applying for the practical test.

Pretty much spells out exactly what the decision tree says for the example, like me, of someone who has no ATP and takes the written before Aug 1st. You get "grandfathered" for up to 24 months.

 

[flyingcheesehead]

Must be a mistake in the tree, because it doesn't match the regulations. As I said, I confirmed this situation with AFS-800. I'll bring this to their attention and report back.

Ron, I think you're confusing the OP of the thread (where the poster had an ATP-RH) and the post you quoted (where the poster specifically stated it was for someone with no ATP at all). Reading that post again, do you still think there's a mistake?

 

[poadeleted20]

No written maybe required, but recently two friends of mine have been shot down trying to add ASES to their current ATP AMEL certificate. They were informed that they needed 50 hours in category & class before being eligible to take the ATP practical for that category & class. They both had ATP MEL, COM SEL and were attempting to add ATP SES and were denied because they lacked 50 hours in that category and class.

That's clearly stated in the governing regulations.

Sec. 61.165

Additional aircraft category and class ratings.
...
(e) Additional class rating within the same aircraft category. Except as provided in paragraph (f) of this section, a person applying for an airline transport pilot certificate with an additional class rating who holds an airline transport certificate in the same aircraft category must—
(1) Meet the eligibility requirements of § 61.153, except paragraph (g) of that section;
(2) Comply with the requirements in Sec. 61.157(b) of this part, if applicable;
(3) Meet the applicable aeronautical experience requirements of subpart G of this part; and
(4) Pass a practical test on the areas of operation of Sec. 61.157(e) appropriate to the aircraft rating sought.

Sec. 61.159

Aeronautical experience: Airplane category rating.

(a) Except as provided in paragraphs (b), (c), and (d) of this section, a person who is applying for an airline transport pilot certificate with an airplane category and class rating must have at least 1,500 hours of total time as a pilot that includes at least:
...
(3) 50 hours of flight time in the class of airplane for the rating sought. A maximum of 25 hours of training in a full flight simulator representing the class of airplane for the rating sought may be credited toward the flight time requirement of this paragraph if the training was accomplished as part of an approved training course in parts 121, 135, 141, or 142 of this chapter. A flight training device or aviation training device may not be used to satisfy this requirement.

 

[FlingWing]

So please correct me if I'm wrong, but it seems the takeaways are:

1) If you have no ATP, you can take the airplane written before Aug. 1 and have 24 months to pass the AMEL practical.

2) If you have an ATP without an AMEL rating, the 24 month window is not available.

 

[poadeleted20]

So please correct me if I'm wrong, but it seems the takeaways are:

1) If you have no ATP, you can take the airplane written before Aug. 1 and have 24 months to pass the AMEL practical.

2) If you have an ATP without an AMEL rating, the 24 month window is not available.

I'm confirming that with AFS-800. I'll let you know when I hear back.

 

[FlingWing]

I'm confirming that with AFS-800. I'll let you know when I hear back.

Awesome. Thank you.

It doesn't seem like a logical result, but since when has that stopped the feds?

 

[poadeleted20]

Awesome. Thank you.

It doesn't seem like a logical result, but since when has that stopped the feds?

Reviewing the bidding, I may have been confused about who was asking what. This goes back to the original discussion several weeks ago. Reviewing my notes, let's summarize this again.

If you are starting with no ATP at all, and you take the current ATP-Airplane written before Aug 1, you can take an initial ATP practical test for AMEL/S class rating within 24 months of taking that written without taking either the 61.156 training or the new ATP-AME written. However, if you take the ASEL/S practical test first and do not complete an AME additional class rating practical test before Aug 1, you will not be able to take the AME additional class rating without taking the 61.156 training and new ATP-AME written. The key in this situation is to make sure you take an AME practical test (land or sea) first, then (if you want) add the ASEL or ASES later.

If you are starting with an ATP with an ASE rating but no AME rating, unless you complete an ATP-AME practical test before Aug 1, you will have to do the 61.156 training and the new ATP-AME written before you take that practical test after Jul 31.

If you currently hold an ATP in some other category with no Airplane category rating, 61.165(c) applies:

(c) Airplane category rating with a multiengine class rating. A person applying for an airline transport certificate with an airplane category and multiengine class rating who holds an airline transport certificate with another aircraft category rating must:
(1) Meet the eligibility requirements of Sec. 61.153 of this part;
(2) After July 31, 2014, successfully complete the airline transport pilot certification training program specified in § 61.156;
(3) Pass a knowledge test for an airplane category multiengine class rating or type rating on the aeronautical knowledge areas of § 61.155(c);
(4) Comply with the requirements in Sec. 61.157(b) of this part, if appropriate;
(5) Meet the aeronautical experience requirements of § 61.159 or § 61.160; and
(6) Pass the practical test on the areas of operation of Sec. 61.157(e)(2) of this part.

...so you are going to have to take an ATP-Airplane written test to add an Airplane cat/class rating. If you take the current ATP-Airplane test before Aug 1, you will be able to take the ATP-AME practical test before Aug 1. However, in this case, if you don't do the AME practical test by Aug 1, the regulation says you will have to take the 61.156 training whether you have previously passed a written or not -- see 61.165(c)(2). Note that in this case the job aid produced by Flight Standards linked above contradicts the actual regulation, and when that happens, the actual regulation takes precedence. What's a bit fuzzy is if you take the current ATP-Airplane written but don't do the practical test before Aug 1, will you have to take the new written before doing the AME additional cat/class practical test? The job aid says "no", but the regulation says you must in this case "Pass a knowledge test for an airplane category multiengine class rating", and the current test is only for Airplane category, not ME class. Is that good enough? This may need to be resolved between AFS and AGC, and they've had their food fights before (generally ending in favor of the Chief Counsel when it comes to what the reg says versus what AFS wants). Either way, despite what the job aid says, the regulation says you cannot avoid doing the 61.156 training if you don't get that AME rating on your non-Airplane ATP before Aug 1.

You will note that the best situation to be in right now is not to have an ATP at all. That's the only way you can avoid having to do the 61.156 training and the new ATP-AME written if you don't get your ATP-AME practical test before Aug 1. If you already hold an ATP with either ASE or other category rating, you'd better get 'er done by Aug 1 your be ready to do the 61.156 training and the new written.

BTW, this seems to me like a hose job for anyone who already has an ATP, since the requirements are (at least for the next 24 months) lighter for people who don't have any ATP at all if they get the current ATP-Airplane written done before Aug 1, but that's the way AFS-200 made it happen, so if you want to blame someone, blame them.

 

[RussR]

Thinking outside the box (and based on my other thread), it would seem that if you had, say, an ATP-ASEL currently, you could SURRENDER your ATP certificate today to prevent having to take the CTP course. Then take the ATP written, take the ATP-AMEL checkride within 24 months, and the next day re-take the ATP-ASEL checkride.

Might actually be worth it for ATP-ASEL. If you already have ATP-RH, the expense might make it not worth it.

Interesting situation we're in, isn't it?

 

[poadeleted20]

Thinking outside the box (and based on my other thread), it would seem that if you had, say, an ATP-ASEL currently, you could SURRENDER your ATP certificate today to prevent having to take the CTP course. Then take the ATP written, take the ATP-AMEL checkride within 24 months, and the next day re-take the ATP-ASEL checkride.

Might actually be worth it for ATP-ASEL. If you already have ATP-RH, the expense might make it not worth it.

Interesting situation we're in, isn't it?

I think it's time you got back in the box.

 

[FlingWing]

If I had an ATP SEL, I think I would be tempted to give it up to get the 24 month window. The ATP Heli, however, took enormous effort and expense.That would be a painful decision.

 

[FlingWing]

I can't imagine the FAA intended for pilots to surrender their certificates to get better treatment. I plan to call James Viola and Barbara Adams to discuss this. Perhaps the FAA could approve a variance???

 

[James331]

The FAA also didnt intend folks to circumvent the new rules (like the 50 in class) by knocking their ATP SEL out in a 172 to hold ther place in line for the ATP MEL.

After you take the written you have 24months to take the ME airplane ATP, miss that date and you get to take that class and buy the sim time. It ain't rocket surgery and their isn't some cheat for it.


Written --> 24 mo ---> ATP ME airplane mins ---> checkride

That's all folks

 

[FlingWing]

The FAA also didnt intend folks to circumvent the new rules (like the 50 in class) by knocking their ATP SEL out in a 172 to hold ther place in line for the ATP MEL.

After you take the written you have 24months to take the ME airplane ATP, miss that date and you get to take that class and buy the sim time. It ain't rocket surgery and their isn't some cheat for it.


Written --> 24 mo ---> ATP ME airplane mins ---> checkride

That's all folks

That's true for some, but not in my case. The issue is that I don't get the 24 months, since I already have a ATP-Helicopter. Already have ATP = You lose the 24 month window altogether.

 

[FlingWing]

I talked with the quite helpful folks in AFS-280 today, and they said their intent was NOT to exclude those already holding ATP certificates in a different category from qualifying for the 24-month window. They said they'd have legal take a look, but that if there was a conflict they would potentially issue a technical adjustment to the reg. They said the situation with ATP-ASE was a bit more complicated, but I didn't dig further.

 

[FlingWing]

I was called back today by AFS-610. I was told the intent was to allow the 24 month window for both ATP-Heli and ATP-SEL certificate holders and that guidance has now been drafted to that effect and is being reviewed by legal. Send me a PM if you are affected by this and I'll try to get you more info.

 

[FlingWing]

I have now received a written opinion from AFS-810 stating that the 24 month window is available in my case. Apparently an ATP-ASEL holder also have the 24 month window if passing the written before Aug. 1. PM me if you need more info.

 

[poadeleted20]

FlingWing's letter came not from AFS-810, but from their boss James VIola, AFS-800. Here's the full text:

Thank you for your conversation over the phone a couple of days ago regarding Airline Transport Pilot (ATP) certificate knowledge and practical test requirements. You explained that you hold an ATP with a rotorcraft-helicopter rating, and seek to add an airplane multiengine (AMEL) rating at the ATP level. You plan on taking the practical test to add the AMEL rating to that certificate after Aug 1, 2014. You have asked if you take and pass the ATP knowledge test (for the airplane category) prior to August 1, 2014, if you will still need to complete the ATP Certification Training Program course described by 14 CFR section (§) 61.156. In your inquiry you noted § 61.165(c)(2).

The short answer is no, you would not need to complete the ATP-CTP. If you pass the knowledge test for the ATP airplane category prior to August 1, 2014, you will be able to use that unexpired knowledge test result when taking the ATP practical without needing to complete the ATP CTP.

I direct you to the language of §61.165(c)(2), which references ‘the airline transport pilot certification training program specified in §61.156’. In turn, §61.156 contains introductory language stating:

‘After July 31, 2014, a person who applies for the knowledge test for an airline transport pilot certificate with an airplane category multiengine class rating must present a graduation certificate from an authorized training provider…’ [emphasis added].

Therefore, the regulations do not require that you complete an approved ATP CTP in the scenario you described above. We would advise, however, that you complete the practical test for the ATP certificate with a multiengine class rating or type rating before your knowledge test results expire or you will need to take the ATP CTP, retake the knowledge test, and then apply for the practical test.

Further, the FAA has indicated this intent through published guidance. Please refer to FAA Order 8900.1 Volume 5, Chapter 2, Section 18, Figure 5-88, which can be found through the following website: http://fsims.faa.gov/. For convenience, I have attached the applicable section of the guidance as well as an excerpt showing just the figure.

Also, as an aside, you had noted that there was some discussion concerning whether simply possessing an ATP certificate with a single-engine airplane rating, would allow a person to take a practical test for the ATP with a multiengine rating, without possessing a valid (unexpired) ATP knowledge test in the airplane category at the time of practical. The regulations do not allow this.

I hope you find this information useful, and I appreciate your inquiry.


This response may be short as it is being sent from a BlackBerry.

Thanks

James A. Viola
Flight Standards Service
Division Manager (AFS-800)
General Aviation and Commercial Division
202-385-9604

 

[tlglenn]

Hmm, could we get them to "re-clarify" the rule regarding candidates for restricted ATPs with a qualifying aviation college degree needing to have done their commercial and instrument ratings with that college?

I can see a few absurd scenarios:
1) Pilot already with commercial single-engine and instrument ratings goes through the college program. Picks up the commercial multi-engine rating through the program, even does the ATP CTP through the program, but must still wait until 1500 hours instead of 1000 or 1250.
2) The pilot could even do all of the training required for the commercial single-engine rating through the program and pass a mock checkride with the examiner, but still has to wait until 1500.
3) The pilot could become a CFI through the program, be hired by the same program, and train new commercial pilots who become eligible for the restricted ATP. But, he or she would still have to wait until 1500.
4) Back to scenario (2): The pilot surrenders his commercial and instrument ratings before the planned mock checkride(s) so that he or she can take the checkride(s) for real. Now he or she can be eligible for the restricted ATP.

 

[FlingWing]

Hmm, could we get them to "re-clarify" the rule regarding candidates for restricted ATPs with a qualifying aviation college degree needing to have done their commercial and instrument ratings with that college?

I can see a few absurd scenarios:
1) Pilot already with commercial single-engine and instrument ratings goes through the college program. Picks up the commercial multi-engine rating through the program, even does the ATP CTP through the program, but must still wait until 1500 hours instead of 1000 or 1250.
2) The pilot could even do all of the training required for the commercial single-engine rating through the program and pass a mock checkride with the examiner, but still has to wait until 1500.
3) The pilot could become a CFI through the program, be hired by the same program, and train new commercial pilots who become eligible for the restricted ATP. But, he or she would still have to wait until 1500.
4) Back to scenario (2): The pilot surrenders his commercial and instrument ratings before the planned mock checkride(s) so that he or she can take the checkride(s) for real. Now he or she can be eligible for the restricted ATP.

I don't know, but in my conversations with the FAA it was clear that 1) they expect several issues will still need to clarified, and 2) surrendering certificates is not something they want to see.

 

[Roberd42]

I know I'm reviving an old thread but I'm about to do this ride. I've got a SEL ATP I got in 2010 to lock in my written as I didn't have access to a twin. I went to CAE simuflite in 2010 on the king air for a 135 medevac op I was flying the F90 and 200. They wanted $6k on top to do my ATP ride along with the training. My employer wouldn't pay for it, so I took the ride in a single to lock in the written.

So now I have access to a b55 Baron. I figured I'd go ahead and get my multi ATP in it now, it might open some new doors for me. Now I see all this CTP crap. My DPE has no idea, says he doesnt see any reason I can't add ME privileges without anything but a practical.hes going to double check and let me know. I'm taking the ride on the 8th of May.

I teach at an FBO that's a laser grade facility (I used to be a proctor). I looked it up in the laser grade manual and AC8080.6. Here's the skinny, they have a chart of added ratings. To get the ME added to a an Airplane ATP, you take the ARA-ATM. No CTP course is required to take the Added rating tests. We checked and the system does not prompt for a course certificate. This is coincidental to the wording in the FAR.

So in short, if you hold any ATP and pursue a MEL ATP, you don't have to take the CTP course but you will have to re-take the written. The ARA tests are shorter, 50 questions and 2.5hrs.

 

[Roberd42]

I stand corrected, if you have a ATP SEL or ATP Helicoter you can add MEL with the ARA test and no CTP per the 8080.6, figure 5-6.

I also have a four year degree in aviation from ERAU and 2 years of 135 experience. I'm going to attempt to get a letter from an inspector if I get any flak. I guess the real tell tale will be in IACRA on the examiners checklist to put up my application. I will post here afterward when I see what goes.

 

[NJP_MAN]

I didn't think you could add the ME after the CTP ruled was established. Let us know I am interested I your findings.

 

[James331]

I thought you had two years from the written if you took it before the rule changes, I don't think there is anyway to "lock" it in.

If you took the writer in 2010, I think you're going to have to take the CTP.

Like the other guy said, let us know how you make out.

 

[Roberd42]

Yep, if you have any other category class ATP (which doesn't follow the figure in the AC includes ATP- helicopter also) you get this requirement to add MEL: 61.165(c) (2) After July 31, 2014, successfully complete the airline transport pilot certification training program specified in §61.156; (3) Pass a knowledge test for an airplane category multiengine class rating or type rating on the aeronautical knowledge areas of §61.155(c);


If you have an ATP SEL you get this requirement to add MEL: 61.165(f)(2): (2) After July 31, 2014, pass a required knowledge test on the aeronautical knowledge areas of §61.155(c), as applicable to multiengine airplanes;

No mention of the CTP to add MEL to an ATP SEL. The laser grade software follows the AC as well and doesn't require me to present a CTP certificate to test. I'll be testing early next week. This is contradictory to 61.155(c)(14) which says you must complete the CTP to test. But bo where does the FAR mention added rating written tests and I'm not sure why it would exist with a procedure for ARA-ATM in the 8080.6 if it weren't applicable.

I wish I could upload the documents to support this but it seems attachments aren't allowed on this forum. I will keep everyone posted.

 

[James331]

Yep, if you have any other category class ATP (which doesn't follow the figure in the AC includes ATP- helicopter also) you get this requirement to add MEL: 61.165(c) (2) After July 31, 2014, successfully complete the airline transport pilot certification training program specified in §61.156; (3) Pass a knowledge test for an airplane category multiengine class rating or type rating on the aeronautical knowledge areas of §61.155(c);


If you have an ATP SEL you get this requirement to add MEL: 61.165(f)(2): (2) After July 31, 2014, pass a required knowledge test on the aeronautical knowledge areas of §61.155(c), as applicable to multiengine airplanes;

No mention of the CTP to add MEL to an ATP SEL. The laser grade software follows the AC as well and doesn't require me to present a CTP certificate to test. I'll be testing early next week. This is contradictory to 61.155(c)(14) which says you must complete the CTP to test. But bo where does the FAR mention added rating written tests and I'm not sure why it would exist with a procedure for ARA-ATM in the 8080.6 if it weren't applicable.

I wish I could upload the documents to support this but it seems attachments aren't allowed on this forum. I will keep everyone posted.

I'd be more interested in hearing from you when you get your ATP multi than seeing a bunch of docs.

 

[Roberd42]

I will find out next week. The docs give someone the basis for a waiver from the administrator. I will follow up.

 

[Roberd42]

Well, turns out I misread the 8080.6 figure. So the ARA test no longer applies to anyone. The figure says you have to administer the ATM after July 31, 2014. So, now the general consensus between everyone in my area, is that if you take the dual purpose ATP test and take an ATP level airplane ride within 24 months of taking the old written, you comply with 61.155(d) and can be grandfathered into the old rules, no new written, no CTP required. I will find out Friday and report back.

 

[NJP_MAN]

^Thats the correct interpretation.

 

[Roberd42]

I'd assume the reverse would be true. So if you guys took the dual purpose test within the last 24 months and want the ATP SE also to pad the resume, you're good. But if you take the ATM, you'll have to take the ATS to add single.

 

[Roberd42]

Examiner had a scheduling conflict. Also he has to consult his POI on the written issue and said he may require my experience/diploma documentation. He said we will likely have to submit the application by paper rather than iacra being an extenuating circumstance that may require wavering. So likely it will be at least one more week until I can take the ride.

 

[Roberd42]

You guys are right earlier in the post. I've quit and I don't quit easily. My FSDO inspector called OKC, they say that there is currently no way to exempt or experience out of the CTP, even with a 4 year degree in compliance with the reg. there's just no method to do that at this time. However, everything is waiverable by the administrator, whomever specifically that is. Wish I knew and sure wish I would have found this thread in summer 2014 and known that this would be the case. Goes against precedent, such as life. ExpressJet here I come lol.

 

[James331]

You guys are right earlier in the post. I've quit and I don't quit easily. My FSDO inspector called OKC, they say that there is currently no way to exempt or experience out of the CTP, even with a 4 year degree in compliance with the reg. there's just no method to do that at this time. However, everything is waiverable by the administrator, whomever specifically that is. Wish I knew and sure wish I would have found this thread in summer 2014 and known that this would be the case. Goes against precedent, such as life. ExpressJet here I come lol.

Sorry to hear about that.

So what's your plan now?

 

[Roberd42]

Well, I'm not going to pay $5k for a course to relearn what I've already learned and do sim time I've already done at simuflite. I didn't spend $140k at ERAU to get out and pay again to be qualified. It's infuriating you cant test out or anything. If I get laid off from my current corporate pilot job, I may apply somewhere like ExpressJet, stay with them long enough to get the type and MEATP, grab a handful of popcorn shrimp and bust out of there. We'll see.

 

[NJP_MAN]

Almost all regionals will get you the ATP via CTP now so there's always that. Now about 140k at ERAU that's a whole 'nother issue.

 

[James331]

Well, I'm not going to pay $5k for a course to relearn what I've already learned and do sim time I've already done at simuflite. I didn't spend $140k at ERAU to get out and pay again to be qualified. It's infuriating you cant test out or anything. If I get laid off from my current corporate pilot job, I may apply somewhere like ExpressJet, stay with them long enough to get the type and MEATP, grab a handful of popcorn shrimp and bust out of there. We'll see.

That's not as bad as I though, I was thinking it was more like 15k or so for all thst sim and ground stuff, still sucks, but not as bad as I thought.

 

[Roberd42]

Yeah, the sportys CTP (air Wisconsin?) is $4595, plus transportation, room board and meals. Then the written, then the practical. Easily $6k+

http://www.sportys.com/pilotshop/atp-certification-training-program-atp-ctp.html

 

[Roberd42]

One last ditch effort. I'm putting in a petition for a personal exemption and rule change to allow ATPSE certificate holders that were issued prior to July 31, 2014 who took the "dual purpose" exam, to be precluded from the written requirement. I have a couple lawyer aviator friends who are helping me word a petition. I will include supporting documentation as to why I meet the safety standard of the current rule and other pertinent info. May be denied anyway but it's worth a shot.

 

[NJP_MAN]

What are you trying to do with your ATP if you don't mind me asking?

 

[Roberd42]

It will make me more marketable in corporate aviation. I have a friend in Atlanta that said it will be much easier for me to pick up trips with the MEATP. Also it will make it easier for me to go into the airlines of that business ever turns around (pay wise). I have a friend flying at the regionals making less than $20k a year so it's not something I'm jonesing to do at the moment. But if I fall on hard times i may have to go that route one day.