Collective Down! Posted August 30, 2007 Posted August 30, 2007 Here is the situation... I currently hold:ATP Airplane Multi-Engine Land, andCommercial Helicopter I am trying to get to ATP Helicopter Do I need to get an instrument-HELICOPTER rating before applying for the ATP Helicopter? ATP Eligibility Requirements 61.153 (d)(1) says I must hold at least a commercial pilot certificate and an instrument rating, but it doesn't specify that the instrument rating has to be in the helicopter. I meet all the aeronautical knowledge, flight proficiency, and aeronautical experience requirements for ATP helicopter... The instrument-rating-first issue is the only question. Everyone I've asked is quick to reference 61.165 (additional aircraft category and class ratings) but 165(a)(1) refers right back to 61.153. I've already searched through the FAA 8400 and 8700, FARS, FARS explained book from Jepp, called AOPA.... No definite answer I did my application on IACRA and it didn't reject it, but that program has been wrong before. I guess my questions are:Has anyone else ever gone from ATP airplane to ATP helicopter without doing the instrument rating first?Do you know of any black & white evidence that says I can or can not do that? Quote
Gomer Pylot Posted August 30, 2007 Posted August 30, 2007 I can't say for sure about what is required before, but the ATP checkride will most definitely require you to fly a helicopter IFR. If you can't do that, to ATP standards, then don't waste your time and money. Quote
Collective Down! Posted August 30, 2007 Author Posted August 30, 2007 Like I said, that's not the issue.... I'm not "winging it." I've just finished 25+ hours of instrument training, and I know exactly what's expected of me in the PTS. There is just a dispute at the Orlando FSDO as to whether or not I can go straight to ATP without stopping at instrument. I AM trying to save my time & money, Gomer, that's why I'm trying to skip the instrument checkride in the first place. Quote
Gomer Pylot Posted August 30, 2007 Posted August 30, 2007 Try another FSDO. FSDO guys know about as much as you do, if that. You can get a different opinion from every suit at every FSDO. What we tell you makes no difference, you have to get a DPE or an FAA examiner to give you the ride, one way or another. If you received 25+ hours of instrument training, why didn't you get an instrument rating? Quote
Collective Down! Posted August 30, 2007 Author Posted August 30, 2007 Try another FSDO. FSDO guys know about as much as you do, if that. You can get a different opinion from every suit at every FSDO. What we tell you makes no difference, you have to get a DPE or an FAA examiner to give you the ride, one way or another. If you received 25+ hours of instrument training, why didn't you get an instrument rating? I decided to do all 25 hours for the ATP at one time because I own the helicopter and had to list it for sale, so time was critical.... After 250 instrument in airplanes, it was the most boring 25 hours of my life burning the time off training in the helicopter. What I'm looking for is black and white evidence either way, not to play he-said she-said between FSDOs. Quote
Gomer Pylot Posted August 30, 2007 Posted August 30, 2007 It doesn't matter what you find, you'll still have to play he-said she-said between FSDOs, or at least between the hes and shes at one FSDO. Getting any agreement is extraordinary, unless they're attacked from outside, in which case they circle the wagons, cf Bob Hoover. Quote
joker Posted August 30, 2007 Posted August 30, 2007 (edited) Collective Down!, I don't think it could not get more 'black and white' than 61.153(d)(1) You may be issued an ATPL(H) on the basis of your airplane IR, so long as you meet the experience requirements of 61.161(a)(4). In other words you don't need this IR(H) to be eligable for ATPL(H).As Gomer says, I don't know why you did 25hrs of training, and didn't spend a further 1.5 doing an instrument rating. Remember, even though you might get your ATPL without an IR in category, at the end of the day you still won't have a helicopter IR. This is a common requirement for any job these days. What you could do is see if the examiner could combine the two checkrides....Helicopter IR and Helicopter ATPL(H). This must mean a longer ride, but at least you get both tickets at the same time which might reduce the costs, and result with you having both tickets. Just as you've found and as Gomer says, FSDOs will always disagree with each other. What I say or what Gomer says is pretty irrelevent. However, I'm surprised there's any debate on this subject. It looks pretty 'B & W' to me. Joker Edited August 30, 2007 by joker Quote
jehh Posted August 30, 2007 Posted August 30, 2007 (edited) You can go directly to the ATP checkride, do not stop at the instrument, do not pay $400 twice... Don't ask the FSDO, ask the DPE who is doing the checkride. If he'll sign it off, don't worry about it, if he won't, find another DPE. Edited August 30, 2007 by jehh Quote
rick1128 Posted August 30, 2007 Posted August 30, 2007 (edited) First, I don't believe Joker is correct. It is my understanding that the VFR Helicopter ATP is no longer issued. I was told it had to do with ICAO issues. If your FSDO is giving you fits about the ATP checkride, I would insist that they talk with legal or region. They will not do so if they can help it, as they think it makes them look bad. So you will have to insist strongly. Good luck. Edited August 30, 2007 by rick1128 Quote
Gomer Pylot Posted August 30, 2007 Posted August 30, 2007 There is no separate instrument rating, the ATP includes it. If you have an ATP, you have an instrument rating, although it's not listed separately on your certificate. The ATP checkride is done almost entirely under the hood - only a few VFR maneuvers are done at the end, such as slope landings, etc. Quote
joker Posted August 30, 2007 Posted August 30, 2007 (edited) There is no separate instrument rating, the ATP includes it. Gomer, Thanks for pointing that out. I didn't take that into consideration. I knew there was considerable instrument training, but didn't appreciate that it gave you all the privilages of an instrument rating, per 61.167(a). That's interesting actually, because I have two other ATPLs and in both the IR is listed as a separate rating. Required of course, but still separate. I don't have an FAA ATPL. Well most of my previous point is moot then. No need for the instrument rating if you have an FAA ATPL. Do employers recognise it? I'm sure I've seen adverts asking for say...ICAO ATPL(H), IR(H). Then again, maybe I haven't. Are you saying by this, that Collective Down therefore does not need a helicopter IR PRIOR to getting his ATPL. That his airplaine IR fulfills the required 61.153(d)(1)? rick1128 I am not talking about a VFR ATPL. See Gomer's post, and see 61.167(a). Joker Edited August 30, 2007 by joker Quote
Gomer Pylot Posted August 30, 2007 Posted August 30, 2007 (edited) I don't know for sure if the IR is required before the ATP checkride. I haven't read Part 61 in a long time, and can't quite get the time or ambition to reread it. It appears, from the controversy at the FSDO, that it may be an ambiguous point, in which case he just needs to find a DE to give him a ride. After the DE signs him off as an ATP, the controversy is moot. At one time, it was possible to have a helicopter ATP limited to VFR, at least in the US. I have no idea what an ICAO ATPL consists of, if it even exists. I always thought each country issued its own certificates. I admit to not having studied non-US aviation regulations in any detail. Edited August 30, 2007 by Gomer Pylot Quote
Collective Down! Posted September 6, 2007 Author Posted September 6, 2007 (edited) It worked... I was able to skip the instrument and go straight to ATP, then CFII... The only snag was that the FSDO politely requested that i do the IFR cross country required in 61.65 (for the instrument rating). Gomer, Ya gotta be careful with that "try another DPE" solution. Just because you get the certificate issued to you doesn't mean it won't get yanked years down the road for a technicality. About 3 years ago nearly an entire class of CFI applicants at Embry-Riddle had their instrument priveleges revoked for a few days because those pilots had not done a legitimate instrument cross-country during their training. They did a localizer back course and an ILS on the same flight, and the local FSDO argued that those are the same thing. The school had to arrange for all of them to redo their instrument cross-countries... Right after they finished all of them the official word came back that those original cross-country flights were legitimate and that a localizer backcourse is not the same as an ILS. But, it just goes to show you how far the FAA will go out of their way in pursuit of a technicality despite common sense. Just because you submit the paperwork and the DPE does the checkride doesn't mean that you will get to keep that ticket. I had another instance myself... I took my 135.297 ride in a single-engine airplane with an FAA inspector exactly one year ago. I brought my 8710, and applied for a single-engine airplane add-on to my ATP. Come to find out (about a week later), that inspector was not authorized to give me that certificate because he didn't have an ATP with an airplane single-engine land rating himself.... I had to give that piece of paper back. Edited September 6, 2007 by Collective Down! Quote
joker Posted September 6, 2007 Posted September 6, 2007 (edited) The only snag was that the FSDO politely requested that i do the IFR cross country required in 61.65 (for the instrument rating). Bloody FSDO going and making up rules again! (Is this Orlando FSDO you're working with?) If it was for ATPL, I disagree with this. Nowhere do ATPL requirements require you to do an IFR cross-country. Nowhere in 61.153-161 is there any reference to the specific requirements of 61.65. This sort of leads back to my previous issue:- whether the ATPL constitutes / includes an IR as an entity? Whether with ATPL, it can be said you have an instrument rating? By making you do the 61.65 X-C requirement, they are admiting that the ATPL requirements are not in themselves equivilent to the IR. If they required it for the CFII portion, then I disagree with that too. You can take the CFII ride as you have privilages instrument privilages on your ATPL 61.167(a). This is all that is required by the requirements of 61.183©(2)(iv) I know you may exercise all the privilages of the IR with an ATPL, but that is not the issue. It's sort of like a 'temporary guest membership to the IR club'. You have all the rights, but you don't actually have full membership. Should you lose your 'guest' membership (ATPL) you lose your IR club rights too. Does that make any sense? In short I disagree that you needed to do this X-C - the rules don't allow it. I assert that without the 61.65 X-C you can go and complete your CFII(H), even though I still pose the technical question of whether you 'get an instrument rating with an ATPL.' I say you just get the privilages. Anyway, moot as we said. I agree with the point about the DPE not being God, and his signature not being enough to save you from having your licence revoked on a technicality 5 years later. Get it clear in writing beforehand. 5 years of flying experience is an expensive thing to lose. Not trying to take anything away from your success. Well done. It's just my morning muse. Joker Edited September 6, 2007 by joker Quote
Collective Down! Posted September 6, 2007 Author Posted September 6, 2007 Bloody FSDO going and making up rules again! (Is this Orlando FSDO you're working with?) If it was for ATPL, I disagree with this. Nowhere do ATPL requirements require you to do an IFR cross-country. Nowhere in 61.153-161 is there any reference to the specific requirements of 61.65. This sort of leads back to my previous issue:- whether the ATPL constitutes / includes an IR as an entity? Whether with ATPL, it can be said you have an instrument rating? By making you do the 61.65 X-C requirement, they are admiting that the ATPL requirements are not in themselves equivilent to the IR. If they required it for the CFII portion, then I disagree with that too. You can take the CFII ride as you have privilages instrument privilages on your ATPL 61.167(a). This is all that is required by the requirements of 61.183©(2)(iv) I know you may exercise all the privilages of the IR with an ATPL, but that is not the issue. It's sort of like a 'temporary guest membership to the IR club'. You have all the rights, but you don't actually have full membership. Should you lose your 'guest' membership (ATPL) you lose your IR club rights too. Does that make any sense? In short I disagree that you needed to do this X-C - the rules don't allow it. I assert that without the 61.65 X-C you can go and complete your CFII(H), even though I still pose the technical question of whether you 'get an instrument rating with an ATPL.' I say you just get the privilages. Anyway, moot as we said. I agree with the point about the DPE not being God, and his signature not being enough to save you from having your licence revoked on a technicality 5 years later. Get it clear in writing beforehand. 5 years of flying experience is an expensive thing to lose. Not trying to take anything away from your success. Well done. It's just my morning muse.Joker By "ATPL" do you mean ATP Limited?... Pardon my ignorance, but I'm not sure what the L is.... I don't have any limitations on what was issued to me, it's not a "VFR only ATP." You do raise a very interesting point about losing the ATP though... If I were to hypothetically go do something that is not of good moral character and got my ATP yanked, but allowed to keep my commercial, I don't know whether or not I'd get the instrument or not. Then again, if I did something that bad, my instrument priveleges would probably not be my biggest concern. As for the cross-country... It was just a gentleman's agreement between me and the FSDO guy, so if he had to go to bat for me down the road it would be a little easier. I could fight it, but I didn't have the time to. I'm trying to be a DPE down the road, so I'm trying to stay in a good position with them. Quote
joker Posted September 6, 2007 Posted September 6, 2007 Hi Collective Down, ATPL = Air Transport Pilot License. Just another name for the same thing. Anyway, I thought about this today and wondered whether I'd made myself clear. I'm not trying to take away anything from you. Your instrument (from fixed wing) is certainly more than enough. Of course all of this wouldn't be possible without a fixed wing instrument rating anyway. So I'm not saying you are a lesser instrument pilot. No. My point is a purely theoretical one. Again, it comes down to the raw nitty-gritty of the FARs and whether they are meaning what they say or saying what they mean. As I read them there in black and white, it seems that, should your ATPL be found invalid for some reason, then your instrument rights are revoked too. If I was a mean bugger, that's how I'd put it in court. Now, the question is, is this what the FARs intend, or is it that they just aren't specific enough to say what the rule makers wanted. The FARs are always being tweaked. They are not infallible. That is a limitation of the written language. As you've probably noticed, I love to find these inconsitencies and muse over what-ifs. I love to follow the rules and references and find breaks in the web. Then I ask whether the missing link is deliberate or a mistake. That's just me. But like you said, that would be the last of your worries, so it is all moot. rgds, Joker Quote
Gomer Pylot Posted September 6, 2007 Posted September 6, 2007 (edited) To be extremely nit-picky, the ATP (as well as the private and commercial) is a certificate, not a license. You may have a hunting license, but it's a pilot's certificate. Edited September 6, 2007 by Gomer Pylot Quote
IGM Posted September 6, 2007 Posted September 6, 2007 Here is the situation... I currently hold:Yffffffffffffffffffffff What a question..FAR stated that You can do as that - ATP without Instrument , however the 'll be restriction imposed on Your license as "VFR ONLY"....and teh next thing - You hav eto meet time requirements in ROTORCRAFT-HELICOPTER ...total time , even within so called "ADD-ON"..considering this time YOU gonna fly and SPEND and unless You can buy brand new one of Your own ...You shoul dgo via Instrument... The good part there be no Type rating , not untill You start flying EC145 , SA 334 , 332, BH412 I belive as well - any heavy , real haevy ones.so , read with care FARs section ATP , all is there ! Regards.IGM ATP Airplane Multi-Engine Land, andCommercial Helicopter I am trying to get to ATP Helicopter Do I need to get an instrument-HELICOPTER rating before applying for the ATP Helicopter? ATP Eligibility Requirements 61.153 (d)(1) says I must hold at least a commercial pilot certificate and an instrument rating, but it doesn't specify that the instrument rating has to be in the helicopter. I meet all the aeronautical knowledge, flight proficiency, and aeronautical experience requirements for ATP helicopter... The instrument-rating-first issue is the only question. Everyone I've asked is quick to reference 61.165 (additional aircraft category and class ratings) but 165(a)(1) refers right back to 61.153. I've already searched through the FAA 8400 and 8700, FARS, FARS explained book from Jepp, called AOPA.... No definite answer I did my application on IACRA and it didn't reject it, but that program has been wrong before. I guess my questions are:Has anyone else ever gone from ATP airplane to ATP helicopter without doing the instrument rating first?Do you know of any black & white evidence that says I can or can not do that? Quote
joker Posted September 7, 2007 Posted September 7, 2007 IGM, It may be that I read your post only 2 minutes after waking up, but I found it totally un-intelligable! Further more, the meaning I did get seemed wrong. Sorry. Whatever it is you're saying, have you followed the progression of the thread? We believe we answered the question ages ago. There are no more 'VFR-Only' ATPs. Gomer Since you have proposed the notion that the term 'licence' and 'certificate' are in a practical sense different, would you care to elaborate on your definitions? Personally, I would go so far as to say these documents are both; certificates (in that they are a testament to your successful training), and licences (in that they give you certain privilages which may be revoked / expire depending on circumstances, such as recency). Joker Quote
Collective Down! Posted September 11, 2007 Author Posted September 11, 2007 To be extremely nit-picky, the ATP (as well as the private and commercial) is a certificate, not a license. You may have a hunting license, but it's a pilot's certificate. Well then no one would ever meet the listed requirments for Era Helicopters... Gotta have an "instrument ticket." The rating just isn't enough these days. Quote
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