General Aviation Policy Letters
Transfer of Responsibility
As indicated in the "Transfer of Responsibility" memo signed by Don Spruston on May 27th, 1996, Commercial and Business Aviation has assumed total responsibility for pilot proficiency checking including instrument flying abilities. General Aviation approval is no longer required in all situations mentioned below.
In order to clarify and implement the transition, the following applies:
The PPC is considered to meet all skill requirements necessary for the issue of an Instrument Rating.
It is also important to note that General Aviation has eliminated the existence of two distinctly different instrument flight test being the "initial" and the "renewal" and has replaced it with only one instrument flight test applicable to both renewals and initials. The only exception is that the initial flight test requires a mandatory precision approach. The PPC Standards reflect the same and the tolerance criteria has been matched between both worlds. Hence, to summarize, based on what GA has done with their standards, there is no difference between a PPC that involves a renewal of an Instrument rating, versus one that involves the initial issuance of an Instrument Rating.
As mentioned above, PPCs may include the renewal and in certain cases the initial issuance of an Instrument Rating. Although infrequent, the conduct of a PPC that involves the latter case, may be found in the following circumstances:
In the case of an instrument rating that has expired for more than two years:
1. Second officer up-grade;
2. Furloughed pilot who has been recalled;
3. Pilot who has been off medically;
4. Pilot being upgraded from a VFR operation to an IFR operation. See Notes 1 and 2 below.
In the case of a pilot who has never held an instrument rating before:
5. Pilot being upgraded from a VFR operation to an IFR operation. see Notes 1 and 2 below.
Note 1: An example to illustrate case no. 4 and 5 would be a helicopter pilot (never held an Instrument Rating) operating under a Part VII type of operation and is being upgraded from a VFR slinging operation flying a B206 onto an IFR charter operation flying a Puma. In this case the initial PPC would not only involve an initial type rating, but also the initial issuance of an Instrument Rating. This would also apply to the helicopter pilot who held an Instrument Rating but let it expire for more than two years.
Note 2: In both cases no. 4 and 5, the pilot must be currently employed and operating under a Part VII VFR type operation and is just upgrading to an IFR type operation.
In addition to the above, you will find attached "Procedures for the CCP Authorized Person’s Program", and an "Authorized Person’s Training Program for CCPs". This will allow CCPs to endorse the license of a pilot as soon as all the requirements have been met for a type rating, a renewal and/or an initial instrument rating. This will permit the operator to engage the pilot operationally with no time delay.
The "Procedures for the CCP Authorized Person`s Program" sets out the conditions to which Commercial and Business Aviation (as agreed by GA) will adhere to in order to ensure that the program is conducted efficiently and correctly.
The "Authorized Person’s Training Program for CCPs" has been designed to meet all of Licensing’s Authorized Person’s training requirements. It has also been customized to fit not only with Part IV but also Part VII and subpart 604 of Part VI requirements.
It is intended that all type A CCPs be delegated with this authority as described above, and it is so reflected in the latest version of the ACP Manual.
In order to ensure that this delegation is correctly implemented, all ACIs will be responsible to brief each CCP on the Authorized Person's Training Program.
A briefing package will be sent to the regions. Included in this package will be a hard copy of the training program and the slide presentation. It will also include a diskette containing all of this information electronically.
Although many CCPs may already have a delegation of Authorized Person's authority, a briefing will still be required due to the fact that all type A CCPs will now be authorized to conduct initial PPCs that involve the initial issuance of an instrument rating, which was never done before.
Note: Type A CCPs will be authorized to conduct initial, renewal, and upgrade PPCs with no restrictions as specified in the ACP Manual.
The ACI will then send (e-mail) a list with the names and license numbers of all briefed CCPs including the date the briefing took place to the Operational Standards Division (AARXB). This will allow the Division to activate their authority in FTAE.
In addition to the above, new CCP Letters of Approval must be sent in order to reflect the CARs, and the latest edition of the ACP Manual.
When issuing this letter, it is absolutely essential that the validity period be restricted to the "current" validity period as it existed in their previous letter of approval. This will ensure that all CCPs remain on their current validity cycle before having to attend an ACP refresher workshop. If not, everybody will become due for a refresher all at the same time and it will be a nightmare to manage.
The current validity period can be found in FTAE. Any problems in finding this date may be forwarded to AARXB at (613) 998-3684.
Any questions regarding these issues may be forwarded to Merlin Preuss at (613) 993-6975.
Procedures for the CCP Authorized Person’s Program
The following procedures have been established in order to allow CCPs to carry out Authorized Person’s duties and responsibilities when it comes to endorsing a license and/or additional privileges card with a type and/or instrument rating.
1. Only type A CCPs who are authorized to conduct initial, upgrade or recurrent PPCs shall be authorized to carry out duties and responsibilities of an Authorized Person as specified above.
2. The duties and responsibilities and procedures of "Authorized Person" as described above shall be clearly outlined within the ACP Manual.
3. The CCP letter of approval shall include a statement authorizing them to exercise "Authorized Person" duties and responsibilities as specified in the ACP Manual.
4. All type A CCPs shall receive a briefing and/or training on those duties and responsibilties and procedures prior to being authorized to carry out such duties and responsibilities.
5. The ACP training program, shall include a training module on those duties, responsibilities and procedures.
6. Any remedial training required by a CCP who is considered deficient in carrying out those duties and responsibilties shall be done by the appropriate regional ACI.
7. Failure to adhere to any procedures within the Authorized Person’s Training Program for CCP may cause the revocation of the ACP Approval authority by Commercial and Business Aviation as requested by General Aviation.
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