ACP Bulletin No. 01/15 (Revision 1)
Instrument Rating - Exemption to CAR 401.03(1)(b) and CAR 401.48 (NCR 040-2015)
Recently published, NCR-040-2015 removes the two (2) year validity (i.e., expiry) date associated with Instrument Ratings. The purpose of this bulletin is to clarify aspects of this exemption relevant to Approved Check Pilot (ACP) and Advanced Qualification Program (AQP) evaluators.
Note 1: ACPs referenced in this bulletin must be qualified to conduct a Pilot Proficiency Check (PPC) in accordance with the instrument flight rules (IFR).
Note 2: The ACP Manual (TP6533, 9th Edition) refers to a PPC/IFT (instrument flight test). This terminology has been changed to PPC/IFR for consistency and to better reflect the Instrument Rating - Exemption to CAR 401.03(1)(b) and CAR 401.48 (NCR 040-2015).
Transport Canada completed a risk assessment in 2007 in order to assess the conversion of the Instrument Rating to a non-expiring qualification. In September 2015, Transport Canada issued NCR-040-2015 which, under certain conditions exempts holders of an Instrument Rating from a limited validity period of 24 months. As a result, an Instrument Rating will no longer expire nor be subject to licensing renewal under CARs section 401.49. It will, however be subject to recency requirements.
ACPs and AQP evaluators must read and understand the following two documents:
AC 401-005 – Maintaining Instrument Rating Privileges as stipulated in NCR 040-2015 Exemption to CAR 401.03(1)(b) and CAR 401.48.
Note: AC 401-005 is due to be released shortly.
The Instrument Proficiency Check (IPC) was introduced as one option to satisfy newly established Instrument Rating recency requirements; ACPs are approved to conduct IPCs. This being said, ACPs will normally conduct assessments of instrument proficiency under CARs Part VII and will not normally encounter pilots seeking to complete an IPC. If an ACP is requested to conduct an IPC, they must first read, understand and follow the procedures detailed in the following document:
- AC 401-004 – Conduct of Instrument Proficiency Checks (IPC).
PPC Renewals and Valid To Dates
PPCs may be renewed up to 90 days in advance of a valid-to-date. PPCs may also be extended under certain circumstances. It is recognized that new instrument rating recency requirements tied to a PPC will follow these policies.
Failure of an Instrument Flight Check Exercise during a PPC or Line Operational Evaluation (LOE)
Failure of an instrument flight check exercise during a Pilot Proficiency Check (PPC) or Line Oriented Evaluation (LOE) will no longer invoke a suspension of instrument rating privileges pursuant to CARs Section 401.17 – Failure of a Flight Test Renewal. Such failures will continue to trigger a failure of the PPC or LOE itself. While the previous IR recency period will be unaffected, a subsequent successful PPC or LOE will be required to exercise privileges of the (appropriate Group) Instrument Rating beyond that period. Established procedures related to the failure of a PPC or LOE are to be followed.
Canadian Aviation Document Booklet (ADB)
Transport Canada has modified its Distributed Air Personnel Licensing System (DAPLS) software which is used to process licensing information. As part of an implementation plan, new licence labels for the Licence and Permit page of the Aviation Document Booklet (ADB) are being mailed to all pilots holding an instrument rating. These (new) labels do not contain an Instrument Rating (IR) expiry date.
Flight Test Report - Pilot Proficiency Check Forms (Forms 26-0249 and 26-0279)
Transport Canada has established new business rules regarding the existing Flight Test Report forms (26-0249 and 26-0279) which accommodate the instrument exemption and specifically the absence of an Instrument Rating (IR) expiry date. ACPs and AQP evaluators must now complete the indicated fields (below) on the 26-0249 and 26-0279 forms as follows:
(Top of form 26-0249 or 26-0279)
Enter the instrument rating group appropriate to the category and class of aircraft. Do not enter an EXPIRY date; leave this field blank in all cases.
(Bottom of form 26-0249 or 26-0279)
IFR VALID TO
Instrument ratings no longer have a valid to date. Do not enter YEAR | MONTH data or fill in the computer scannable dots.
IFR / PASSED or FAILED
The PASSED computer scannable dot is only filled in when licensing action is required such as issuing a new Instrument Rating or converting an existing Instrument Rating Group to another Group (i.e., Group 4 to 1, 2 or 3; Group 1, 2 or 3 to Group 4; Group 3 to 2; Group 3 to 1; or Group 2 to 1). The FAILED computer scannable dot is never filled in.
GROUP 1, 2 or 3 (Aeroplane) / GROUP 4 (Helicopter)
The appropriate computer scannable dot is only filled in when licensing action is required such as issuing a new Instrument Rating or converting an existing Instrument Rating Group to another Group (i.e., Group 4 to 1, 2 or 3; Group 1, 2 or 3 to Group 4; Group 3 to 2; Group 3 to 1; or Group 2 to 1).
Note: As a reminder, if a new label for a new Instrument Rating for the Licence and Permit page of the Aviation Document Booklet is required (e.g., upgrading from a Group 3 to a Group 1) then the fee for endorsement of a rating (i.e., $30.00) as stated in CAR 104 Schedule IV – Personnel Licensing and training (Item 15), still applies. Failure to submit the required fee will delay or prevent the issuance of a new label. Furthermore, an Application for Endorsement of a Rating (form 26-0083) is not required if the candidate already possesses an Instrument Rating and is simply upgrading or converting to another Instrument Rating Group.
Maintaining Evidence of Meeting the New IFR Recency Requirements
As detailed in AC 401-005, it is the responsibility of the pilot to maintain evidence of meeting the new IFR recency requirements. Pilots must be able to provide evidence of having met the Instrument Rating recency requirements when requested to do so in accordance with paragraph 401.03(1)(d) of the CARs. Evidence can be presented in a variety of forms; examples include the following:
- An entry on the Competencies Record page of the pilot’s Canadian Aviation Document Booklet (ADB), entered by the examiner, stating the date of expiry of the PPC and the name and licence number of the examiner.
Historically, the Competency Record section of the Aviation Document Booklet (ADB) has not been used by some CARs Subpart 705 air operators as a procedure for qualification tracking. The tracking of qualifications may be handled by an air operator's crewing department or other administrative means. There are no required changes to this practice.
ACP Program Coordinator
Flight Crew Training, Evaluation and Examinations (AARTFE)
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