ATP SEL to ATP MEL...Aug 1

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.

Be sure to read the applicable sections of 14 CFR part 11, specifically 11.71(a)(4), which requires you to demonstrate how the exemption would be in the public interest. This can be a tough one for individuals to meet. Take a look at Http://aes.faa.gov for other petitions for exemption. You might notice the success (or lack thereof) others have had petitioning the FAA for an exemption.
 
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.

This is true, our company only asks for a CPL license, however I have never heard of one fixed wing pilot being hired who did not have his ATP.
 
This is true, our company only asks for a CPL license, however I have never heard of one fixed wing pilot being hired who did not have his ATP.

I suspect that will change in the future as the folks with "easy" ATPs have already been picked up, leaving only eager Commercial Pilots.
 
Yeah brad I read that on the website. I'm not sure why having not only qualified but experienced ATPs in the cabin wouldn't be in the public interest but I'll be sure to mention it to cover that basis.
 
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I suspect that will change in the future as the folks with "easy" ATPs have already been picked up, leaving only eager Commercial Pilots.

You taking that R-ATP?

Personally a fan of it, or the false logic behind it.

Even a full ATP doesn't meet the experience requirements of most of the good QOL jobs, most I've seen are 2500tt and up, turbo prop time, good chunk of IMC time etc, so a R-ATP, well guess it gets you into a poverty level regional :dunno:
 
James. I think by easy ATP he is talking about blasting the written out with sheppard and getting ATP on your first type ride. That was pretty easy. Now there is more too it of cour$e.
 
You taking that R-ATP?

Personally a fan of it, or the false logic behind it.

Even a full ATP doesn't meet the experience requirements of most of the good QOL jobs, most I've seen are 2500tt and up, turbo prop time, good chunk of IMC time etc, so a R-ATP, well guess it gets you into a poverty level regional :dunno:
Question about the restricted ATP.. After you gain the required times for a full ATP, is there an additional check ride or is it just a certificate exchange at the local FSDO? If it's the latter, what's the point of making it "restricted" in the first place? Possibly can't act as PIC??
 
^ correct. It just converts to ATP after 1500. I say rATPs are the best pilots in the world. They can do everything (except act as PIC) an ATP does except they have less experience.
 
^ correct. It just converts to ATP after 1500. I say rATPs are the best pilots in the world. They can do everything (except act as PIC) an ATP does except they have less experience.
Why are RATP's the best pilots in the world?

The whole restricted thing just seems like a loophole if you ask me. Yes, the pilot must demonstrate ATP level competency, but generally airline check rides have always used that standard.... They just never issued a certificate.
 
Maybe I should take that back... I'm sure at least some airlines may have used commercial standards.

Anyway, experience is extremely important. I think the PIC restriction is very wise. In fact, im not even convinced the 1500 is enough.
 
Why are RATP's the best pilots in the world?

The whole restricted thing just seems like a loophole if you ask me. Yes, the pilot must demonstrate ATP level competency, but generally airline check rides have always used that standard.... They just never issued a certificate.
I'm saying that because they get to do at 1000 what I have to wait till 1500 to do. They must be amazing pilots because they have 66% of the experience I will have! ;)
 
I'm saying that because they get to do at 1000 what I have to wait till 1500 to do. They must be amazing pilots because they have 66% of the experience I will have! ;)

lol!!! I have seen many pilots that perform to ATP level as brand new IR pilots.. And conversely, many ATP's that should not have an IR.

That said, an ATP does not buy experience, and a PPL or a CPL does not mean lack of experience.

I think a full ATP should be at least 3,000 hours. That's just talking from looking back at things...

Flame away...
 
I'm a 3500 hour ATP, took the old ME ATP written and can't add ME without jumping through flaming hoops -- there really should be a method to experience out of the CTP. I agree 100% with you kritch
 
You taking that R-ATP?

Personally a fan of it, or the false logic behind it.

Even a full ATP doesn't meet the experience requirements of most of the good QOL jobs, most I've seen are 2500tt and up, turbo prop time, good chunk of IMC time etc, so a R-ATP, well guess it gets you into a poverty level regional :dunno:

I'm refer to people who either passed their atp check ride before 8/1/2014, or took the written before then to be grandfathered for the following 24 calendar months...i.e. Folks who are not required to take the ATPCTP.
 
I'm refer to people who either passed their atp check ride before 8/1/2014, or took the written before then to be grandfathered for the following 24 calendar months...i.e. Folks who are not required to take the ATPCTP.
What exactly is the ATPCTP ?
Pardon me for my ignorance.
 
James. I think by easy ATP he is talking about blasting the written out with sheppard and getting ATP on your first type ride. That was pretty easy. Now there is more too it of cour$e.

Yeah that.
 
Yeah brad I read that on the website. I'm not sure why having not only qualified but experienced ATPs in the cabin wouldn't be in the public interest but I'll be sure to mention it to cover that basis.

Be sure to read through the various denials to get an idea of what the FAA considers "public interest". If you limit your searches to the office of "AFS-800" you'll find more of the part 61/91 exemptions. You can also cross reference the docket number to www.regulations.gov to track down the rest of the docket.
 
Extra training that precedes taking the ATP knowledge test.
Okay, thanks... That must be fairly new.

Do you still need the FAA logbook check to get the sign off for the written?
 
Thanks for the input brad. I will review that to make it conform as much as possible before I submit the petition.

Kritch, I think they just go off of the honor system on what you input in iacra on the 8710. I don't recall having my logbook double checked by the examiner on my ATP ride in 2010. The CTP course is a week long including classroom training on aviation topics, airline ops ect, and two days of Level D Sim training in a transport category aircraft with an MTOW above 40,000lb. It runs about $5k plus accommodations and there are only a couple places currently certified that hold out to the public. A course completion certificate allows you to take the ATP ME written. Now they have developed a different written for the ATPME vs any other category/class. Really a good rule I think but it neglects any experience in lieu.
 
Just waiting on a response from the FAA now. I've got a strong case and plenty of support. The way I read it, since this affects licensing, I may be able to take this to the NTSB for independent review if the FAA declines my petition under the Pilots Bill of Rights. My lawyer said we would look into pursuing that option if it gets that far. Fingers crossed.

http://www.regulations.gov/#!docketDetail;D=FAA-2015-2192
 
Just waiting on a response from the FAA now. I've got a strong case and plenty of support. The way I read it, since this affects licensing, I may be able to take this to the NTSB for independent review if the FAA declines my petition under the Pilots Bill of Rights. My lawyer said we would look into pursuing that option if it gets that far. Fingers crossed.

http://www.regulations.gov/#!docketDetail;D=FAA-2015-2192

Refresh my recollection on why you need this? Most employers that will require the ATP-ME will provide the required CTP training, at least the regionals will.

Just curious.
 
Refresh my recollection on why you need this? Most employers that will require the ATP-ME will provide the required CTP training, at least the regionals will.

Just curious.

I think he is just trying to prove a point. Also I believe he doesn't want to go to the regionals.
 
Who else is requiring ATP-ME? :dunno:

Most part 91 and all scheduled 135 operators to be pic. Which is garbage because ATP is "airline transport pilot" not, "satisfies the insurance so you gotta have it pilot "
 
Place I work for doesn't require it, but I have yet to meet another pilot here without a real ATP ME.
 
Most part 91 and all scheduled 135 operators to be pic. Which is garbage because ATP is "airline transport pilot" not, "satisfies the insurance so you gotta have it pilot "

Bingo bango. Marketability, I'm not planning on going to the regionals. I have a buddy at gojet brought home $18k last year gone 240+ days. I'm a 3,500hr ATP and honestly think I'm worth more than that. Can't pay off $140k riddle degree and live on that. I'm eyeballing a 135 that has a king air 200 with a citation in certification. I'm teaching and flying a cirrus 91 for a construction company in ATL that may move to turboprop here soon, making more than double my buddy at gojet and I'm gone about 80 days a year. The new ATP written is even different for 135 ops from what I understand.

And yes, to make a valid point.
 
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Most part 91 and all scheduled 135 operators to be pic. Which is garbage because ATP is "airline transport pilot" not, "satisfies the insurance so you gotta have it pilot "
It's a delineation for weeding people out. Put yourself in managements position.. Two people qualified and about equal in all other categories. One gas an ATPL, the other CPL. Which would you hire?
 
Bingo bango. Marketability, I'm not planning on going to the regionals. I have a buddy at gojet brought home $18k last year gone 240+ days. I'm a 3,500hr ATP and honestly think I'm worth more than that. Can't pay off $140k riddle degree and live on that. I'm eyeballing a 135 that has a king air 200 with a citation in certification. I'm teaching and flying a cirrus 91 for a construction company in ATL that may move to turboprop here soon, making more than double my buddy at gojet and I'm gone about 80 days a year. The new ATP written is even different for 135 ops from what I understand.

And yes, to make a valid point.
Lol!!! Ahhh... GoJet is not recognized as the bar setter. Not sure, but I think you can get hired there with a PPL, three FAA violations, nine DUI's, and three felonies.
 
Lol!!! Ahhh... GoJet is not recognized as the bar setter. Not sure, but I think you can get hired there with a PPL, three FAA violations, nine DUI's, and three felonies.

So, you're saying I'd have a shot?? :D

His buddy could double his salary at most other regionals.
 
He claims a bump to $35k for year two. We shall see. He's probably got the DUIs and felonies come to think LOL
 
Lol!!! Ahhh... GoJet is not recognized as the bar setter. Not sure, but I think you can get hired there with a PPL, three FAA violations, nine DUI's, and three felonies.

LOL I can assure you that would not happen.
 
Well, took 20 months to get a denial on the exemption on the grounds that exempting pilots from training is not in the interest of safety and therefore not in the public interest. There's more detail in the denial which I would post if I could figure out how, to include that a king air isn't representative enough of a 40,000lb transport category aircraft and that university level aviation courses neglect to cover airline procedures. They blanket this rule for 135/91 operators where insurance and job applications look for the ATPME.

They state that I had the opportunity to retake the old written exam and "reset" the clock on the exam expiration. However, for an airman to assume the FAA would create a rule to retroactively invalidate previously completed testing requirements with no grandfathering provision in total disregard for precedence among nearly every type of licensing is unreasonable. Regardless of my previous training and education, I met those requirements under the old rule and should have been afforded some reasonable time period to take the multi engine practical exam.


Review by one person with authority issued by the administrator to deny an exemption to someone who has been unjustly harmed by a regulation is not due process. The denial even stated falsely that the time required as a pilot did not increase for ATP with the rule change.

This is a regulatory issue and not really an issue for exemptions. My only option going forward may be to appeal to the NTSB as the FAA is going to fall back deny on "safety/public interest" regardless of the circumstances related to the exemption. The rule is unjust and is contrary to precedence.
 
Well, took 20 months to get a denial on the exemption on the grounds that exempting pilots from training is not in the interest of safety and therefore not in the public interest. There's more detail in the denial which I would post if I could figure out how, to include that a king air isn't representative enough of a 40,000lb transport category aircraft and that university level aviation courses neglect to cover airline procedures. They blanket this rule for 135/91 operators where insurance and job applications look for the ATPME.
Why wouldn't they? An ATP-ME is an ATP-ME. You want a provision for a "Pretend ATP-ME"?

They state that I had the opportunity to retake the old written exam and "reset" the clock on the exam expiration. However, for an airman to assume the FAA would create a rule to retroactively invalidate previously completed testing requirements with no grandfathering provision in total disregard for precedence among nearly every type of licensing is unreasonable. Regardless of my previous training and education, I met those requirements under the old rule and should have been afforded some reasonable time period to take the multi engine practical exam.
You had a year after the rule was enacted. How much time do you consider "reasonable"?


Review by one person with authority issued by the administrator to deny an exemption to someone who has been unjustly harmed by a regulation is not due process. The denial even stated falsely that the time required as a pilot did not increase for ATP with the rule change.
What was the previous time requirement, and what is it now?

This is a regulatory issue and not really an issue for exemptions. My only option going forward may be to appeal to the NTSB as the FAA is going to fall back deny on "safety/public interest" regardless of the circumstances related to the exemption. The rule is unjust and is contrary to precedence.
IIRC, the reason for the rule change is that Congress determined the precedent to not be in the public interest.
 
Is this where I say I told ya so?
 
What is happening is that the faa does not want people that do not NEED an ATP to have one. So by adding the requirements, which does not effect the airlines, except for the time requirements, they make it so the only realistic way to get the rating is through a 121 operator.
 
Cleverly disguised by requiring more pilots to be ATPs sooner.:rolleyes:
 
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Review by one person with authority issued by the administrator to deny an exemption to someone who has been unjustly harmed by a regulation is not due process.

Anyone who's been around aviation long enough to qualify for an ATP knows there's virtually no due-process involved in aviation regulatory actions, and never has been.

Not sure why you'd be surprised by this at your stage of the game.

My only option going forward may be to appeal to the NTSB as the FAA is going to fall back deny on "safety/public interest" regardless of the circumstances related to the exemption.

See? You knew... you also know what your odds are before an ALJ or the NTSB... just sayin'...
 
Yeah, I knew what would likely come but halfway believed someone would notice what was really going on here was merely more security theater to the benefit of lining the pockets of those approved to give the course and take notice that there was no grandfathering clause, as in common place in most licensing systems. All of this process was done mostly out of principal with at best I'd get grandfathered and at worst I'd get a "no, get back in line". I don't NEED an ATP to fly transport aircraft, I NEED one because the 135/91 operators and their insurance companies require it anyway. Maybe that will change for non-121 pilots in the future.

Before the time for atp was 500 hours and now it's 1500 hours for an unrestricted atp, 1000 for a restricted one I believe. The moment the rule went live in July 2014, the new test and CTP went active and I was unknowingly precluded from adding ME privileges because there was no grandfathering clause. The way I read part 61, I wasn't required to do anything but a practical exam. This is merely their interpretation of the rule. Why would I voluntarily retake a written I already took and hold a certificate for? Why would I have any reason to believe I would need to when I have an ATP card in my pocket? I wouldn't retake a written if I held a private or commercial and wanted to add another category/class in the future. I just got duped. And it sucks. But momma always said life ain't fair however I'm a die hard for this kind of stuff (probably should have went to law school haha!) The precedent wasn't satisfactory of public interest for 50+ years of refinement to its condition at the time? That's the purpose of precedence, to give a prediction of outcome based on a set of facts. It sort of grounds the rule of law so that it's not arbitrary in similar situations.

I know there's no due process inside of these administrations but the POBR is slowly changing the game IMO.

I called flight safety in Atlanta, $4500 for the CTP course and they are booked out through march. Lucrative gig apparently. Follow the money trail to find the real truth... shame.
 
Cleverly disguised by requiring more pilots to be ATPs sooner.:rolleyes:

requiring an ATP in the right seat was congress, not the FAA. The only real effect that had on 121 ops was they could no longer hire people with less than 1500 ( or 1000 if they qualify for a RATP) because 121 has trained/checked to ATP standards. It is really only paper work to issue an ATP and a type to a right seater. its three additional maneuvers on the check ride. for the operators that have gone to loft/maneuver style training it is really only two, the right seater has to taxi and do a rejected TO.

bob
 
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