Expired RTR Licence Before a Controlled Departure
A pilot passed the RTR(A) examination and received a licence with an expiry date. Fourteen months later, while preparing for a cross-country flight, the pilot notices the licence expired 18 days ago. The renewal application has been submitted but no new licence has arrived. The aircraft is at a controlled aerodrome and the pilot is scheduled to fly with an instructor who holds a valid RTR(A) licence. The pilot plans to make the departure call, because 'the examiner said the application number is enough.' The tower frequency is busy and the instructor is completing the walk-around. The pilot must decide who may operate the aircraft radio, what to do if the instructor is delayed, and what record should be kept. The flight is private, not commercial, and the aircraft has a single VHF radio.
1. May the pilot operate the aircraft radio for the departure call? Explain.
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No. The pilot should not operate the aircraft radio on the strength of an expired licence or a renewal application number. The RTR(A) licence is a personal authorisation, and its privileges depend on the licence being valid. A submitted renewal application is evidence that a renewal process is under way, but it is not the licence itself and does not by itself restore operating privileges.
The instructor, who holds a valid RTR(A) licence, may operate the radio. The pilot may still perform cockpit duties that do not require radio transmission, but the pilot should not make the departure call, read back clearances, or handle ATC communications unless another valid licence holder is operating the radio. The pilot's own logbook or training record should not be used as a substitute for the licence.
2. What should the pilot do if the instructor is delayed and the aircraft is ready to depart?
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The pilot should delay the departure or arrange for another valid RTR(A) licence holder to operate the radio. At a controlled aerodrome, a departure without the required radio communications is not appropriate merely because the aircraft is ready. Do not make the call and then hand over to the instructor after start-up; the initial call and any clearance readback must be handled by a person who is authorised at the time of transmission.
If the delay is short, remain at the parking position and keep the frequency monitored. If the delay becomes significant, inform the operator or flying school and reschedule. Do not use a mobile phone to obtain a clearance as a substitute for aircraft radio communications unless an approved procedure and the controller specifically allow it. The safe decision is to wait rather than create an unauthorised transmission.
3. What records or actions should be taken before flight, and what should be avoided?
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Before flight, confirm that the person who will operate the radio has a valid, in-date RTR(A) licence and is named in the flight documentation as appropriate. Keep a copy of the valid licence with the flight documents or in a place acceptable to the operator. Record the licence details in the training or flight record if the operator requires it. The pilot whose licence has expired should keep evidence of the renewal application separately, but should not present it as a valid licence.
Avoid relying on verbal reassurance such as 'the application number is enough'. Avoid allowing the pilot to make 'just one call' because the frequency is busy. If the instructor later takes over, there should be a clear handover of radio duties, including the current frequency, clearance, and any pending readback. If there is doubt about validity, the conservative action is to stop and verify before transmitting.