Foreign Flight Engineer Licence Conversion with Logbook Gaps
Mr. Adeyemi, aged 24, applies to the NCAA for a Flight Engineer licence with a Boeing 727 rating. He holds a foreign Flight Engineer licence with a B727 rating, issued by a State whose licences Nigeria accepts for verification purposes, and completed an approved Flight Engineer course in 2023. His logbook shows 1,050 total hours, of which 310 are entered as Flight Engineer time. However, 90 of those 310 hours are annotated 'second observer' and signed by a company check engineer who was not listed on the flight crew for those sectors. His Class 1 medical certificate was issued 13 months ago. His foreign licence carries an English language proficiency endorsement that expired four months ago. The operator wants him on line in 10 days and asks NCAA to 'process urgently'. A licensing officer must decide what can be accepted.
1. Identify the licensing deficiencies in this file and distinguish those that are substantive from those that are evidentiary. What should the licensing officer do before issuing the B727 Flight Engineer licence?
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The officer should test each requirement independently rather than treating the file as a package.
- Medical: A Class 1 medical certificate must be valid for the privilege being issued. A certificate issued 13 months ago is outside the normal 12-month validity for this age group, so the applicant does not currently hold a valid medical. This is substantive: no licence may be issued until a fresh Class 1 certificate is produced and verified.
- Language: The English proficiency endorsement has expired. Language proficiency is a licensing requirement, not a company preference. The officer should require a current endorsement or an approved language assessment before issue.
- Experience: The 310 hours cannot be accepted at face value. 'Second observer' time is not normally creditable as Flight Engineer flight time because the person was not occupying the FE station and performing FE duties. The officer should recompute credited FE time, excluding the 90 hours unless the applicant can produce flight records, crew manifests and training records showing approved FE duties. If the remaining 220 hours still meets the applicable minimum and the type course is valid, the issue is evidentiary rather than disqualifying.
- Foreign licence: Verification with the issuing authority is required. A foreign type rating does not automatically convert; the NCAA may require a skill test or additional type training.
Decision: do not issue on the operator's timeline. Issue only when medical, language, verified logbook and any required skill test are complete.
2. The operator argues that the 90 'second observer' hours should count because a check engineer signed them. How should the NCAA treat this claim?
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A signature proves only that someone wrote an entry; it does not prove the capacity in which the applicant flew. The key question is whether the applicant occupied the Flight Engineer station and performed FE duties, or was carried as an additional observer.
The NCAA should:
- Request the operator's crew manifests, dispatch records and flight-time records for the 90 sectors.
- Compare those records with the logbook entries and interview the check engineer and the pilots on those flights.
- Ask whether the operator had an approved training or observation scheme that permitted crediting observer time. Without such approval, the hours are not FE flight time.
- If the entries are honestly annotated but wrongly claimed as FE time, correct the logbook and recompute experience. If they were altered or misrepresented to obtain a licence, treat it as a logbook falsification matter and refer for enforcement.
The check engineer's personal signature does not cure the deficiency, and company urgency is irrelevant to the licensing decision.
3. Can the licensing officer issue the licence with a restriction pending renewal of the medical and language endorsement?
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No. A restriction is not a substitute for a mandatory licence requirement. The medical certificate and language proficiency are conditions of holding the licence, not optional endorsements that can be deferred by administrative note.
The officer may:
- Advise the applicant to renew the Class 1 medical and obtain a current English proficiency endorsement or assessment.
- Continue processing the parts of the file that are independent of those items, such as foreign licence verification and logbook reconciliation.
- Issue the licence only when all requirements are satisfied on the date of issue.
A temporary or restricted document should not be invented locally unless the Nig. CARs and NCAA-AC-PEL 018 specifically provide for it. The operator should be told in writing that the applicant cannot exercise FE privileges until the licence is issued, and that allowing him to fly on the foreign licence without validation would create a separate enforcement exposure.