COMMENTS

on DRAFT
NATIONAL
CIVIL AVIATION
POLICY 2015

NOVEMBER 2015

INTRODUCTION
Indian Aviation has grown leaps and bounds ever since the government of India opened aviation
to the private sector during the early 90's. India witnessed its first aviation boom back then with
the advent of numerous private airlines. The first boom soon turned into a bust by the late 90's
and many private airlines shut down with only one or two private carriers remaining.
Indian aviation witnessed its second boom with the introduction of low cost carriers from 2004 to
2007. This period led to an explosive growth and brought flying to the doorsteps of the middle
class who were finally given an opportunity to taste the freedom of flight.
This boom turned into a bust as well due to the Global Financial Crisis of 2008 and the oil price
hike.
Unfortunately the after effects of the last bust are still being felt in Indian aviation. Airlines are
still struggling to pay off debt and some operators have shut down leaving huge debts still to be
paid off.
It has led to thousands of pilots being unemployed many of whom still dream of making a
career in aviation. It has affected their lives significantly and taken away a good part of their
youth searching for decent employment.
While Indian aviation is on the verge of the next boom its foundations on which it relies upon are
still shaky. If we are to prevent another bust in Indian aviation we must fix its problems at the
earliest. Indian Aviation is burdened with huge taxes both at the central and state government
level. It is also burdened with rules and regulations the kind of which never seen anywhere else in
the world and given step motherly treatment to many of its issues.
India is blessed with a huge opportunity for growth in the aviation industry which can result in
removing unemployment among the masses and providing air travel to each and every citizen
and make a huge impact on its economic growth.
In order to realize this potential the Government of India and the Ministry of Civil aviation need
to cut down the shackles which prevent Indian aviation from growing rapidly.
India's Aviation problems are mostly man made and hence can be easily solved, provided, there is
a will to solve them. Only certain factors like crude oil prices remain outside the realm of control
of the Government of India.
We at the Unemployed Pilots Welfare Association have highlighted several important issues
facing Indian Aviation. We strongly believe that if the Government of India and Ministry of
Civil Aviation implements our recommendations as part of the National Civil Aviation Policy, we
can propel India to become the number one country in Civil Aviation.
Sd/Capt Ashok Arya
President
Unemployed Pilots Welfare Association
upwaindia@gmail.com

TABLE OF CONTENTS
No.

Topic

Page Number

5 Year 20 Aircraft Rule

Taxation

Route Dispersal Guidelines

Airport Charges

Regional Connectivity Scheme & Scheduled Commuter Airlines

DGCA

Unemployment in Civil Aviation

13

Employment in ATC

16

Employment in DGCA

19

10

Employment as Flight Instructor

20

11

5 Year Flying Experience Rule

22

12

Validity of Pilot Licenses

24

13

Validity of Type Rating

25

14

ATPL License

27

15

Cross Country Time

29

16

Pilot License Exams

30

List of Abbreviations

AAI

Airports Authority of India

AAIB

Aircraft Accident Investigation Bureau

AFIR

Assistant Flight Instructor Rating

AI

Air India

ATC

Air Traffic Control

ATF

Aviation Turbine Fuel

ATPL

Airline Transport Pilot License

AUW

All Up Weight

CAA

Civil Aviation Authority

CAR

Civil Aviation Requirements

CASA

Civil Aviation Safety Authority ( Australia)

CPL

Commercial Pilot License

DFC

Domestic Flying Credits

DFT

Directorate of Flying Training

DGCA

Directorate General of Civil Aviation

DTL

Directorate of Training and Licensing

EASA

European Aviation Safety Agency ( European Union )

FAA

Federal Aviation Administration ( U.S.A )

FIR

Flight Instructor Rating

FSD

Flight Standards Directorate

GST

Goods and Services Tax

ICAO

International Civil Aviation Organization

IR

Instrument Rating

MoCA

Ministry of Civil Aviation

NCAP

National Civil Aviation Policy

nm

Nautical Mile

OMR

Optical Mark Recognition

PIC

Pilot In Command

PMO

Prime Ministers Office

PPC

Pilot Proficiency Check

PPL

Private Pilot License

PPP

Public Private Partnership

RBI

Reserve Bank of India

RCS

Regional Connectivity Scheme

RDG

Route Dispersal Guidelines

SCA

Scheduled Commuter Airlines

SEBI

Securities & Exchange Board of India

SIC

Second In Command

TRE

Type Rating Examiner

TRI

Type Rating Instructor

UPSC

Union Public Service Commission

VAT

Value Added Tax

VGF

Viability Gap Funding

INDIAN AVIATION
INDUSTRY
REFORMS

5 YEAR 20 AIRCRAFT RULE

a) The 5 year 20 aircraft rule required by the Civil Aviation Ministry in order to allow a
scheduled airline to fly to international destinations is an unfortunate and regressive rule that
prevented the growth of Indian carriers from achieving its potential in International Aviation. It
was introduced to prevent competition for flights in the international sector.
1) No other country in the world imposes such a rule on its scheduled airlines.
2) This same rule is not applicable to foreign airlines flying into India.
3) We would like to remind the Ministry of Civil Aviation that India has thousands of
unemployed pilots whose numbers keep growing. Indian Aviation needs to undergo rapid
growth within a short period of time in order to absorb all these unemployed pilots.
4) The 5/20 rule is one of the primary reasons that India's scheduled airlines could not grow
despite huge demand in the international sector. Removal of this rule will help Indian Aviation
to grow rapidly thus absorbing a huge number of unemployed pilots.
5) It is in public interest that the Government of India via the Ministry of Civil Aviation
remove rules and regulations that keep the citizens of India unemployed. Removal of this rule
will bring jobs not only to pilots but even to engineers, cabin crew, ground staff etc. It cannot be
overemphasized by saying generation of Employment is the need of the hour .
6) Certain airlines have argued for a level playing field saying that they had to suffer these rules
before being allowed to fly abroad. Going by this logic then there would be no need for any
reforms at all because any reforms that remove suffering will always benefit new businesses. This
argument for maintaining status quo goes against the Objectives mentioned in the Draft NCAP
2015 i.e iii) Enhance ease of doing business through deregulation, simplified procedures and e-governance .
7) The Domestic Flying Credits ( DFC ) concept introduced in the draft would also be another
unnecessary and complicated rule. This would also put an Indian airline at an unfair
disadvantage when pitted against a foreign airline that does not suffer such a rule in their own
country. The DFC concept would again be against the above mentioned objective of ease of
doing business.
8) There should not be a scenario where Open Skies as mentioned in the bilateral scheme coexists with the 5/20 rule. This will put Indian Airlines at a serious disadvantage while foreign
airlines take advantage of the artificial restrictions imposed on Indian airlines.
REFORM :
We strongly request the Government of India and the Ministry of Civil Aviation to remove the
5 Year 20 Aircraft rule once and for all in public interest and for the sake of the thousands of
unemployed citizens of India who will benefit immensely with the rapid growth in Indian
Aviation that will follow with the removal of this rule.
1

TAXATION
a) While the draft addresses taxation issues in order to make RCS routes viable it has ignored the
major issues in ATF taxation. Other minor taxation issues have also been ignored.
b) It is unfortunate that the policy document after months of deliberation has completely ignored
the single biggest factor that is responsible for the losses in Indian Aviation.
1) VAT on ATF charged by individual states in India is the single biggest reason for the all the
losses suffered in Indian Aviation so far.
2) Airlines are forced to raise airfares in order to cover these costs thus severely affecting
demand. This in turn has contributed to the huge losses in the entire Indian Aviation industry.
3) The losses suffered in Indian aviation on account of high ATF prices is the single biggest
factor responsible for thousands of unemployed pilots in India.
4) The draft NCAP 2015 vision of bringing affordable flying to the middle class will not be
achieved if airfares remain high on non RCS routes.
5) The number of 300 million passengers flying annually as envisioned in the
policy will unfortunately remain a distant dream if ATF taxation is not
addressed.
6) It is not enough that airfares be low only on regional routes but also on busy metro to metro
routes and from metro to non metro routes where the bulk of demand for air travel lies.
7) Customs duty on ATF is another factor that contributes to difficulty in doing business as
airplanes are forced to wait at airports until customs duty is paid. This cheaper ATF from
abroad can easily lower costs for Indian Aviation but instead airlines and other operators are
forced to pay this duty which instead could have been used for offering cheaper airfares
domestically.
8) Customs duty collected from ATF F.Y 2014 - 2015 was a mere 59 crore when compared to
the 74,465 core collected via central government duty on petroleum products. This customs
duty only contributed to 0.07% to the overall tax collection on petroleum products.
http://articles.economictimes.indiatimes.com/2015-05-08/news/61947751_1_excisecollection-petrol-and-diesel-litre
9) Avgas which is needed to operate piston engined aircraft is 300% - 500% more expensive
than ATF in India. This is due to the high VAT and customs duty on the same. Avgas prices
need to be brought down on par with ATF in order to encourage the growth of General
Aviation.

 10) High cost on ATF prevents the development of airport hubs in India.
11) An Indian airline with a hub in India has to pay very high ATF prices in order to carry a
passenger between a domestic airport and a domestic hub. For example when a passenger
wishes to fly from Chennai to London via a Delhi hub, the airline has to pay very high ATF
prices for carrying the passenger from Chennai to Delhi. On the Delhi to London sector the
airline pays much lower ATF prices since VAT is not charged on ATF for international flights.
12) An international airline with a hub outside India can carry passengers to their hubs and
further onwards to their destination with a much lower cost since they dont have to pay the
more expensive ATF prices as an Indian airline with a domestic hub.
http://dgca.nic.in/aic/aic03_2003.pdf
13) This puts Indian carriers with a hub in India at a significant disadvantage as they have to
charge higher fares than their international counterparts in order to meet the expensive
domestic costs on ATF.
14) The proposal for open skies if implemented will significantly put Indian carriers with a hub
in India at a disadvantage if domestic ATF prices are not bought on par to that when flying to
international destinations from India.
15) The 20% growth in passenger numbers that India has been experiencing over the past one
year can primarily be attributed to low fares as result of lower ATF prices. If ATF prices were
to go back up then airlines will be forced to raise airfares thus affecting growth and the
economy as a whole.
16) It would be much easier for the Government of India to bring ATF under declared goods
at present when crude prices are low and hence revenue earned on VAT from ATF is low. If
crude were to go higher it would be much harder to negotiate with the State governments.

REFORM :
1) ATF and Avgas should be given " declared goods " status so that states dont charge more
than 5% VAT.
2) With the advent of GST, states will also receive 50% of the tax on sale of air tickets, airport
charges and other businesses that deal in aviation from nil today.
3) Excise duty on ATF should reduced to a specific one Rupee per litre instead of ad valorem at
present. This way ATF prices wont rise exponentially as and when crude oil price rises.
4) Customs duty on ATF and Avgas should be abolished completely. The amount earned on
ATF as shown above is negligible but has wide reaching negative consequences for the aviation
industry as a whole.
5) Customs duty on import of aircraft ( irrespective of the category ) and spare parts should be
abolished completely.
6) Customs duty on equipment needed to build and operate infrastructure needed for the
Aviation industry should be abolished completely.
7) There should be no service tax ( or GST ) on schools or institutes that provide skill
development for the aviation industry.
8) Avgas prices should be regulated as the same is only imported in India and not locally
manufactured. Lack of competition in supply of Avgas has resulted in undue gains to the Oil
Marketing Companies at the expense of General Aviation and Flying Training Institutes in
India.
9) ATF prices by Oil Marketing Companies need to be brought on par with other countries like
Singapore where fuel is imported.
c) We believe both the Central and State government should take a cut in revenue from taxes on
aviation fuel and lubricants for the sake of bringing affordable flying to masses and to the
hinterlands of India in addition to generating employment for thousands of Indian citizens.
d) We humbly request the Government of India to pay heed to the above mentioned
reforms as implementing them would provide necessary relief to a heavily taxed
industry. This would also result in the generation of thousands of jobs due to the
explosive growth that would result when the above mentioned reforms are
implemented.

ROUTE DISPERSAL GUIDELINES

a) The Ministry of Civil Aviation introduced the Route Dispersal Guidelines ( RDG ) after
allowing private companies to setup scheduled airlines back in the early 90's. This was intended
to provide connectivity to unviable remote locations that are otherwise difficult to access by road
or rail and various other reasons.
b) However one cannot ignore the fact that the RDG causes significant financial burden on
airlines and at the same time. We believe the following arguments should convince the Ministry of
Civil Aviation for doing away with the Route Dispersal Guidelines.
1) The RDG is a significant financial burden in an industry that suffers from high cost and low
margins and is known for high financial losses world over.
2) Due to the losses airlines have to suffer while flying unviable routes, they are forced to raise
the airfares on other routes. Raising airfares affects demand thus forcing airlines to fly empty
seats. This negatively affects consumers. This also forces airlines to charge very high airfares to
consumers who need to book an air ticket for immediate travel.
3) RDG does not differentiate the various business models in the airline industry like Full
Service Carriers and Low Cost Carriers. It expects even full service carriers which have higher
cost of operation to ply on routes that would make no business sense whatsoever.
4) RDG prevents airlines from making business plans that service particular markets. A good
example would be where the Government of Kerala in partnership with Cochin International
Airport plans to setup an airline that serves exclusively to Non Resident Indians who live and
work in middle eastern countries. RDG would make it unviable for such an airline to exist.
5) While the national carrier Air India can afford to fly unviable routes as its losses are funded
by taxpayers money there is no entity to fund the losses flown by private carriers. while flying
on RDG routes. This imbalance severely distorts the market and destroys the level playing field
necessary for airlines to compete.
6) We would like to use this opportunity to remind the Ministry of Civil Aviation that during
first boom period in Indian Civil Aviation during 1990's a lot of private airlines had to shut
down due to introduction of RDG. This forced a lot of airlines to dump capacity on routes
where little to no demand existed due to the state of the Indian economy at the time.
7) Vayudoot is another example of an airline that flew many routes with little to no demand
and eventually had to merge with the erstwhile Indian Airlines due to the huge losses flown on
such routes.
8) RDG is nothing more than a remnant of the License Raj era and should be done away with if
MoCA intends to bring ease of doing business in civil aviation.

 9) The proposed 2% cess on airfare to fund regional connectivity would be a double burden on
the industry when it is combined with the losses on the RDG routes.
10) The airlines alone share the burden of flying on loss making RDG routes. Airports, ATC,
Tax authorities, ATF suppliers etc all extract their pound of flesh and do not share this burden.
c) We have suggested the necessary reforms needed in this regard which we believe will give a
boost to regional connectivity and minimize losses at the same time.
d) As mentioned earlier forced losses on the Aviation Industry in India has prevented it from
reaching its growth potential and kept thousands of pilots unemployed.
e) If the reforms mentioned are implemented then this will help remove unemployment in the
Aviation Industry and reduce losses suffered by the industry.

REFORM :
1) The Ministry of Civil Aviation should remove the Route Dispersal Guidelines once and for
all. It should not interfere in the business models of private airlines and should give them the
freedom to run the airline on routes as they see fit.
2) Government of India via the Ministry of Civil Aviation which has its own scheduled airline
Air India and its subsidiaries should be used to meet its goals of regional connectivity. This
would be a better use of tax payers money than plying capacity on loss making routes which
have adequate connectivity at present.
3) There should be no Value Added Tax, Excise or Customs duty, fuel throughput charges on
ATF for aircraft flying on unviable routes.
4) The ministry should exempt landing and parking charges on these routes. This should be
applicable both at the origin and at the destination airports.
5) These routes should be exempt from paying Route Navigation charges.
6) There should be nil service tax ( or GST whenever it is introduced ) on such routes.
7) An example of this would be an Air India flight flying from Chennai to Port Blair and back
should be exempt from paying taxes on ATF, exempt from paying airport charges at both
Chennai and Port Blair and exempt from route navigation and service tax ( or GST ) as well.
8) The losses made on unviable routes should be borne by all the stake holders that provide
aviation services and not just the scheduled airlines alone.
9) Oil Marketing companies should provide a discount on ATF to aircraft flying unviable
routes.

AIRPORT CHARGES
a) We appreciate MoCA's efforts in bringing down the airport charges in India which are very
high vis--vis airport charges at other international airports. This is of particular importance
because airport charges during the last 5 years have grown exponentially.
1) We are disappointed that MoCA has proposed the Hybrid Till model for airport charges
instead of the Single Till model.
2) The Hybrid Till model is against consumer and airline operator interests and is
singlehandedly responsible for the huge airport charges that India is experiencing today.
3) This has resulted in very high airfares when flying into and out of PPP airports thus affecting
demand, contributing to losses and partially responsible for the thousands of unemployed
pilots in India.
4) India being a developing country with a low purchasing power cannot afford a Hybrid Till
model if MoCA wishes to bring affordable flying to the middle class of India.
5) If developed countries with high labour charges can build and operate private airports with
Single Till model then there is absolutely no reason why the same cannot be implemented in
India.
6) Hybrid Till model would prevent Indian Aviation from achieving its potential by making
airfares and airport charges unaffordable for the common man.
REFORM :
1) MoCA should adopt Single Till model for all future airports including the upcoming airport
in Navi Mumbai.
2) Contracts for existing airports under PPP model should only be renewed if the operator
agrees to Single Till model.
3) In order to promote the growth of General Aviation all aircraft ( Scheduled, Non Scheduled,
Private etc ) with AUW below 5700 kg should be exempt from landing and parking charges at
all airports in India.
4) MoCA should abandon the practice of awarding brownfield airports to private companies
on the basis of revenue share model. This is model is single handedly responsible for the very
high charges that one witnesses today at Delhi and Mumbai airports.
5) MoCA should ban Fuel Throughput fees at all airports in India as it has nothing to do with
the cost of operations and is only a market access fee.
7

REGIONAL CONNECTIVITY
SCHEME & SCHEDULED
COMMUTER AIRLINES
a) Going through the draft policy document we understand that the Ministry of Civil Aviation
wishes to start a new category of airlines called Scheduled Commuter Airlines ( SCA ) which will
make use of the Regional Connectivity Scheme ( RCS ).
b) From out understanding of the draft policy wording RCS routes are over and above the routes
that form part of the Rout Dispersal Guidelines ( RDG ).
1) We find it unnecessary to introduce an all new category of airline just for the sake of
obtaining viability gap funding ( VGF ) for flying on Regional Connectivity Routes.
2) Existing airlines should be allowed to bid for VGF irrespective of the number of seats on the
aircraft they use for operations. It should not be limited to 100 seats as given in the policy
document.
3) The number of aircraft and capital requirements for Regional Scheduled airlines may be
reduced to match that of the proposed SCA.
4) The 2% cess on existing scheduled airlines is a double burden when the industry also has to
stick to the Route Dispersal Guidelines. Either RDG OR RCS should exist. Both should not
exist simultaneously.
5) Should MoCA remove the RDG once and for all then the 2% cess would not be a significant
burden on the existing airlines.
6) The concessions to be provided by stakeholders on RCS routes should be made available to
all airlines flying on RCS routes irrespective of whether they avail of VGF.
7) Airports on RCS routes should be developed with runways to handle a narrow body aircraft
of Boeing B737 or Airbus A320 type or similar. The runways should be long enough to handle
takeoffs and landings with a full load of passengers and cargo in all weather conditions.

DGCA
a) The DGCA is the primary organization in India responsible for Aviation safety. However it
also deals with many approvals, permits, licenses etc.
b) It is unfortunate that the draft civil aviation policy has omitted major reforms necessary for
running the DGCA in the modern era.
c) That DGCA has earned itself a bad reputation both inside and outside India for corruption,
bureaucracy, lethargic attitude to issues in Indian aviation and acting in a dictatorial manner.
These are characteristics that should not be even be rumored for an organization whose primary
job is one that deals with aviation safety.
d) Ease of doing business in Indian aviation is seriously hampered with the way the DGCA is run
at present.
1) Its organizational structure has not kept pace with the growth of Indian Aviation and and it
has become outstretched beyond its capabilities.
2) It is heavily dependent upon mountains of paperwork.
3) Many disputes keep arising between stakeholders and DGCA due to lack of clarity in the
rules.
4) Pilots are made to run from pillar to post in order to get their licenses issued or renewed or
endorsed.
5) No other country in the world makes its pilots suffer as much as the Indian DGCA.
6) Since the DGCA is headquartered in New Delhi every pilot has to visit New Delhi in order
to get their problems solved.
7) The DGCA rules and regulations are archaic and not in sync with rest of the world.
8) This has made life difficult for everyone from airlines to pilots to engineers when dealing with
the DGCA.
9) Many rules and regulations created by DGCA are made by people who have no technical
qualification or knowledge in the subject area whatsoever and the stakeholders end up suffering.
10) Many rules and regulations also contradict each other creating further confusion.
11) The rules are interpreted as the DGCA sees fit which is a cause for significant disputes with
the stakeholders.
12) There is no time bound delivery of services offered by the DGCA. Even though the DGCA
has a citizens charter, it only exists on paper and not in practice.

 13) Since the DGCA is not an independent organization a conflict of interest exists as the
DGCA falls under the same ministry that owns Air India, AAI and its subsidiaries. This severely
affects DGCA's duty towards its job as a safety regulator.
14) The Director General keeps changing frequently which hampers necessary reforms. The
working of the Director General is also hampered by political clout or influence.
15) DGCA procedures for a license or permit are designed in such a way that treats every
applicant guilty unless proved innocent.
16) Stakeholders are afraid against speaking or complaining about DGCA for fear of life being made difficult
later when having to deal with the DGCA.
17) The downgrading of the DGCA by the FAA to category 2 status is a testimony to how the
organization is run. It took a foreign authority for the government to sit and take notice that
something is wrong in the DGCA.
18) The Indian DGCA has a bad reputation not only within India but also outside India. This
has caused significant harm to stakeholders why flying abroad or to unemployed pilots when
seeking jobs abroad.
19) Some foreign operators wont even consider applications from unemployed pilots in India
simply due to the reputation of the DGCA.

REFORM :
1) In the light of the above mentioned points now is a good time as any to replace the DGCA
with an independent Civil Aviation Authority ( CAA ) on the likes of RBI, SEBI etc.
2) This new CAA should be independent in making rules and decisions and should have
financial autonomy as well. It should not be under any ministry of the Government of India.
3) It should be lead by a Technocrat who has experience in dealing with aviation as a
stakeholder or as a consultant. The technocrat should only be hired by the PMO. The
technocrat should be given a long tenure of at least 10 years or more.
4) It should be allowed to set standards necessary to hire and fire employees as deemed fit.
5) It should be given the freedom to set salaries as per market conditions so as to hire the best
talent needed for the job.
6) It should be decentralized. Every state in India should have a local wing for issue of licenses
and approvals. That way stakeholders won't have to run to New Delhi every single time.
7) Any disputes should be resolved by visiting the local offices.

10

 8) The rules and regulations should be written from the ground up and harmonized with rules
similar to FAA, EASA, CASA etc. Stakeholders must be consulted at the time of writing the
rules and a consensus must evolve before publishing the rules.
9) Any changes to rules or while introducing new rules a draft should be made publicly
available for commenting and all comments should be made publicly available.
10) Pilot licensing rules should reflect ICAO Annex 1 as much as possible.
11) All applications for approvals and licenses should be online only with physical paperwork
completely eliminated.
12) There should be time bound delivery for the services provided. The new CAA employees
should strictly adhere to timelines for delivery of services.
13) Queries and doubts sent via email should be replied to in a time bound manner.
14) An Ombudsman ( preferably a retired High Court or Supreme Court judge ) should be
made available in the new CAA for adjudication of disputes arising from rejection of licenses,
approvals etc. Disputes should be resolved in a time bound manner as well.
15) Since Civil Aviation is a highly technical field the government of India should consider
setting up an Indian Civil Aviation Service so as to train the next generation of citizens who
specialize in civil aviation field.
16) The new Civil Aviation authority should not be another name for the existing DGCA.
17) The government of India should do away with the requirement for security clearance from
the home ministry for pilots who have an OCI card.

e) In the meantime we have highlighted some issues with respect to issue of pilot unemployment
and licenses . We have many more issues to sort out however the few issues we have highlighted
we believe are ones that needs to be changed at the earliest.
f) We request MoCA to study the issues in the next few pages and resolve them at the earliest as
part of the National Civil Aviation policy.

11

UNEMPLOYMENT
ISSUES AND
SOLUTIONS IN
CIVIL AVIATION

UNEMPLOYMENT IN CIVIL
AVIATION
a) When Indian aviation boomed during the 2005 - 2007 period a significant number of India's
citizens jumped on the bandwagon of pilot jobs that became suddenly available at the time.
Many people shifted jobs to pursue their childhood dreams as now jobs were available when
compared to earlier times. Many pilots from yesteryears who could not find jobs during the last
boom renewed their licenses and found jobs once again.
b) The financial crisis of 2008 and the oil price hike hit Indian aviation hard and overnight the
jobs disappeared. This unfortunately left Indian Aviation with thousands of unemployed pilots.
From the years 2008 - 2014 recruitment from airlines were mostly static as majority of them were
loss making. The few airlines that made profits did recruit but they were too small a number to
make any meaningful impact.
The collapse of Kingfisher Airlines was another major dent that prolonged the unemployment
scenario.
c) The biggest factors that can be attributed to this unemployment scenario are the losses suffered by the airlines in
India due to the huge ATF charges, airport charges and other rules and regulations like 5/20 which prevent growth
in the international market.
- The following are some of the difficulties faced by the unemployed pilots in India.
1) The skills learned as part of learning to become a pilot cannot be used outside of the
Aviation industry. This has led to severe unemployment and underemployment.
2) When applying to non aviation jobs many companies won't hire someone if they find out
that the applicant holds a pilot license for fear of losing them later should a pilot job come their
way.
3) Even some airlines refuse to hire a CPL holder for a non flying job due to the same reason.
4) Many pilots are stuck with huge loans to pay off their pilot training costs.
5) These pilots are unable to find jobs abroad due to the lack of experience needed by foreign
countries/airlines in order to hire a foreigner.
6) Many pilots in India are trained abroad in countries like USA, Canada, Australia, New
Zealand, Philippines etc. They are forced to return to India due to difficulties in obtaining a
work permit.
7) Many airlines charge ridiculously huge costs for type rating upfront thereby preventing many
pilots to join the airline even if they are capable of passing the exams and interviews.
8) In some cases the cost of the type rating far exceeds the cost of becoming a Commercial
Pilot.
9) Many airlines charge huge fees just for the sake of attending an airline assessment. In many
cases the cost of the assessment is more than what a pilot earns from their non flying jobs in a
month.
13

 10) Working in non flying jobs affect pilots when they are called for written exam or interviews
as they dont find the time needed to study for the same.
11) Many pilots are also not granted leave from their non flying jobs in order to attend airline
assessments.
12) The lack of employment opportunities has led to the growth of touts and middlemen who
promise jobs due to their connections in exchange for huge sums of money. Many pilots due to
their desperation have fallen into such traps and lost lakhs of rupees.
13) Since a pilot license is not equivalent to a college degree many pilots who joined flying
schools straight after high school are finding it difficult to find decent jobs.
14) Since aviation industry is only understood by a few, unemployed pilots are stigmatized in
society as unworthy or incapable of becoming a pilot.
15) Many unemployed pilots are unable to provide for their parents once they retire.
16) Since Indian aviation openly practices age discrimination in hiring of fresh pilots ( 35 years old is
the usual limit ) many pilots who obtained a CPL late in life now find themselves too old to
apply for a job.
17) Some extremely unfortunate pilots have been declared permanently unfit during the annual class 1
medical renewals.
18) Some extremely unfortunate pilots have lost a parent who was a significant earning member of
the family. This has either prevented them from continuing their pilot training or converting
their foreign pilot licenses to the Indian DGCA or time spent in working in jobs where they are
too busy to study for an airline pilot assessment.
19) The large unemployment among pilots in India has led to airlines and non scheduled
operators fleecing pilots by charging exorbitant fees either as recruitment cost or type rating
cost. Prior to 2008 most airlines would bear the cost of the type rating and charging to appear
in a recruitment was unheard of in private companies.
d) The above mentioned issues are only a few that are encountered by the many unemployed
pilots in India.
e) We believe that the primary method of alleviating the unemployment problem should be through massive growth
by the airlines, non scheduled and general aviation operators.
f) But for that to happen huge reforms are required in the way Civil Aviation is run today in
India.
g) Since the knowledge and skills learnt as part of becoming commercial pilot have little use
outside the aviation field it is only prudent that they be put into the aviation field itself even
though it might be in non flying jobs.

14

 h) MoCA during the year 1973 had issued a directive to the organizations that operated under
it to hire CPL holders for various posts including but not limited to Assistant Aerodrome
Officers , Airport Officers in the erstwhile International Airports Authority of India and the
National Airports Authority of India. This was continued by AAI until the year 2004.
https://www.dropbox.com/s/crtkouzb1ef67ig/CPL%20Holder%20Airport%20Ad
%20UPSC.pdf ?dl=0
i) Many CPL holders were hired in Air Traffic Control as well.
j) CPL holders were hired into various positions in erstwhile Air India, Indian Airlines,
Vayudoot etc.
k) We believe its time again for MoCA to issue such a directive so as to make use of the vast
untapped talent pool and remove the unemployment in Civil Aviation.
l) This is especially important in light of the fact that MoCA has 44% of its vacancies
unfulfilled as per the 7th Pay Commission report.
http://www.livemint.com/Home-Page/X6U6xFe5oR2pW4simMmAhK/Union-govthas-729000-vacancies-report.html

15

EMPLOYMENT IN ATC
1) India has been facing a perennial shortage of Air Traffic Control ( ATC ) personnel. Despite
numerous recruitments there continues to a shortage of the same. This shortage has caused
numerous incidents in Indian Aviation which is a safety hazard.
http://articles.economictimes.indiatimes.com/2015-08-04/news/65204933_1_atc-controllersport-blair
2) With the rapid growth forecasted for Indian Aviation and increase in number of controlled
airports this shortage will only get worse.
3) Unfortunately AAI at present for arbitrary reasons requires a candidates to have a specific
degree in engineering ( electronics , telecommunications , IT etc ) or in the basic sciences
( Physics , Maths ) .
http://www.aai.aero/employment_news/Recruitment-JE(ATC)andJE(Electronics)_030915.pdf
4) While basic knowledge of math and science might be useful it is not at all compulsory for
the post of ATC controller.
5) If the educational requirements by AAI was absolutely essential in order to become an ATC
controller then other countries would also have had the same or similar requirements.
6) Even AAI's requirement to accept both Engineers and B.Sc degree holders in maths or
physics are contradictory to each other.
a) The unemployed pilots of India are a talent pool that can be tapped easily in order to fill this shortage. The
Government of India has in the past recruited pilots to work in ATC when they experienced
periods of large unemployment. These candidates then went on to have successful careers in
ATC.
b) We have outlined the educational requirements for ATC controllers in a few english speaking
countries which have well developed aviation environments and some handle much more air
traffic than India does today.

i) U.S.A - FAA - Candidate should hold a Bachelor degree in any subject OR 3 years of
progressively responsible work experience.
https://www.faa.gov/jobs/career_fields/aviation_careers/
ii) U.K - NATS - High school pass with grade C or above with Maths and English as subjects.
http://www.nats.aero/careers/trainee-air-traffic-controllers/eligibility/
iii) Canada - NavCanada - High School pass, no requirement for special subjects.
https://takecharge.navcanada.ca/selection-requirements-and-process/basic-requirements
16

 iv) Australia - Air Services Australia - High School pass OR Diploma OR College Degree OR
Pilot license CPL / PPL from either Australia or New Zealand.
http://www.airservicesaustralia.com/careers/air-traffic-controller/air-traffic-control-intraining-program/
v) New Zealand - Airways NZ - High school pass with Maths and English as subjects OR hold
a CPL / PPL from the New Zealand.
https://www.airways.co.nz/careers/train-to-be-an-air-traffic-controller/frequently-askedquestions/

c) In light of the above information it can be very clearly seen that AAI's requirement of either
becoming an engineer OR B.Sc in maths or physics in order to become an ATC controller as
arbitrary.
d) If the above countries can train air traffic controllers without the onerous requirements as
required by AAI, there is absolutely no reason why we can't implement the same in India.
e) Australia and New Zealand are two shining examples of accepting only pilot licenses to work in ATC
- Here are a few advantages when it comes to hiring pilots as air traffic controllers
i) Pilots have first hand experience of flying an aircraft at various airports and in various
weather conditions.
ii) Pilots have experience of flying in both controlled and uncontrolled airspace.
iii) Pilots have the ability to empathize and visualize from the point of view of other pilots.
iv) Pilots have good situational awareness which they develop during their flying training.
v) Pilot have the experience of talking with ATC and hold Radio Telephony licenses where they
are tested on radio knowledge and ATC procedures for various situations.
vi) It would take less time and effort to train a pilot to become an ATC controller when
compared to someone who has nil aviation knowledge.

17

REFORM :
1) We request MoCA to recruit only pilots for the post of Jr. Executive ATC in AAI for the
next two to three years.
2) The educational qualification to apply must only be a pilot's license.
3) The exam for the post of ATC must be modified accordingly to test pilot knowledge only.
4) Pilots with PPL, CPL and ATPL should be accepted.
5) Maximum age limit to apply should be extended to 40 years.
6) Indian citizens with ICAO pilot licenses should also be accepted and not limited to only
those issued by DGCA.

18

EMPLOYMENT IN DGCA
1) The DGCA has been perennially short staffed.
2) Recruitment by UPSC for various posts in the DGCA has been pending for years.
3) Growth in manpower has not kept pace with the growth in Civil Aviation.
4) This has seriously affected its functioning as a regulator and huge delays take place for the
approvals of various licenses and permits.
5) Being short staffed contributes to difficulty in doing aviation business in India.
6) It also affects it function as safety regulator.

REFORM :
1) We request MoCA to hire unemployed pilots of India as staff in various arms of MoCA like
DGCA, AAI, Air India, Pawan Hans and the new AAIB.
2) Pilot knowledge can be very useful in the Flight Standards Directorate ( FSD ), Directorate of
Training and Licensing ( DTL ) and the Directorate of Flying Training ( DFT ) in the DGCA.
3) Pilots with expired licenses or permanently unfit should be considered as well.
4) Age limits should be extended.
5) Pilots would be more than willing to accept permanent government jobs in the DGCA or
MoCA on government employee pay scale.

19

EMPLOYMENT AS FLIGHT
INSTRUCTOR
a) Aircraft rules 1937, Schedule II, Section Q & R deal with rules regarding issue of Assistant
Flight Instructor rating ( AFIR ) and Flight Instructor rating ( FIR ) .
1) Despite the large number of unemployed pilots in India there continues to be a shortage of
Flight instructors in India.
2) This can be attributed to the requirements for becoming an AFIR.
3) When a pilot graduates flight school he or she normally has the minimum 100 hours of Pilot
In Command ( PIC ) time necessary for the issue of a CPL .
4) However the requirement to become an AFIR requires 200 hours of PIC which is double
the minimum requirement for issue of CPL .
5) In order to obtain an AFIR one has to spend another 50% of their CPL training cost over
above the cost of the CPL .
6) The requirement for 200 hours PIC within the last 5 years is a bigger burden on pilots who
have been waiting for jobs for a few years and now wish to become a Flight Instructor.
7) In other countries the only requirement to become a flight instructor is to hold a CPL .
REFORM :
1) We request MoCA to reduce the 200 hours PIC requirement to 100 Hours PIC for issue of
Assistant Flight Instructor rating.
2) The requirement for last 5 years should be removed.
3) Validity of AFIR should be extended to at least 2 years.

20

PILOT LICENSING
REFORMS

5 YEAR FLYING EXPERIENCE

RULE
a) Certain Pilot licenses issued by the DGCA require a candidate to have certain number of
hours within the last 5 years. These are as follows
CPL (A) with/without IR

AFIR

FIR

200 hours Total Time

200 Hours PIC

300 hours Total Time

100 hours PIC

10 hours flying training as an

Instructor

20 hours night flying

50 hours PIC Cross Country

time ( for issue of IR ) / 20
hours for CPL only

---------

20 takeoff and landings at

night

---------

Approved Flight Instructors

Course

40 hours of Instrument time

( max 20 hours on Sim )

b) This is one rule that needs immediate attention. It negatively affects a lot of pilots who
for reasons many a time beyond their control are unable to meet the same. These reasons include
but not limited to medical, financial, educational etc.
c) This rule after deliberation with many pilots does not seem to have any logical reasoning
behind it especially in light of the following :
1) PPL, ATPL and CPL (Helicopter) licenses do not have such a requirement.
2) For issue of CPL(A) (fixed wing) with IR a Pilot needs 50 hours PIC Cross Country within
last 5 years. Whereas for issue of IR alone there is no requirement that the 50 hours PIC Cross
Country has to be flown within the last 5 years.
3) A pilot who has obtained a DGCA issued CPL after flying 200 hours and does not fly a
single hour for 6 years can renew his or her license by just giving skill test and continue to
exercise its privileges.
4) Whereas a pilot who has flown 200 or more hours or holds a CPL from a foreign country
and for some reason or the other could not apply at the DGCA for an Indian CPL has to fly
the entire 200 hours again along with the other requirements.
5) ICAO countries with well developed aviation environments do not have such a limitation nor
is one given in ICAO Annex I with regard to issue of the above mentioned licenses.
22

 6) Flying 200 hours is an expensive affair. Asking someone to fly the entire 200 hours again just
because its been more than 5 years is very expensive and an unnecessary financial burden on
the applicant.
7) Many pilots who learnt to fly abroad continued to work in foreign countries as flight
instructors or charter/airline pilots due to the lack of pilot jobs in India.
8) Upon return to India applying for issue of Indian CPL many find their applications rejected
because the DGCA asks for all 200 hours to be flown again as a PILOT TRAINEE at a flying school .
9) Indian Citizens who have a foreign ATPL but cannot convert to an Indian DGCA ATPL
( due to higher flying experience requirements ) face the same problems when wanting to
instead obtain an Indian DGCA CPL.
11) Prior to applying for a pilots license all pilots have to demonstrate their capabilities through
skill tests which have to be done within the last 6 months.
12) If a Pilot is capable of passing the skill tests then he or she will have proven the fact that
they are qualified to hold the respective license irrespective of the number of hours they have
flown within the last 5 years.
13) The only entity that seems to unduly benefit from this rule are the flying schools in India or
abroad depending on where the pilot applicant decides to do the 200 hours of flying all over
again.
14) It has been found that certain unscrupulous flying schools in India have tried to misuse this
rule by saying that any shortfall in flying hours can only be flown at a flying school in India.
15) This is a sad and unfortunate rule that has created untold suffering among the pilot community in India .
REFORM :
d) We request MoCA to amend Aircraft rules 1937 , Schedule II which will remove the limitation
that requires a pilot to have certain number of hours within the last 5 years for the issue of the
following licenses.
1) CPL (A) - Section J , 1 (e)
2) CPL (A) with IR - Section L , 1 (e)
3) AFIR - Section Q , 1 (c)
4) FIR - Section R , 1 (c)

23

VALIDITY OF PILOT LICENSES

a) Presently the Pilot licenses issued by the DGCA have a limited validity
PPL - 10 years
CPL - 5 years
ATPL - 5 years
b) The requirements for renewal include but not limited to within the last 6 months
- 10 hours PIC on any aircraft endorsed on the license
OR
- Skill test by day and night
c) It is very important to remember that even if a pilot holds a valid license he or she does not necessarily meet the
requirement for exercising its privileges .
d) A valid pilot license is only one of the requirements needed to exercise its privilege.
1) Renewing a pilot license is an unnecessary burden on the pilot ( especially if one is
unemployed or flying abroad ) and a burden on the employer as well as on the DGCA as all it
does is waste everyone's time, money, manpower and other resources.
2) Many a time unemployed pilots who have been unable to find jobs since the issue of their
license often find themselves unable to apply for jobs because they could not renew their pilot
licenses in time. Many unemployed pilots who work in fields unrelated to Civil Aviation do not
have the time or money to chase their license renewals.
3) Experienced Indian pilots who leave India in search of better job opportunities face the same
difficulty when they wish to return to India . Given the acute shortage of experienced
Captains / TRI / TRE etc its only prudent that the Government of India make the transition
easier so that they can share their experience and knowledge which they gained abroad with
pilots in India.
e) Many ICAO countries have pilot licenses that have perpetual validity eg : U.S.A, Australia,
New Zealand, Europe etc. If these countries can issue pilot licenses with perpetual validity there
is absolutely no reason why the same cannot be implemented in India.
REFORM :
1) We request MoCA to alter the validity of pilot licenses given in Aircraft Rules 1937 for PPL,
CPL and ATPL to lifetime validity .
2) Pilots whose licenses have expired or upon expiry should be granted lifetime validity license.
3) The only requirement for renewal of license to lifetime validity should be a valid medical
and a one time license renewal fees.
24

VALIDITY OF TYPE RATING

a) A type rating or type qualification training is a specific qualification where a pilot needs to
undergo ground and simulator training prior to operating a particular aircraft.
Aircraft with AUW above 5700 kg require pilots to undergo a type rating and get the aircraft
endorsed on the pilot's license in order to operate it.
They are required to undergo recurrent training on the aircraft at regular intervals in order to
test their knowledge and proficiency.
b) A type rating is a very expensive cost to bear. New pilots are asked to bear this cost by their
employers. It costs between 15 - 40 lakh rupees depending upon aircraft and operator for a type
rating.
c) DGCA CAR Section 8, Series F, Part 1 deals with requirements needed to exercise the
privileges of the type rating.
1) The requirements to exercise the privileges of the type rating as mentioned in the CAR is
onerous and very confusing.
2) The CAR does not clearly state the point from which the countdown of 6 month to 3 years
starts.
3) Disputes between pilots and DGCA are quite common when it comes to interpreting the
rules.
4) The CAR requires a pilot to undergo the entire type rating all over again should they not meet the
requirements for 3 years. This is an unfortunate and outrageously expensive rule that penalizes
the pilots and the employers involved.
5) A pilot who has flown an aircraft that requires a type rating for thousands of hours and then
goes on to fly another aircraft for more than 3 years and wishes to fly the original aircraft is also
subject to this rule.
6) This rule removes flexibility for operators with multiple fleets in transferring pilots from one
aircraft type to another.
7) This rule goes against the objectives of the draft NCAP 2015 with regards to ease of doing
business.
8) Many pilots who have done self sponsored type ratings without a job offer are forced to shell
out lakhs for rupees every year simply to prevent the type rating from expiring.
9) Aviation Authorities that regulate pilot licensing in other countries do not have such onerous
rules and regulations for type rating which requires one to undertake the entire type rating all over
again to the best of our knowledge.
25

d) We request MoCA to advise the DGCA to make the following changes to the CAR Section 8,
Series F, Part 1 with respect to exercising the privileges of a type rating.
http://dgca.nic.in/cars/D8F-F1.pdf
REFORM :
1) Prior to exercising the privileges of the type rating a pilot will see to it that he or she meets the
following requirements.

Within last 90 days

Within last 6 months

Within last 1 year

3 Takeoff and Landings by

day or night as the case may
be

Pilot Proficiency Check

( PPC )

Instrument Rating Check

( IR )

Either in actual aircraft or an

approved simulator

Approved simulator

Approved Simulator

2) Implementing the above mentioned reforms will go a long way in removing this painful and
expensive burden which the stakeholders in Indian Aviation suffer at present.

26

ATPL LICENSE
a) The Airline Transport Pilot License ( ATPL ) is the highest level of license issued by the
DGCA. It is necessary for pilots who wish to act as Pilot in Command ( PIC ) of an aircraft with
AUW above 5700 Kg to hold an ATPL.
1) Applying for an ATPL today is a burdensome process . There is an unnecessary and difficult
amount of procedures, rules and paperwork needed to apply for the ATPL today.
2) There is huge shortage of ATPL pilots in India and airlines are forced to hire expensive
expatriate pilots in order to fill the gap.
3) The ATPL rules and procedures are not in sync with the requirements for the issue of the
ATPL license with other ICAO countries.
4) The requirement for 150 hours of flying within the last 1 year is unfair to pilots who have
flying experience but are unemployed or medically unfit for a temporary period of time or any
other reason.
5) Only 50% of Co Pilot / Second in Command ( SIC ) flight time is recognized even for
aircraft that require an SIC by virtue of the aircraft's type certificate.
6) The 1000 hours cross country time is too high and unfair to pilots who do aerial work or
flight instruction.
7) The requirement to maintain a separate logbook for logging of PIC Under Supervision is
unfortunate and unnecessary burden on Indian Pilots.
8) Since PIC Under Supervision can only be logged when flying with captains with certain kind
of experience or qualification, pilots can keep flying for thousands of hours without being
paired with such captains.
9) These hours then cannot be used for applying for the issue of ATPL .

27

REFORM :
b) We request MoCA to alter the necessary rules in Aircraft Rules 1937, Schedule II, Section M
and bring about the following reforms for the application and issue of the ATPL (A) .
1) Remove the requirement for 150 hours of flying experience within the last 12 months
Section M, 1 (e)
2) 100% of Co Pilot flight time should be recognized for the issue of the ATPL when the flight
time is flown in an aircraft that requires a Co Pilot as per the aircraft type certificate.
Section M, 1 (e), ( i )
3) 500 hour of PIC time should be changed to the following.
500 Hour PIC or SIC or a combination thereof should be accepted.
4) 1000 hours of total cross country time should be reduced to 500 hours.
5) 200 hours of PIC cross country time should be changed to the following.
200 hours of PIC or SIC cross country time or combination thereof should be accepted.
6) 50 hours of PIC cross country night time should be to changed to accept SIC time as well.
7) Requirement for maintaining a separate logbook for PIC Under Supervision flight time
should be removed once and for all.
8) Once DGCA accepts 100% of SIC time towards PIC time or a combination thereof then
the need for logging PIC under supervision will no longer be required.

28

CROSS COUNTRY TIME

a) Logging of cross country time is a necessary requirement to for the issue of PPL, CPL and
ATPL licenses.
b) The DGCA as per Aircraft rules 1937, Schedule II, Section A, 5 a) and 5 b) outlines the
requirements for logging of cross country time.
http://dgca.nic.in/schedules/section-a.htm
1) The DGCA rules unfortunately has two different definitions for cross country flight time.
2) For PPL it is 50 nm and for CPL and ATPL it is 100 nm.
3) The 100nm only for the issue of CPL and ATPL seems to be a random and arbitrary
requirement.
4) Pilots who fly abroad find it difficult to convert their CPL and ATPL licenses due to this
arbitrary requirement.
5) Pilots flying on small regional routes cannot use their cross country flight time for issue of
higher category licenses like ATPL.
6) Eg : Flying from Bengaluru ( BLR ) to Mysore ( MYQ ) or Jammu ( IXJ ) to Srinagar ( SXR )
would not count as cross country time for issue of ATPL .
7) This issue will exacerbated once the regional connectivity scheme comes into effect.

REFORM :
1) We request MoCA to make the necessary changes in Aircraft Rules 1937 and change the
definition of cross country time to 50 nm for all categories of licenses.
Aircraft Rules 1937, Schedule II, Section A, 5 (a) and 5 (b) .

29

PILOT LICENSE EXAMS

a) The DGCA pilot license exams today are conducted 4 times a year. Most subjects are
conducted online and the results are instantaneous.
However for some reason unknown to us the DGCA still conducts the Technical exams i.e
Technical General and Technical Specific on OMR sheets.
b) Despite some reforms in 2011 candidates still face difficulties in the application and conduct of
the DGCA Pilot license exams.
1) The DGCA's decision to conduct Technical exams on OMR is unfortunate for those
candidates giving these exams.
2) Despite the exams being made online and the application online the DGCA still requires
candidates to send paperwork by post. This defeats the advantages of having an online
application.
Eg : Even though the DGCA has the records of CPL's issued and their endorsements, the
DGCA still requires pilots to send a gazetted officer attested copy of the CPL when applying
for the ATPL written exam.
3) The DGCA has a ridiculously long list for rejecting applications for applying for a written
exam.
4) Many a time despite meeting the all the requirements the candidates are rejected with false
reasons due to which they lose their exam fees.
5) In the October 2015 session the DGCA has mentioned 82 reasons to reject an application
http://dgca.nic.in/admit/Pilot102015Rej.pdf
6) Many candidates who had been admitted to an exam earlier and could not pass, when
applying again are rejected saying they do not have the qualifications to appear for the exam.
This is despite the fact they successfully appeared for the same exam earlier.
7) In the online exam there is no option available to a candidate to flag questions with wrong or
false information or if the correct answer does not appear in the options.
8) While Indian pilots have to wait 3 months to appear for an exam, exams for expat pilots are
conducted every 2 weeks.
9) There is no avenue available to the candidates to appeal a false rejection of the exam
application due to which they lose the exam fees.

30

REFORM :
1) DGCA should remove the requirement to send paperwork by post after applying for an
exam online.
2) Original paperwork can be verified on the day of the exam.
3) DGCA should conduct Technical exams with immediate results online.
4) DGCA should conduct exams at least once every month. This should be increased to ondemand exams similarly available in foreign countries.
5) DGCA should provide a method to appeal to candidates whose applications were falsely
rejected . They should either refund the amount immediately or credit it towards a future exam
application.
6) DGCA should allow CPL holders with only a single engine endorsement to appear for ATPL
written exams.
7) DGCA should remove the requirement for photocopies to be attested by a gazetted officer
and instead should accept self attested copies of licenses and other documents.
8) DGCA should provide an avenue to pilots to dispute any questions that appear in the online
exams for valid reasons.

31