IMC INSTRUCTOR REVALIDATION

[BEagle]

Under JAR/FCL 1.355, if you hold instructional privileges for IR instruction, to revalidate by experience you have to instruct 10 hours towards IRs in the 30 hours you have to do in the last 12 months of the 3 year period in which you have to instruct 100 hr. Plus do the seminar or revalidation test.

But guess what? Our esteemed CAA has decided at a stroke of the pen to apply the same rules to those whose instrument instruction is solely to IMC level!! So every FI who holds 'applied IF' instructional qualifications now has to do 10 hours IMC Rating instruction in the last of the 3 years - or it's the expensive and time-consuming seminar and flight test route! Note that teaching IF to PPL students doesn't count for this....

This is typical arrant Belgrano bull$hit! There is a world of difference between PPL FIs at RFs teaching the odd bit of IMC Rating instruction and FIs at FTOs teaching towards IRs. There is no safety case here - because no matter what instruction an IMC Rating applicant has been given, the quality assurance check is the IMC Rating Skill Test! If instruction has been poor, the applicant won't pass - pure and simple.

So, unless this nonsense is stopped, very few FIs will bother to keep up their IMC Rating instructional powers, because the cost and time required for completing seminar and revalidation Skill Test will just not be worth it. So fewer pilots will bother with IMC Rating training as there won't be many available FIs - that's a real safety gain, isn't it CAA?

I urge anyone who agrees with me and opposes this nonsense to write to the [email protected] address and put their views as strongly as possible. Before it's too late.......

[ 21 October 2001: Message edited by: BEagle ]

[RVR800]

This area of licencing is even more of a
dogs breakfast than the rest.

How and why do they justify the costs
of their legislation.

On one hand it is ludicrously lax i.e. UK CAA CPL with no IR attached does not need a test to maintain his instrument priviledges of his embedded IMC rating for 10 years!

On the other hand we have a CPL/IR hoder who
is required to spend £2000 p.a. on a rating that is about as much use as a chocolate fireguard under the current climate.

We also have a situation where the number of people doing PPL/IRs has dropped like a stone recently

Only 21 people did it last year I think,
due to the draconian costs and time, and this
could drop to single figures.

No wonder many businessmen I know have their own US registered aircraft for ops in Europe from fronting US businesses

Additionally there are no training providers able to justify the costs of the PPL IR course. I believe PPSC ran a course but they have now gone.

People will vote with their feet.
JAA ratings are just not economic sense for most people.

Unfortunately JAA legislation will exacerbe the effects of the downcycle in recruitment
and jobs will continue to be lost...

Of course the big advantage of JAA licencing is that guys from Swissair and Sabena will be able to get jobs with Ryanair due to common licensing - small comfort to UK
wannabees indeed...

[cesspit]

Beagle,

So just to clarify, in my case, I am re-validating my FI rating soon by flight test and I have well in excess of the 100hrs instructional, however (BIG CRUNCH), in the last 12 months I have only done 3 hours of instruction towards IMC ratings...so I can kiss good-bye to my applied IF instructors ticket???!!!

If that is the case I am stuffed, until I fork out for a seminar as well, which incidently, are held no-where near my local flying club (hence me opting for the flight test route), and the next one is not taking place until December, AND I HAVE A NEW STUDENT WANTING TO START AN IMC IN THE NEXT MONTH!!

(Letter to SRG pending)

All the best,

Cess

[hugh flung_dung]

...appropriate letter sent.
Where did you hear about this?

[BEagle]

cess - I understand that it's unenforceable as there is technically nothing to 'revalidate' - there are no grounds for removing 'applied instrument instruction' from your FI Rating since it's only possible under the ANO to remove 'no applied IF', not the other way round! They cannot say that you haven't met the 'revalidation by experience requirements' as stated under JARs if you don't instruct for IRs (not IMC Ratings); ask what possible help towards applied IF instruction the Seminar would be if you had chosen to revalidate by experience and Test? No-one even mentioned applied IF instruction at the seminar I attended.....

No - this is another daft Belgrano-ism which simply hasn't been properly researched!

hfd - I read about the requirement in the FE's handbook - this is a guidance document only and has no legal status. They have simply taken the relevant JAR concerning IR instructional revalidation requirements and changed them to read 'IR or IMC Rating'!

[ 22 October 2001: Message edited by: BEagle ]

[zzzz]

Again a total lot of CAA inspired pap.

I cannot be the only one to have read BEagle's post and been surprised, nay, shocked, not so much at the CAA being a bit daft but the fact that this information isn't spread by the CAA, but by hear say.

How many pilots are out there who think all their ratings etc are up to date and valid, when in fact due to another little bit of unpublicised JAR inspired legislation,their paper-work is not in order?

Does it mean that before the change, they were safe, and that the day after the change they are now dangerous.

Or are we just drowning in bureaucracy?

In this case ignorance is bliss.

I wish I was as well read as BEagle!

(I'll head back to the books, what other things have I missed)

Well done Sir..

[Noggin]

Or could it be just another error in the Examiners Manual? After all there are a lot of other errors.
Take table 13B as an example, an IRI who can only instruct for an IR, must quote:

"Complete 100hrs instructing in the 3 years preceeding expiry, to include 30 in the last 12 months, of which 10 must be for the IR or IMC"

What precisely could the other 20 be?

[ 23 October 2001: Message edited by: Noggin ]

[Wee Weasley Welshman]

Beags, I read things the same way as you do. Which pisses me off. I am going to rain down a solid wall of **** on The Campaign Against Aviation on this.

If nothing else it is contrary to flight safety principles of encouraging PPL holders to be as highly qaualied as possible for the conditions in which they might find themselves.

WWW

[Wee Weasley Welshman]

And BTW I am only 20 mins down the road from Brize these days if you fancy a pint one night to set the worlds to rights...

WWW

[BEagle]

Wot you doin' in Tcheltenham, weasely one?

Never fear chums, I've had speaks with a CAA chum and also an influential ex-Queso Grande of the examining world and they both agree that, as it stands, the statement is utter bolleaux. So it may well be that a fluffy 'Oops - we porked it up a bit' correction may well be defecated out from the Belgrano 'ere long.

What we need is something along the lines of

"To instruct for the IMC Rating, an instructor shall:-

1. Hold a valid FI Rating which does not preclude 'Applied Instrument' instruction.

2. Hold a valid IMC Rating."

..and that's all. Because to make a more substantial amendement to historic privileges would require a Regulatory Impact Assessment - and they haven't done that.

[ 23 October 2001: Message edited by: BEagle ]

[The Flying I]

Beagle - by your 2 point, do you mean the instructor should have an IMC Rating - or have IMC privileges?

[BEagle]

Sorry - 'Have IMC Rating privileges'!

[BEagle]

RESULT!! Had a word with a chum at the Belgrano and, as a result, the Chief Flight Examiner will be deleting any reference to 'IMC rating training' in Table 10B 'FI Revalidation' in his excellent FE's Handbook.

So for anyone qualified to instruct for the IMC rating worrying about not having completed a specific number of IMC rating training hours - fughedaboudit! There is NO such requirement.

I'm sure 'Noggin' and 'Blue Line' know who to thank......

[Meeb]

Whilst I understand where you are coming from Beagle, I do not think that 10 hours of IMC instruction in the last 3 years is excessive! One could argue that not having taught any IMC for the last 3 years, in the case of a flying club instructor who might not be too current on procedural IF, is not conducive to effective teaching of the syllabus. Just a thought!

[BEagle]

NO!! IMC rating training is all about safe operation of the aircraft in IMC. Far, far too much emphasis is placed by some instructors on things like NDB sector joins and holding procedures which are a very minor part of the IMC rating. When I conduct IMC rating tests, I am also conducting de facto qulaity assurance on the applicant's instructor. I'm far more interested in sound basic IF skills (I usually try and conduct a lot of the test in actual IMC), whether the applicant can cope with flying the ac on instruments, ATC instruction and management of relevant navaids than arcane irrelevances such as how to refine the primitive NDB hold. In any case, there is NO requirement for ANY procedural flying on the test; radar vectored ILS is fine and is what I would expect most people to opt for given poor weather at destination if the aerodrome was so equipped.

[hugh flung_dung]

Following letter received yesterday:

"Your email regarding the harmonisation of IR/IMC Instructor qualifications has been passed to me for a reply.

I think it fair to say that the so called grapevine information comes from an incorrect interpretation of the wording that appears in Table 10B of the Flight Examiner's Handbook.

JAR-FCL 1.355 (a) (1) gives the requirements for FI(A) revalidation and states that where 100 hours of flight instruction is used, 30 hours shall have been within the 12 months preceding expiry, and that where IR instructional privileges are included, 10 of the 30 hours shall be instruction for the IR.

Table 10b also includes reference to the IMC rating which is a National rating and is not subject to the requirement of JAR-FCL 1.355. I have an assurance from the Chief Flight Examiner that reference to the IMC rating
will be removed from Table 10b on the next amendment of the Handbook.

With the exception of this reference in Table 10B, I am not aware of any attempt to harmonise instructor rating requirements for the UK IMC rating with those required under JAR-FCL for instructors wishing to instruct for the IR."

[BEagle]

Typical! It was as a result of the incorrect wording of Table 10B, not the result of incorrect interpretation.

Whoever that patronising reply came from should apologise for his libellous statement!!

['I' in the sky]

BEagle.

Regarding your last but one post about a radar vectored ILS being sufficient for the test. I always understood that one approach should be a full procedure to qualify as a 'pilot interpreted approach'

Is this incorrect ?

[BEagle]

A procedural approach is NOT required; it is the pilot-intrepreted 'descent on the final approach' phase which being assessed. How the pilot achieves the LOC/GP intercept point is irrelevant on an ILS - so long as it has been achieved safely, smoothly and correctly. Neither is it necessary to fly a NDB hold on the IMC Rating skill test unless ATC require it.

However, many examiners will arrange for the NDB or VOR tracking exercise to be incorporated in achieving the approach fix in order to kill two birds with one stone.

The emphasis on the IMC Rating test is first and foremost sound IF skills, secondly the ability to follow directons and to achieve a descent point from which a safe IMC approach (followed by a poor visibilty visual circuit) can be flown, thirdly the ability to carry out elementary radio navigation and very much lastly, the ability to fly holding procedures.

[cesspit]

BEagle

What angers me is that this exclusive bunch of PPRUNE folk now know that the reference to 10 hrs IF instruction in the last 3 years is not relivent to imc instructors...however those who matter i.e. FIC examiners DO NOT KNOW THIS.

I spoke to one the other day who told me that this requirement had been discussed at an examiner's meeting, and re-validations would be carried out with this in mind. those who didn't have their 10hrs would lose their imc instructors prviledge.

So much for the ar$e at the CAA saying it is 'incorrect interpretation' & 'grapevine information', when the bloody examiners carrying out the tests think it is true.

Why can't the CAA get on the phone to all the examiners and tell them the facts, to remove the confusion caused, once again, by the boys from the Belgrano. :mad:

[BEagle]

cesspit - I spoke to a chum at the Belgrano who confirms that the Chief Flight Examiner has agreed that his FE's handbook statement is wrong.

The FIE of whom you speak needs to remove head from sand and phone Capt Hills sharpish. I obtained this victory for commonsense through speaking to those with influence; tell your FIE to wise up - you do NOT need any specific IMC instructional hours to revalidate your FI rating if you have no IF restrictions on your FI rating; JAR/FCL 1.355 refers to IR instruction only, not IMC instruction. If anyone tries to withold IMC instructional privileges from a revalidation, advise them that they are being professionally incompetent and might face legal action for false restraint of trade!! Do NOT think that the FIE necessarily knows everything - some of them are miffed that they are getting less revenue now that the revalidation skill test is only 1 of the '2 out of 3' options and will be keen to persuade you to do a flight test as well as a seminar...

Once again, you do NOT need ANY specific IMC instructional time to revalidate a FI rating (assuming that you don't have a 'no applied IF' restriction on it)

[ 31 October 2001: Message edited by: BEagle ]

[moggie]

BEagle is right - there is no requirement to do a PROCEDURAL approach for the IR. Mind you, very few people will believe you when you tell them this. However, I believe on a personal level that any FTO that sends a candidate into an IR never having flown a procedural approach is letting that candidate (and their future employers down). If you can not prove yourself able to fly procedural approaches because you have never been taught, how on earth do you expect to cope later when learning them on a 737?

Now, on the instructor qualifications - we MCC Simulator instructors had a great laugh over the CAAs qualification requirements for us. We had to have or have held a profeesional pilots licence, flown 1500 hours as pilot on multicrew aeroplanes and undergo the type training for the type of aeroplane being simulated as well as observe a set number of sectors from the jump seat.

Fair enough, until you read that an MCC Simulator (FNPT2 MCC) only has to be a gas turbine powered, pressurised aeroplane which has performance, handling and systems which are typical of the class of aeroplane to be simulated. This means that it can be a generic type - look a bit like an airliner but not actually exist in the real world! So, just how do you do type training and observe sectors on a non-existant aeroplane?

The answer was (when we pointed this out) "ah, we must have got that bit wrong then". Confidence inspiring, what?

[BEagle]

moggie - absolutely! Although I was talking about the IMC Rating, not the IR, there is indeed no requirement for a procedural approach.

Interestingly, the military ME IRT has a mandatory requirement for a procedural approach, amongst other things. But the CAA doesn't recognise military IRs, so those who want a civil IR as well have to take a CAA examiner along on the jumpseat and pay for the privilege!

How any FTO could, notwithstanding the fact that there is no IR requirement, consider it acceptable to graduate a student who has never demonstrated the ability to fly an accurate procedural approach I cannot comprehend. But then again, some 'airline' FTOs don't even have an ILS at their aerodrome......

[ 02 November 2001: Message edited by: BEagle ]

[rolling circle]

moggie - Remind me. just which CAA publication was it that laid down your quoted requirements for MCC instructors?

As I recall the situation, the JAA produced the requirements for Synthetic Flight Instructors and the CAA, recognising the problems this would present for training on FNPTs, introduced the Synthetic Training Instructor and MCC Instructor, qualifications that exist nowhere else in the JAA Member States.

However, we musn't let the facts get in the way of a good story, must we?

[moggie]

Rolling Circle - The CAA originally said they would apply the SFI/TRI rules for MCCI qualifications - hence the need for type qualification on generic machines.

However, when we raised the issue with them they introduced the MCCI "qualification" to get round the problem. As far as I know, no other JAA state has done so, therefore the question remains: how does your instructor become type-qualified on a non-existant aeroplane?

Facts is facts mate - I was the one who raised the question with John Clemmons who then realised that no-one had thought about that problem. The MCCI qualification was invented that afternoon at Prestwick!

[ 02 November 2001: Message edited by: moggie ]