Class Rating Instructor privileges

[indiaoscar]

Hopefully I am on the right forum for advice on this question. I am a CAA PPL/owner and occasionally fly as p u/t with a friend who has a Class Rating Instructor licence. This is useful if I feel rusty, run out of the 90 day rule etc. He logs CRI time on these flights but there is no remuneration as he does not have a CPL.
A recent 'hangar chat' conversation has suggested that this is only allowable if he is officially attached to an approved flight training operator. Is that true, or can he simply be freelance?

[mad_jock]

Its fine its just a school trying to put the wind up you so you stop doing it and pay them instead.

He can also do the 1 hour with an instructor flight and sign your log book.

This can and does wind the local schools up to hell.

The CRI rating is the relatively undiscovered rating of choice for groups. Its is relatively cheap and easy to acquire, its renewal experience requirements are very easy to comply with, and it drops your group insurance by a fair whack as well. Linked in with a tame RT examiner who has ground exam authorisation to sign your SEP rating off when required. It can make huge savings for the group instead of using the local school and all its associated fixed costs.

[Whopity]

Its a very interesting question because it highlights what could be considered an anomaly in the ANO. Look at Schedule 8 and the pilots licence privileges. All UK licences from PPL to ATPL contain the following statement:
in either case in an aeroplane owned, or operated under arrangements entered into, by a flying club of which the person giving the instruction or conducting the test and the person receiving the instruction or undergoing the test are both members; Thus it would appear that any instruction given outside a flying club is illegal! This will include all commercial FTOs and even CAA examiners! Needless to say, this piece of law is largely ignored!

Of course the simplest definition of a Club, is two persons with a common interest!

[indiaoscar]

Yeah, that figures - it was the owner of the flying club to whom I rent my aircraft who made this worrying suggestion of illegality. I helped my CRI friend to get his qualification by using my aircraft, and in return he gives me a lot of help. It seems in aviation we should all help each other and some of the interpretations of JAA/EASA can be very worrying to an owner trying to stay the right side of the law.

[betterfromabove]

Another question that occurred to me when I looked into the CRI, is are you allowed to "advertise" as such?

Clearly a flying school might not be too happy you putting up a note on their noticeboard unless you were attached to them, but providing you make it clear there's no commercial connotation, could you effectively offer your free services this way?

Asked an examiner/CFI the other day & he said "no", but others have said "yes".....any ideas or are the rules contradictory on this too ?!?

Cheers
BFA

[Whopity]

The CRI is perfectly at liberty to advertise as is any other FI for that matter.

[betterfromabove]

Whopity - Interesting...thanks for the clarification!

[Ex Oggie]

As Whopity stated, the ANO states both individuals should be members of a club, therefore an RF or an FTO. Quite how this fits in with a group operation using a CRI has been niggling me for a while. I will seek some clarification when I am back in the office on Tuesday.

If your CRI has any concerns, any 'decent' flying club will let him ally himself by way of temporary membership or similar. In practice, I have never known a freelance CRI end up with a problem. If it was an FI (A) instucting for a licence or rating that would be a different matter.

XO

[Whopity]

In practice, I have never known a freelance CRI end up with a problem. If it was an FI (A) instucting for a licence or rating that would be a different matter.

Not really, the privileges are associated with the licence, not the rating therefore the CRI is no more limited than the FI.

I believe that the wording in the ANO dates back to the days when "flying clubs" were exempted from the requirement to hold an AOC therefore, all instructional activities were associated with clubs. Pre JAR-FCL the CAA published a guide stating that PPL and BCPL(R) holders could only instruct in a Flying Club and that holders of Professional licenses could instruct outside a club environment either independantly or in a commercial school. That letter was by way of an exemption but it disappeared in 1999 when JAR-FCL was introduced.

[Ex Oggie]

Not really, the privileges are associated with the licence, not the rating therefore the CRI is no more limited than the FI.

I fully agree as far as privileges of the licence are concerned. I was thinking more about the "is it worth us investigating" view taken by the authority when an indiscretion is brought to their attention. This is more likely if an individual is caught out whilst training someone for an initial licence, which of course a CRI can't do.

XO

[ifitaintboeing]

I believe that the wording in the ANO dates back to the days when "flying clubs" were exempted from the requirement to hold an AOC therefore, all instructional activities were associated with clubs. Pre JAR-FCL the CAA published a guide stating that PPL and BCPL(R) holders could only instruct in a Flying Club and that holders of Professional licenses could instruct outside a club environment either independantly or in a commercial school. That letter was by way of an exemption but it disappeared in 1999 when JAR-FCL was introduced.

The wording is in there to permit MICROLIGHT instructors to operate legally and be paid as PPL holders. It was inserted several years ago, and was put in to remove the requirement for an exemption which the BMAA previously held.

FI(R) and CRI

The CRI may act as an individual and does not have to be part of a club, and may indeed instruct in the manner you describe.

The significant difference between an FI(R) and a CRI is that the FI(R) is required to be supervised by an unrestricted FI, whereas the CRI is not.

CRI Time

He logs CRI time on these flights but there is no remuneration as he does not have a CPL.

He must log this time as P1 and instructing, and the "student" as PUT.

Examiner Authority

Linked in with a tame RT examiner who has ground exam authorisation to sign your SEP rating off when required

You actually need to be a Revalidation Examiner. Ground examiners are GR which is both Ground and Revalidation examiners. Almost any pilot can be a stand alone Revalidation examiner, providing they are nominated by an RF/FTO, and it's one of the only things from the CAA which is free!

[mad_jock]

Revalidation Examiner I had never heard of just knew that some RT examiners with ground examiner could do the dirty deed.

Whoopity and Ex oggie cheat though in the nicest possible way due to thier contacts. I will look forward to finding out what they come up with.

I suspect that schools and CFI's are going to become more militant with solo operators. I have seen some quite bizarre charging schemes surrounding the renewal and revalidation of SEP ratings. And I have seen fists outside due to one examiner signing someone's rating off on experience in 2 years for basically lunch. It had saved the PPL 100 quid which was the local charge. The poor examiner was out on a jolly and was just chatting to a mate. But to be fair he wasn't to bothered about stepping outside.

[Sciolistes]

Thus it would appear that any instruction given outside a flying club is illegal!
My reading of the ANO is that it states "for the purposes of aerial work" and aerial work is defined as flying for the receipt of "valuable consideration", then it seems it is perfectly legal. There were no issues for the chaps in my old group getting their revals signed by our local examiner for any of the instruction I conducted as a CRI.

[BEagle]

And I have seen fists outside due to one examiner signing someone's rating off on experience in 2 years for basically lunch. It had saved the PPL 100 quid which was the local charge.

Sorry, are you saying that 'the local charge' was £100 just for signing the Certificate of Revalidation?? No LPC or LST, just a logbook cheque and signature - for which they were charging £100??

[Whopity]

The wording is in there to permit MICROLIGHT instructors to operate legally and be paid as PPL holders. It was inserted several years ago, and was put in to remove the requirement for an exemption which the BMAA previously held.

I disagree, it appears in the ANO 1989 some 20 years ago:
(i) he may fly such an aeroplane for the purpose of aerial work which consists of:

(aa) the giving of instruction in flying, if his licence includes a flying instructor's rating or an assistant flying instructor's rating; or

(bb) the conducting of flying tests for the purposes of this Order;

in either case in an aeroplane owned, or operated under arrangements entered into, by a flying club of which the person giving the instruction or conducting the test and the person receiving the instruction or undergoing the test are both members;

If it had anything to do with remuneration in Microlights, why would it appear in professional licences as well as Helicopter, Autogyro and Balloon pilots licences, the holders of which are not likely to have anything to do with Microlights!

[mad_jock]

Yep. And the cheeky bugga apparently would only take cash for it.

There are quite a few other places with extortionate fee's for paper work bollocks. I used to get folk flying up to Inverness from the central belt because 3 of them in a Cherokee could come up, get there hour with an instructor and there license signed off for 15 quid each for me and a donation to the examiner. The 3 landings at HIAL airports were training rates of £5.50 and a very pleasant afternoons flying around the west coast and North isles of Scotland was had by all. The amount that 3 of them saved more than payed for the ferry to Inverness and back.

[Whopity]

Anyone who is charged to sign a revalidation by experience form should look elsewhere, most of us do it for free!

An RTF Examiner Authority contains no authorisation to sign anything other than RTF examinations and English language proficiency Level 6.

[mad_jock]

I agree completely Whoopity. A spot of lunch or a pint I don't think is out of order though. Although some club rules are set up so you don't have the choice if you want to fly the club's aircraft ever again.

And you will note I did clarify

Revalidation Examiner I had never heard of just knew that some RT examiners with ground examiner could do the dirty deed.

[Whopity]

Revalidation Examiners or "R" examiners were simply people who could sign the old 13 month C of E at locations where there were no other examiners; unlicensed airfields etc. They remained post JAR-FCL on a grandfather rights basis. Guess what, to become one, you now have to be sponsored by an RF, which completely defeats the object of having them! Ground Examiner can sign C of R or C of E.

[mad_jock]

Just for complete clarification.

Is there any split in the ground examiners qualification?

ie Alot of them are ground examiners and only hold the papers for VHF and HF RT papers.

And to be fair a fair few RT examiners are quite rightly from the other end of the RT exchange and have never seen a Pilots license. I think I have seen a yellow peril twice in the years I have been flying.

Are they also qualified to sign the C of E for SEP ratings?

It really matters to me not a jot but getting hold of the RT examiner at short notice sometimes is significantly easier than tracking a SEP examiner down for a signature.

I should imagine that if this option is available it will help out quite a few people in the Inverness area after Highland Flying School departed the scene.

[indiaoscar]

Thanks to all - I shall continue to use my CRI friend and ignore the suggested illegality from others who may have their own motivation!
As a supplementary query, can the airfield management object to independent CRI instruction? If my aircraft is based there and is being used with my permission I have always assumed that within the constraints of the law and insurance requirements anyone can use it, but it suddenly occurred to me that the local club could put pressure on the management - or am I being paranoid?

[Whopity]

That would be discrimination!

[Robin400]

Is my Rating still valid to sign C of E for ppl with the required experience now I have retired from professional flying?
Thanks.

[Whopity]

To sign a C of E you must hold an Authorisation issued by the CAA. It contains an expiry date. Assuming you are not a Ground Examiner and hold a Flight Examiner Authority, then to exercise the privileges of that Authority you must hold a valid pilots licence with appropriate class rating and a valid FI rating.

[orionsbelt]

Is a CRI permitted to teach Aerobatics in the same manner as an FI who has had the Aerobatic restriction removed? And can claim to be able to teach the AOPA Aerobatic course?

[Whopity]

Thats a interesting question. As there is no such thing as an aerobatic rating for pilots, then it is not illegal for any qualified pilot to teach aerobatics as its not contrary to article 36 (2)(2) This article applies to instruction in flying given to any person flying or about to fly a flying machine or glider for the purpose of becoming qualified for:
(a) the grant of a pilot’s licence; and
(b) the inclusion or variation of any rating or qualification in his licence.
Whilst no instructor rating is legally required to teach aerobatics, it is the recommendation of the CAA that any person teaching aerobatics should hold a FI rating without aerobatic restriction, to ensure they are adequately qualified. A CRI has no such qualification but would not be breaking the law.

AOPA state:
This course comprises 8 hours dual flying with an approved instructor who is qualified to give aerobatic instruction, covering the standard manoeuvres, and 8 hours of ground briefings/lectures.
A CRI is not "qualified" and is therefore unlikely to be approved by AOPA.