Instructing For the IMC/IR(R)

[Pringle 1]

CAP 804 is out. See link: http://www.caa.co.uk/docs/33/CAP804.pdf

In relation to an IRI, the document states the following requirements:

"The privileges of an FI are to conduct flight instruction for the issue, revalidation or renewal of:

(g) an IR in the appropriate aircraft category, provided that the FI has:
(1) at least 200 hours of flight time under IFR, of which up to 50 hours may be
instrument ground time in an FFS, an FTD 2/3 or FNPT II;
(2) completed as a student pilot the IRI training course and has passed the skill
test for the IRI certificate, ......."

Does this mean that from July 2012 :

1. You will able to instruct for the IMC/IR(R) if you are an existing IRI with an IMC rating and under 200hrs actual IFR flight time? (ie will existing privileges be lost?)

2. You will be able to complete the IRI course if you are an FI with an IMC/IR(R) and under 200 hrs actual IFR flight time if you only wish to instruct for the IMC/IR(R)? (ie is the requirement for a full IR and 200hrs IF only for those wishing to instruct for the full IR?)

Thanks to anyone who know the answer as I am considering doing the IRI course and qualify under the existing rules. (I have over 50 hrs actual IF) but don't seem to under these new ones. I only wish to instruct to IMC/IR(R) level.

[Whopity]

(g)(1) above is a prerequisite to obtain the qualification, not to exercising the privileges of it if already obtained. New book poor wording!

You should be aware of AIC 13/2012 (http://www.ead.eurocontrol.int/eadbasic/pamslight-0E193A421DB30416D1FD10BCF77B3EDA/7FE5QZZF3FXUS/EN/AIC/W/013-2012/EG_Circ_2012_W_013_en_2012-02-23.pdf) which announces a change to the requirements to add the IF Instructional privilege to an FI rating. You have until 1st July to complete your training and get the application in!

The AIC also contains an error:
3.2 Applications from 1 July 2012 for privileges granted under Part-FCL requiring the individual to have completed a minimum number
of flying hours in an aircraft in accordance with IFR will only be accepted where the required experience has been gained in flight in
circumstances requiring compliance with IFR. Part FCL only requires that it be flight conducted in accordance with the IFR and makes no stipulation that the IFR experience has to be be gained in flight "in
circumstances requiring compliance with IFR" i.e. mandatory rather than optional IFR!

The CAA recognised in 1997 that this requirement would just about stop dead instrument instruction and introduced the 4:1 ratio. It appears there is now nobody left that understands the issue, and the supply of instrument instructors will cease forthwith.

[BillieBob]

Since the IMCr is not an EASA qualification, the UK CAA is under no obligation to require that instruction is given only by FIs qualified in accordance with Part-FCL. There is nothing to prevent the Authority from maintaining the current criteria for instructors.

[BEagle]

The CAA have agreed to take another look at the creation of an IRI(R) and an IRE(R) so that qualifications to instruct and examine at IMCR / IR(R) level will be continued.

Yet another aspect of the nonsense of €urocracy about which they were warned some while ago.....:rolleyes:

[Whopity]

I see they have already withdrawn the downloadable pdf!

[Pringle 1]

Thank you for the replies. BEagle's post looks most encouraging as I don't have time to do the course before 1st July 2012. Any chance we will have an answer before the deadline?

[EK4457]

Quick question on this;

Under current rules, if you have an IR and have the 'no applied instrument' restriction removed from your FI(A), can you instruct for the actual IR or is it just the IMCr?

Ta,

EK

[S-Works]

I believe in order to teach for the IR you must hold an IRI. When I did mine I got an IRI as a standalone rating as well as an unrestricted FI(A).

[Aware]

As I understand the JAR system, if you were an FI with the applied instrument restriction removed , you could teach to the rating held. If you have an IR you can teach to that if you have an IMC but not an IR you can teach to only the IMC. I dont have an IR so can teach only to the IMC stage, and have taught to CPL as you do not need an IR to do this, but 500 hours as a FI and be approved by the school under their approvals with the blessing from the CAA.

But looking at the new EASA rules I cant see where the future IR instructors will come from with 200 actual IF requirement.

But at least I think can I continue to get my students through IMC courses until 2014.

[EK4457]

Thanks guys,

It's amusing how many instructors don't actually know what the current rules are and what they will be in the future. Myself included.

I recently had my IR renewed and the examiner wasn't too sure either!

I'm thinking of doing the course in the next month or so but only if I get the ability to become a permanent IRI. From what I can tell this will be the case but I'm not too sure....

[Aware]

Do you have 200 hours actual IFR ? If you do not as I understand the rules presently, you can't teach for the IR.

[S-Works]

It's amusing how many instructors don't actually know what the current rules are and what they will be in the future. Myself included.

The problem is the UK has some oddities. Everywhere else in EASA land to teach IR you must be an IRI. It's only when you start throwing the IMCr into pot that the waters become muddied.

If my reading of Part FCL is correct an IRI is still going to be needed for IR.

[ifitaintboeing]

The privileges and IR training for FIs remains pretty much the same as under JAR-FCL, with the caveat of the qualifying flight time under IFR for FI/IRI.

FCL.905.FI FI — Privileges and conditions

The privileges of an FI are to conduct flight instruction for the issue, revalidation or renewal of:

(g) an IR in the appropriate aircraft category, provided that the FI has:

(1) at least 200 hours of flight time under IFR, of which up to 50 hours may be instrument ground time in an FFS, an FTD 2/3 or FNPT II;

(2) completed as a student pilot the IRI training course and has passed an assessment of competence for the IRI certificate; and

(3) in addition:

(i) for multi-engine aeroplanes, met the requirements for the issue of a CRI certificate;

(ii) for multi-engine helicopters, met the requirements for the issue of a TRI certificate;

So an FI will not need to hold a standalone IRI.

[EK4457]

As I understand it, if you have an IR you get to multiply your IF hours by 4 at the minute. I do qualify via this 'back door' route.

However nobody seems sure if this is going to be carried over to EASA land. Of course, it makes a huge difference as I'm never going to get another 150 hours of IF any time soon.....

EK

[Whopity]

However nobody seems sure if this is going to be carried over to EASA land. It is abundantly clear that the 4:1 ratio will not apply after 1 July 2012. The CAA have even issued an AIC (http://www.ead.eurocontrol.int/eadbasic/pamslight-CB5CF2F8ECA0FE257D74C13A785B98C3/7FE5QZZF3FXUS/EN/AIC/W/013-2012/EG_Circ_2012_W_013_en_2012-02-23.pdf) to inform everyone.

An FI does not need to be an IRI however; the training is the same, but the pre-entry requirements are different. All further confused by the fact the UK CAA never got around to removing the old National Applied Instrument limitation and the same course was used to remove it.

[EK4457]

Thanks Whopity. I hadn't realised that AIC had been issued.

[Mickey Kaye]

So where do they expect the next generation of IR instructors to come from?

[BEagle]

I am advised by the CAA that:

It is our intent that FIs and FEs who have the privilege to instruct and examine for the IMCR will retain this for the IR(R).


I have suggested the IRI(R) and IRE(R) to meet this objective as this would follow the normal EASA methodolgy.

[Mickey Kaye]

And what would then happen when an IRI(R) adds an IR or EIR to his licence?

[Whopity]

You can't expect those making all these wild promises to actually understand such things!

[BEagle]

And what would then happen when an IRI(R) adds an IR or EIR to his licence?

As regards the IR - nothing until he meets the full IRI requirements.

As regards the EIR - well, that'll depend upon the NPA 2011-16 Opinion finding its way into European Law.

[bookworm]

You should be aware of AIC 13/2012 which announces a change to the requirements to add the IF Instructional privilege to an FI rating.

Hmm. This doesn't look very good.

There's no requirement under UK law to record flight time under IFR (let alone "flight time in circumstances that require compliance with IFR"). So how is that supposed to work?

Have you taken this up with the CAA or EASA?

[Mickey Kaye]

"As regards the IR - nothing until he meets the full IRI requirements."

And when he does what then

[BEagle]

Assuming he can read, he can look up the answer for himself in CAP 804....

[Cobalt]

1) the requirement is 200 hours IFR, 50 of which can be "Instrument Ground Time" --> FNPT time. So if you have an IR, you start with 50-55. If the IR training isn't under IFR, nothing is.

2) If you have logged "sole reference" time only, be pragmatic. If someone asks you how much cross-country time you have, you go back over your logbook and see which flights were CC. Do the same.

--> Any flight with "sole reference" must be, at least partly, been IFR?
--> Any flights with remarks showing an IAP also, at least partly, IFR
--> Any flights you remember having flown airways?

etc.

The real problem, I suspect, is that most of those that have not logged 150 additional hours of IFR after gaining the rating actually have not FLOWN 150 hours IFR after gaining the rating. Previous CAA rules allowed any FI with a full IR to meet the requirements. Now, shock horror, the FI needs to have actual IFR experience...

[blagger]

A cynic might suspect that a lot of parker pen IFR time will be found to make sure the 200hrs IFR are achieved by looking back at past flights.

[Cobalt]

A cynic might suggest that for any minimum hours requirement.

No real difference to someone logging IFR time "creatively" with a goal of 200 hours in mind.

I would hope that anyone claiming substantial "made up" IFR experience would easily be discovered in an interview, with questions on Eurocontrol flight planning, the realities of flying IFR in light aircraft, and by simple plausibility checks on the aircraft flown in. (IFR in the C152 from Biggin to Shoreham and back, with no time in IMC? Pull the other one)

[smithgd]

As someone who was looking in the future at the possibility of doing the stand alone IRI to add to my CRI....interesting thread!

With the removal of the 4:1 for flying with sole ref to Instruments that makes it impossible :{

Is the ANO still our bible for air law in the UK and will it be updated to reflect EASA rules?

Remember Cobalt you don't have to be IMC to be IFR !!! IFR is defined in the ANO and basically relates to altitudes followed during flight.

I guess at the end of the day "they" are wanting IRI's to have real IFR experience and not just Biggin to Shoreham in a C152 and creative parker pen hours, not a bad thing it just makes it a longer road to get there!

An interesting note; to be an IRI you need 800hrs IFR..to be an IRE you need 450hrs IFR, have I misunderstood that or what, should it not be the other way around?

[Cobalt]

smithgd,

No, you got that right. But the IRE needs to hold an IRI rating, which makes this a mockery since the IRI needs the 800 hours IFR.

This is yet another EASA mistake. The hours requirement (200 - FI, 800 - IRI, 450 - IRE) is a copy from the JAR rules, which required any examiner to also have the ratings to instruct for what they examine. So under JAR-FCL (1.452, if you want to read it up), both an IRI and an FI with the "no applied instrument" restriction removed would have been sufficient. EASA explicitly requires an IRI. I don't think this is intentional.


On to your other point - technically, ANY flight in class G below 3000ft, clear of clouds, in sight of surface, and 800m visibility is according to IFR (and if you don't believe it, read rule 33 and 34 in the ANO, which are the IFR in class G). And of course also the departures, approaches and landings in accordance with normal aviation practice, for example, circuits.

I'd just LOVE to see anyone pitching up at the CAA and claiming substantiall ALL their flying as IFR as long as it was in Class G and below 3000ft, which includes all PPL training... EASA didn't think that one through, did they? As I wrote above, the reply will most likely be, pull the other one...

[smithgd]

But it does raise the question of what the CAA will require as evidence of the flight being under IFR, given that up till now my logbook doesn't list IFR hours? Only recently have I been putting "IFR to xxxxx" in the remarks column.

I'm thinking a new logbook may be required :ugh:

[Cobalt]

Luckily, being proud of my newly CAA-given capabilities at the time, I added the IFR hours in the remarks column from the outset (I just added another column on the far right).

As far as evidence is concerned, it is your signature in your logbook.

The last three times (IR, CPL and FI ratings) I have given the CAA a printout of my electronic logbook (Excel) which I keep since (a) I am rubbish at adding hours and (b) I also needed to add my hours according to FAA rules, which are completely different. The CAA wanted it signed as correct on each printout page, but accepted it. I always offered them my handwritten paper logbooks as well, they didn't want them.

I have no idea if the CAA checks anything for truthfulness. They could check a lot, though. In my case, I could point to the capabilities of the aircaft flown (all my IFR flights after the rating, other than revalidations, were in turbocharged aircraft, and 60-70% in de-iced tourers), the routes (mostly international, which is much easier to fly IFR than VFR), if they want they can try to dig out the Eurocontrol flight plans for most of them, and even weather reports for IMC hours... but I think that significant "Parker hours" are more likely to be discovered in an interview, or by the FIC instructor giving you the IRI training.