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View Full Version : Removal of FCL1.325 FI(A) restriction


Trim Stab
22nd Aug 2012, 12:28
According to LASORS, to obtain unrestricted FI(A) an instructor must have 100 hours of instruction and have supervised 25 solo flights.

Does this have to be on a SEP and in a JAA administration? I can't see this specified anywhere.

BillieBob
22nd Aug 2012, 13:03
Does this have to be on a SEP...No, it may also be on a SET...and in a JAA administration?Depends what you mean by 'in a JAA administration'. The restricted privileges may be exercised anywhere so long as the training given is for a JAA PPL(A) or for a single-engine class or type rating and is supervised by an FI(A) holds a JAA licence and FI rating.

Trim Stab
22nd Aug 2012, 13:27
Thanks.

Is it possible for a restricted FI(A) to become a CRI/IRI (assuming minimum class and IR requirements are met)? Reading section H2.1 of Lasors it seems to me that this is possible.

Whopity
22nd Aug 2012, 14:45
Any pilot with the required experience can become a CRI/IRI, they are stand alone qualifications and have nothing to do with being a FI(R).

You can also gain the experience for removing the FI Restriction on a TMG

dobbin1
22nd Aug 2012, 17:29
I asked the CAA what I would need to do to add a CRI to my FI(R). Their response was:-

LASORS section H3.5 states 'an existing AFI (A) or FI (A) holder who does not wish to revalidate or renew that rating, but would like to gain the CRI (A) rating will be required to complete the following...' As you still wish to hold the FI (A) rating, you will be required to meet the initial CRI requirements as per LASORS H3.2. As you are the holder of an FI (A) you are credited the Teaching and Learning part of the CRI course. This information is detailed in H3.2.

Personally, I believe all FIs should be given a CRI automatically. This would then allow the FI(R) to train qualified pilots without the need for supervision.

nick14
22nd Aug 2012, 17:54
Just out of interest, why would you want to add the CRI to an FI rating? As far as I understood it, there was nothing an FI couldn't do that a CRI could.

Might be wrong.

Trim Stab
22nd Aug 2012, 18:07
Just out of interest, why would you want to add the CRI to an FI rating?


Ideally I would like to do IR/ME, MEP and CPL instruction, hence I am interested in becoming a CRI (on a MEP) and an IRI. I have the required MEP and IFR hours, and have plenty of instructor time (mostly MEP and mostly IFR - though this is not in a JAA environment).

I am hence trying to work out whether I can instruct CPL/MEP/IR under JAR without first doing 100 hours and 25 solo supervisions of JAR PPL instruction. It seems that this is viable if I do a CRI and IRI course.

dobbin1
22nd Aug 2012, 18:12
Just out of interest, why would you want to add the CRI to an FI rating? As far as I understood it, there was nothing an FI couldn't do that a CRI could.

Might be wrong.

In my case, I wanted to be able to teach aerobatics to qualified pilots. I was unable to do this unsupervised as an FI(R) despite having the aerobatics instruction restriction removed. I found it difficult to get a willing supervisor because none of the supervising instructors at the school where I did most of my work knew anything about aerobatics. It was frustrating.

Being a restricted instructor also means you can't fly the SEP "one hour with an instructor" for your fellow group members or mates unless you can pursued someone to supervise you while you do it.

blagger
22nd Aug 2012, 18:58
Trim stab - you will need an FI rating for teaching CPL, others you can do on CRI and IRI. reality is that no commercial school would take you without an FI as most of the work will be integrated training or modular CPL onwards.

Trim Stab
22nd Aug 2012, 19:55
Blagger - just to be asolutely clear - I do have a JAA FI rating - but it is still restricted as I have never taught PPL.

Whopity
22nd Aug 2012, 20:35
Then you will not be able to teach CPL other than the PPL elements on an integrated course. Look at the Privileges of an FI versus a FI(R) in either JAR-FCL or Part FCL.

As you are the holder of an FI (A) you are credited the Teaching and Learning part of the CRI course. This information is detailed in H3.2.You have already exceeded this requirement by a factor of 10. Sadly, the clerks and their supervisors in PLD don't seem to understand that! When JAR-FCL was first published it actually stated that a FI includes the privileges of a CRI but it disappeared from the text, nevertheless a FI is a CRI SE.

Trim Stab
22nd Aug 2012, 20:51
Whopity - thanks.

It does seem that an instructing career in the JAA-world is not really viable for me.

BillieBob
22nd Aug 2012, 21:48
In my case, I wanted to be able to teach aerobatics to qualified pilots.It's all too late now as the rules change in just under four weeks time but, under JAA requirements, you never needed an instructor rating of any kind to teach aerobatics to qualified pilots. What is more, the JAA FI rating never included that privilege in any case.

Genghis the Engineer
22nd Aug 2012, 22:48
Whilst it may seem inelegant, why not just do the CRI course and skill test?

With the teaching and learning component not required, and assuming you're as experienced and current instructor as you sound to be - it should be 4ish hours flying over 3 days, and a skill test on the 4th.

No, not as cheap as I'm sure you'd like, but not horrendous either.





Incidentally, of anybody who has done both FI(R) and CRI, how different are the two skill tests? I've only done the latter and although I'm sure I'll get around to FI at some point, I'd be interested to know what the real differences are at the skill test point in the meantime.

G

Whopity
22nd Aug 2012, 23:36
how different are the two skill tests?Like chalk and cheese. An FI completes a comprehensive test based initially on teaching one of the primary teaching exercises, followed by a series of shorter secondary exercises and then a series of comprehensive questions covering the entire PPL syllabus. A CRI on the other hand has received only 10% of the training and is only required to demonstrate teaching elements of a class rating conversion with differences training type questions.

Whilst it may seem inelegant, why not just do the CRI course and skill test?Up to now, the CAA has issued a CRI rating to any FI who has requested it. It is not inelegant, it is an indication of the gross ignorance and stupidity that is beginning to emerge from the Belgrano.

Genghis the Engineer
23rd Aug 2012, 07:01
Your description of the FI skill test Whopity sounds much closer to what I took (as a CRI skill test) than your description of the CRI skill test.

My brief was that I had a lapsed pilot, who had already failed their revalidation by test, and given a list of deficiencies to "sort out" - including stalling, PFLs and circuits. I also had to do two briefs (one for circuits, one for PFLS and stalling), two debriefs, and a long brief on a topic I was given the day before (I got W&CG). In between was a fairly wide variety of mostly quite deep questions on licencing, good practice, and so-on that went fairly deeply into my CPL knowledge.

Checking my logbook, it was about 1:50 flying, and from memory about another 4 hours on the ground.

Class conversion really didn't feature in it to be honest. On the other hand, it was certainly relevant to much of what I've done as an instructor since and I have no complaints.

G

Whopity
23rd Aug 2012, 07:25
and so-on that went fairly deeply into my CPL knowledge.But as a CRI you are not required to have CPL knowledge; you had an advantage over the many PPL holders who attempt the rating! You did not of course have to teach a primary exercise: E of C; S & L; or Stalling at the basic level. Yes, the format is basically the same because that is what the requirement is but the depth is quite different. Whilst most FIs will have covered the same base material, the background of CRIs is a real mixed bag, with only 3 hours training it is simply not possible to achieve a consistent standard, some are good, whilst others are very marginal. The transition from CRI to FI has also challenged all those I have encountered.
Class conversion really didn't feature in it to be honest.I would say that it did:who had already failed their revalidation by test, and given a list of deficiencies to "sort out" - including stalling, PFLs and circuitsYou have been asked to prepare a qualified pilot for their Class Rating Skill Test; thats what the rating is all about.

S-Works
23rd Aug 2012, 08:36
My FI(A) and CRI(A) SE tests were pretty identical. Full presentation of an exercise from the PPL course including board brief, in air then a full ground debrief. The CRI(A) ME covered an exercise from the MEP but was the same again with regards to content.

All done with Ontrack who are superb. Now either they are over teaching in which case I certainly got value for money or others are under teaching.

Whoppity, your distaste for the CRI rating has always been easy to see. But I think you do it a great disservice. Virtually everything I do as an Instructor and Examiner at work is covered by the CRI rating. I keep the FI(A) current purely so I can do PPL skill tests and act as a supervising FI(A).

Whopity
23rd Aug 2012, 09:28
There is nothing wrong with the CRI rating; the problem is that the rating was ill conceived in the first place; you can't tell me that 10 times the training produces the same result or test requirement even though the rules refer to the same test schedule. That leaves the FIE as the arbitrator, no advice or guidance was ever produced by the regulator and it is impossible to achieve a common standard. Most CRI candidates do not have anything like the level of experience that was assumed when the CRI was first envisaged; some of course do and it shows. The FIE is left in the position of having to make the most of a buggers muddle. It will be interesting to see what happens when the Gizit CRIs have to take their first revalidation test under EASA!

squawking 7700
23rd Aug 2012, 10:36
The CRI course and test that I undertook certainly seems to follow that of Genghis & Bose's experience.
Brief on the exercise in hand (whatever that might be - 1hr with instructor, differences etc.), air test (and from someone who did the FI test a few weeks before me, the content and time seemed similar) followed by a board brief on a subject from the PPL syllabus.
And then followed by questions on licencing etc.

Even though the CRI classroom training element is shorter than for an FI course you still have to have the knowledge behind explaining how instruments work to weather etc.

And yes, it is down to the FIE but that's the same whether it's an FI or CRI test.

And I did my CRI course after about 325hrs in other words not far off the minimum requirement but my experience was varied and I came from a gliding background.
Having the rating, I see PPL's with treble my hours who fly like they're still at the Ex14 stage, plotting their way round the circuit with visual markers instead flying to the conditions.


7700

Genghis the Engineer
23rd Aug 2012, 10:46
If the examiners have been provided with inadequate information to support conducting a CRI skilltest, then that's clearly wrong, and also would explain why several of us have experiences of the CRI skilltest that resemble an FI skilltest. On the other hand, we're standalone instructors with a fair range of privileges, and as such should be rigorously assessed.

Personally, as a CPL with reasonable hours, and one who tries to stay as competent as possible, I found it challenging - appropriately so. I honestly don't think I could have passed the skilltest as conducted, when I was a 300 hour PPL.

What do you mean Whopity by "when the Gizit CRIs have to take their first revalidation test under EASA" ? CRI, unlike FI, doesn't require a revalidation test only sufficient teaching experience. That's arguably wrong given our range of privileges, but is the case unless EASA is changing it and I missed the fact.

We are losing the right to do type ratings on "single pilot high performance complex aeroplanes", which goes over to TRIs, which personally makes no difference one way or the other, nor to very many others I suspect - but that's the only EASA change I was aware of.

Also what's a "Gizit CRI"? - is there anybody holding CRI who hasn't passed the skill test?

G

S-Works
23rd Aug 2012, 11:19
All CRI's in future will have to revalidate by test, without looking it up I think its the same process as the FI(A).

It was possible in the past for the holder of an FI(A) restricted or not to apply for a CRI(A) without doing any form of test. Reasonable in my opinion as they had already demonstrated to test standard for the issue of in FI(A).

I should imagine that as with any system there are a few CRI(A) kicking around that may be under par and were tested lightly, but then there are a few FI's and TRI that fit that bill as well.

For what it is the CRI is a good rating, it allows the generally experienced to put something into the system.

Genghis the Engineer
23rd Aug 2012, 11:53
Just looked that up...

FCL.940.CRI CRI – Revalidation and renewal
(a) For revalidation of a CRI certificate the applicant shall, within the 12 months
preceding the expiry date of the CRI certificate:
(1) conduct at least 10 hours of flight instruction in the role of a CRI. If the
applicant has CRI privileges on both single-engine and multi-engine
aeroplanes, the 10 hours of flight instruction shall be equally divided
between single-engine and multi-engine aeroplanes; or
(2) receive refresher training as a CRI at an ATO; or
(3) pass the assessment of competence in accordance with FCL.935 for multiengine
or single-engine aeroplanes, as relevant.
(b) For at least each alternate revalidation of a CRI certificate, the holder shall have
to comply with the requirement of (a)(3).
(c) Renewal. If the CRI certificate has lapsed, the applicant shall, within a period of 12 months before renewal:
(1) receive refresher training as a CRI at an ATO;
(2) pass the assessment of competence established in FCL.935.

Looks like you're right.

CAA didn't mention this in their recently published guide to new European pilot licencing regulations, which is arguably a significant oversight on their part.

However, it'll maintain standards and credibility of the qualification, which can only be a good thing, even if it does mean a bit more work and money from us.

G

Whopity
24th Aug 2012, 08:50
The CRI rating was slow to get started, simply because it was put there as the new JAA equivalent to the National TRI(SPA). At exactly the same time the JAA removed the requirement for SP "Type ratings" formerly needed on every different type of aircraft (Yes, every FI conducting professional training had to have a separate Type Rating for each aircraft type they taught on)

At the same time, CAA management, without any reference to its technical licensing staffs, produced a back door agreement giving a number of pilots "instructional privileges" these included BGA Tug pilots and LAA coaches. Ironically, some of these were even given approval to be paid whilst a PPL FI could not! At some point to cement over this "old boy" activity, all such "GIZIT" "instructors" were given a CRI rating free gratis, having never received any training or testing. Many of them were even too lazy to follow the revalidation procedure (a free sign off by a FIE) and went en-mass to the CAA expecting them to do it for them. Some had expired, but they were charged £75 a head and given another "GIZIT" CRI without meeting the renewal requirements.

I recall one Microlight FIC instructor saying to me, "I have just run a Microlight FI course for an aeroplane CRI, how the hell did he qualify?" Clearly he didn't and the day of reckoning is nigh.

Not only is there no defined standard for the CRI test, there has never even been a syllabus of training for a CRI(SE). The JAA never produced one so there was nothing for EASA to copy and the EASA AMC 900 page Compendium of Crap contains nothing. The initial CRI Courses included 60 hours groundschool, until a JAA amendment gave rise to some doubt over the actual requirement which was and still is not clear. The resulting AIC still exists. (http://www.ead.eurocontrol.int/eadbasic/pamslight-C6CFF482661A9DAA82C86DDDCF00C0E4/7FE5QZZF3FXUS/EN/AIC/W/047-2004/EG_Circ_2004_W_047_en_2004-06-24.pdf)

OpenCirrus619
24th Aug 2012, 08:55
I have just been through this exercise.

I have an FI(R) and the requisite hours for a CRI. After exchanging emails with the CAA Policy Department I was told:
Assuming all the required things are in place, all you need to do is submit an Instructor Form 1 (Form FCL 675 Issue 5) completed at sections 1, 3, 4, 5, 6 and 14 together with the requisite rating issue fee, logbook evidence of the required flying experience and evidence of a current single engine aeroplane rating and FI(A) by no later than 16 September 2012. The CRI(SPA) on issue will have the same validity as the F(A).

I filled in the form, visited the counter service at Gatwick, had my wallet lightened and got CRI added to my licence.

Not sure about why the stipulation "before 16 September 2012" - but be aware that the CAA Licensing services are not available 13-16 September (see: http://www.caa.co.uk/docs/33/srg_lts_Licensing%20Services%20unavailableINv1Aug%2012.pdf)

OC619

P.S. They get a lot of knocks - but I found everyone at the CAA very helpful while I was working out how to do this :ok:

dobbin1
24th Aug 2012, 09:57
I have just been through this exercise.

I have an FI(R) and the requisite hours for a CRI. After exchanging emails with the CAA Policy Department I was told:
Quote:
Assuming all the required things are in place, all you need to do is submit an Instructor Form 1 (Form FCL 675 Issue 5) completed at sections 1, 3, 4, 5, 6 and 14 together with the requisite rating issue fee, logbook evidence of the required flying experience and evidence of a current single engine aeroplane rating and FI(A) by no later than 16 September 2012. The CRI(SPA) on issue will have the same validity as the F(A).
I filled in the form, visited the counter service at Gatwick, had my wallet lightened and got CRI added to my licence.

Not sure about why the stipulation "before 16 September 2012" - but be aware that the CAA Licensing services are not available 13-16 September (see: http://www.caa.co.uk/docs/33/srg_lts...v1Aug%2012.pdf)

OC619

P.S. They get a lot of knocks - but I found everyone at the CAA very helpful while I was working out how to do this

So how come I was told I had to do all the CRI groundschool (apart from the teaching and learning element), flight training and test when I wanted to do this? There seems to be a frustrating lack of consistency at the CAA - you were lucky to get the right person and I must have just got the wrong clerk on the wrong day! Doh!

Quote:
In my case, I wanted to be able to teach aerobatics to qualified pilots.
It's all too late now as the rules change in just under four weeks time but, under JAA requirements, you never needed an instructor rating of any kind to teach aerobatics to qualified pilots. What is more, the JAA FI rating never included that privilege in any case.

It is true that anyone could "coach" aerobatics, but I don't think they could charge for it and I don't think both of them could log the time. It is also true that the FI rating doesn't include privileges to teach aerobatics, but having to do the additional training and testing required to remove the no aerobatics restriction does imply that it is legitimate for a so qualified FI to do it.

ifitaintboeing
26th Aug 2012, 10:53
Whopity,

Your post referring to the Gizit CRI ratings is a little brash. Pre-JAR one could conduct type conversions and differences training without an instructor rating. It was right that these individuals be allowed to continue this activity - similarly a number of instructors who held PPLs were given BCPLs since the new JAR-FCL regime required this to allow them to continue to be paid.

The CAA provided CRI ratings to a few who were conducting training on behalf of the LAA and BGA, to allow them to continue this activity under JAR-FCL. This was a long time ago (1998), so the reality is that the LAA system now only has 3 people who obtained their instructor rating in this manner. Everyone else either held an FI at the time, or has subsequently passed a FI or CRI skills test.

There has been a significant period of regulation change in the industry which has done nothing to enhance safety. We will see a similar situation occur in the near future with the EASA aerobatic rating. Presently no rating is required to conduct aerobatics, although under EASA there will be (on EASA aircraft). Both myself and BEagle have been involved in the conversion report for this, to allow what you might call 'grandfather rights' to be carried forward.

Not only is there no defined standard for the CRI test, there has never even been a syllabus of training for a CRI(SE).

The syllabus of training is contained within the FTOs Training Manual, as approved by the CAA. Whilst there is no AMC for FTOs to 'copy and paste' into their manuals, there must be a syllabus of training in order to obtain approval to conduct the course.

Standards Document 10 (A) contains detail of the Content and Conduct of the CRI skills test, along with the Assessment Criteria at Appendix 1 of the same document.

ifitaint

Whopity
26th Aug 2012, 17:23
Pre-JAR one could conduct type conversions and differences training without an instructor rating.Not if it involved licensing action. similarly a number of instructors who held PPLs were given BCPLs since the new JAR-FCL regime required this to allow them to continue to be paid.This action preceded JAR-FCL by nearly 10 years (1989) and was to cater for a change in UK Law, nothing to do with the JAA.to allow them to continue this activity under JAR-FCL.But this activity related to licencing action which had never been part of any previously held privilege, so was not truly a grandfather right.

FTOs submit a syllabus of training based upon a defined requirement; there is no accurately defined requirement in JAR-FCL or Part FCL. Both detail exactly the same Skill Test and content for a CRI test as a FI TestCRI
On completion of the course, the applicant shall take the skill test in accordance with Appendix 1
and Sections 1, 2, 3, 4 and 7 of Appendix 2 to JAR FCL 1.330 & 1.345.
FI(A)
On completion of the course, the applicant shall take the skill test in accordance with Appendices 1
and 2 to JAR-FCL 1.330 & 1.345.(Section 5 being ME)This is unrealistic for two courses that differ in length and content by a considerable margin.
Standards Doc 10 is issued for Guidance and may well cover a deficiency in JAR-FCL but; the CAA has no remit to add to the EASA regulation to cover perceived deficiencies. i.e. it cannot be more stringent than the basic regulation.

Cobalt
26th Aug 2012, 20:14
The requirement below does not mean that the FI and CRI skill test are identical - only that the format and duration are approximately the same.

I would expect a CRI to be examined on exercises relevant to teaching someone who already has a licence and adds a different rating - so 10B / 12 / 13 / 16, for example, would be the most relevant.

An FI could be examined on Ex. 4.1 (effects of controls), which makes NO sense for a CRI.

The need to cover more exercises in more depth for FI also explains the difference in course duration.

Phil Elder
3rd Dec 2012, 21:02
could anyone help me with regard how many hours experience are required to teach CPL? I hold a frozen ATPL (A) with unrestricted FI rating currently teaching PPL students however I am looking to teach CPL students also but I m not clear of the hour requirements of EASA.
Thanks

Whopity
3rd Dec 2012, 21:06
No difference from JARFCL.905.FI FI — Privileges and conditions
The privileges of an FI are to conduct flight instruction for the issue, revalidation or renewal of:

(d) a CPL in the appropriate aircraft category, provided that the FI has completed at least 500 hours of flight time as a pilot on that aircraft category, including at least 200 hours of flight instruction; You will of course need to do this at an ATO where they will have a requirement for in house standardisation.