IRI / Instrument restriction removal with FI(R)

[OhNoCB]

Hello folks!

I am considering doing an Instructor rating in the near future and I have a question which I have thus far received conflicting answers for!

I would like to do the FI course and incorporate the night training with it as well. I also have a desire to teach towards the IMC rating and perhaps in future the IR itself (and any new renditions of it per EASA). I do however have to travel to do the course due to my location and I wondered if I was able to do the IRI (not the standalone one) either alongside or directly after the core FI course to keep travel/accommodation costs down.

I appreciate that a FI(R) cannot teach instruments but I can't find anything to say that you need to be unrestricted to do the course. The conflicting answers I have found thus far are as such:

No don't be silly, you must be unrestricted to do the course.
Yes you can do it but you can't use the privileges until unrestricted.
Yes you can do it but you can't get the restriction removed (/privilege added?) from (/to) licence until unrestricted.

All these answers have been from course providers and the CAA aren't being much help to resolve, so I hope you guys can!

I thank anyone in advance for the reply.

Regards,

ONCB

P.S. The providers I am current considering are TPC, Ontrack, Andrewsfield and Pooleys, if anyone has any thoughts feel free to let me know as I will likely choose on a price basis unless there are better reasons!

[S-Works]

You need 200hrs of IFR in order to do the course. Do you have this?

[nick14]

As far as i can see there is nothing in the regulations that prevent you doing the course however, the ATO will have an approved course manual in which it stipulates the pre-course entry requirements. You may well find that the ATOs have specified an unrestricted FI certificte prior to course enrollment. Then again they may not.

[172510]

FCL.905.FI
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;
(...)

You must have completed the IRI training course, as I understand the regulation, it is not required to have a full FI nor to have 200 hours under IFR to commence the IRI training course, so I think you may commence the IRI course directly after having passed the FI test.
You must have passed an assessment of competence for the IRI certificates, and I could not find any prerequisite.

So it seems that you don't have to be a full FI, and that you don't even have to have flown 200 hours under IFR to get your IR extension, provided that you don't teach for the IR until you have flown 200 hours under IFR.
Nevertheless, the ATO may have different prerequisites in their manuals, and it's perhaps CAA policy to demand that ATOs do not commence IRI course if the student has not met the IFR experience requirements.

[nick14]

I would imagine that you couldnt take the AoC having not met the required experience level just as you cannot with the CPL, so the training would be useless unless you could get the required experience very soon after the course.

[OhNoCB]

To clarify - I have in excess of 200h IFR time, the only thing I wouldn't meet would be the 'unrestricted' bit. Obviously it is preferable for me (having to travel, as mentioned) to do it all in the one trip hence the question!

Would the agreed opinion tend to then be that it depends on what the ATO has written in their manual and thus ATO dependent?

Thanks for all replies so far!

[nick14]

I would ring the HOT at the ATO you intend to use and have a chat as they will be able to tell you exactly what they require for their approved course. If you had considered Central at Tatenhill then hive craig a ring he will be able to let you know in a flash. Great course too!

I would imagine that the FI course would enough but with an IRI ontop its going to be quite a challenge.

Good luck

[OhNoCB]

Thanks! I'm sure it will be a challenge if it's possible.

[BEagle]

The recent Art4(8) amendment enables the CAA to decide the appropriate qualifications for IR(R) instruction under para (d):
...applicants having completed appropriate training with qualified instructors and demonstrated the required competencies to a qualified examiner, as determined by the Member State;
The intention is that such IR(R) instructors will only need to meet the same pre-requisites and complete the same course as previously applied for the 'removal of no applied instruments restriction' for IMCR instructors.

[OhNoCB]

What exactly was required previously, BEagle?

I have contacted a couple of providers today who have told me that it is NOT possible to do the course without being an unrestricted FI, so you're post leads me to think what is required (now) to be able to instruct for the IR(R) but not the IR, if that's what was being got at.

[Whopity]

Pre JAR this was the requirement:16.3.7 Removal of the applied instrument flying instruction restriction
16.3.7.1 Where an AFI Rating (Aeroplanes) is issued with a restriction on applied instrument flying instruction the rating holder may qualify for removal of the restriction by completing additional training and by passing a further flight test and ground examination conducted by an FIE. The additional training must include not less than 15 hours of ground training and 7 hours of flying training, and it must be carried out at an approved FTO under an FIC Instructor. Holders of an API Rating granted prior to 1 August 1987 are required to carry out 20 hours of ground training and 10 hours of flying training for the removal of the res tri ction.

16.3.7.2 An applicant must have completed not less than 100 hours instructional flying and not less than 250 hours as PIC before undertaking the additional training and testing specified in paragraph 16.3.7.1 except that the holder of an Instrument Rating (Aeroplanes) may combine the additional course of training with the basic course detailed in paragraph
16.3.4. In any event the above instructional and PIC requirements will not apply in the case ofthe holder of an Instrument Rating (Aeroplanes) wishing to qualify for the removal ofthe restriction.

I wonder how close to that we will get!

[Level Attitude]

A very interesting question !
(g) an IR in the appropriate aircraft category, provided that the FI has:

(2) completed as a student pilot the IRI training course and has passed
an assessment of competence for the IRI certificate; andYou must be an FI to do the IRI training course so, as a minimum, you
must do the FI course first (including passing the test and having the
Rating issued)

An FI with restricted privileges is not allowed to teach for the IR. However
I believe that Part-FCL, as written, assumes that these restrictions on an
FI simply fall away, with no further action required, once the requisite
experience requirements have been met.

There is, therefore, nothing in law (that I can see) to prevent an FI with
restricted privileges from doing the Instrument Instruction course
(provided any ATO's entry requirements are met) and then teaching for
the IR as soon as they have met the requirements to remove the
restriction on their FI privileges.

Usually a certain level of instructional experience is expected of an FI
before they extend their instructional qualifications and, for UK Licence
holders this is effectively formalised: The CAA do not issue an FI Rating
to new instructors they issue an FI(R) (only country in EASA to do so?)
and the only way to remove the restricted privileges is to apply to the
CAA to do so (ie convert the FI(R) to an FI).

So, as they don't hold an FI, I doubt the CAA would accept any UK FI(R)
from undertaking the IRI course - and doubt that any UK ATO would offer
to teach any FI (from any country) who still has restricted privileges.

[S-Works]

Our ATO manuals do not permit a restricted FI to do training for the removal of the restriction unless they are unrestricted and meet the hours requirements.

However we can do a CRI course and an independent IRI course as long as the prerequisites are met.

This was done like this at the request of the CAA when the manuals were submitted for approval.

[Whopity]

So, as they don't hold an FI, I doubt the CAA would accept any UK FI(R)
from undertaking the IRI course - and doubt that any UK ATO would offer
to teach any FI (from any country) who still has restricted privileges. But there are current proposals to do so, the purpose being to allow an FI to gain the IFR experience necessary to qualify to each the IR. The full details have not yet been anounced. A FI(R) is a FI, they are not seperate ratings as the UK used to make them!

[Level Attitude]

A FI(R) is a FI, they are not seperate ratingsWhopity,
If you re-read my Post you will see that (for once http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/embarass.gif ) it seems we agree.

However:
FCL.910.FI FI — Restricted privileges
(c) The limitations in (a) and (b) shall be removed "Shall" can mean "mandatory" which doesn't make sense in this context,
but in can also imply that an "action needs to be taken" - but I cannot
see listed anywhere in Part-FCL what that action would be, so it can be
left to the Competent Authority.

The UK CAA require a Licensing Administrative Action to occur in order
to remove the restrictions on the privileges of an FI - and my point was
simply that this does give them more scope for controlling what courses
FIs with restricted privileges (FI(R)s as the UK call them) can take.

[Whopity]

this does give them more scope for controlling what courses
FIs with restricted privileges (FI(R)s as the UK call them) can take. I don't believe it gives them any scope at all, they must comply with Part FCL. If you read FCL.910.FI FI carefully, it is subtly different to JAR-FCL 1.325
(a) An FI shall have his/her privileges limited to conducting flight instruction under the supervision of an FI for the same category of aircraft nominated by the ATO for this purpose, in the following cases:The following cases make no reference to Instrument instruction so the FI(R) is not limited in that respect. In contrast, JAR–FCL 1.325 listed what a FI(R) could do and that did not include instrument instruction.

As it is the CAA is looking to ease the current situation and not impose greater burdens than EASA has already done.

[Level Attitude]

The following cases make no reference to Instrument instruction
so the FI(R) is not limited in that respectI believe, taken as a whole, that FCL.910.FI is quite clear that an FI
has their privileges restricted to only give instruction for those items
listed in Para(a) and that such instruction is subject to Para(b).

From the way you have underlined your quote I do see that it could be
possible to interpret it to mean that instruction for items listed in Para(a)
are, in fact, the only items to which any restriction applies.

Yet again, badly worded law (due to translation ?), that can be interpreted
in different ways. EASA are not about to re-write Part-FCL so I would go
with whatever interpretation is deemed the correct one by the relevant
Competent Authority - and, as discussed, the UK CAA have a "formal" way
of applying this by only printing FI(R) on a Licence.