Proposed Changes To Fi(a) Revalidation Requirements

[BEagle]

As all FIs should know, to revalidate your FI Rating nowadays you have to complete 2 out of the 3 options of ‘experience’, ‘seminar’ and ‘test’. This seems to have settled down quite happily over recent years; previously you needed only 5 hours experience every 6 months and had to fly a FI check every 2 years.

However, under NPA-FCL 1-16 (Aeroplane), a proposal is now being made to the JAA that ‘For every second revalidation of a FI(A) rating the holder shall pass, as a proficiency check, the skill test set out in Appendices 1 and 2 to JAR-FCL 1.330 & 1.345’.

This is yet another example of the JAA attempting to shift its own goalposts. There has been no consultation with current FI(A)s or UK/FE PPLs over this proposal - only with the FIEs who, perhaps unsurprisingly as they would be the ones to benefit financially from such a proposal, are in support.

I consider that this is a wholly unsatisfactory situation. No Regulatory Impact Assessment has been conducted and certainly no safety case has been demonstrated. As a result I will be writing to Mike Dobson (UK CAA delegate on the JAA Licensing Sectorial Team) to register my objection to this proposal as he will be the one who will supposedly be responsible for presenting the UK’s view. Should anyone else feel as I do, perhaps they might also care to write to him. His e-mail is: [email protected] . If you don’t make your views known, don’t then complain if the JAA introduces this unwelcome and wholly unnecessary amendment.

[drizzle]

I agree with you, its crazy for no other reason that yet again many poor instructors will have to pay out more on top of medicals, seminars etc.
With over 700 instructional hours I have never had a medical paid for nor do I know of any other peson that has. I have worked at several clubs in the SouthEast/West.

.

[CaptAirProx]

BEagle...........where did you get the info from thanks? This sounds bloody outrageous.

[BEagle]

'Sources' is all I will say. But the quote ‘For every second revalidation of a FI(A) rating the holder shall pass, as a proficiency check, the skill test set out in Appendices 1 and 2 to JAR-FCL 1.330 & 1.345’ comes directly from the draft amendment.

A further problem might be the impartiality in this issue of the Chairman of the Licensing Sectorial Team, as he was, I am led to believe, personally in favour of this proposal when it was first mooted.

This proposed change to FI revalidation requirements is a very real threat, not just an unsubstantiated rumour. I have already e-mailed Mike Dobson with my objections and would encourage others to do the same.

[CaptAirProx]

BEagle, thanks..........

No access to JAR for the next couple of days. Therefore this skill test, is it similar or same to the SEP(L) for licence issue etc? Don't mind doing tests but if we already have to do one for the FI and also for our licence validity, sounds like a load of tosh. I will write to Mike when I see the facts! Cheers

[Another_CFI]

The proposal to require a test at every second FI renewal is, in my opinion, a retrograde step. Having held an instructor rating for over ten years I have operated under both the ‘old’ system and the current system a feel that the current system is superior. Apart from the few instructors who fail to meet the experience requirements each of us can chose either to undertake a test or attend a seminar.

At my last renewal I opted to attend a seminar and whilst it occupied two days I believe that it was much more useful than renewal by means of a test. The presentations and workshops at the seminar were more stimulating and thought provoking than a test with an FIE and the opportunity in the evening to talk with instructors from other flying schools added to the value of the seminar.

If the system is going to be changed then why? Has the current system led to a lower standard of instruction? Are the PPLs that are being produced less safe? I have neither heard nor seen any evidence to support either of these views.

If someone is going to be consulted about the proposed change surely the best people to consult are FE(PPL)s and the Chief Flight Examiner. As an FE(PPL) I see the results of training by the same group of instructors on a frequent basis and I, and my fellow FE(PPL)s, are in a much better position to spot any underlying deficiencies and suggest remedial action than an FIE, who under the proposed system may only see any individual instructor once every six years. The CFE has the advantage of having available every Skill Test report and should be in a position to spot any diminution in standards on a national basis. Is there any such evidence?

:(

[BEagle]

Perhaps I should have made it clearer - it means that the FI reval skill test would be mandatory every other revalidation!

In other words the options of:

1. At least 100 hours instructional experience in 3 years, of which at least 30 hours must be in the final 12 months of the FI Rating validity period,

2. Attendance at a 2-day FI refresher seminar,

3. A FI revalidation rating test

of which you currently have to do any 2 out of the 3, would change so that the FI revalidation test would become mandatory, NOT optional every other revalidation period.

There is NO safety case to prove that this change is needed, we have only just got used to the current requirements and we have not been consulted. However, now that Examiners are formally standardised by the 'observed flight test' requirements, their standards will be more or less similar across the industry. Hence they will all be able to detect any weaknesses in their PPL applicants resulting from poor instruction and any applicant failing because of such weakneses has a report raised which goes to SRG and to the CFE. Hence the CAA must be aware of any weak areas emerging from the new system - otherwise there'd be no point in FEs having to write these reports, would there CAA? Are there any? You haven't made us aware of any!

The quality assurance of PPL instruction is continually monitored by UK/FE(PPL)s through the medium of PPL Skill Tests, revalidation and renewal proficiency checks and SEP Class Rating Skill Tests. A 'poor' instructor will be readily identifiable at any RF as a result of 'his' students' failure. There is consequently NO NEED to change the current system and we should object in the strongest possible terms to this NPA.

[CaptAirProx]

BEagle, thanks you have made it clearer! I must say then I am not so hot to contest this.

As much as the seminar must be good. (I have not attended one but most say its worthwhile) I believe there is no substitute for being put through the renewal flight test. And every other renewal i.e six years is no great sweat! As I see it under the JAR system so far, you can get away with no flight test altogether. Hmmmmm.

Everytime I make a ballsup of something on the flight test and learn from it. It makes me remember why we are taught to be disciplined in our approach to it all.

The test seems to cost no more than the seminar. Now I have no objection to the seminar but feel we should be "standardised" by test from time to time as we examiners are.

I can't imagine the CAA wanting me to sit my LPC/OPC by swapping bar stories over a coffee or six instead of sweating my backside off in the sim! I'm sure you would agree on this bit? Why should it be different for instructing. And as RF/FTO's go the standard of monitoring that goes into its staff of instructors is very varied. So the CAA need a check of some sort, we can't rely on RF/FTO system.

So I am sorry BEagle, but I will be in support of this if the details are correct as you put them. Bullet proof vest is on and ready!

[BEagle]

You are entitled to your opinion, of course. The old FI retest included some really pointless items - for example you had to fly a 'pilot-interpreted approach' and to demonstrate to a FIE that you could recover from a spin and complete a safe off-aerodrome PFL. Something which any FI should be able to do at any time and which was probably the result of CFS-inspired heritage in the CAA FIE world. But very little of which had the slightest thing to do with a check of instructional ability in the air.

Now, however, you have to demonstrate your flying skills during a 2-yearly 'dual training flight' no matter who you are - so the pure flying skill set is routinely tested in any case. But your instructional methods and knowledge may be refreshed at a seminar; instead of pretending that the FIE is a basic student to whom you are giving a single basic lesson - usually something very simple like medium turns or stalling, certainly never navigation - at a seminar (which is not dependent upon a suitable combination of ac availability, dubious UK weather and FIE availability), you are refreshed on a whole range of topics and brought up to date. This is a far more useful standardisation method.

But what would happen to someone who didn't pass this proposed 6-yearly revalidation? Would all his previous 6 years of instruction be declared null and void? Would all his students be recalled for further training?

No - this NPA is a nonsense. Unless there is clear and present evidence that the current system is unsafe, it should be left well alone.

The devious and underhand way it was proposed is another story.........

[Another_CFI]

I concur with BEagle and must disagree with CaptAirProx. Handling skills and demonstration of decision-making ability can only be checked by practical test whilst instructional skills are better checked by sampling.

Each and every instructor is subject to sampling, irrespective of any internal mechanisms within the RF/FTO, every time he/she submits a candidate for a Skill Test. If an instructor has a lower success rate than his/her colleagues or presents students for test who repeatedly fail a particular part of the Skill Test then this should become obvious to both the FE(PPL) and the instructor’s CFI. Surely this continual sampling is a superior method of monitoring instructional standards when compared to the previous system where during the instructor test the FIE acted as a student and was then ‘taught’ disjointed fragments of a variety of exercises.

As an FE(PPL) I do however believe that the requirement for us to be re-tested as examiners is an improvement upon the old system where the BX examiner authority was revalidated simply by paying a fee. The FIE can set up situations during the dummy Skill Test that call upon us to make a decision as to the outcome of the dummy test and then ensure that the result which each of us awards is consistent with the test standard

[Wee Weasley Welshman]

This shall not be allowed to stand. NO. NO.

WWW

[BEagle]

Regarding the comparative costs of a 2-day seminar and a FE revalidation proficiency check, I was somewhat surprised at the comment:

"I think you will agree that a proficiency check with an FI(E) is probably cheaper than a two day seminar."

Does anyone agree that this is the case? An hour and a half at £90 per hour, plus a fee of about £175, plus the FIE's expenses will set a FI back over £300 - I certainly paid nothing like that for a 2-day seminar, even allowing for overnight accommodation!

I understand that this proposal actually started with the UK FIEs at one of their conferences and was subsequently taken up by the JAA Flight Examiners' Working Group, who introduced it as a text change to the helicopter requirements (JAR-FCL 2) and suggested that perhaps it should be introduced for the aeroplane instructors (JAR-FCL 1) as well. So it was never even suggested by a fixed-wing group in the first place!

I consider that 6-yearly mandatory testing would serve no useful purpose and would merely alienate FIs against what seems to be a heavy-handed CAA.

Please say NO!! I shall certainly be writing to the JAA Regulation Director to register my opposition to this proposal and would urge others to do the same. The correct address is:

Yves Morier
JAA Regulation Director
Central JAA
PO Box 3000
2130 KA Hoofddorp
The Netherlands

[cessnababe]

BEagle - this sounds like a case of "he who doth protest too much" -one test every six years!! Hardly onerous. When I became an instructor I did four tests in the first three years in order to become a MEI, then to upgrade to QFI on singles and then to upgrade to QFI on ME. I learnt an enormous amount every time I did a test and I consider that it is only in the one to one environment in the air that any unusual habits or misconceived methods can be straightened out. If someone does not want to take a test I am curious as to whether they are doubtful of their own ability. In the interests of imrpoving standardisation regular testing is surely desirable.

By all means have a seminar - it is a useful forum for conveying large amounts of material to a large number of people. I would be in favour of both being compulsory, although I believe that the schools should pay for the attendance by their instructors. I also think that three years is far too long between tests. Effectively a new instructor need never be checked again by test, which is as unsatisfactory as the PPL who never ever flew again with an instructor; at least they now have to do the dual training flight on a biennial basis.

By the way BEagle it may have cost a little less to attend the seminar but did you factor in the two days of lost revenue (as opposed to half a day if you do the test) or are you in the fortunate position, not enjoyed by the majority of instructors, of having a salary?

[climbs like a dog]

The contention that Instructors are TESTED every two years by dint of an instructional flight is overstating the nature of the flight with an instructor. It isn't a test remember. I'll wager that at more than a few clubs, two instructors from the same club will go tootling off for a jolly and there won't be an element of testing. It is a formality, or possibly will be in the minds of the individuals concerned. The system we have in place now ensures that no instructor need be tested after their initial flight test and that is wrong. By introducing the mandatory test you are introducing an independant eye and a standard to the revalidation of the rating and you are ensuring that specific skills are being assessed.

You may find it preposterous that high standards, such as applied by yourself, aren't universal; and I'm not suggesting that a majority of FI's are so irresponsible, but come on guys, you have as much of a vested interest too.

As a postscript....any test to renew any rating also counts as an instructed flight. Therefore an airline pilots LPC/OPC counts? What relevance does that have to flying and instructing in light aircraft?

[cessnababe]

Absolutely Climbs like a dog - you are the only one posting here to have got the point!! Thanks!

[CaptAirProx]

climbs like a dog. I totally agree. Your comments about LPC/OPC and light aircraft are spot on. They are two totally different fields of aviation.

I am still, regardless of the responses of others here, in total favour of an FI renewal flight test.

I disagree with some comments on here that instructors are monitored through sampling via the PPL Skill Test Candidate.

That system works if the instructor has done the majority of the course for the candidate, but one of the clubs I frequent as an instructor/examiner, every lesson is completed by a different instructor. I have found both the standard of progress of the student is slow, inconsistant knowledge and skill, and the student records are awful. I have tested these guys and found that it is very hard to find out "who" was teaching the wrong techniques etc.

There are some great instructors around the skies and there are some not so good ones. Skill Test sampling is just not good enough at weeding the men out from the boys. Its a good help but testing of the instructor is surely the final nail in their coffin!

Instructors want to be seen as professionals in their chosen career, so why is it they aren't all in agreement to be tested as professionals.

Mr Dobson - if your reading this.....................bring back mandatory testing!

I believe that I am still learning heaps about aviation, and therefore testing is a great way to put my money where my mouth is and I often fluff it! All very humbling!
I am hoping that one day I will walk into my LPC/OPC and treat it like water off a ducks back. I probably never will but I am sure some guys/gals do but they still have to go through the hoops. Its all part of professional aviation and hopefully stops us from getting complacent.

[BEagle]

Climbs like a dog - whilst it might not be unreasonable to check 'instructional ability' in some way, checking flying skills on a FI revalidation is irrelevant. I know the UK CAA wanted to continue as they had pre-JAR; however, they weren't prepared to file a National Variance to back up their chuntering opinions as this would have attracted flak from the JAA! In fact they went out of their way to tell us what a good idea the seminar was..... Sorry - either you sign up to JARs or you contract out of them altogether!

This 'opportunity' to re-introduce mandatory testing was first suggested by FIEs at one of their symposiums. Convince me that this suggestion wasn't financially influenced, that there has been a worrying downward trend in instructional standards or that all FEs have been consulted and perhaps I'd feel different.

6-yearly testing would be totally meaningless. If an FI hadn't learned how to instruct by then, then perhaps he never would. If this is made mandatory, many of those 'get the hours any old how and go to the airlines asap' FIs would have come and gone in 6 years, leaving only those who choose to instruct because that's what they want to do, not just hours-build pre some 737 bucket-and-spade RHS job.....

An alternative? Make the first FI revalidation of a new FI's career include a mandatory revalidation proficiency check - not 'every second revalidation' as is proposed? That way the development of instructional ability can be adequately proven and thereafter the FI should continue to revalidate as at present

[CaptAirProx]

BEagle, yeah right?

So like a new instructor, I go to my first airline job. Now as I'm a professional pilot I don't need to be tested everytime I go flying, I know it all already. All I need is just a reval of my type rating in the first year and then go off never to be checked again. All because I know it all already and have nothing to learn from any further re-test. Yeah right. I don't think so some how!

Well I don't know what you guys do on the heavy metal at Brize, flying VC's et al but I bet you get tested every now and then as a professional? Am I right.

Come on Beagle, you don't surely think that once you have an instructor's ticket you become immortal? That is certainly the way I read your lines. Please correct me if I'm wrong. ta

If we are not going to be tested as instructors any more then I reckon they should up the requirements in the initial test and include the pilots attitude to aviation. Then we might just be left with the sort of guys that take pride in their qualifications and go seek advice when needed and take advice when given. Then there would be no need for testing. But hey, that's the ideal world and we all have to live to the lowest common dinominator. Get tested every now and then to get rid of the bad wood. And I might add, make us better at our job in the meantime.

[CaptAirProx]

And another thing..............

You could take it the other way. Why make PPL's do a 2 year instructional or prof check. Why not make them attend a seminar instead and not be tested ever again?

I wonder if you defended the PPL's when this was first mooted. Because lets face it, you and I both benefit from this new scheme as PPL FE's. Whats your view on that?

Is it a case of the table has turned now?

[BEagle]

1. The dual training flight does not need to be conducted by a FE. Ergo, as a PPL FE, I do not gain materially from this reqt. But most reputable clubs have always required an annual dual check of their pilots in any case, so this wasn't really anything new for most folk.

2. The prof. check requirement is really only the same as the old 'GFT if not enough P1 hours' reqt.

3. I am not talking about the 'testing of flying skills' - I am querying this proposed revised reqt. for the evaluation of the ability to impart instruction.

4. My last instructional check was conducted during the asessment of a captain on an international route flight. Nothing to do with my own flying skills - those are tested 2-yearly at CR(S) level.

5. Please re-read my posts, you haven't quite got the gist of my argument.

[CaptAirProx]

Hang on..................

I thought at the beginning of your posts you were suggesting that we had to do a test flight of just our flying skills as well as doing the usual 1 or 2 year Class Rating thingy that all PPL's do. Now that seemed odd to be tested yet again for flying skill in what seemed a similar test format.

You then told me that what Dobson et al were saying was effectively re-introduce the old QFI renewal type flight test. Now as far as I am concerned thats fine. As thats a test specifically for that rating. Yes it does test your flying skill, but obviously the aim is to see if you can still teach correctly. No point being able to teach yet can't fly accurately!

Your comment about your last instructional flight you did. Yeah, thats fine, because being Multi Crew, thats what you need to do. You ain't teaching the guy how to fly basics, your building on his/her already demonstrated professional skill.

A PPL is being taught the whole thing from scratch. You need to show that you can teach the basics. Demonstrate them accurately, and fly a SEP (L) professionally, and safely for that trial lesson you can legally do with paying punters!

I think your professional instructor bit is a totally different kettle of fish. Most of techniques are the same but the material is different.

Please correct me again if I have the wrong idea of this proposed new FI renewal, but thats how I read your later posts.

[BEagle]

The basic technique of imparting flight instruction is the same in any environment. Brief-monitor-debrief.

The UK CAA favours re-introducing the FI revalidation proficiency check. Does this still include such pointless items (for instructional ability) as a pilot-interpreted let-down (also revalidated on IMC/IR checks)and a non-instructed PFL? Those do NOT need to be checked on such a test; they might have been back in the days when there were no mandatory checks of piloting skills post-GFT, but not nowadays.

I can't see that a 6-yearly re-test will have much merit; it might well be desirable in some people's opinions, but they must prove that it is essential before such a change is approved. Which I challenge them to do with factual proof of lowering standards or deteriorating safety records...............

............and the CAA is not testing 'Q'FIs - only the military does that! Civil terms are FI and FI(R)!

[CaptAirProx]

Beagle,

Your quite right about the QFI bit. I was quoting the old "QFI" test for example purposes. No need to split hairs there me thinks.

Anyway, one my last renewal test that I chose to do last year. I did the let down and pattered it, as asked by the FIE. Yes I got to do umpteen ILS's etc on my last LPC, and yes I got to do an ILS on my MEP(L) IR this year, but I never pattered the ILS thing till this renewal. So thats why the CAA want it done in the renewal surely. We can all fly one but can we still fly and talk? As to the PFL, well I look at it like this. Yes I do do a PFL from time to time, but I can renew my SEP(L) by doing my MEP(L) prof check every year, based on my hours flown SEP(L). So infact, looking at it I will never have to demo to an examiner my skills on no engine ever again under JAR.

So perhaps thats why as a instructor it is still wise to be tested for our skill at forced landing. Remember, they have got to cover the worst case scenario, so I am just glad that I am hopefully not allways the worst case!!!!!!

Now I'm off to do some ground school for a week so can't respond for a while............safe flying.

[FormationFlyer]

Id like to add a little here from a newbie perspective....

Im a relatively new instructor with about 115hrs instructional time, 600TT - just about to become unrestricted.

Personally I welcome flight tests - indeed for my renewal in a couple of years time I have already decided to do both the flight test AND the seminar - even though I will be able to renew on experience. Why? Because I relish every flight test I do - maybe, just maybe I can walk away with just one iota of information that I didnt have before, perhaps another view of a technique I didnt have before, also its one of the few chances you get to speak to FIEs really - I mean yeah we talk about technique amongst ourselves as instructors but it really is important to be able to access that examiner and hear their take on things (I also enjoy canvassing FE to see their take on things...very useful).

The guys who concern me are the ones who have been in the business for years and perhaps think they have seen it all - maybe they have - but I dont think you ever stop learning - and an oppurtunity to reaffirm your skills/lnowledge should not be sniffed at. Surely we should be aiming at continued self-improvement?

This aviation lark is a serious thing. I dont care if you fly for fun, pleasure or whatever - but when you get into an aircraft lives are at stake. As an instructor you want to make sure that you wont kill yourself, other wont kill you and more importantly that someone you teach wont kill themselves/others. Therefore surely the test of ability regardless of experience should be welcomed?

Also, I see no problem in checking BOTH my own personal skills to ensure safe/recoverable flight given emergency situations as well as my teaching ability/techniques.

As I say - Roll on my IRI, & roll on those flight tests...I look forward to picking up some useful tips. I know I did at my initial.

Regards,
FF

[climbs like a dog]

It is my contention that we should never have moved away from the previous system which had worked perfectly well for a number of years in the first place.

Beagle, you are defending the indefensible. The notion that instructional skills in the air shouldn't be tested post initial test is ludicrous. The fact that there is no element of examination of flying skills post initial SEP (L) rating test is also ludicrous (for an instructor particularly).

Having re-read your previous posts I don't see your point is justified. Why not make all revalidations subject to flight tests, instead of relying on these companies springing up to run the seminars, which in itself is quite a racket. Why not press the CAA to provide the seminars as standardisation events? They probably are a very useful tool for disseminating best practice but how can you test or measure any increase in skills achieved or indeed whether the baseline skills are being retained?

You mention that your club, or any decent club will insist on a checkride every year or two; indeed your insurer may compel you to. The only problem is that this isn't a test either. Not in terms of a rigourously applied standard.

I think in cases where an instructor demonstrates skills by renewing a rating, such as the IR revalidation, that the testing on an instructor revalidation should only cover the instructional skills.

I agree with the poster who queried your reliance on an assessment of the overall standard of PPLs coming through the system. That assumes that the standard amongst examiners remains constant or that the emphasis on tests doesn't change.
As a for instance; if you were to use the test standards as a yardstick, you could say that for an average FI their basic IF teaching skills are of the same standard as the average was 5 years ago. That would be a dodgy statement because the IF syllabus in the PPL has become far more basic under JAR ie 180 on instruments and fly out of the cloud. More accurately you could say that the IF tuition has been sufficient for the student to pass the exam. This doesn't assess in any way the ability, in terms of flying skills, of the instructor.

I think you'll find that most JAA edicts get by with at best a cursory RIA. The CAA should have stuck to its guns and filed a difference.

[CaptAirProx]

Formation & Climbs like a dog.................

Thanks guys, I was beginning to think I was the only one with a view on this one!

As formation said, we never stop learning. I have just completed some ground school as a student in whats called "differences" training for an added series of aircraft to go on my type rating.

i have just learnt loads about aviation that I should have already learnt yonks back............must have got lost in the blurb somehow! I am off to the stimulator next week and will be under "test". I expect to learn a great deal more...........and I'm looking forward to it!

I thought that was one of the delights of aviation, in that we never stop learning.

Bring back the old system. I was tested nearly every two months as a new "AFI" years back. As the old system required a quick test flight with an FIE to fly a new series of aircraft as an instructor. It was a great way to refresh and develop my instructional skills. Shame it is still not in place. My have avoided the EGHH incident a couple of years back.

[BEagle]

Thanks to all the contributors to this thread.

My conclusion is that FI revalidation by alternate mandatory flight test might be considered 'desirable' by some, but it must be proven to be 'essential' before changes to current legislation may be considered.

However, I do consider that it would be reasonable for the first FI revalidation to include a mandatory flight test.