CRI privileges (again): training under IR

[172510]

A IR qualified pilot wants to fly with a more experienced pilot besides him to built up experience, out of an ATO.

The more experienced pilot is a CRI. The CRI is neither FI nor IRI.

(i.) May they fly under VFR the CRI logging PIC, the student P/UT?

(ii.) May they fly under IFR the CRI logging PIC, the student P/UT?
[
I]FCL.905.CRI CRI — Privileges and conditions
(a) The privileges of a CRI are to instruct for:
(1) the issue, revalidation or renewal of a class or type rating (...);
(2) a towing or aerobatic rating (...).[/I]

You would certainly answer yes to (i). But if you get a closer look at the regs, it does not appear that the CRI makes any usage of his privileges during the flight, as the aim of the training is not specifically for any of the above-mentioned purposes.
If you say that it's a training for the SEP revalidation it's fine, you may do it out of an ATO. Even in that case one might say that more than hour is too much, but it's too far-fetched in my opinion.

What prevents you from training under IR for a SEP revalidation?
I don't see anything against that.
So my answer would be yes to (ii). What would be yours?

[nick14]

Unless you have the privileges to instruct under IFR you cannot do so!

If he wants to fly under IFR then you can go with them but this must be under a very strict set of circumstances:

If he is to act as PIC then you will not log any time but will be acting as safety pilot. If you are PIC then he must not log any time as you cannot provide instruction under IFR.

It doesn't matter if the flight is conducted in VMC if you artificially restrict the view, it's an IFR simulation and the PIC must be qualified.

[Whopity]

A IR qualified pilot wants to fly with a more experienced pilot besides him to built up experienceThen any experienced pilot will do, his capacity is Passenger!

A CRI has no privileges in respect of IR instruction therefore; no such instruction can be logged and IFR flight could not be counted as the hour with an instructor if the instructor is not qualified.

[172510]

On what legal basis does a client log as DUAL a "cross channel check" with an instructor?

It's basically just a check of the client's ability to execute a navigation, and probably some instruction too.
Do you do any exercise that would be require for a SEP revalidation? You don't instruct for the issue of a license either.
So what FI/CRI privilege to you exercise during that sort of flight? I don't see any

The regulation does forbid to instruct if you are not an instructor,
FCL.900 Instructor certificates
(a) General. A person shall only carry out:
(1) flight instruction in aircraft when he/she holds:
(i) a pilot licence issued or accepted in accordance with this Regulation;
ii) an instructor certificate appropriate to the instruction given, issued in accordance with this Subpart;
but the above mentioned sort of instruction is not part of any instructor privilege.

[3 Point]

172510

Isn't Take Off, departure, climb, cruise, descent, arrival and landing required for the SEP re-validation? Isn't navigation and compliance with ATC procedures relevant? If I fly a "cross channel check" with a qualified but inexperienced pilot for the purpose of teaching him those things and I fly as the aircraft commander then I will certainly log P1 and he will log dual. The flight would certainly count for the instructional hour for SEP re-validation.

All perfectly legal.

3 Point

[Whopity]

On what legal basis does a client log as DUAL a "cross channel check" with an instructor?
Any flight involving instruction can be logged as Dual. Regulation 1178 give the privileges of the instructor to give instruction and AMC FCL.050 states:(iii) the holder of an instructor certificate may log as PIC all flight time during which he or she acts as an instructor in an aircraft; What more do you want?

[nick14]

I'm sorry but am I the only one surprised by this sort of question?

My question to the OP, could you stand in front of the CAA, and hand on heart demonstrate to them you are conducting a dual flight under IFR, or under simulated IMC, within the privileges of your CRI?

:ugh:

[Genghis the Engineer]

Let's see if I get this straight?

Pilot A wants an experienced pilot sat next to him whilst he builds up some experience. He is, presumably, fully qualified and current to perform said flight - so not looking for instruction towards a licence or rating. This is presumably a single pilot aeroplane. Basically he just wants somebody sensible to help with a little confidence and feedback during some flight IFR. Pilot A is still managing the aircraft and signing the tech log.

So, considering various qualifications:-

(1) Pilot B is a CRI with nothing else. He's a passenger, as this isn't an instructional flight.

(2) Pilot B is an IRI. He's a passenger, as this isn't an instructional flight.

(3) Pilot B holds an IR. He's a passenger, as he's not required on a single pilot aeroplane.

(4) Pilot B doesn't hold an IR or IR(R). He's still a passenger, as he is unqualified to fly the sortie anyhow.


But there may be reasons to have a "grown up" along as a passenger to provide useful feedback. I've certainly done that with more experienced pilots before - but they didn't log it, and I didn't relinquish being PiC. If they offered advice, I listened to it, but continued to be PiC. For that matter, I've flown with friends on that basis, given them what I hope was a bit of useful advice and feedback, but never pretended to be PiC or delivering a briefed instructional flight - so didn't log it either. (Actually I usually did for interest, but with nothing in the totals columns of my logbook, so making no pretence of being crew.)


Or am I missing something?

G

[Level Attitude]

What prevents you from training under IR for a SEP revalidation?Nothing at all.
But for it to be a training flight the PIC must hold "an instructor certificate appropriate to the instruction given" If the flight is to be conducted under IFR then the Instructor must hold IFR instructional privileges (which you say you don't)

[Genghis the Engineer]

Err but.

Let's invent the scenario that CRI and pilot both have current SEP/IR or SEP/IMCR. But, "pilot" hasn't got EFIS differences training, whilst CRI is qualified to deliver that. Climb up through some cloud, pop up VMC on top (so legally IFR), deliver training, pick up an approach and pop back down to a landing at the end of the sortie.

Legally, not being in sight of the surface, that flight was IFR. But it wasn't instrument instruction, so I can't see why a CRI with IR or IMCR couldn't have done that.

G

[Level Attitude]

GtEVMC on top (so legally IFR),Care to re-think that sentence?
Legally, not being in sight of the surface, that flight was IFRAnd, probably, this one as well?

[S-Works]

Jesus, who is training these people? Is nobody being taught the privileges of the ratings they hold?

Original question. Answer is no. Going and build your own hours by actual going flying.

[Genghis the Engineer]

GtECare to re-think that sentence?
And, probably, this one as well?

Okay, too much time in permit aeroplanes lately. So let's put the aircraft regularly within 1000ft of cloud because of the weather conditions at the time, or in a helicopter, or whatever variation you like.

The principle there remains. You can be IFR in VMC, that might be the right place to do the training where both pilots are qualified to fly IFR, but the training is not instrument flying training. Or going through IMC into, and back out of, suitable training conditions. Or night, which is probably a bad idea, but not necessarily illegal that I can see; for example I recall a day slipping to the right for a checkout I was due in an aeroplane (I was a vanilla PPL at the time), but I and the instructor both had a valid NQ, so we continued the checkout flight into legal night until complete.

None of which changes that the "instructor" shouldn't be logging the flight discussed by the OP.

G

[3 Point]

Lot of people making things much more complicated than they need to be here.

Firstly, you don't need to be in IMC to be flying under IFR; VMC/IMC and VFR/IFR are two completely different things.

For a flight to be in instructional flight it doesn't have to be at an ATO or even part of a formal syllabus. Somebody's teaching, somebody's learning; it's an instructional flight. It doesn't have to be "for the issue or renewal of a rating" although anything I can think of teaching would meet that criteria because anything I can teach to another pilot will either be new skills or revision of existing skills, all instructional.

With a privately operated aircraft there's no formal "tech log" to sign so no formal indication there of who is the aircraft commander.

To the OP question; if the CRI is really just holding hands and bolstering the other guy's confidence then you'd probably say that he is not part of the crew and so logs nothing with the other guy logging P1. If they agree that his role is a little more formal than that the CRI would be aircraft commander and the other pilot would log dual because that's what happened. In either case the flight must take place within the privileges of the aircraft commander's licence so, for it to happen in IFR the commander must have an IR(R) or an IR.

It's really between the two of them to agree on the format of the flight and nobody, not me or anyone on this forum nor even the CAA can really argue with the choice they make. It's certainly within the CRI's privileges to give refresher training in any skills the pilot already holds whether this is formal training for re-validation or just general skill development and improvement.

3 Point

[Genghis the Engineer]

If they agree that his role is a little more formal than that the CRI would be aircraft commander and the other pilot would log dual because that's what happened.

Well put, and well put in our places :}

Yes. It's agreed as instructional, and the CRI is captain, or it's not and they're not.

G

[S-Works]

Am I the only one the sees this as the CRI wanting to log time for nothing...... :ugh:

[3 Point]

Hi Bose, no, you're not. That could be the case here or it could equally well be the case that the pilot feels he wants to learn and benefit from the wider experience and knowledge of the CRI. Only the CRI and the pilot in question know the answer to that!

The OP said

"qualified pilot wants to fly with a more experienced pilot besides him to built up experience"

That sounds to me as if he wants some training and it would be within the scope of the CRI's privileges to give such training. If the OP decides that all he wants is comfort factor but the CRI insists it's "training" then the OP may want to look for another "more experienced" pilot to sit beside him so that they share a common view of their roles.

For myself, if I am asked to fly with another pilot who is fully qualified but wants some "advice" or wants to "build his experience" I will always expect to be the aircraft commander and the flight will always be dual. If the pilot is not happy with that there are other instructors available. I'm not in any way trying to build hours, I have enough! Simply put, if I'm asked to fly and in any way to be responsible for supervising any aspect of the flight I will expect to be in command and will subsequently log the flight as P1. If I'm not participating in the flight I'll look out the window, enjoy the view and log nothing. It's really very simple and there's no need to over complicate it!

3 Point

[S-Works]

For myself, if I am asked to fly with another pilot who is fully qualified but wants some "advice" or wants to "build his experience" I will always expect to be the aircraft commander and the flight will always be dual.

I am not of the same camp. I am quite happy to go along for the ride and if someone wants a bit of advice then as long as there is a coffee and a sarnie in it then its enough for me. I would not expect to be the commander of a flight if someone just wants me along for a bit of advice and comfort.

[3 Point]

Horses for courses and I respect your right to take that view. I personally prefer to avoid the risk of any situation arising where it's not clear who's in charge.

it's a choice which the OP and his CRI have to make for themselves. I think where we might all agree is that they have to consciously make that choice and fully understand their roles before they strap in.

Happy landings

3 Point

[nick14]

Still doesn't get round the fact that the OP was asking whether they could teach IFR with a CRI......

[Genghis the Engineer]

"Teaching IFR" is not however the same as "Teaching under IFR".

Similarly to my (as a CRI!) doing a biennial flight on a taildragger, where both I and the student are tailwheel qualified already. I am teaching on a taildragger, but I am not teaching tailwheel - that, he's done before with somebody else.

G

[3 Point]

Still doesn't get round the fact that the OP was asking whether they could teach IFR with a CRI......

The CRI can teach under any set of Flight Rules he is qualified to fly under, IFR or VFR. If the CRI has an IR he can fly under IFR, he can also teach under IFR.

"Teaching IFR" is not however the same as "Teaching under IFR".

Quite! One could quite properly fly under IFR and teach various exercises while doing so. In fact I could, if I wished, teach most of the PPL Syllabus under IFR! GtE suggested an example earlier of a CRI, qualified to fly an EFIS aeroplane and holding an IR teaching EFIS differences training while flying under IFR. Don't see a problem with that.

Of course the CRI could take a course and become an IRI then he could teach applied Instrument Flying (while flying under IFR or VFR!).

Why does everybody have to over complicate the thing? It's not really that hard!!

3 Point

PS, did you notice that I finally managed to figure out how to quote!! :D:D

[Level Attitude]

Somebody's teaching, somebody's learning; it's an instructional flight.NO, absolutely not. To be an instructional flight (ie for the person learning to be able to Log PUT) the PIC must be a qualified Instructor, acting within their instructional privileges.
Eg: A flight where the World Aerobatic Champion teaches some manoeuvres to another pilot would not be an instructional flight unless they also held an Instructor Certificate (which would need to contain the privileges to instruct aerobatics)

It's certainly within the CRI's privileges to give refresher training in any skills the pilot already holdsNO, a CRI may only give instruction within their instructional privileges

Firstly, you don't need to be in IMC to be flying under IFR; VMC/IMC and VFR/IFR are two completely different things.Correct but (unlike previously in the UK) to fly IFR does require some form of IR. Therefore to instruct, for anything, during an IFR flight implies the requirement to monitor, and intervene as needed, the correct exercise of IR privileges - and hence requires the qualification to instruct for an IR (of any form).

Pre EASA the UK did state that the Instructor had to be qualified, in all aspects, for any instruction that might occur during a flight.

I agree that Part-FCL state instructional privileges in the form of instruction towards Licence/Rating Issue or Renewal but they do state that an "Appropriate" Instructor certificate must be held for any instructional flight and, as a simple soul, I prefer to interpret that as the UK CAA used to in the past.

[172510]

There a many different of arguments of that sort, where people disagree on what the regulation says.
If you ask the CAA, what they will answer (if they answer) will not be necessarily what the authority of another country will answer.
There does not seem to be an official way to get clarification.

[3 Point]

Somebody's teaching, somebody's learning; it's an instructional flight.

NO, absolutely not. To be an instructional flight (ie for the person learning to be able to Log PUT) the PIC must be a qualified Instructor

Yes, true, I should have said "an instructor's teaching ..."

a CRI may only give instruction within their instructional privileges

Which includes everything a basic PPL can do!!

to instruct, for anything, during an IFR flight implies the requirement to monitor, and intervene as needed, the correct exercise of IR privileges

No it doesn't! I can file an IFR flight plan on a CAVOK day and then go out to teach spinning! I could climb to 500' below the cloud-base to get high enough for a stall, there are many ways I can fly an instructional flight under IFR while teaching anything other than applied Instrument Flight. I could actually fly in cloud while teaching basic instrument flying which is within the PPL syllabus and therefore within a CRI privileges.

If I hold an IR or an IR(R) on my licence I can operate under IFR; that's not the same thing as saying that I can teach applied instrument flying!

3 Point

[Level Attitude]

I could actually fly in cloud while teaching basic instrument flying which is within the PPL syllabus and therefore within a CRI privileges.
3 Point,
We are not going to agree and that is perfectly fine but you have chosen an horrendous example.

A CRI is not entitled to teach the PPL syllabus (the clue is in the name) and certainly is not qualified to teach IF.

[nick14]

I'm with LA and Bose on this.

The purpose of the intended flight is to improve the inexperienced pilots IFR/IMC flying skills. Now regardless of whether the intention is to teach or just be a helping hand my fear is that the CRI would be teaching.

I have a few thousand hours of which the majority is IFR in singles/twins/jets, and both a TRI and CRI. I consider myself a competent SPA and MPA instrument pilot, however I would never get into an aircraft with another pilot with the intent to teach/coach instrument procedures unless I gained the IRI. I would either be a safety pilot or passenger.

[Genghis the Engineer]

There's a lot of cross purposes going on here.

Nobody is disputing, that I can see, that a CRI who is not an IRI should not be teaching IF.

However, most of us agree that a CRI, who is instrument qualified, can teach other things (such as for example a new type, or an EFIS system) under IFR, if that is appropriate to the task.

The case posted by the OP, I thought was just "helpful pax" anyhow - but if it is instruction, then no, if it's about IF, it certainly can't be done by a CRI.

G

[Big Pistons Forever]

The OP said


For myself, if I am asked to fly with another pilot who is fully qualified but wants some "advice" or wants to "build his experience" I will always expect to be the aircraft commander and the flight will always be dual. If the pilot is not happy with that there are other instructors available. I'm not in any way trying to build hours, I have enough! Simply put, if I'm asked to fly and in any way to be responsible for supervising any aspect of the flight I will expect to be in command and will subsequently log the flight as P1. If I'm not participating in the flight I'll look out the window, enjoy the view and log nothing. It's really very simple and there's no need to over complicate it!


Exactly my approach to this situation as well.

[S-Works]

Why on earth would an Instructor consider it appropriate to be teaching non IF skills under IFR?

[172510]

BoseX: Climb close to a cloud in a class E airspace to be as high as possible before a stall is a example of a VFR SEP skill taught under IFR

[3 Point]

Certainly people are at crossed purposes, look at the OP's question. It relates to a CRI giving instruction under VFR or under IFR. If the CRI is qualified to fly the aeroplane while operating under IFR then he may also give instruction while flying under IFR; that's the answer to the OP's question!

Now, there are supplementary questions which follow on from that. Can the CRI teach basic Instrument Flying? Can he teach applied Instrument Flying? Can he teach anything while flying in cloud? I of course have been looking for extreme examples to illustrate some of these questions. Just because I am suggesting that something is within the rules does not mean that I think it is sensible or that it would be right in every case.

A CRI who gained the qualification last week and has a few hundred hours in his logbook giving instruction in a solid overcast with turbulence and icing; not good! A CRI with 10,000 hours of which 2,000 are operating single pilot aircraft under IFR who continues the lesson while climbing through a layer of stratus between 2,000 and 4,000 feet? Perfectly reasonable!

The regulations don't substitute for judgement and experience; this is one very good reason why most training is now delivered through an ATO where there is a proper management structure.

I said

teaching basic instrument flying which is within the PPL syllabus and therefore within a CRI privileges.


Level Attitude said

A CRI is not entitled to teach the PPL syllabus


Note that I did not say that the CRI is entitled to teach a student pilot who has no licence. The CRI is absolutely entitled to teach for the renewal of an SEP class rating (provided he has an SEP rating himself). A pilot with a lapsed SEP rating will require refresher training at an ATO and the format of that training will be determined by the HoT at the ATO but could well include any or all of the requirements for the rating which is basically a PPL syllabus. The CRI is therefore entitled to teach those exercises and I can't see why that wouldn't include Ex 19! Its not what the CRI teaches that matters here but who he teaches it to!

Bose, you said

Why on earth would an Instructor consider it appropriate to be teaching non IF skills under IFR?

Did you actually mean that or did you mean "Why on earth would an Instructor consider it appropriate to be teaching non IF skills while flying in cloud?

Two different questions!

There are already examples further up the thread of where a non instrument flying lesson may take place under IFR. How about night flying? Is that taught under IFR or VFR? Are the flights flown in IMC or VMC? Can a CRI teach for the night rating??

The regulations do not provide a precise answer for every possible situation; they provide a set of limitations and within those constraints we are all required to go about our business with the application of sound judgement based on our experience. That's how flying works!

A basic PPL course or even an ATPL course does not give a pilot all the answers for every situation he will ever meet. Rather it provides him with a store of knowledge and experience and teaches him some decision making tools which he is expected to rely on to go safely about his business in the sky. This principle transfers very well to the ground!

Don't look to the rules for a precise answer to every situatoin. Take them as limitations, don't read into them things which are not there and apply your knowledge, experience and intelligence to make good decisions.

Happy landings

3 Point

[nick14]

So by that understanding a CRI could teach EFIS differences on a MEP without MEP privileges? Could an FI do the same?

[Genghis the Engineer]

Not sure how you reach that conclusion.

A CRI, like any other instructor, if teaching is flying as PiC. Therefore, to teach they must be qualified to fly that aeroplane in those conditions. I can't see that 3-point said anything to contradict that.

An interesting question might be somebody who, say, has CPL/ME/CRI (SE) and consuders teaching EFIS on an ME. The answer to that is presumably that they can't, as their CRI rating is only able to be exercised on SE - but you could argue it either way.

Incidentally, apparently a CRI can't teach for the NR. When it was a "qualification" it was deemed that a CRI could teach *for* ratings but not qualifications. When the NQ changed back to the NR, the ruling apparently remained. On the other hand a CRI can in effect teach the whole PPL syllabus - that's what you're doing for an NPPL (M)--> NPPL (SSEA) "upgrade, if the student is going to pass ! As 3-point said, it depends who you're teaching it to.

G

[S-Works]

BoseX: Climb close to a cloud in a class E airspace to be as high as possible before a stall is a example of a VFR SEP skill taught under IFR

Its a VFR skill and should be taught under VFR.....

[Captain Stravaigin]

I think this question is directed specificially at Whopity, Bose X and a few others of our cognoscenti.

I flew with an FAA Private Pilot on a flight in Malaysia to Pangkor Island and back from Kuala Lumpur. The aircraft was N registered. So we were legal to fly as s/he did not require a Malaysian Student Pilot Licence.

I did not log the time as I am not an FAA CFI although I do possess an FAA PP/IR. I am a Malaysian AFI and also a British FI (R). I regarded myself as Safety Pilot only.

So my question is if I am flying in Malaysian airspace on a US registered plane with an FAA PPL in the left hand seat and me (at his request due to airspace/local knowledge) in the right, should I log instructional hours for this flight ?

As a further addendum I might add that Malaysian Air Law is heavily based on UK Law and indeed the CAA are the providers of the various written exam papers. I was booked (and paid) as an Instructor and the PIC was previously unknown to me.

Comments from all quarters also welcome.

Cheers

[nick14]

Ghengis,

That was my question, if a CRI can teach whilst flying IFR without an IRI, then a CRI who holds an MEP/IR can presumably teach EFIS on a twin with a CRI/SE.

The conclusion from 3 point I believe was that it does not matter under what conditions you are teaching it only matters what you are teaching?

I agree a CRI cannot teach for the Night rating but teaching under night for a rated pilot is another debate, I seem to remember it happening not so long ago.

[3 Point]

nick14

So by that understanding a CRI could teach EFIS differences on a MEP without MEP privileges? Could an FI do the same?

Of course not! An instructor has to be qualified to act as the aircraft commander and in this example he is not and therefore could not fly the flight. The CRI is qualified to teach all aspects of an SEP rating which is basically the same thing as an initial PPL syllabus; he can therefore teach Exercise 19! Like what GtE said!!

Bose X

Quote:
BoseX: Climb close to a cloud in a class E airspace to be as high as possible before a stall is a example of a VFR SEP skill taught under IFR
Its a VFR skill and should be taught under VFR.....

I know what you are saying and I suspect that you know very well what I am saying! VFR/IFR and VMC/IMC are two entirely different things as you know. Additionally, IFR and "flying in cloud" are also two different things!

I could file an IFR flight plan on a CAVOK day and then get airborne, establish an appropriate ATC service within an appropriate block of airspace and proceed to teach then entire PPL syllabus. I can not think of any real advantage to doing this but it would fall entirely within the regulations and would not, as far as I can see be at all unsafe. The example of climbing to cloud-base to enter a stalling exercise has already been given; in general, as soon as one is within 1,000 of the cloud one is in IMC and therefore must, by definition be IFR to remain legal. There's a debate to be had about the wisdom of going so close to the cloud while maneuvering close the the edge of the flight envelope but it would not be illegal to do so.

Stalling is a VFR skill ...


Really? Tell that the the crew and passengers of all the Commercial Airliners which have stalled and crashed in recent memory! Of course the initial stall training for a PPL syllabus is best taught in clear visual flying conditions (either under VFR or IFR as convenient) but what about advanced training? Did you ever stall an aeroplane while flying it "under the hood" and recover on instruments? Did you ever stall at night or actually in cloud (at least in a simulator if not an aeroplane)? Managing the Angle of Attack to remain within the flight envelope is a basic requirement throughout any flight, as you know very well. Not just a "VFR skill"!

As I said, I know what you mean and I'm sure that you also know quite well what I mean. Interesting debate.

To repeat what I said before (with spelling corrections!)

Don't look to the rules for a precise answer to every situation. Take them as limitations, don't read into them things which are not there but apply your knowledge, experience and intelligence to make good decisions.

3 Point

[nick14]

3 point,

In my example both pilots are qualified MEP, one just needs the EFIS differences. The CRI is SEP only but as he is not teaching the ME skills then surely he can conduct the differences training in any aircraft he is able to act as PIC on? The same goes for your example of the flight being IFR, both are qualified however the training conducted is for SEP exercises and can be done without an IRI?

[S-Works]

In order to teach on a Class or Type you are required to hold a valid rating for the Class or Type AND Instructional Privileges on the Class or Type.

So no, your single engine Instructor can't teach differences training on a Class or Type for which they don't hold Instructional privileges.

The same as an IRI must hold Instructional privileges on the Type or Class on which they wish to teach. A good friend of mine and a member of this forum encountered exactly this recently and had to go and do a CRI ME in order to teach as an IRI on MEP following a ruling by the CAA.

[3 Point]

nick14

then a CRI who holds an MEP/IR can presumably teach EFIS on a twin with a CRI/SE.

Nope, I don't believe so! He's not qualified to exercise any instructional privileges on the ME aeroplane therefore he can't. However ...

FCL.900 Instructor certificates
(a) General. A person shall only carry out:
(1) flight instruction in aircraft when he/she holds:
(i) a pilot licence issued or accepted in accordance with this Regulation;
(ii) an instructor certificate appropriate to the instruction given, issued in
accordance with this Subpart;

In FCL.900(a)(1)(ii) above, you may choose to interpret the phrase "instructor certificate appropriate to the instruction given" as meaning that teaching the operation of an EFIS system on a single engine aeroplane is appropriate to teaching how to operate it in an ME aeroplane. Even I think that a bit of a stretch but I'm sure a good lawyer could get you off if you were hauled up for it.

Again, all this ilustrates that the rules do not cover every possible situation, I'll repeat what I already said ...

Don't look to the rules for a precise answer to every situation. Take them as limitations, don't read into them things which are not there but apply your knowledge, experience and intelligence to make good decisions.

3 Point

[nick14]

That's understandable and the IRI for ME must meet the requirements of the CRI ME as per Part-FCL.

I was just trying to play Devils advocate for the scenario.

[nick14]

So a CRI is not qualified to exercise their instructional priviledges under IFR?!

Is it not a similar situation?

[S-Works]

I dont understand why a CRI would need to teach anything under IFR?

All of the stuff they can teach is VFR only. Calling yourself IFR in VFR conditions is pointless and its only the UK that has the concept of IFR OCAS anyway.

If you are in IFR airspace and not training for IFR skills then I have to ask why any responsible Instructor would be trying to teach VFR skills in IFR?

[3 Point]

C'mon Bose ...

If you are in IFR airspace and not training for IFR skills then I have to ask why any responsible Instructor would be trying to teach VFR skills in IFR?


How about because the only clear weather is in an area of airspace where flight under IFR is the best choice. How about my scenario of operating less than 1,000' below the cloudbase?

BTW, what's "IFR airspace"?? As I understand it IFR is a set of flight rules which a pilot can choose to operate under, he may make this choice while flying in any class of airspace he likes.

As instructor I believe it is incumbent upon us to be precise in our use of the technical language associated with aviation and not, for example to say IFR" when we mean "IMC", not to say "sideslip" when we mean "drift", not to say "bank" when we mean "roll", not to say "power" when we mean "thrust" etc etc. It's confusing enough without the experts muddying the waters still further.

3 Point

[nick14]

Class A is IFR only.

[S-Works]

No, I really can't see what you are suggesting other than some personal reason for booking IFR time....

I have never taught VFR skills under IFR in over 2,000hrs of teaching and testing. The training side of our operation in Spain operates in CAS and we do not file IFR flight plans for VFR training. Our ops manual clear states that where conditions require compliance with IFR then training is not permitted for VFR courses. I also do not accept time logged on VFR courses as IFR towards the Instrument Instruction pre requisites....

We have very clearly stated VFR minima and its not permitted to circumvent them by filing IFR.

I also fully understand the need to differentiate between flight under IFR and and flight in IMC and don't seem to recall talking about flight in IMC. :ok:

[dobbin1]

To do the stalling exercises under VFR with a recovery by 3,000 ft AGL would require a minimum cloud base of around 4,500 ft. Such days are rare in the UK.

On a good flying day with a cloud base at say 3,500 ft I have the choice of doing them lower or getting closer to the cloud than VFR allows and starting at say 3,300 ft. Personally, I prefer the higher option and so I must do them under IFR to remain legal.

The only motive for me doing this is to complete the exercise as safely as I can. I don't log any of the time as IFR. I don't see any problem with this.

Of course, if we all worked in sunny Spain......

[S-Works]

VFR is clear of cloud and in sight of the surface for pretty much all of the UK airspace that we train in.

4500ft for stalling? You are pulling my leg?

Filing an IFR flight plan or are just calling yourself IFR in order to meet some notion that you think you need to be IFR?

[Genghis the Engineer]

There are types you might wish to be at 4,500 or rather higher for stalling, but to be fair, none of them I fly normally. If Dobbin needs 1500ft to recover from a stall in an SEP, then he might want to reconsider how he's teaching it, and 3000agl for recovery is a bit on the high side for most common training types isn't it?

A classic a few months ago, which I'm sure was quite legal. As a CRI I was teaching an exercise on measurement of climb and glide performance for a specialist course (before anybody asks, not on any PPL syllabus, and this all went up as far as EASA HQ and they approved it, also done within an ATO with the full approval of the Head of Training), to an aeronautical engineer who held a PPL. Cloudbase was about 1000ft, cloud tops about 3,000ft.

Took off, climbed into cloud, did the entire exercise between cloud tops and 8,000ft or so. Then took an approach back into base.

Within my licences and privileges. All logged as instruction. safe, chunks of it logged as IFR. But, of-course, I was not teaching any aspect of IF - I'm not qualified to, and he didn't need me to.

G

[S-Works]

Our ops manual is recovery by 2,000ft and I have no problem doing stalling in a regular trainer at 2,500ft.

Like I said, we don't permit VFR exercises to be trained in conditions that require compliance with IFR.

[3 Point]

GtE,

A perfect example of intelligent decision making to get the job done while remaining entirely within the constraints of the regulations.

Bose, I have operated in and out of airports located within airspace which required the filing of IFR flight plans when coming and gong yet we were training basic visual flying exercises. Wasn't breaking any rules to do so.

As GtE has said (and Dobbin has hinted) some aeroplanes and some instructors may wish to be higher than 3,000 to safely carry out stall training. Also, clear of cloud and in sight of the surface only applies up to 3,000'; above that you need 1,000' vertically clear of cloud or you are no longer VMC!

4500ft for stalling? You are pulling my leg?



dobbin said

To do the stalling exercises under VFR with a recovery by 3,000 ft AGL would require a minimum cloud base of around 4,500 ft.


He's quite right! 3,000'AGL would be 3,500' altitude in many parts of the UK (or even much higher) so to remain 1,000' vertically clear of cloud (required for VMC) you'd need a cloud-base of 4,500'!

As GtE said, there are types for which I would want to be considerably higher than 3,000' AGL before stalling.


We all need to use our intelligence to make sensible decisions to operate safely and efficiently while remaining within the rules. Simple!

3 Point

[3 Point]

Sorry, just to add.

Bose, I understand that your Ops manual imposes various constraints and of course you operate within those limits. Other people however may not be constrained by such Ops manual limitations and so can operate with greater freedom; doesn't make it wrong!

I agree, I have no problem stalling in a standard trainer at 2,500'agl but in some parts of the UK that would put you above 3,000' requiring >1'000 vertical cloud separation to remain VMC. Also, not all aeroplanes are "standard trainers"! There are some types I fly in which I would not consider entering a stall at that height.

3 Point

[dobbin1]

4500ft for stalling? You are pulling my leg?

No. Stalls at 3,200 ft for recovery by 3,000 ft. Not unreasonable, especially when demonstrating a wing drop / incipient spin. As you know, VFR requires 1,000 ft clearance from cloud above 3,000 ft.

I am quite happy to do stalls down to the 2,000 agl limit in our flying orders, but the additional height is worth having in some circumstances. A 1 turn spin in the T67m I sometimes use will burn 1,100 ft, so if there is any possibility of a spin I would prefer to be a bit higher.

If I can only achieve that additional height by switching to IFR, why wouldn't I? What is the problem?

[172510]

its only the UK that has the concept of IFR OCAS anyway.
It's ICAO standard.
You may legally fly IFR OCAS in the UK, Belgium, France, and certainly in other countries.

[172510]

During my CPL training, my instructor had me fly in clouds (the time in clouds being part of the 10 hours I had to fly without external references.)
Was it bad practice to your opinion?
I don't know whether he had undertaken the IRI training or not, but assuming he had not, would have it been illegal?

I think that Flying without external reference is also part of the PPL syllabus. Would you undertake that part of the training in real clouds without being an IRI? Would you think it's a bad practice?

[LAI]

IMHO - No, I think what your instructor did sounds entirely reasonable. In order to teach the basic IF element in the PPL syllabus, you do not have to hold an IRI qualification - any FI can teach it. However, your instructor would obviously have had to be the holder of a current IR (or IMC, if in the UK) in order to actually fly in cloud during the lesson - but that is a separate issue.

Personally, if the circumstances present themselves appropriately, I think it's actually a very good thing to fly in real cloud. It is a different experience when you don't have the chance of peering out of the corners of the dreaded foggles/hood/poorly fitting aircraft screens!

[TheOddOne]

On my FI course, I was taught to conduct this PPL exercise in cloud, I maintain my IMC rating mostly to enable me to do this. I obtain a traffic service from our local radar unit, usually very helpful.

TOO

[172510]

If I want to summarise what has been said so far:
It's obvious that a CRI may never fly under IFR with a student if the CRI is not an IRI, but it's a good practice for a FI who is not an IRI to do so.
I fail to see how it is substantiated by the regulation.

[3 Point]

I fail to see how it is substantiated by the regulation.


That's because it's not substantiated by the regulations! It's rubbish to say that a CRI without IRI can't teach while operating under the IFR. It would be quite correct to say that he can't teach applied instrument flying skills.

It's been a great debate but I feel we've come to a point where we are all entrenched in our opinions and so, as they say in Dragon's Den, I'm out!

Happy landings

3 Point