CRI & TRI revalidation change proposals

[BEagle]

In NPA 2014-29, EASA proposes to change TRI(A) and CRI revalidation requirements.

Currently, all instructors are required to meet certain criteria for revalidation; these are ‘experience (the required flight training delivered to others)’, ‘refresher training’ and ‘assessment of competence’.

For an FI, two of these have to be met, although for at least each alternate revalidation an assessment of competence is mandatory.

Hitherto, for a CRI or TRI(A) only one of these criteria had to be met; however, EASA now proposes that all instructors (FI, TRI and CRI) must meet two out of the three, with the assessment of competence being mandatory for at least each alternate revalidation.

There is no explanation for the change proposals in EASA’s covering note, neither has an assessment been conducted into the financial impact of these changes....

Views from the floor?

[Mach Jump]

I wasn't aware that the revalidation requirements for CRI's/TRI's were any different from FIs, and I don't see why they should be.

Better to revise the other way though.


MJ:ok:

[nick14]

I have already submitted my comments on this, for a hobby CRI like me it's going to stop me revalidating.

[Genghis the Engineer]

As a reasonably busy CRI who gets a bit fed up of the proportion of FIs who look down their noses at me, I'd like to see parity of requirement - that way I can demonstrate that I have to meet the same requirements that they do.

As a great fan of evidence based policy making, I'd like to see the evidence for either in ensuring competence in flying instruction.

As a pragmatist - right now as a CRI I'm flying a reasonable number of annual instructional hours, and would have to do a test every 6 years anyhow. So this change would require me to do either another test or a seminar halfway between those 6 yearly tests. So the real impact would be minimal.

So, let's see the evidence - and then standardise all of us on the minimum shown necessary to ensure good instructing standards.

G

[Whopity]

One of the major problems with revalidaton seminars is that they have to be relevant to the activities involved. FI activities are straight forward, they are based upon the basic PPL exercises and there are plenty of FIs to make provision of seminars a viable activity. CRIs are far less in number and their range of activities has potentially become wider since the introduction of Part FCL and additional ratings. It would not be realistic to expect CRIs to attend the same seminar as a FI because much of the material is not relevant and a CRI seminar could easily be conducted in a single day. Commercially, there will be very little incentive for any organisation to run a seminar for small numbers of candidates.

[Genghis the Engineer]

I agree to an extent.

I did a seminar last year having (despite what I said earlier) managed a lean year just under the 10 hours instructing minimum. With the agreement of all parties, I did half of an AOPA FI seminar, supplemented with a couple of hours 1:1 with an FIE. It worked, and much of the material - teaching and learning, best practice in x, y or z was appropriate to my role as a CRI. But it was a "special", and I suspect that if I'd stayed for the other half of the FI seminar it would have been less appropriate.

There are enough of us that organising the occasional dedicated CRI seminar shouldn't be that hard - but at the moment apart from my special arrangements, the two options are an occasional at On-track, and a similarly occasional seminar organised by LAA for their CRI/coaches. So opportunities exist, but they're rare.

Does anybody know how many CRI/SPAs there are in the UK?

G

[BEagle]

An omission from the AMC & GM to Part-FCL is that there is no mandated content for a CRI seminar - 'AMC 1 FCL.940.CRI' doesn't actually exist.

Surely it should?

[Genghis the Engineer]

Hard to disagree!

I believe that all of the existing seminars have been individually agreed between the training provider and the authority.

G

[Whopity]

I believe that all of the existing seminars have been individually agreed between the training provider and the authority.

This is the "Approval Process". Initially, the CAA issued a Standards Document, based upon the European requiement,for those seeking such an approval. In the first instance 3 organisations were granted approval; one was not. Approval was dependent upon compliance with the Stds Doc leaving very little margin for flexibility.

[Sleepybhudda]

Its my understanding that the NPA referenced above removes the term seminar from instructor revalidation and renewals. Replacing it with refresher training. That's might upset On Track, Pooleys and AOPA since it takes a lot to get the seminar approval.


Still requires seminars for examiners though.

[BEagle]

Sleepybhudda, see NPA 2014-29(B) which states the 'refresher training' seminar requirements - except for a CRI...

[ifitaintboeing]

At present 'refresher training' is at the discretion of the FIC instructor, and can be conducted on a one-to-one basis as ground and/or flight training or by seminar as per the LAA Pilot Coaching Scheme.

I consider that the current system introduced by EASA is sufficient, where an Assessment of Competence is mandatory at least every other revalidation. I would be interested to know if the proposal of further requirements have been driven by accident statistics or just committee opinion.

ifitaint...

[S-Works]

There was nothing wrong with the previous system. I don't see a safety case for the change. I do my FI and CRI at the same time so its a moot point for me but I don't see why there was a need to change the way it was done.

Whatever Ghengis may think, the CRI is not the same as an FI and aligning the requirements to revalidate will not make you an FI and therefore remove the stigma you perceive. The only way to do that is become a full FI..... :ok:

[Genghis the Engineer]

Of course it's not the same as an FI. But I can live without a few people around the bazaars saying that, within their licence privileges, CRIs are lesser instructors. Similar revalidation requirements help.

G

[Whopity]

30 hours flying versus 3 sounds lesser to me! A FI can teach people to fly, a CRI may not. The CRI is an experienced pilot who may convert other pilots to "type" etc they are not taught to teach basic exercises any more than an IRI is. The CRI is a serious qualification, but it is not an FI and sorting out a pilot's basic problems should be left to FIs who are trained to do it.

[Genghis the Engineer]

As I said.

My CRI skill test included "sorting out", a nominal pilot who had failed reval by test on circuits and PFL. Either I was trained to do that, and passed the skill test, or I didn't.

Last week I was converting a rusty PPL onto an elderly taildragger that I have plenty of hours on. I could have got an FI with half my hours on type and tailwheel to do it, but the logic escapes me why?

Yes a CRI can do less than an FI. But we have a licence and rating obtained by passing a skill test, are required to revalidate them as per the rules, and if we do: deserve to be judged as "an instructor" like any other so long as we stick within the privileges of our rating.

But as we are given quite a lot of privileges, with significant overlap to FI privileges, similar revalidation requirements to an FI seems appropriate to me.

G

[S-Works]

Sorry Ghengis, I disagree. I hold both FI, CRI (SE/ME) and IRI as individual ratings. I think the CRI is a terrific rating but it is not in the same league as an FI. Claiming that having the same revalidation requirements somehow makes you equal is naive and is just you wanting to shoot down a few people by saying that as you have met the same revalidation requirments you are an equal. But to put it bluntly you are not.

As I said if you want to be an equal in the bazaars go and do an FI, get it unrestricted and then say if you think the two ratings are similar.

As I said before, I don't see what was wrong with the old system for revalidating a CRI.

[Genghis the Engineer]

There's no point in us getting into a spat about it, particularly as this is a general question about revalidation - not about anybody in particular and their standing as an instructor.

Or worry about hours / types / relevant experience / licences. .. none of us are equal, even to ourselves last month !

The question is what's necessary?

G

[BEagle]

ifitaintboeing wrote: At present 'refresher training' is at the discretion of the FIC instructor, and can be conducted on a one-to-one basis as ground and/or flight training or by seminar as per the LAA Pilot Coaching Scheme.

I cannot find anything in the Aircrew Regulation which states that such the content of CRI refresher training is at the discretion of an FIC instructor. Moreover, although the good guys would doubtless have some form of well-structured in-house policy, the system could be open to abuse by the smartarses; "Let's bog off somewhere for lunch and I'll give you your 3-yearly CRI revalidation tick on the way there and back - we can always say that we were refreshing 'the avoidance of infringements' to keep the CAA happy!".....:uhoh:

[ifitaintboeing]

AMC and GM to Part-FCL

AMC1 FCL.940.CRI CRI — Revalidation and renewal

REFRESHER TRAINING

(a) Paragraph (c)(1) of FCL.940.CRI determine that an applicant for renewal of a CRI certificate shall complete refresher training as a CRI at an ATO. Paragraph (a)(2) also establishes that an applicant for revalidation of the CRI certificate that has not completed a minimum amount of instruction hours (established in paragraph (a)(1)) during the validity period of the certificate shall undertake refresher training at an ATO for the revalidation of the certificate. The amount of refresher training needed should be determined on a case by case basis by the ATO, taking into account the following factors:

(1) the experience of the applicant;

(2) whether the training is for revalidation or renewal;

(3) the amount of time lapsed since the last time the applicant has conducted training, in the case of revalidation, or since the certificate has lapsed, in the case of renewal. The amount of training needed to reach the desired level of competence should increase with the time lapsed.

(b) Once the ATO has determined the needs of the applicant, it should develop an individual training programme that should be based on the CRI training course and focus on the aspects where the applicant has shown the greatest needs.

ifitaint...

[BEagle]

Yes, that's the previous document. Which confuses renewal and refresher training and is quite clearly contrary to the latest NPA proposals..... They've got themselves tied up in knots, it would seem!

Even the document which you quote doesn't state that the training for revalidation is at the discretion of an FIC instructor - neither does it provide any clear indication as to the content of a CRI seminar nor state that a CRI seminar is even an option!

Amendment of AMC1 FCL.940.CRI should have been included in NPA 2014-29(B), if only to reflect the proposed FCL.940.CRI proposals of NPA 2014-29(A).

EASA should really sit on its hands until RMT.0596 releases its NPA!