Flying Instructors & ExaminersA place for instructors to communicate with one another because some of them get a bit tired of the attitude that instructing is the lowest form of aviation, as seems to prevail on some of the other forums!
As it seems that independent instructors will need to become registered as RFs before 17 September 2012 (see CAA IN-2012/112) in order to continue instructing once the UK adopts Part-FCL, will their careers be short-lived, i.e. just until 8 April 2015 when all RFs have to be re-registered as ATOs, given the ATO requirements will be too onerous and expensive for one-man-band outfits?
Or, will indpendent instructors still be permitted to carry on as RFs if instructing for licences and ratings for use Annex II aircraft only? Clearly they won't be permitted, as an RF, to teach EASA Part-FCL licences (which will be acceptable for use on Annex II aircraft), but will they instead be permitted to teach national licences such as the NPPL for Annex II aircraft pilots, or will these national licences become a thing of the past as well?
The IN relates specifically to instruction for the issue or renewal of aircraft ratings for EASA Part-FCL licences.
According to CAP 804, training for the NPPL(A) SSEA shall be conducted at an "organisation acceptable to the CAA", training for the NPPL(A) SLMG at an "approved BGA site" and there are no specific organisational requirements for the NPPL(A) Microlight. In no case is an RF mentioned and so it is logical to assume that there will be no requirement for registration in order to provide training for the NPPL(A). But then, when was anything involving CAA policy logical?
So long as it has not expired you can do it with an examiner directly however; if it has expired, you will have to go to an ATO for an assessment, training and then the test, so you could say at least one flight on top of the test as a minimum cost at an IR approved ATO.
According to AMC1 FCL.625(c) , if the rating has expired by less than three months, no refresher training is required but you still need a certificate issued by an ATO to get the rating renewed. However, the stated opinion of the UK CAA (subject to approval by EASA) is that, within that three month period, the renewal may be certified by an IRE without reference to the Authority.
If the rating has expired by more than three months, there is mandatory refresher training, in accordance with AMC1 FCL.625(c), and the rating has to be re-issued by the Authority, for which they will require a fee. In the absence of any approved alternative means of compliance, the requirement is for 1 training session if the rating has expired by less than 1 year and 3 training sessions if the rating has expired by more than 1 but less than 7 years. 'Training session' has not been defined and , therefore, need not necessarily include any flying.
If the rating has expired by more than 7 years, the applicant is required to undergo the full training course for the issue of the IR (as well as re-taking the theoretical knowledge examinations).
Not sure if anyone else is in my position. I have a CRI rating and have conducted revalidation flights in Malaysia with JAA PPLs who have the experience and require the 1 hour with an Instructor. I have a Malaysian AFI rating which permits me to instruct on 9M registered aircraft.
I am independent and the Registration fee is more than I charged in the whole of last year so economically it is a non-starter.
Any advice on whether there is a solution - or do I just give up offering revalidation flights ?
Revalidation flights (the hour with an instructor) are not a problem so you will continue to be able to do them. Renewal flights require an examiner and are outside the scope of a CRI rating anyway, so not an issue. You will have to do a test to revalidate your CRI in the future, at least every 6 years.