FI(R) IRI course

[172510]

A FI may undertake the IRI course and teach for the IR rating provided he has logged 200 hours under IFR.
My understanding is that there is no need for a FI to be unrestricted to teach for the IR rating.
Am I right?

[Level Attitude]

No one else seems to want to answer so:

Am I right?

No. You are wrong.

FCL.910.FI FI — Restricted privileges
(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:

(1) for the issue of the PPL, SPL, BPL and LAPL;

(2) in all integrated courses at PPL level, in case of aeroplanes and helicopters;

(3) for class and type ratings for single-pilot, single-engine aircraft, class and group extensions in the case of balloons and class extensions in the case of sailplanes;

(4) for the night, towing or aerobatic ratings.

An FI with Restricted privileges may only teach for the above (provided they are appropriately qualified) at an ATO and under the supervision of a nominated FI.

No mention of teaching for an IR, therefore an FI(R) cannot; and, therefore, I very much doubt that any ATO would accept an FI(R) on to a course to gain a "privilege that may become valid later" after their restriction is lifted.

NB: I know that some people have suggested that an FI(R) may teach for anything (provided they are appropriately qualified) with the above only being a list of the types of "Instruction that must be supervised"
Good Luck if you rely on that interpretation !

[Whopity]

But as as a stand alone IRI you can teach for the IR with or without a FI rating.

[BillieBob]

An FI shall have his/her privileges limited .....in the following cases:

ergo, in any other case, such as instruction for the IR, the privileges are not restricted.

[172510]

@Level Attitude: Billie Bob and I agree.
FCL.910.FI FI Says that the FI is restricted in certain cases, and teaching for the IR is not one of them. So maybe a FI restricted may not teach for the IR, but it's not what FCL.910.FI says.

The FCL says
FCL.905.FI FI—Privileges and conditions
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;
I could find no other prerequisite for the IRI course than 200 hours IFR if you are a FI or 800 hours IFR if your are not.
My conclusion is that, unless someone finds something I could not find by myself in the regulation, a FI restricted with 200 hours IFR may undertake the IRI course and teach for the IR if he/she passes the assessment of competence.

[Level Attitude]

You paraphrase this way:

An FI shall have his/her privileges limited .....in the following cases:

and I would paraphrase like this:

An FI shall have his/her privileges limited to conducting flight instruction ....in the following cases:

For the want of a comma a disagreement ensues.........and we all know how well written Part-FCL is !!!

My conclusion is that, unless someone finds something I could not find by myself in the regulation, a FI restricted with 200 hours IFR may undertake the IRI course and teach for the IR if he/she passes the assessment of competence.

And I say again: "Good Luck if you rely on that interpretation !"

Please let us know of any ATO that accepts an FI(R) on to their course to learn how to Instruct for an IR.

Please let us know of any Competent Authority who has granted the Privilege to Instruct for an IR to an FI(R).

In the UK the CAA require that an FI is not restricted in order to teach for the IMC Rating - I cannot see them allowing an FI(R) to Instruct for an IR ( or even an IR(R) ), but not an IMCR.

[S-Works]

I have an Instrutor with a restricted FI who did the IRI course. He has it as a standalone rating along with a CRI however he required the 800hrs IFR not the 200hrs which as a current commercial pilot was not an issue.

The CAA were adamant that they could not issue it using the FI requirements as he is restricted.

[Whopity]

To teach for an IR you have to have the IRI qualification, that has nothing to do with being an FI(R). The only question is whether you can complete this qualification on the basis of 200 hours under IFR or 800. Under the JAA is was always considered that 800 was necessary, but I can find nothing specified in Part FCL that requires you to have 800 hours if you are an FI. An FI(R) is an FI and it is not one of the limitations stated in FCL.910.FI FI — Restricted privileges.

[ifitaintboeing]

Have to say that I agree with Whopity on this one. Under JAR-FCL you were required to be a unrestricted FI to remove the 'no applied instrument' instruction restriction last stated in LASORS 2010 H1.4. However, under EASA this no longer applies.

As Whopity says, it's not listed under the restricted privileges in FCL.910.FI.

ifitaint...

[172510]

Originally Posted by Level Attitude

You paraphrase this way:

An FI shall have his/her privileges limited .....in the following cases:

and I would paraphrase like this:

An FI shall have his/her privileges limited to conducting flight instruction ....in the following cases:

I would agree with you if the FCL wording was "An FI shall have his/her privileges limited .....to the following cases:" but the preposition used is in not to
Another point in the favour of my understanding:
FCL.905.FI FI—Privileges and conditions
The privileges of an FI are to conduct flight instruction for the issue, revalidation or renewal of:
(a) a PPL, SPL, BPL and LAPL in the appropriate aircraft category;
(...)
(e) the night rating, provided that the FI:
(1) is qualified to fly at night in the appropriate aircraft category;
(2) has demonstrated the ability to instruct at night to an FI qualified in accordance with (i) below; and
(3) complies with the night experience requirement of FCL.060(b)(2);
(...)
(g) an IR in the appropriate aircraft category, provided that the FI has: etc.
You certainly agree that a FI restricted may instruct for the night rating. The night rating is not treated differently than the IRI in the FCL. It's not written that the FI may be restricted to instruct for the night rating, nor is it written that the FI may be restricted to instruct for the IR, because IR and night are not in the FCL.910.FI list of restrictions.

[Level Attitude]

I would agree with you if the FCL wording was "An FI shall have his/her privileges limited .....to the following cases:" but the preposition used is in not to

An FI shall have his/her privileges limited to conducting flight instruction ....in the following cases:

Another point in the favour of my understanding: ......It's not written that the FI may be restricted to instruct for the night rating......

Yes it is.
FCL905 Lists the Privileges that nay be attached to an FI Rating and includes both Night (e) and IR (g).
FCL.910 Lists the limited Privileges that an FI(R) can exercise. IR is not mentioned, but Night (4) is.
Which doesn't change the debate at all as it still requires an interpretation of what being included (or excluded) from the list in FCL.910 actually means.

It does not matter whether we agree or disagree. No Privilege can be exercised until it has been entered on to a Licence, so it is solely the interpretation of a Competent Authority that counts.

[Level Attitude]

To teach for an IR you have to have the IRI qualification, that has nothing to do with being an FI(R).

No you don't and (in terms of this debate) Yes it does

To teach for an IR someone would either have to have an IRI or have Privilege (g) added to their FI (or both).

Without 800 hours IFR an IRI is not possible, so the question remains: Would any Competent Authority grant Privilege (g) to an FI with Restricted Privileges?

I think not ......... but happy to be proved wrong

[Whopity]

FCL905 Lists the Privileges that may be attached to an FI Rating and includes both Night (e) and IR (g).

An FI(R) is not a seperate or different rating, it is simply that certain privileges of the FI are "Restricted" Those privileges are stated in

FCL.910.FI FI — Restricted privileges
(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:

There is no mention of restricting the IR privileges if so qualified. I have in the last year encountered two FI(R)s who are qualified to teach the IR.

[gnome11]

Somebody suggested to me that the 200hr IFR experience requirement for the removal of applied instruments instruction was set to change again in the near future, has anybody else heard anything similar? I have found nothing to support this.

I would also welcome any helpful suggestions on how people build their IFR time. As a PPL instructor I am clocking up plenty of hours VFR but get little time (or money) to do much flying for myself. I am trying to fly every couple of weeks with a safety pilot under the hood, but its going to be a very long road to 200hrs...

[Level Attitude]

I am trying to fly every couple of weeks with a safety pilot under the hood, but its going to be a very long road to 200hrs...

You are wasting your time and money. It is 200 hours IFR flight that is required not 200 hours IF flight.

As a PPL Instructor you really ought to know the difference: A PPL course requires no IFR time but it does require a small element of IF flight.

If you hold an IMCR, IR(R) or IR yourself then just go and fly IFR.

[gnome11]

yes granted - I understand the difference between IMC and IFR but I don't think practising IMC flying is a waste of time...

I don't currently fly much other than instructing so I try and get as much out of those flights as I can.

[Level Attitude]

I understand the difference between IMC and IFR but I don't think practising IMC flying is a waste of time...

I don't think you do. It is not possible to 'practice IMC flying' - the aircraft will either be in IMC or it won't.

IFR time, which is what you have said you want, can be gained in either VMC (optional) or IMC (mandatory).

"Under the hood", as you say, is a great way to practice and maintain your IF flying skills - but is nothing to do with VFR/IFR or IMC/VMC.

but its going to be a very long road to 200hrs

It will be even longer if you do not fly, and correctly log, IFR.

[gnome11]

But if those hours under the hood are also following IFR then it can be logged IFR whilst practicing instrument flying - correct?

[Happy Wanderer]

I would also welcome any helpful suggestions on how people build their IFR time. As a PPL instructor I am clocking up plenty of hours VFR but get little time (or money) to do much flying for myself. I am trying to fly every couple of weeks with a safety pilot under the hood, but its going to be a very long road to 200hrs...

I'm aware of FIs at at least two established ATOs not a million miles away from where I am who seemed to quite legitimately log a large percentage of their student's PPL training exercises as flight time under IFR by flying (amongst other things) according to the Quadrantal Rules. Assuming this is allowed, it seems to me to be a significant bending of the rules at the very least and dilutes the valuable experience that the FI would otherwise have acquired by flying procedures and approaches under genuine IFR time which would be passed on to the benefit of their students as an IRI.

HW

[Whopity]

Assuming this is allowed, it seems to me to be a significant bending of the rules at the very least and dilutes the valuable experience that the FI would otherwise have acquired by flying procedures and approaches under genuine IFR time

There is no requirement to fly procedures; the whole 200 hours can by IFR in perfect VMC with the autopilot in and no contact with the controls whatsoever. That is the requirement, no rule bending, just daft rules!