JAA is proposing to introduce a new requirement that FI(A)s cannot instruct on any type unless they have 15 hours on that type. The proposed text does say "type or class" which would appear to allow instruction on a new SEPL type as long as you have 15hrs total time on SEPL aircraft. But the explanatory text is far from clear.
The proposals are in NPA FCL 1-19 which is on the JAA website at:
http://www.jaa.nl/catalogue/npas/480869.pdf
The new text of JAR-FCL 1.310 says:
All instructors shall (i) hold at least the licence, rating and qualification for which instruction is being given, and (ii) have at least 15 hours experience as pilot on the type or class of aeroplane on which instruction is being given
The explanatory text says:
A Working Paper and the LSST(H) proposal to the LST both introduced a requirement for an instructor, and this would include all carrying out flight instruction for a licence or rating, are required to have a minimum experience of 15 hours of flight time on the specific type (and in the case of aeroplanes class).
This requirement is a general one which could apply to an FI giving training for a licence, or an FI(A), FI(H) or TRI(H) giving type rating training.
So:
1. does the 15hrs only apply to training for a licence or rating (so not, for example, to club checkouts or the biennial 1hr SEPL reval flight)?
2. does it have to be 15hrs on the type AND class, or 15hrs on the type (if it's a type-rated aircraft) OR 15hrs on an aircraft in the same class (for non-type rated types such as SEP/MEP)?
3. is the proposal that it WILL apply, or just that it "could" apply as the "explanatory" text says?
Suggestions to JAA...