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CPLs are not required for BFRs and I think the Association ensured that all the coaches now have CRI status.
In order to be able to receive payment or valuable consideration for aerial work one needs at least a CPL and Class 1 medical, unless there is a CAA exemption such as exists for microlighting.
Indeed no need for a CPL for BFRs, a CRI will do, but most CRIs will not have CPLs I hazard a guess.
LAA coaches are able to take valuable consideration which includes hard cash for their services as coaches without a CPL or Class 1 Medical. All LAA coaches are a minimum of CRI now and a minimum of
1500hrs.
The LAA are exempted from Article 26 of the ANO 2005 under a special exemption that is renewed yearly at the end of March. The exemption list carries the name of all LAA PCS coaches. All LAA Coaches are also authorised under Par 3(1) Sec 2 Part C of schedule 8 as revalidation examiners.
I have this years Exemption on the desk in front of me.
The LAA publish a list of charges on the LAA website as a guide that an LAA Coach may make. CRI's/FI's without a CPL are therefore able to take payment without any underhand transactions having to take place.