AMC5 to Appendix 6 Modular training courses for the IR
The amount of credit given should not exceed the amount of hours completed as instrument flight time.
'Should' is not mandatory.
I am not disagreeing with the sentiment as I think it would be ludicrous to require one person on an initial short, intensive, course to have completed a minimum of 40 Hours IF where as someone spreading the same course over several years would require less.
If they meant only PIC time which was coincidentally both IFR and IF was countable then they should have said so.
Possibly another case of primary legislation being written by someone who didn't understand what they were writing (difference between IFR and IF)? With that paragraph subsequently inserted in to the AMC to try and rectify the error?
An IR(R) holder who has gained 15 hrs instrument flight time as PIC on aeroplanes (not simply 'IFR time'), will probably also
have flown 15 hrs instrument flight instruction time for the IR(R).
All he/she then has to do, in order to convert to a full C-bM IR, is to:
- Pass the C-bM IR theoretical knowledge exams
- Fly an additional 10 hrs instrument flight instruction time at an ATO
- Pass the IR Skill Test
The problem here is:
Part-FCL Ammended
Aa. IR(A) — Competency-based modular flying training course
FLYING TRAINING
(i) When the applicant has:
(A) completed instrument flight instruction provided by an IRI(A) or an FI(A) holding the privilege to provide training for the IR; or .....
......these hours may be credited towards the 40 hours above up to maximum of 30 hours,
(d) The completion of the instrument flight instruction provided by an IRI(A) or FI(A) in accordance with point (a)(i) or (b)(i) shall be documented in a specific training record and signed by the instructor.
AMC Amended
The assessment to establish the amount of training to be credited and to identify the training needs should be based on the training syllabus established in Appendix 6 Aa.
(b) TRAINING RECORD
(1) Before initiating the assessment the applicant should provide to an ATO a training record containing the details of the previous flight instruction provided by the IRI(A) or the FI(A). This training record should at least specify the aircraft type and registration used for the training, the number of flights and the total amount of instrument time under instruction. It should also specify all the exercises completed during the training by using the syllabus contained in Appendix 6 Aa.
(2) The instructor having provided the training should keep the training records containing all the details of the flight training given for a period of at least 5 years after the completion of the training.
Although the AMC gives flexibility ('should') it doesn't take away the fact that any prior IF training has to have been documented ('shall be') to be allowable as credit against the CB IR requirements.
Can anyone who passed their IMC Rating 15, or even 2, years ago confirm their training was documented in an acceptable manner for CB IR purposes? Can they prove it, ATOs will want to see a record?
Is it written anywhere that a Flight Test Pass/Rating Issue is an acceptable alternative to a Training Record?