I finally received a reply from the CAA in response to my email request for further guidance on the FCL.945 obligations. This was my enquiry:-
I have now received my updated CPL with FCL.945 added to my instructor certificate. I was a little surprised that this arrived with no additional guidance as to how to exercise this privilege. I would therefore like to clarify two things regarding my new “obligation”:-
1. The wording used to describe the FCL.945 obligation is vague. I have interpreted the phrase “Upon completion of the training flight....” to mean at any time after the completion of the training flight and after all the other FCL.740A(b)(1) criteria are met (even if these were not all met at the time of the training flight), but before the expiry date of the SEP rating. Please confirm that this interpretation is correct.
2. Please also confirm that the I (as an FI with the FCL.945 Obligation) should complete and sign section 4 of form SRG1119E for everyone I revalidate.
And this the response:-
Thank you for your email below and please accept my apologies for not responding to your original email in May.
1. Your interpretation is correct.
To assist in the timely revalidation of class ratings we want applicants to be able to take advantage of the full 12 months preceding the expiry of the rating. As such if the applicant does not meet all of the revalidation requirements at the time they complete the training flight or flight(s) with a suitable authorised instruct, then the applicant must return to that instructor once all of the revalidation requirements have been completed prior to the expiry date on the certificate of revalidation and obtain the revalidation of their rating(s).
It is vitally important that any applicant who does not meet the all of the revalidation requirements at the time they complete the training flight or flight(s), is made aware of the need to still obtain the revalidation of their rating and what the implications are if they fail to do this.
2. As the authorised instructor you can sign either SRG 1119E, in section 4 or SRG 1157, in the sections relating to the revalidation by experience, endorsement of the certificate of revalidation and confirmation by examiner. Please remember that you will need to retain a copy, a copy must be given to the applicant and a copy forwarded to the UK CAA. The instructor’s and applicant’s copy may be electronic, but the original must be returned to the CAA. Unfortunately, the CAA will not be updating the forms. Our stated objective is to move to electronic means of application and at present all resources are engaged in this project.
It was also a pity that the guidance card outlined in the Information Notice was delayed in being produced, hopefully this will be ready soon and it will answer many of these questions.
I hope that has clarified the use of the new authorisation.
This seems very clear, and contrary to the advice that Bose received. Perhaps there has been an outbreak of common sense at the CAA.