Restricted FI - what can and can't I do?

[Babel Fish]

I'm sure this has been done before, but I can't find the answer on here. JAR–FCL 1.325 says:

(b) Restrictions. The privileges are restricted to carrying out under the supervision of a FI(A) approved for this purpose:

(1) flight instruction for the issue of the PPL(A) - or those parts of integrated courses at PPL(A) level - and class and type ratings for single-engine aeroplanes, excluding approval of first solo flights by day or by night and first solo navigation flights by day or by night; and

(2) night flying, provided a night qualification is held, the ability to instruct at night has been demonstrated to an FI(A) authorised to conduct FI(A) training in accordance with JAR-FCL 1.330(f) and the night currency requirement of JAR-FCL 1.026 is satisfied.

(1) above seems to be saying that a restricted FI can (under the supervison of a FI) only instruct for the issue of a PPL, and not conduct training with an already qualified PPL, for example the dual hour required for a SEP revalidation by experience, or a club checkout flight.

Am I reading the regulations correctly?

Or is the above passage saying that a restricted FI has all the privileges an (unrestricted) FI has, with the exception of initial PPL training and night flying, where they must be supervised by an (unrestricted) FI? :confused:

[alphaadrian]

My understanding is that as a restricted FI, ALL your instruction must be under the supervision of an unrestricted FI ie there must be one must be around! But even with this supervision you cannot authorise first solos or first solo navs (day or night). Club checkouts and instructor flights (1 hour) for SEP renewal you can do too. At least this is how things were done wen I was restricted many moons ago.

Alpha

[Whopity]

The rules do refer only to the giving of instruction for the issue of a PPL, Class or Type ratings however you can also perform instruction relating to those licenses and ratings. Continuation training, revalidation training etc.

You do not have all the privileges of a Unrestricted FI for example, you cannot do CPL training other than as part of an Integrated Course to PPL level or IR training unless you hold a standalone IRI qualification.

Any new instructor should have been taught the privileges of the rating.

The privileges of the rating are in the ANO Schedule 7
Flight instructor rating (aeroplane)
A flight instructor rating (aeroplane) entitles the holder of the licence to give instruction in flying aircraft of such types and classes as may be specified in the rating for that purpose subject to the restrictions specified below.
Restrictions - restricted period
(1) Until the holder of a flight instructor rating (aeroplane) has completed at least 100 hours flight instruction and, in addition, has supervised at least 25 solo flights by students, the privileges of the rating are restricted.
(2) The restrictions will be removed from the rating when the requirements specified in paragraph (1) have been met and on the recommendation of the supervising flight instructor (aeroplane).

[Babel Fish]

Any new instructor should have been taught the privileges of the rating.
Indeed. The essence of what I currently understand is as alphaadrian describes. But the wording of the passages regarding restricted privileges in JAR-FCL and in the ANO are very similar and quite specific. They refer to two types of training only: initial PPL training, and night training. Therefore if, as you say, a restricted FI can conduct other types of training (continuation training, revalidation training), the implication is that this training could be conducted without a supervising FI.

The reason for the question is that I have been asked act as instructor for a dual hour required for a SEP revalidation in a private aircraft. From a licensing perspective I was fairly confident that I couldn't help them due to being restricted, but after re-reading the JAR–FCL 1.325 passage I'm not so sure.

[DFC]

(1) flight instruction for the issue of the PPL(A) - or those parts of integrated courses at PPL(A) level - and class and type ratings for single-engine aeroplanes, excluding approval of first solo flights by day or by night and first solo navigation flights by day or by night; and



The above says that the restricted instructor can teach under supervision;

PPL(A) Licence
CPL(A) Licence Integrated Course elements at PPL level
Class Rating for single engine aeroplanes
Type Rating for single engine aeroplanes

They can not;

Approve First Solo by day or night.
Approve first solo navigation by day or night.

--------

The 1 hour dual that many pilots complete as part of the SEP Class Rating revalidation is training for a Class Rating (single engine aircraft). Therefore the restricted instructor can provide this training (under supervision) to a PPL, a CPL or even an ATPL holder that requires this training.

The club checkout is again type specific / class rating training and it matters not if the pilot being ehcked is a PPL, CPL or ATPL.

[Whopity]

The wording came from a European document written by people whose native tongue is not English. This posed a number of problems when JAR-FCL first appeared.Those parts of JAR-FCL that were adopted into UK law were copied virtually word for word into the ANO resulting in different wording to that used to describe similar privileges for National ratings.

In the original draft of JAR-FCL1 the privileges of the FI and FI(R) also included the CRI (SE) privileges; this disappeared at a very early stage, maybe because a CRI does not need supervision whereas a FI(R) must be supervised. The UK interpretation is based on the old UK AFI rating which was replaced by the JAA FI(R). The wording is not the same and may be interpreted differently in different States. The UK CAA made their interpretation clear to Industry back in 1997/8 in a series of road shows. It was a long time ago.
The reason for the question is that I have been asked act as instructor for a dual hour required for a SEP revalidation in a private aircraft.No problem so long as you are supervised by a nominated FI.

[RTN11]

As has been said, the legislation comes from 2 different sources so differences appear.

Most notably, the definition of supervision.

In the legislation for the old AFI rating (still used for microlight instuctors) it clearly states in the legislation that the supervising FI needs to be present at the airfield for the take off and landing of the AFI's instuctional flights.

For the FI(A) restricted, there is no such wording, leading to the implication you can be supervised by an FI(A) who is either flying all day, or not even present at the airfield.

What level of supervision is actually required, and what is acceptable?

[Babel Fish]

No problem so long as you are supervised by a nominated FI.
OK, that's what I suspected. I believe it has been mentioned on here before that this is one situation where a CRI would have an advantage as they have no requirement to be supervised. When you say "nominated", is this referring to the supervising instructor(s) notified at a RTF, or simply an (unresticted) instructor with who agrees to supervise the flight?

What level of supervision is actually required, and what is acceptable?
TrainingCom 1/2007 (http://www.caa.co.uk/application.aspx?catid=33&pagetype=65&appid=11&mode=detail&id=2855) offers advice for "best practice", but since the only documents with any legal standing (JAR-FCL, ANO) don't actually specify what supervision entails it appears that there is still massive room for interpretation (as an experiment ask a handful of FIs what they think constitutes supervision, then sit back and admire the rainbow of responses you receive :) )

[JD02FLY]

RNT11

I would love the definitive answer to this one also, i have spoken to 2 FIE's lately about this and they can't give me an answer either.

Come on CAA or even Exam 01, lets have an answer. What is meant by "Supervision", and what are the expected duties...lets have it in black and white.

How can you supervise from another airfield to that of the FI(R).... as is what is happening at a school i know....:ugh::ugh:

[MIKECR]

babel fish,

I had a similar conversation with someone just recently re this. The same questions were asked - what is 'supervison'? and could the typical PPL SEP revalidation flight be carried out by an FI(R),whilst unsupervised? The general conclusion was that the FI(R) WOULD have to be supervised to carry out any form of 'instruction' until such time as the restriction is removed. The exact wording in Lasors etc quite clearly states that the biannual SEP Revalidation is an 'instructional' flight. The irony of course is that some who has perhaps just completed a CRI rating for SEP could of course conduct the flight 'unsupervised'.

[blagger]

It is for this very situation that I kept my CRI(A) as well as my FI(R) - if you are an FI(R) that is going to be required to do non-PPL training flights unsupervised you can always get a CRI rating as well to cover this - think it would just be a paperwork / cheque to the CAA exercise?

[DFC]

The irony of course is that some who has perhaps just completed a CRI rating for SEP could of course conduct the flight 'unsupervised'.

There is no irony at all.

Look at the experience that a person wishing to obtain a CRI Rating must have compared to what the prospective FI needs. Remember also that the CRI will only ever be dealing with people who hold a licence i.e. they are either refreshing prior knowledge / previously certified skill level or extending their knowledge / skill into a new area.

If anything the irony is that the less experienced of the two gets to teach people who have never had any previous contact with an aircraft and it is only right that this is supervised during the formative stages.

-------


How can you supervise from another airfield to that of the FI(R).... as is what is happening at a school i know


You could ask - how can you supervise an instructor in a non-radio aircraft?

If you are saying that a nominated supervising FI has to be present for take-off and landing then you are never going to have an FI(R) flying with student to another aerodrome as for example during a dual navigation exercise.

Please explain how your restricted FI can teach all elements of the sylabus without ever landing at another aerodrome while teaching the student?

Are you saying that the FTO / RTF has to have one of it's supervising FI's present at away landing sites?

How can the CAA supervise all flight training in the UK (and some places outside the UK) without being present for every take-off and landing?

[Cows getting bigger]

Answering the original question in a rather glib manner, why don't you ask your supervising FI? :rolleyes:

[JD02FLY]

Fair one DFC....

[MIKECR]

Sorry DFC, I completely disagree. Taking it to the basics and looking at the course entry requirements - A PPL with only 300 hours 'total' time can obtain a CRI rating by completing only 30 hours ground instruction and only 3 hours flight instruction. The FI(R) must have a CPL(CPL theory will suffice of course), minimum 200 hours flight time, of which 150 hours PIC. During the FI course they will cover minimum 125 hours ground instruction and also 30 hours flight instruction. So which instructor would you say is the lesser experienced - the PPL CRI with 300 hours or the CPL FI(R) with 200 hours? Neither is experienced in my opinion but hey ho! The irony as I suggested was the fact that(in the case of a simple PPL biannual SEP revalidation) the newly qualified PPL 300 hour CRI could complete the check unsupervised, yet the FI(R) who has completed significantly more Flying Instructor Training would have to be supervised to conduct the flight. I think this is exactly the point that babel fish was making, as was also sugested by blagger. The fact that the FI rating includes CRI privilages further makes the point.

[Babel Fish]

Thanks for all the input. I guess I'll be arranging some supervision (whatever that may be) for the SEP revalidation flight.

From LASORS it would seem that to obtain a CRI rating would involve completing the CRI course and taking a skills test, the only concession to FI rating holders being that the 25 hours of theoretical knowledge training is reduced to 10 hours. But even if obtaining a CRI rating were a simple paperwork exercise I'm sure the CAA fee would make it unattractive to the average FI(R).

Answering the original question in a rather glib manner, why don't you ask your supervising FI? :rolleyes:
I fail to see how this goes any way towards answering the original question. What makes you assume I didn't ask my supervising FI?

[RTN11]

Having flown at 3 different schools while restricted, I have asked each of my supervising instructors about the level of supervision required.

One insisted he had to be present at the airfield, another was happy for me to fly when he wasn't there but not to send anyone solo, and the third was ok with me doing whatever I wanted while he was on holiday for a week.

Since the legislation on this point is very unclear, and the CAA don't really give a proper answer, who can give a definitive answer on what supervision really consists of?

It seems to be designed for a busy school with plenty of students, since you need to obtain 25 solo sign offs. Would it not be better to have to evidence that you have taught every lesson in the syllabus at least once, rather than just making up the time with Ex 3?

[BillieBob]

Since the legislation on this point is very unclear, and the CAA don't really give a proper answer, who can give a definitive answer on what supervision really consists of?Only the courts when something goes horribly wrong.

[Cows getting bigger]

Babel Fish, my point was that your supervising FI should know, chapter and verse, what you can and can't do. Hence the need for you to be supervised by someone who knows what he/she is supervising. May I speculate that your supervisor shouldn't be supervising until they know the answer to the question?

[blagger]

Interesting to read that the following is what the UK CAA said in reponse to the EASA proposals:

"there is no definition to what constitutes ‘supervision’ or the experience or
qualifications required of a supervisory FI. As these requirements are common
to all FI categories a general requirement is needed in FCL.950 to
clarify/standard standardisation.

Justification: Safety/Legality – A definition, for this purpose of this Part, is
required for what is acceptable as ‘supervision’ and the minimum acceptable
experience level and responsibilities of a ‘supervisor’.

Standardisation - The lack of a binding definition in JAR already causes
confusion/variation in standardisation and a ‘loophole open to abuse.

Proposed Text: (if applicable)
A new FCL.950 Supervision of the Restricted Instructor

(a) The supervising instructor shall hold an unrestricted instructor rating
with at least 200 hours of flight instructional experience to include
experience on the type or class of aircraft for which supervision is being
given, the syllabus/exercise being taught and the experience/limitations of
the individual he is supervising.

(b) The supervising instructor shall be nominated, in the organisations
Operations Manual or Flying Order Book, so that he/she may be readily
identified. Such a document should also list the qualifications and
responsibilities of the supervising instructor.

(c) Before flight training commences, the supervising instructor shall assess
the day’s programme as appropriate having considered the exercise(s) to
be flown, student performance and progress, aircraft maintenance and
serviceability, the weather forecast, NOTAMS and any other factors likely to
affect the planned activities.

(d)The supervising instructor must be present at the airfield during any
instructional flights and be contactable without undue delay.

(e) The supervising instructor shall be informed of any student solo flying and
be available to observe, where appropriate, any briefings conducted by or
student solo flights authorised by the restricted instructor.

[BillieBob]

Interesting to read that the following is what the UK CAA said in reponse to the EASA proposals:Less interesting but, perhaps, more revealing to read the EASA response:Thank you for providing your opinion.

The Agency has carefully reviewed your comment but came to the conclusion
not to introduce a specific requirement for the supervising instructor. The
training organisation is asked to nominate an instructor for this purpose which
will be in most of the cases one of the most experienced the ATO has available.
200 hours instruction time is not needed to fulfil this task as the unrestricted
instructor is allowed to instruct himself also without any additional supervision.Which, if nothing else, proves that the bureaucrat that drafted the response has no understanding of the initial comment and even less understanding of the flight training industry, not to mention a pathetically misplaced trust in the integrity of certain parts of that industry.

[DFC]

On the contrary, there is no reason to introduce an unworkable requirement for a supervising FI to be present at every location a restricted FI departs from.

and the third was ok with me doing whatever I wanted while he was on holiday for a week.

The above is a perfect example of the problem.

Most people who have only experienced the UK system will have abig problem with the supervisor being on holidays and will focus all their attention on that as a clear example of not actually supervising (despite perhaps being in regular contact, and being aware of the issues the CAA likes raised).

People elsewhere will probably focus more on the "doing whatever I wanted" as being a better example of poor supervision no matter what the location of the supervisor. For me this is what jumps out as being poor rather than the fact they were not at the terminal bar enjoying their 5th pink of special brew = present at the aerodrome!!

[BEagle]

Well, I think that 'supervision' does indeed need to be more closely regulated - but not to the extent proposed by the UK CAA.

I have recommended the following to EASA:

(a) Supervising instructors shall hold unrestricted instructor ratings with
experience on the type or class of aircraft for which supervision is being
given, the syllabus/exercise being taught and the experience/limitations of
the individual he/she is supervising.

(b) Supervising instructors shall be nominated by the ATO.

(c) Supervising instructors should be present at the aerodrome during any
instructional flights conducted by holders of restricted flight instructor
certificates and shall be contactable without undue delay.

(d) Supervising instructors must be informed of any student solo flying and
be available to observe briefings conducted by, or student solo flights
authorised by, holders of restricted flight instructor certificates.

Not too demanding - and note that 'should', 'shall', 'must' are used in accordance with EASA vernacular usage.

[hugh flung_dung]

BEagle, for your third bullet to work we need to define "present at the aerodrome". On a quiet day, with only one FI and one FI(r) on duty, must the FI stay on the ground while the FI(r) is flying - if so there is additional cost to using FI(r)s. If the FI is allowed to be in the air, is this only in the circuit, or the local area ... or on a dual land-away? What happens if the FI is airborne and the FI(r) or their student blacks the runway? It's all a bit of a minefield in the real world.

When I'm formally supervising I regard it as simply being available for advice and dealing with first solos. I'm not sure that anything else is viable in reality.
I'll certainly "have a word" if anything looks a little out of line but I (and I expect most other experienced aviators) do that even when not supervising.

HFD

[DFC]

The whole problem with the "being present" is that almost everywhere outside the Uk has never had such a requirement. In some places prior to JAR-FCL the only instructor in a club who could authorise First Solos was also responsible for supervision of all other instructors and training activity at that club - the CFI. Organisations ijn those places will cite the lack of previous problems as a reason for not introducing a new "be present" requirement.

How can an organisation have a supervising FI present at aerodromes where navigation exercises may temporarily land during an exercise.

What if the restricted FI decides to divert - do they have to divert to an aerodrome where their organisation has pre-positioned an FI so that they have someone present when they arrrive.

In my experience organisations that apply the "be present" rule rush restricted FI's through to avoid what hfd correctly describes as extra expense and other related issues. Flight training safety and quality is actually worse as a result.

What is very important is to put something in place to firstly provide on-the-job training (line training if you like) for instructors in their first post, career development and proper supervision.

[BEagle]

When I'm formally supervising I regard it as simply being available for advice and dealing with first solos.

That is hardly supervision.....

If the FI is allowed to be in the air, is this only in the circuit... I would consider that to be 'at the aerodrome'.

or the local area ... or on a dual land-away? Nope, it's blindingly obvious that neither of those examples could be considered 'at' the aerodrome.

What happens if the FI is airborne and the FI(r) or their student blacks the runway? You cannot legislate for every conceivable scenario. If such a thing happened, you would either have to divert and call in, or wait whilst the wreckage is pushed onto the grass, then land.

[BillieBob]

I have recommended the following to EASA:...and their response to your recommendation? Judging by the content of the CRD, they have ignored it completely, as with so many other well-reasoned comments, and retained their original, deeply flawed, wording. Anyway, what do you know about anything? - you are merely a functionary, an operator of machinery, entirely worthless in Monnet and Schuman's great scheme for a european federated state.

You must realise that you are dealing with terminally narrow-minded bureaucrats who regard the 'stakeholders' as an unnecessary distraction. Future amendments to the Implementing Rules will not be subject to the NPA process, which is seen by the establishment as entirely negative and counter-productive.

Thank God, Greece and the rest of the PIIGS that the whole rotten edifice is about to come crashing down.

[BEagle]

My comment was made following the CRD release and is in the current round of consultation responses which ends in a few days time.

European Economic Community ('Common Market') - fine idea. Single currency - I'm yet to be convinced. European Community superstate run by a European Parliament - no b£oody way. But Trust-me-Tone and Incapability Brown lied to us about the prospect of a referendum and the pooch has now been well and truly screwed....:uhoh:

[freon1978]

How can you supervise from another airfield to that of the FI(R).... as is what is happening at a school i know....:ugh::ugh:


Thats nothing I've seen schools using "instructors" without an instructor rating restricted or otherwise!

My understanding and that of our CFI was that if the "student" was a PPL licence holder then supervision was not necessary. However I can't find this in black and white any where.
An FIC instructor i've just spoken to also feels this is the case but again can't find a reference anywhere, going to try and get a more solid answer from the CAA.

[Whopity]

However I can't find this in black and white any where.
JAR-FCL 1.325JAR–FCL 1.325 FI(A) – Restricted privileges
(a) Restricted period. Until the holder of a
FI(A) rating has completed at least 100 hours
flight instruction and, in addition, has supervised
at least 25 student solo flights, the privileges of
the rating are restricted.
(b) Restrictions. The privileges are
restricted to carrying out under the supervision
of a FI(A) approved for this purpose:
(1) flight instruction for the issue of
the PPL(A) – or those parts of integrated
courses at PPL(A) level – and class and type
ratings for single-engine aeroplanes,
excluding approval of first solo flights by day
or by night and first solo navigation flights by
day or by night; and

Instruction of a PPL holder is for a Class or Type Rating.

Thats nothing I've seen schools using "instructors" without an instructor rating restricted or otherwise! So you watched a totally illegal flight that was uninsured! What did you do about it?

[freon1978]

JAR–FCL 1.325 FI(A) – Restricted privileges
(a) Restricted period. Until the holder of a
FI(A) rating has completed at least 100 hours
flight instruction and, in addition, has supervised
at least 25 student solo flights, the privileges of
the rating are restricted.
(b) Restrictions. The privileges are
restricted to carrying out under the supervision
of a FI(A) approved for this purpose:
(1) flight instruction for the issue of
the PPL(A) – or those parts of integrated
courses at PPL(A) level – and class and type
ratings for single-engine aeroplanes,
excluding approval of first solo flights by day
or by night and first solo navigation flights by
day or by night; and


Yes i think thats been mentioned before and i am capable of finding that and an almost identical reference in LASORS,but it really does seem the be focused on ab initio training and not further and currency training. Specifically it doesn't mention recurrent training with a PPL holder.


So you watched a totally illegal flight that was uninsured! What did you do about it?


Wow, just climb down off your high horse one moment... you don't know what I did or didn't do about it and thats my business not yours thanks.

[Duchess_Driver]

....the privileges of the rating are restricted.
(b) Restrictions. The privileges are restricted to carrying out under the supervision of a FI(A).....

Seems perfectly clear to me.

[BEagle]

And to me!

Thats nothing I've seen schools using "instructors" without an instructor rating restricted or otherwise!

So did you turn a Nelsonian eye or what?

[freon1978]

So did you turn a Nelsonian eye or what?


How my collegues and I dealt with it is absolutely none of your business as i've already said. You know nothing of the circumstances and i don't intend to explain them to you. It was dealt with appropriately is all i'm willing to say and thats the end of discussion.

Are you always this aggressive? looking through your posts on this thread I'd say that seems the case.

If this was SO clear how come 2 pages has now been devoted to discussion on it?
I'll wait for a reply from the flight crew licencing department or a CAA staff examiner thanks rather than speculating. In the mean time i'll make sure any restricted FI's I know are erring on the side of caution. No harm in that.

[BEagle]

So why bother mentioning your allegation if you won't explain your subsequent actions?

[BillieBob]

freon - you're totally outclassed. The clever thing to do now would be to quit while you're not too far behind. As for waiting for an answer from the flight crew licensing department (which, incidentally, doesn't exist - I suppose you mean the Licensing and Training Standards Department), you've already had it.

[Whopity]

Specifically it doesn't mention recurrent training with a PPL holder.Would that be for a SEP Class rating perhaps?