SEP Revalidation dual flight

[ty4815162342]

Hello all!
I am a FI(R) and was recently asked if i could fly the dual flight to revalidate a SEP rating:

"Revalidation of single-pilot single-engine class ratings.
(1) Single-engine piston aeroplane class ratings and TMG ratings. For
revalidation of single-pilot single-engine piston aeroplane class ratings or
TMG class ratings the applicant shall:
(i) within the 3 months preceding the expiry date of the rating, pass a
proficiency check in the relevant class in accordance with Appendix 9
to this Part with an examiner; or
(ii) within the 12 months preceding the expiry date of the rating, complete
12 hours of flight time in the relevant class, including:
– 6 hours as PIC;
– 12 take-offs and 12 landings; and
– a training flight of at least 1 hour with a flight instructor (FI) or a class
rating instructor (CRI). Applicants shall be exempted from this flight
if they have passed a class or type rating proficiency check or skill
test in any other class or type of aeroplane. "

I've been reading through CAP 804 for my privileges:

"An FI shall have his/her privileges limited to conducting flight instruction under
the supervision of an FI for the same category of aircraft nominated by the ATO
for this purpose, in the following cases:
(1) for the issue of the PPL, SPL, BPL and LAPL;
(2) in all integrated courses at PPL level, in case of aeroplanes and helicopters;
(3) for class and type ratings for single-pilot, single-engine aircraft, class and
group extensions in the case of balloons and class extensions in the case of
sailplanes;"

..and it seems like i can give instruction class ratings.. but another issue i'm having is that this dual flight is to be flown on their own plane -a Tail-dragger. and i've never flown one! I'm thinking i cannot provide instruction on a tail-dragger if i've never been signed off in one!

Can somebody please give some advice on this one, Thanks!

[S-Works]

..and it seems like i can give instruction class ratings.. but another issue i'm having is that this dual flight is to be flown on their own plane -a Tail-dragger. and i've never flown one! I'm thinking i cannot provide instruction on a tail-dragger if i've never been signed off in one!

Aside from the rules. Common sense mode... What do you think?

[bingofuel]

As the FI for the dual revalidation flight you are P1.

You have not done difference training for taildraggers.

You cannot fly it as P1

[DB6]

May not apply but have you asked the chap if he has done any other skill tests in the last year or so e.g. IMC? This also includes LPCs in a simulator if he's an airline pilot. If so he doesn't need the flight with instructor.

[Whopity]

if he has done any other skill tests in the last year or so e.g. IMC?The IMC can only count as an hour with an instructor, it is not a Class or Type rating Skill test, so does not meet that criteria. If he had done an hour with an instructor, the question would not have arisen.

[Trim Stab]

As the FI for the dual revalidation flight you are P1.

You have not done difference training for taildraggers.

You cannot fly it as P1

Since when has there been any "differences training" for taildraggers? They aways used to be part of the SEP class.

I am also fairly sure he can do this anyway. The purpose of the dual flight is not to give instruction, but simply to ensure that the flight is conducted safely. I've signed people off on dual check on taildraggers before - I've certainly never had any "differences training" on them.

[BillieBob]

Since when has there been any "differences training" for taildraggers?Since at least 2003 and probably since JAR-FCL 1 was introduced (I don't have anything earlier than Amendment 3 to hand).

[AltHold]

Whopity

The IMC or IR renewal/reval no longer counts as the dual flight with an instructor Part FCL 740.A (b) (ii) states
a training flight of at least 1 hour with a flight instructor (FI) or a class rating instructor (CRI). Applicants shall be exempted from this flight if they have passed a class or type rating proficiency check or skill test in any other class or type of aeroplane.

The imc or IR are not class or type rating therefore if you are solely revalidating an SEP you will need a flight with an instructor however your 747 type rating will do nicely as the dual flight

[Whopity]

My comment related only to the IMC, which of course is flown with an instructor and if it lasts 1 hour will fulfill the requirements of FCL.740 (b) (ii)!

[BEagle]

....however your 747 type rating will do nicely as the dual flight ....

Not so, technically, as the clumsy piece of €urospeak states: a class or type rating proficiency check or skill test in any other class or type of aeroplane.

It does not say 'simulator'.....:\

I first asked the CAA to sort this out on 13 Aug 2012 and have raised it since at face-to-face meetings with CAA Head of Licensing and Training Standards on at least 2 occasions. I drafted a proposed amendment which was favourably received at the EASA part-FCL Partnership Group meeting and it has now gone to FCL.002. But they won't release the NPA until the end of the year, at the earliest.

The text of the proposed amendment reads:

‘Applicants shall be exempted from this flight if they have passed any other skill test, proficiency check or assessment of competence for the same category of aircraft.'

I'll give the CAA yet another nudge on Tuesday.....:hmm:

[Talkdownman]

My comment related only to the IMC, which of course is flown with an instructor and if it lasts 1 hour will fulfill the requirements of FCL.740 (b) (ii)!
Quote from email to FE from Head of Licensing & Training Policy UK CAA
'Part-FCL says that the 1 hour training flight with an instructor is not required if the pilot has passed a skill test or proficiency check for a Type or Class rating within the relevant period. There does not appear to be any credit for an IR test - and by implication no credit for an IR(R)/IMC test either. EASA has agreed to consider this further. We may have an answer at the next meeting in April. However, for the moment I must advise that you should not revalidate an SEP rating on the basis of an IMC test'
Was there an answer in April?

[Whopity]

An hour with an instructor is an hour with an instructor! FCL.740 does not specify what you should be doing therefore debating it is rather pointless!

[BillieBob]

FCL.740.A(b)(2) requires "a training flight of at least 1 hour with a flight instructor (FI) or a class rating instructor (CRI)." Neither a proficiency check nor a skill test is a 'training flight' and, therefore, would not normally meet the requirement. However, FCL.740.A(b)(2) specifically and solely allows "a class or type rating proficiency check or skill test in any other class or type of aeroplane" as an alternative.

Now, here's the difficult bit - a proficiency check for any purpose other than the revalidation or renewal of a class or type rating does not meet the requirement of FCL.740.A(b)(2). The proficiency check for the revalidation or renewal of an IR or IMC Rating is not for the purpose of revalidating or renewing a class or type rating and, therefore, does not meet the requirement of FCL.740.A(b)(2). There, that wasn't so hard, was it?

[Tay Cough]

It does not say 'simulator'.....

Presumably ZFT approval for a simulator counts as no airline pilot would be able to revalidate their type ratings otherwise. ;)

[Whopity]

There, that wasn't so hard, was it? Define "Training Flight"
If the IMC test were failed, or God forgive the candidate did not have a valid medical, it could only be logged as Dual!

The definition of "Dual" implies instruction.

‘Dual instruction time’ means flight time or instrument ground time during which a person is receiving flight instruction from a properly authorised instructor.

The original purpose of the Dual flight was copied directly from the FAA before being "Eureobuggered" its purpose is clearly nothing to do with the SEP class, rather, it is to ensure some level of exposure to a controlled environment, instructor examiner etc. The UK has issued an Alternative means of compliance, 3 x 20 minute flights with the same instructor, realistically 30 minutes airborne time just enough for 3 separate circuits. If that is good enough, the content of an IMC test may be well over the top! At the end of the day, we have to trust the instructor, some beaurocrat, who can't instruct, sitting in an office pontificating over what is or isn't instruction will achieve nothing. Its worked for 13 years, what is the safety issue?

[BEagle]

I hear that the specific content of the 'dual training flight' might well be the next piece of €urocrap to find its way from Köln....:uhoh:

It seems that one of those countries vich must haff rules for everything can't live with the concept of leaving it to the FI and pilot to decide what they wish to include in the flight....:ugh:

It is being discussed (and has been for ages now) by the FCL.002 group whose NPA is anticipated at the end of the year.

[Level Attitude]

It seems that one of those countries vich must haff rules for everything can't live with the concept of leaving it to the FI and pilot to decide what they wish to include in the flight

In the UK an Instructor could decline to sign off the dual flight if they
felt the pilot was unsafe/required further training.

Is that still possible?
As written, the rules only state that a dual flight has to be completed
(a Log Book signature not being required) - which means there is no check
on preventing potentially unsafe pilots from legally continuing to fly.

The CAA used to recommend some content for the dual flight (stall recovery, PFLs, etc)
so I am not against this in principal. But, if the content is mandated, what
happens if the pilot is not competent?
This is supposed to be a training flight, not a check or test.

A Pass in an IR or IMC test (in an aircraft) not being an acceptable substitute for
the dual flight is an anomaly (given that a Fail is a Dual flight and,
providing it was 1 hour long, would fulfil the requirements).

However I am not too bothered as I see it as an anomaly in the concession
(not to require the dual flight) and, if BEagle's amendment (Post "12)
comes to pass, then it will eventually be resolved.


To the OP:
You asked a good question but, as a restricted FI, you should have
discussed it with your supervising FI.

To give a dual training flight you, as the instructor, must be able to
(legally) log PIC. If you have only flown tricycle gear aircraft then,
as previously stated, you require difference training (which must be
signed off) before you can be PIC in tail wheel aircraft.

Even if legal, what could you teach someone in an aircraft you had never
flown before? I am guessing you were thinking of this as just a
paperwork exercise: going up, in effect, as a passenger - relying on
your student to make all the decisions, hopefully correct ones, because you have
insufficient knowledge yourself to know when, as the instructor, to override them
or otherwise properly exercise your duty(ies) as PIC.

[flybymike]

Mandating the content of the instructor flight completely buggers up the concept of the pilot (or the instructor) choosing to make use of the flight to concentrate on any aspect of the pilot's flying which either of them consider to be the most useful to the pilot.
Whether it be circuits, landings, tail wheel flying, navigation, instrument flight, complex training, type training, aeros, whatever, it is a wasted opportunity not to use the time specifically to the maximum benefit of the individual pilot.

[Talkdownman]

Which is why the AIC 'Content and Conduct of the Dual Flight with an Instructor' was withdrawn.