Do instructor take-off/landings count towards 90 day currency?

[Trim Stab]

If flying as an instructor - do take-offs and landings count towards the 3 in 90 currency regulation?

The regulation states that only take-offs and landings as "pilot-flying" count - but if the student has no licence is the instructor the de-facto "pilot-flying"?

[Genghis the Engineer]

It's always been my understanding that it's the person handling the controls who counts for 90 day rule, not who is Captain.

[mad_jock]

yep its sole manipulator of the controls or used to be words to that effect.

[Whopity]

but if the student has no licence is the instructor the de-facto "pilot-flying"? The insdtructor is the PIC but if the student does the landing and take off, the instructor is not the sole manipulator of the flying controls which is the bit that counts.

As an instructor I would expect you complete a number of demonstrations so it is highly unlikely that you would not have met the 90 day requirement!

[Heston]

What they all said.

I find I can often go all day instructing without handling the controls. I know instructors who always do a circuit on their own at the start of the day - seems a pretty good idea to me. Not that there is any danger of going past 90 days.

[Check Airman]

90 days?

With some students, I couldn't go 90 minutes without having to salvage a landing.

I never minded the days where I never flew. Meant the students were doing well:)

[mad_jock]

90mins your bloody lucky.

9 mins with some, although rescuing one isn't really counted as sole manipulator of the controls for approach and landing.

I did have a period with lots of full time students all starting at the same time I managed over a month without landing an aircraft.

And Cpl and IR instructors must be able to get passed 90 days easy.

But then again 90 day rule doesn't apply flying with students as they are not pax they are part of the flight crew.

[172510]

How do you log that in your logbook?

[dobbin1]

I only log the landings that I do myself. The student logs any landings that they do.

[Whopity]

How do you log that in your logbook? With a pen! However; in the UK there is no legal requirement (Art 79) to log landings or take offs at all.

[TheOddOne]

Here's another one...

I really like night instructing, did 3 people last year but nothing yet this season due appalling wx (until this week).

Now, some folk say that an instructor can launch straight into a night session with the student doing all the flying, but I'm uncomfortable with that as I think I need 1 night take-off and landing in the 90 days prior to be able to be P1. I always start a period of night flight with a solo circuit to ensure I'm legal (unfortunately at my own expense...) I then subsequently ensure that I do enough demos during the next 90 days to keep current.

Thoughts?

The OddOne

[nick14]

Or hold an IR in that aircraft category.

[Whopity]

I think I need 1 night take-off and landing in the 90 days prior to be able to be P1No, you need 1 take off and landing at night to be able to carry passengers. The definition of a passenger is a person on board who is not a member of the crew, so you do not need 90 day currency to be PIC on a training flight so long as no passengers are carried.

[TheOddOne]

so you do not need 90 day currency to be PIC on a training flight so long as no passengers are carried.

Thanks, Whopity
TOO

[172510]

Let's see if EASA has some useful guidance about that:

AMC1 FCL.060(b)(1) Recent experience
When a pilot needs to carry out one or more flights with an instructor or an examiner to comply with the requirement of FCL.060(b)(1) before the pilot can carry passengers, the instructor or examiner on board those flights will not be considered as a passenger.

Isn't that hair splitting?

GM1 FCL.060(b)(1) Recent experience
AEROPLANES, HELICOPTERS, POWERED-LIFT, AIRSHIPS AND SAILPLANES
If a pilot or a PIC is operating under the supervision of an instructor to comply with the required three take-offs, approaches and landings, no passengers may be on board.


So you may carry passengers if you cannot fly at all, or if you can fly, but want an instructor with you to do some training. BUT the flight will not count for the 3 take-offs! Il will only count if you're solo or with an instructor

[Whopity]

So you may carry passengers if you cannot fly at all, or if you can fly, but want an instructor with you to do some training. BUT the flight will not count for the 3 take-offs! Il will only count if you're solo or with an instructor I think you are a little confused. Any take off and landing counts towards the 3 required for 90 day recency; the problem occurs when you don't have 3 within the previous 90 days, then you can only complete them solo, or with an instructor, and no passengers may be carried on those flights.

[BEagle]

....or with an instructor....

Which means an FI qualified to give instruction for the Night Rating and not a CRI (e.g. LAA non-FI coach).

[nick14]

Don't start that debate again beagle. My brain still hurts from the last time.:O

[Genghis the Engineer]

Which means an FI qualified to give instruction for the Night Rating and not a CRI (e.g. LAA non-FI coach).

Err, why?

If a CRI has a current NQ, why can't they instruct another NQ holder in conditions where the "student" could legally fly solo and the instructor can legally fly PiC.

I can't see a difference from a CRI instructing somebody who has lapsed from 90 day rule to get their currency back in daylight.

G

[Whopity]

I can see both points of view here however, if it came to an accident and the instructor, who must be exercising instructional privileges to be anything other than a passenger, must be able to point at those privileges. FCL.900 Instructor certificates
(a) General. A person shall only carry out:
(1) flight instruction in aircraft when he/she holds:
(ii) an instructor certificate appropriate to the instruction given, issued in accordance with this Subpart; For the FI:FCL.905.FI FI — Privileges and conditions
The privileges of an FI are to conduct flight instruction for the issue, revalidation or renewal of:
(e) the night rating, provided that the FI:
(1) is qualified to fly at night in the appropriate aircraft category;
(2) has demonstrated the ability to instruct at night to an FI qualified in accordance with (i) below; and
(3) complies with the night experience requirement of FCL.060(b)(2); Wheras for the CRIFCL.905.CRI CRI — Privileges and conditions
(a) The privileges of a CRI are to instruct for:
(1) the issue, revalidation or renewal of a class or type rating for non-complex non-high performance single-pilot aeroplanes, when the privileges sought by the applicant are to fly in single-pilot operations;
(2) a towing or aerobatic rating for the aeroplane category, provided the CRI holds the relevant rating and has demonstrated the ability to instruct for that rating to an FI qualified in accordance with FCL.905.FI(i). There is no mention of Night being a privilege.

One could argue that the night recency is neither an issue, revalidation or renewl, in which case no instructor is required; the flight must therefore be conducted with no passengers including one who might hold a CRI rating.

[nick14]

No but equally there is no prohibition and the instruction is not being given for the night rating and it cannot count towards such so I personally don't see why not. I'm perfectly entitled to instruct on my other type at night even though there is no such privileges stated in my instructor certificate so why not a CRI?!

[Whopity]

the instruction is not being given for the night rating and it cannot count towards suchSo, you are not acting as an instructor, and therefore can only be a passenger!

[nick14]

Does the same count for night circuits in my other type then?

[172510]

I can see both points of view here however, if it came to an accident and the instructor, who must be exercising instructional privileges to be anything other than a passenger, must be able to point at those privileges.
Quote:
FCL.900 Instructor certificates
(a) General. A person shall only carry out:
(1) flight instruction in aircraft when he/she holds:
(ii) an instructor certificate appropriate to the instruction given, issued in accordance with this Subpart;
For the FI:
Quote:
FCL.905.FI FI — Privileges and conditions
The privileges of an FI are to conduct flight instruction for the issue, revalidation or renewal of:
(e) the night rating, provided that the FI:
(1) is qualified to fly at night in the appropriate aircraft category;
(2) has demonstrated the ability to instruct at night to an FI qualified in accordance with (i) below; and
(3) complies with the night experience requirement of FCL.060(b)(2);
Wheras for the CRI
Quote:
FCL.905.CRI CRI — Privileges and conditions
(a) The privileges of a CRI are to instruct for:
(1) the issue, revalidation or renewal of a class or type rating for non-complex non-high performance single-pilot aeroplanes, when the privileges sought by the applicant are to fly in single-pilot operations;
(2) a towing or aerobatic rating for the aeroplane category, provided the CRI holds the relevant rating and has demonstrated the ability to instruct for that rating to an FI qualified in accordance with FCL.905.FI(i).
There is no mention of Night being a privilege.

One could argue that the night recency is neither an issue, revalidation or renewl, in which case no instructor is required; the flight must therefore be conducted with no passengers including one who might hold a CRI rating..
My understansding is that the CRI would not count as a passenger according to
AMC1 FCL.060(b)(1) Recent experience
When a pilot needs to carry out one or more flights with an instructor or an examiner to comply with the requirement of FCL.060(b)(1) before the pilot can carry passengers, the instructor or examiner on board those flights will not be considered as a passenger.

But I don't understand the "need to". Does it mean that the instructor does not count as a passenger if the pilot may not fly alone? If a pilot may not fly without an instructor, what's the use of the 90 days rule?

[Whopity]

But I don't understand the "need to"Therin lies the answer, why would a pilot need to carry an instructor for the purposes of night recency? Probably, because the pilot does not feel competent to conduct the flights solo, therefore the instructor is there to give confidence and correct any mistakes that might be made. That requires an instructor who is competent to do this and logically would be a FI with the training and privileges to do so. Surely a court would consider such factors in any test of reasonableness?

I don't dispute the fact that CRI could conduct Class rating training at Night, there being nothing in law to prevent it, and presumably, any landings and take offs so conducted would count towards recency requirements, The problem only occurs when the purpopse of the flight is solely to obtain recency requirements when they have lapsed and the reason why the "instructor" is carried.

Another classic mess from the chumps in charge!

[mad_jock]

Yes but the counter argument is that its not for initial training for a rating and as the CRI has no restrictions for night its fair game to do circuits with the pilot as it is for day.

personally I was a CRI I would be doing it.

[Level Attitude]

I don't dispute the fact that CRI could conduct Class rating training at Night,
there being nothing in law to prevent it, and presumably, any landings and take offs
so conducted would count towards recency requirements, The problem only occurs
when the purpopse of the flight is solely to obtain recency requirements when they
have lapsed and the reason why the "instructor" is carried.

This is just silly.

If it is believed that a CRI can exercise their privileges at night then they
can do any training they like, within the Class Rating, at night - as long as
that training is not (used) for the issue of a Night Rating.

[nick14]

I asked this exact question on my course and was told by the FIE it is fine.

[squawking 7700]

Just changing tack slightly, how many FI's are there who are qualified in accordance with FCL.905.FI(i) who can 'validate' my CRI rating (and towing experience) such that I can teach the towing rating?


7700

[ifitaintboeing]

The answer is...not many. If you contact the BGA they will have a short list - I spoke to the BGA about this last week.

ifitaint...

[squawking 7700]

And what did the BGA say?

As I understand it, providing someone who has either an FI or CRI rating and can demonstrate having given tug pilot instruction before April 2015 will be grandfathered the privilege.

I know there aren't many, if any, FIC instructors who are tug pilots, that's why I asked the question.


7700