IR-(A): Privileges without an FI?

[Jakobsens]

Hi Girls & Guys,

I am currently in the process of obtaining an IR-I. Due to the fact, I don't have the FI(A), I instead hold +800hrs IFR (and the other requirements), and now also have obtained the Teaching & Learning Course as well as gone through the entire IR-I training programme. The only thing missing is the Assessment of Competence.
And then I received the following phonecall from the Norwegian CAA saying something like:

"If you do NOT hold an FI-IR, and only IR-I, you can only teach students attending a modular programme and NOT integrated students". I can not find ANY information in any EASA-legislation nor local Norwegian rules, and I am obviously quite frustrated since I will most likely not get the job-offer I have been offered, if I can not obtain a "full" IR-I rating with all privileges applicable to being an Instrument-Instructor.

So my question goes; Have anybody heard of any reason for the above, and if not; what are my options of complaint or changing their mind, if they will not back off and instead keep standing their ground on an interpretation of a law, that I do not think exist?

Thanks for your help!

Kind regards,
A very frustrated, laid-off ex. B737 FO really longing for some good news in 2020.....

Oh, and by the way:
Since I hold a valid ME-IR rating, I did not think either, I needed a valid SE-IR to fly SE instrument flying (only a valid class-rating for SEP(L), obviously). Apparently the CAA here interprets that so you need to have flown a SE-IR skilltest once upon a time to do that - even if that skilltest was 15 years ago. But obviously I can get thru that by accepting a new SE-IR skilltest and move on. Did that make any sense?

[rudestuff]

Students on an integrated course do not hold any kind of licence (until the very end).

As an IRI you can only teach the IR and IRR (to licenced pilots). During an integrated course the students are combining PPL, CPL and IR into one, so you need to be able to teach all three.

Unfortunately after your IRI you need to do an FI course, hour build 30 hours PIC on a MEP, then do the MEPCRI course. If you don't have the PIC time you're looking at another £20k+

[Jakobsens]

Hi, and thanks for your reply.
That is most likely the philosophy they have as well. The thing is, I have discussed the matter with two other CAA's in neighboring countries, which do not agree on the interpretation at all. If you have a reference to where I can find substantial explanation of this, please post it here.

The only thing I find from PART-FCL, subpart J Section 6 is the following:

"FCL.905.IRI IRI — Privileges and conditions(a) The privileges of an IRI are to instruct for the issue, revalidation and renewal of an EIR or an IR on the appropriate aircraft category.

(b) Specific requirements for the MPL course. To instruct for the basic phase of training on an MPL course, the IRI(A) shall:

(1) hold an IR for multi-engine aeroplanes; and

(2) have completed at least 1 500 hours of flight time in multi-crew operations.

(3) In the case of IRI already qualified to instruct on ATP(A) or CPL(A)/IR integrated courses, the requirement of (b)(2) may be replaced by the completion of the course provided for in paragraph FCL.905.FI(j)(3).".

If the interpretation from the Norwegian CAA is correct, I then would be allowed to teach integrated students, already holding a PPL from before on the IR-programme, but not students which do not. Hence; I do not see the connection with Modular vs. Integrated students, nor do I find any reference to this in any legislation.
It is further specifically stated in Section 6, an IR-I (without FI) can teach MPL-students in the I-programme if he fulfills the requirements in the paragraph I quoted above.
Since MPL-students do not necessarily take out a PPL/CPL etc. before the very end of the MPL-programme, I would not neither be allowed to teach these students on the IR-programme, even when I fulfill I requirement (1) and (2) in the above. However, according to Section 6, that is possible.
I can not find the connection..

Thanks for the discussion!

[Whopity]

Agree with Rudestuff above. However; to teach ME IR you also need to be a CRI(ME)
Oh, and by the way:
Since I hold a valid ME-IR rating, I did not think either, I needed a valid SE-IR to fly SE instrument flying (only a valid class-rating for SEP(L), obviously). Apparently the CAA here interprets that so you need to have flown a SE-IR skilltest once upon a time to do that - even if that skilltest was 15 years ago. But obviously I can get thru that by accepting a new SE-IR skilltest and move on. Did that make any sense?

Some Authorities in Europe have adopted this stance leading to the recent amendment to Part FCL
(24) in point FCL.620, the following point (c) is added: ‘(c) Applicants who have completed a skill test for a multi-engine IR in a single-pilot multi-engine aeroplane for which a class rating is required shall also be issued with a single-engine IR for the single-engine aeroplane class or type ratings that they hold.’;]

Presumably your current IR is Multi Pilot so you would need to have SP privileges as well which requires a seperate Prof Check. If you revalidate the SP IR on a MEP Aircraft you now need a valid MEP Class rating, but it should give you privileges on SEP aeroplanes in accordance with FCL.620.

[Jakobsens]

Thanks for the input.
I think the interpretation from the authority is the same. Please note, for the time being I am only considering the SEP(L) IR-I.

Directly copy/pasted from Part-FCL. Subpart J, Section 6 regarding IR-I, it says: "FCL.905.IRI IRI — Privileges and conditions

(a) The privileges of an IRI are to instruct for the issue, revalidation and renewal of an EIR or an IR on the appropriate aircraft category.

(b) Specific requirements for the MPL course. To instruct for the basic phase of training on an MPL course, the IRI(A) shall:

(1) hold an IR for multi-engine aeroplanes; and

(2) have completed at least 1 500 hours of flight time in multi-crew operations.

(3) In the case of IRI already qualified to instruct on ATP(A) or CPL(A)/IR integrated courses, the requirement of (b)(2) may be replaced by the completion of the course provided for in paragraph FCL.905.FI(j)(3)."

And further:

"FCL.915.IRI IRI — Prerequisites

An applicant for an IRI certificate shall: (a) for an IRI(A):

(1) have completed at least 800 hours of flight time under IFR, of which at least 400 hours shall be in aeroplanes; and

(2) in the case of applicants of an IRI(A) for multi-engine aeroplanes, meet the requirements of paragraphs FCL.915.CRI(a), FCL.930.CRI and FCL.935;"
If a student on an integrated programme can not be instructed by an IR-I (without FI-IR) due to the fact that the student does not hold a specific license, then the IR-I should be able to teach the same integrated students classmate, if he/she was holding a PPL or CPL from before starting the programme. Or; a student doing a PPL skilltest on his/her own basis during the integrated course thereby suddenly holding a valid license. Hence I do not see the connection between the Modular and Integrated programs.

Further; If a student follows an MPL-programme, he/she do usually not take out a PPL/CPL license during the course. Therefore an IR-I should not be able to teach IFR on the MPL-programme due to the fact, the student do not hold a valid license (PPL, CPL or similar). But from the paragraph attached above, it says an IR-I can teach MPL-students if the IR-I fulfills the requirements regarding experience etc. But it is not stated, the instructor needs a specific FI.

I am still unable to find any legislation where it states, an IR-I can not teach candidates who are not holding other licenses than a solo-permit (which in my humble opinion is considered some type of a "license"/"rating" - the student is however flying solo around the country). If any of you guys have a link to any documentation, please advise.

Thanks for the discussion!

[Whopity]

I see where you are coming from on this and some of the regulation is difficult to follow.

An Integrated CPL/IR course is an ab-initio course and requires no pilot qualification and staff are appointed accordingly, the fact that a proportion of students might already hold a licence has no bearing on the matter, its still an ab-initio course for the issue of a CPL.

(a) General. A person shall only carry out:
(1) flight instruction in aircraft when he/she holds:
(i) a pilot licence issued or accepted in accordance with this Regulation;
(ii) an instructor certificate appropriate to the instruction given, issued in accordance with this Subpart;

FCL.905.FI FI – Privileges and conditions
Regulation (EU) 2020/359
The privileges of FIs are to conduct flight instruction for the issue, revalidation or renewal of:
(e) a CPL in the appropriate aircraft category, provided that FIs have completed at least 200 hours of flight instruction in that aircraft category;

An Integrated ATPL/CPL course falls under the privileges stated above.

The MPL Course is a relatively new idea however; the requirements don't quite add up. It appears as though an IRI may give instruction on an Integrated MPL Course in the basic phase, but this is all conducted in simulators and you would need to meet the Multi Engine requirement for an IRI not the SE requirement.

(3) In the case of IRI already qualified to instruct on ATP(A) or CPL(A)/IR integrated courses, the requirement of (b)(2) may be replaced by the completion of the course provided for in paragraph FCL.905.FI(j)(3)."
But, there is no FCL.905.FI(j)(3) it stops at (2) it could be (k)(3) but all reference is to FIs.

FCL.905,FI (k)(3) in the case of FIs already qualified to instruct on ATP(A) or CPL(A)/IR integrated courses, the requirement in point (2)(ii) may be replaced by the completion of a structured course of training consisting of:
(i) MCC qualification;
(ii) observation of five sessions of flight instruction in Phase 3 of an MPL course;
(iii) observation of five sessions of flight instruction in Phase 4 of an MPL course;
(iv) observation of five operator recurrent line-oriented flight training sessions;
(v) the content of the MCCI course.
In this case, FIs shall conduct their first five instructor sessions under the supervision of a TRI(A), an MCCI(A) or an SFI(A) qualified for MPL flight instruction.
As an IRI is not qualified to instruct on an ab-initio course, how anyone could become already qualified is a mystery except perhaps on a MPL Course.
I am still unable to find any legislation where it states, an IR-I can not teach candidates who are not holding other licenses than a solo-permit (which in my humble opinion is considered some type of a "license"/"rating" Solo flying is conducted under an Exemption not to require a licence under specified conditions FCL020.
An IRI can only instruct for a rating which can only be added to a licence.