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bohpilot
24th Jul 2021, 15:24
It was my understanding that for a TRI AOC that the test is done by a TRE and not an SFE. I was certain that this was in PART FCL Sub Section J but cannot find it.

Is this still the case or not??

deltahotel
24th Jul 2021, 15:49
Sub part K

FCL.1005.TRE TRE – Privileges and conditions Regulation (EU) 2019/1747 (a) (b) TRE(A) and TRE(PL). The privileges of a TRE for aeroplanes or powered-lift aircraft are to conduct: (1) (2) (3) (4) (5) skill tests for the initial issue of type ratings for aeroplanes or powered-lift aircraft, as applicable; proficiency checks for revalidation or renewal of type ratings, EIRs and IRs; skill tests for ATPL(A) issue; skill tests for MPL issue, provided that the examiner has complied with the requirements in FCL.925; assessments of competence for the issue, revalidation or renewal of a TRI or SFI certificates in the applicable aircraft category, provided that they have completed at least 3 years as a TRE and have undergone specific training for the assessment of competence in accordance with point FCL.1015 (b).

The equivalent para 5 for SFEs:

5) assessments of competence for the issue, revalidation or renewal of an SFI certificate in the relevant aircraft category, provided that they have completed at least 3 years as an SFE(A) and have undergone specific training for the assessment of competence in accordance with point FCL.1015(b).

Which says to me that SFE can only qualify SFI. That is a surprise to me, but there we are.

rgds

bohpilot
24th Jul 2021, 17:31
Great, that is what i wanted. All clear now TRE can do SFI/TRI SFE can only do SFI

milan.pilot
29th Jul 2021, 01:01
Great, that is what i wanted. All clear now TRE can do SFI/TRI SFE can only do SFI

well this is not 100% true, since most of TRI AoCs are doing in FSTD, so basically you are assessing TRI restricted to FSTD that equals SFI. Same analogy applies for CRI AoC done by FIE examiner who is holder of FI, but not CRI. So no worries and go on.p
Thats why you dont find how long should be TRI AoC, but you can clearly find that SFI AoC should last at least 3 hours.

imagine - you as SFE do the AoC to SFI. But just b gaining 15 legs on type his SFI can be turned into TRI without any checkride…

SFI = TRI restricted to FSTD.

BizJetJock
29th Jul 2021, 07:44
I agree with your logic, but sadly not all NAAs do. Some are a lot more literal in their interpretation of the rules, so an SFE cannot even do a sim-only AoC for a TRI. Common sense is irrelevant!

deltahotel
29th Jul 2021, 09:39
Again, can’t fault your logic, which is why I was so surprised when I did the cut and paste from sub part K - there doesn’t seem much room for manoeuvre there.

milan.pilot
29th Jul 2021, 15:43
I agree with your logic, but sadly not all NAAs do. Some are a lot more literal in their interpretation of the rules, so an SFE cannot even do a sim-only AoC for a TRI. Common sense is irrelevant!

can you name anyone except LBA?

BizJetJock
29th Jul 2021, 19:20
UK which is not EASA anymore. I suspect most of them if you asked them, but if you just go ahead and do it the paperwork gets filed and nobody notices...

As you said, if it is for initial issue, then they can do an SFI AoC then submit the paperwork for issue of a TRI.But it doesn't apply to revalidations. Stupid!

milan.pilot
29th Jul 2021, 19:43
well.. based on that strict analogy, even TRI would not be allowed to do SFI AoC. So lets take it easy :-) I know only about LBA which is not accepting it.
This issue has been addressed on my last Senior examiner seminar by FOI of EASA NAA.
We all have been assured, that SFE doing TRI AoC is fine (except if LBA is SOLI)

BizJetJock
30th Jul 2021, 13:58
TRE specifically can do an SFI AoC - it is written in FCL.1000.TRE.

milan.pilot
31st Jul 2021, 03:43
TRE specifically can do an SFI AoC - it is written in FCL.1000.TRE.
true, my bad. It is in FCL.1005.TRE literally like that. Well.. how about this one..
SFE does SFI AoC to license holder.
fills out and signs the papers for SFI.
After AoC even before endorsement of SFI, license holder submits the request to upgrade SFI to TRI iaw FCL.930.TRI(c).