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foxmoth
4th Sep 2021, 21:09
Something I have steered well clear of but another examiner had this - less than 25% if the hours supervised solo were not included but over 25% if included so could this examiner do the Skills test with the candidate or not?

Arrow Flyer
5th Sep 2021, 15:04
I don't think they can do it, covered in CAA IN 2016-003 and/or IN 2016-004.

It's in Section 6.2, which is too big to copy and paste verbatim here, but the important bit:

For the purpose of (a)(1), instruction includes any flight that relies upon the privileges of the instructor certificate, and so includes ‘progress checks’ completed during the course.

Supervised Solo requires exercise of the FI privileges so the hours count towards the 25%.

BEagle
5th Sep 2021, 23:51
Supervised Solo requires exercise of the FI privileges so the hours count towards the 25%.

Not so. See FCL.1005: Limitation of privileges in case of vested interests of Regulation (EU) 2019/1747
Examiners shall not conduct:
(a) skill tests or assessments of competence of applicants for the issue of a licence, rating or certificate to whom they have provided more than 25 % of the required flight instruction for the licence, rating or certificate for which the skill test or assessment of competence is being taken;

Which means for a PPL course, it's 25% of 25 hours, i.e. 6h 15 min, no matter how long the applicant takes to meet the Skill Test entry standard.

foxmoth
6th Sep 2021, 08:41
Which means for a PPL course, it's 25% of 25 hours, i.e. 6h 15 min, no matter how long the applicant takes to meet the Skill Test entry standard.

well I am sure that is even more restrictive than most people realise but it does not actually answer the question, if you are supervising a solo does that count towards the 25%?

sluggums
6th Sep 2021, 09:33
Hmm, spoke to an SE recently. They stated that it was 25% of the 45 hours.

Whopity
6th Sep 2021, 12:33
if you are supervising a solo does that count towards the 25%?
I really don't see how by any stretch of the imagination that supervised solo can be regarded as flight instruction.
Solo flight is when the student is the only person on board, so there cannot be an instructor who would meet this derfinition:
to whom they have provided more than 25 % of the required flight instruction
The 45 hours has already been broken into its constituent parts to determine 6.25 hours i.e. 25 hours dual instruction; 10 hours supervised solo and 10 hours any other flying.

milan.pilot
6th Sep 2021, 12:55
well I am sure that is even more restrictive than most people realise but it does not actually answer the question, if you are supervising a solo does that count towards the 25%?
supervised solo is not a flight instruction.
so supervised solo is excluded from 25%

BEagle
6th Sep 2021, 19:29
We discussed this at length at an EASA meeting and the agreed policy was as I have stated.

If a student needs 100 hrs dual before reaching the standard required before taking the PPL Skill Test, the FE who conducts the Skill Test may not have conducted more than 6:15 flight instruction for the applicant as it's only the 25% of the mandatory 25 hrs dual which is permitted.

Duchess_Driver
6th Sep 2021, 23:13
Out of interest, what mechanism is in place for your “decision” being ratified at the meeting and that interpretation then reaching each National Authority and then out to examiners. Surely this should “end up” as either an AMC or GM to Part FCL?

I expect there is a great difference between each CA checking and applying the regulation.

And, if you would humour me, what happens to the U.K. now we’re not a fee paying member of the club!

Fl1ingfrog
7th Sep 2021, 00:04
We discussed this at length at an EASA meeting and the agreed policy was as I have stated.

I have to agree with Duchess_Driver on this. Such conduct if the case, is unacceptable. The above, may be an expression of disagreement with the original working group decision, being made by discontents. Not unusual on committees but should be treated as nothing more.

" ......Examiners shall not conduct: (a) skill tests or assessments of competence of applicants for the issue of a licence, rating or certificate to whom they have provided more than 25 % of the required flight instruction for the licence, rating or certificate for which the skill test or assessment of competence is being taken; and........."

The above rule is appallingly constructed and can be read in the way one chooses: i.e. is the 25% a percentage only of the mandatory dual exercise minimums? But then, not all mandatory dual exercises have a minimum duration set against them. Can the examiner have flown, with the candidate, all that is required of a particular exercise, such as the complete requirement of stall/spin (10/11) awareness, but not exceed the maximum of 25% overall? The syllabus actually "requires" 45 hours (of which ten must be student solo). It is not correct in my view to separate the solo time from 'instruction'. The solo flight must be guided, authorised, observed and debriefed by the instructor and so is not independent of training. It is therefore arguable to claim that 25% of the whole course of 45 hours is permissible. Why not then 25% of the quoted 100 hours if this has been "required".

BigEndBob
7th Sep 2021, 20:59
If a student is paying training rate for a licence, then surely that is flight instruction, whether dual or solo.
I'm sure that is common practise so that the instructor gets paid for their responsibility to supervise solos.
Student cannot get licence without the solo element.
"required flight instruction" needs better defining, does it mean minimum 45 hours or possibly more to meet a standard to pass test..

foxmoth
10th Sep 2021, 12:02
There is certainly an argument that if a student is not up to test standard after 25 hrs dual and 10 solo then he requires more instruction so this then becomes part of the required instruction!

Whopity
10th Sep 2021, 15:27
If a student is paying training rate for a licence, then surely that is flight instruction Then how do you differentiate between ground instruction and flight instruction? Does the aeroplane have anything to do with it or is it just because payment is made?

Like most European rulings they were put together with little thought, we should be used to this by now.

What it means is down to what the NAA issuing the licence allows, even they are probably not capable of making a rational decision, its just rules, tick enough boxes and you win a prize at the end.
As it probably wasn't written in English originally, nobody can really tell what the original committee intended if indeed they did any more than rubber stamp the NPA proposal without giving it any great thought.

deefer dog
20th Sep 2021, 12:10
We discussed this at length at an EASA meeting and the agreed policy was as I have stated.


25% of the required flight instruction is crystal clear. It's the flight instruction required to meet the standard. Had the rule makers meant what you believe BEagle they would have stated 25% of the minimum required flight instruction. Quite why you bothered to discuss this at length amazes me, unless you were getting paid by the hour.

BEagle
21st Sep 2021, 09:23
The Commission Regulation (EU) 2015/445 FCL.1005 '25%' rule change was discussed at EASA's #5 FCL TAG/SSCC meeting at Köin in June 2015. I stated:
The word 'required' is ambiguous. Does this mean the mandatory flight instruction (e.g. 25 hours for the PPL) or the actual flight instruction the applicant needed ('required') to meet the standard to be ready for the Skill Test? For example, if he/she had needed 40 hours of dual flight instruction, would the '25%' figure mean 6.25 or 10 hours? We assume that it means 6.25, but this ambiguity should be resolved.

After discussions, the conclusion was:
Outcome: The participants agreed that the 25% rule should at this moment be based on the minimum hours established in the ATO course approval. However, this issue should be reviewed by the GA task on simplifying the balloon requirements to further clarify the intent. This task is already considering changing the 25% requirement to 50%.


The issue was subsequently reviewed, but no changes have been made. The UK CAA has also adopted the outcome policy stated above.

Whopity
21st Sep 2021, 09:42
Back ín the pre JAA days there were a couple of schools offering PPLs in 40 hours and IMC ratings in 15 hours; they seldom went more than a few minutes over the minimum time and quite often the Examiner was also the instructor. The lack of any independent assessor was a bad thing and the move to no instructiion by the Examiner was perhaps a step too far in the wrong direction. To arrive at a figure of 6.25 hours really was the result of a committee of niff naff and trivia. The overall purpose is simply to ensure that a candidate does not obtain a licence or rating with only the involvement of one person. On that basis, no more than 25% is quite an easy amount to comprehend by some people.