Training from unlicenced aerodromes
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Training from unlicenced aerodromes
1) When a normally licenced aerodrome becomes unlicenced (for whatever reason - fire cover, runway condition etc), is it still the case that a PPL training flight must begin and end at a licenced aerodrome - requiring a ferry section to and from the licenced aerodrome?
I have heard it rumoured that training can now be logged by the student towards their licence / rating for the airborne time to/from the UN-licenced aerodrome.
Personally I haven't seen any official statement one way or the other and would be obliged if someone could point me to the current regulation.
2) Assuming the situation remains as per the former, under what rule is the ferry flight conducted? I assume it cannot be training since the departure airfield is unlicenced, and it cannot be private since the student is still paying for all the dual time, (i.e. the PIC Instructor is not paying an equal share as required under the rules for a private flight). Does this not make it illegal public transport??
Could one argue that the ENTIRE flight is training time - but during the ferry section only REVISION of previous exercises is carried out, so long as the Student only logs the time between licenced airfields towards his / her licence or rating?
3) In which case, can anyone clarify if the instructor logs ALL the time as PIC and INSTRUCTION time, (since the entire flight is a training flight), or does the instructor only log the training time as per the student?
Regards,
I have heard it rumoured that training can now be logged by the student towards their licence / rating for the airborne time to/from the UN-licenced aerodrome.
Personally I haven't seen any official statement one way or the other and would be obliged if someone could point me to the current regulation.
2) Assuming the situation remains as per the former, under what rule is the ferry flight conducted? I assume it cannot be training since the departure airfield is unlicenced, and it cannot be private since the student is still paying for all the dual time, (i.e. the PIC Instructor is not paying an equal share as required under the rules for a private flight). Does this not make it illegal public transport??
Could one argue that the ENTIRE flight is training time - but during the ferry section only REVISION of previous exercises is carried out, so long as the Student only logs the time between licenced airfields towards his / her licence or rating?
3) In which case, can anyone clarify if the instructor logs ALL the time as PIC and INSTRUCTION time, (since the entire flight is a training flight), or does the instructor only log the training time as per the student?
Regards,
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Training
Training for a licence as you say must begin and end at a licenced aerodrome. Remember if you are acting outside of an AOC you must be exploiting the exemption given to training within a club. One member training the other. A ferry flight therefore isn't part of that and cannot count as instruction.
As for the Instructor, like any other pilot the time is logged from the moment the aircraft moves with the intention to fly and ends when the aircraft comes to a halt following that flight. Chocks off to chocks on in other words. A 'flight', it couldn't be simpler.
Is the ferry part legal? Of course it isn't without an AOC. However if you don't like the answer then don't ask the question. We may, due to the nature of things now have a running debate about this angle and that but just the same however it is dressed up someone is paying for the ferrying portion. Aircraft and flight don't come cheap.
As for the Instructor, like any other pilot the time is logged from the moment the aircraft moves with the intention to fly and ends when the aircraft comes to a halt following that flight. Chocks off to chocks on in other words. A 'flight', it couldn't be simpler.
Is the ferry part legal? Of course it isn't without an AOC. However if you don't like the answer then don't ask the question. We may, due to the nature of things now have a running debate about this angle and that but just the same however it is dressed up someone is paying for the ferrying portion. Aircraft and flight don't come cheap.
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Originally Posted by Homeguard
Remember if you are acting outside of an AOC you must be exploiting the exemption given to training within a club. One member training the other. A ferry flight therefore isn't part of that and cannot count as instruction.
Would I be correct in thinking a registered training facility (for PPL) does not need to exploit this exemption in order to conduct training. i.e. the students / instructors do not need to be members of any "club". (I'm pretty sure we're not a club since plenty of Trial Lessons are "walk-ins").
I was more interested in the "licenced aerodrome" aspect. Not entirely comfortable with the idea of "if you don't like the answer then don't ask the question". Whilst I appreciate the commercial aspects that the flight must be paid for, should the flight be deemed to be "illegal public transport" in the "subsequent board of enquiry", then it would almost certainly be uninsured - with commercial consequences far more dire than I care to contemplate - for both the school and the individual instructor.
I take it, then, that any rumours to the effect that the training flight can be conducted from "wheels up" to "wheels down" at a normally licenced aerodrome which has become temporarily unlicenced, is basically b*ll*cks?
Regarding the instructor, I realise he can log PIC from chock to chock, but I was wondering if he can also log Instructor Time from chock to chock or only for the legitimate training time.
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Club Exemption
In the UK flying instruction is a commercial activity, 'Arial Work' which requires an AOC. Other countries such as France see it differently. The UK has deemed that if the Training takes place wholly within a club and the Instructor and the student are both members then you are exempt holding an AOC.
The term club in UK law, it seems, is a very loose term and not onerous to achieve. Something like ,' an association of two or more persons who declare themselves so'. How far it goes in terms of constitution is up to the members. With the joining of JAA the CAA required for any club that trains for a Pilots licence or rating was to register with them and to comply with certain minimum standards, which are not much. A lot more if you wish to conduct an 'approved course' such as MEP courses.
Remember the Instructor is required to be a member and also the student including 'Trial flights' to exploit the exemption.. Most clubs under its constitution automatically provides membership to its instructors. Students/pilots enrol as members. Trial Flight students normally 'sign in' as temporary members for the day at least and the charge is deemed to be included in the trial flight cost.
The pilot logs the flight 'chock to chock' and instruction from when it commences to when it ends, in most case the two will be the same. Not in the case of a 'ferry flight'.
When a licenced aerodrome is unable to meet its licencing standard then the licence is not valid until it does. Flights requiring a Licenced aerodrome cannot operate during that period.
The CAA, it would seem, show a high degree of tolerance and are not pro-active with regard to ferry flights. BUT, it would only need a party to complain and they will have no choice but to act. I do not know of any CAA proscecutions having taken place.
The term club in UK law, it seems, is a very loose term and not onerous to achieve. Something like ,' an association of two or more persons who declare themselves so'. How far it goes in terms of constitution is up to the members. With the joining of JAA the CAA required for any club that trains for a Pilots licence or rating was to register with them and to comply with certain minimum standards, which are not much. A lot more if you wish to conduct an 'approved course' such as MEP courses.
Remember the Instructor is required to be a member and also the student including 'Trial flights' to exploit the exemption.. Most clubs under its constitution automatically provides membership to its instructors. Students/pilots enrol as members. Trial Flight students normally 'sign in' as temporary members for the day at least and the charge is deemed to be included in the trial flight cost.
The pilot logs the flight 'chock to chock' and instruction from when it commences to when it ends, in most case the two will be the same. Not in the case of a 'ferry flight'.
When a licenced aerodrome is unable to meet its licencing standard then the licence is not valid until it does. Flights requiring a Licenced aerodrome cannot operate during that period.
The CAA, it would seem, show a high degree of tolerance and are not pro-active with regard to ferry flights. BUT, it would only need a party to complain and they will have no choice but to act. I do not know of any CAA proscecutions having taken place.
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The problems with interpretation of the law is it is just that. With no test cases to quote your are wholly left to the discretion of lawyers judges etc and we all know how they can disagree amongst themselves, that is one of the reasons we we have several levels of appeal in this country.
The reasons that instructional flying for ratings and licences must start and end at licensed airfield is because of the increased potential for accident, that is my deduction. However it would be my contention in any court that if the instructor was the sole handling pilot such a requirement although illegal could be overlooked in certain situations, again that is my opinion.
In regard to your ferry question any comment on here is purely speculative for the reasons given above. Take for instance a flight back to a licensed aerodrome where the fireman on duty goes sick and you land back illegally(you should have diverted of course) that is a much different scenario from when the intent before flight was to illegally conduct a training flight between two unlicensed airfields.
Much time of these forums is spent speculating about unenforceable laws. To put it in perspective it is still illegal in this country not to report to the lord of the manor for regular long bow training.
It is important to operate within the spirit of the law and apply common sense to why the law is in place.
I give you a classic example from many years ago when log books could be checked by the CAA while you waited.
Flt Lt Jones was ex RAF transport command(26 years) and had just been demobbed and had brought his log books to the CAA to have them checked for the issue of a CPL.
He waited a few hours and eventually the clerk came back and said. We have checked your log books and we can see no evidence of the required triangular cross country.
Ah but Jones said i have flown around the world 9 times.
Yes said the clerk but that is not a triangular cross country!
The reasons that instructional flying for ratings and licences must start and end at licensed airfield is because of the increased potential for accident, that is my deduction. However it would be my contention in any court that if the instructor was the sole handling pilot such a requirement although illegal could be overlooked in certain situations, again that is my opinion.
In regard to your ferry question any comment on here is purely speculative for the reasons given above. Take for instance a flight back to a licensed aerodrome where the fireman on duty goes sick and you land back illegally(you should have diverted of course) that is a much different scenario from when the intent before flight was to illegally conduct a training flight between two unlicensed airfields.
Much time of these forums is spent speculating about unenforceable laws. To put it in perspective it is still illegal in this country not to report to the lord of the manor for regular long bow training.
It is important to operate within the spirit of the law and apply common sense to why the law is in place.
I give you a classic example from many years ago when log books could be checked by the CAA while you waited.
Flt Lt Jones was ex RAF transport command(26 years) and had just been demobbed and had brought his log books to the CAA to have them checked for the issue of a CPL.
He waited a few hours and eventually the clerk came back and said. We have checked your log books and we can see no evidence of the required triangular cross country.
Ah but Jones said i have flown around the world 9 times.
Yes said the clerk but that is not a triangular cross country!
Some misconceptions here. Firstly, an AOC is not required for flight instruction, whether or not given within a club environment. An AOC is required only for public transport, not for aerial work.
Secondly, assuming that the flight is training or testing for the purpose of becoming qualified for the grant of a pilots licence or the inclusion of an aircraft rating, a night rating or a night qualification in a licence, the aircraft may not take off or land anywhere other than at a licensed aerodrome or a government aerodrome.
If a positioning flight is required from an unlicensed to a licensed aerodrome, it can, in law, only be a private flight and no valuable consideration can be given in relation to it.
Secondly, assuming that the flight is training or testing for the purpose of becoming qualified for the grant of a pilots licence or the inclusion of an aircraft rating, a night rating or a night qualification in a licence, the aircraft may not take off or land anywhere other than at a licensed aerodrome or a government aerodrome.
If a positioning flight is required from an unlicensed to a licensed aerodrome, it can, in law, only be a private flight and no valuable consideration can be given in relation to it.
From the ANO Schedule 8 Licence privileges:
And Article 126
(4) Subject to paragraph (5), he shall be entitled to fly as pilot in command of an aeroplane of a type or class specified in an instructor’s rating included in the licence on a flight for the purpose of aerial work which consists of:
(a) the giving of instruction in flying; or
(b) the conducting of flying tests for the purposes of this Order;
in either case in an aeroplane owned, or operated under arrangements entered into, by a flying club of which the person giving the instruction or conducting the test and the person receiving the instruction or undergoing the test are both members.
(a) the giving of instruction in flying; or
(b) the conducting of flying tests for the purposes of this Order;
in either case in an aeroplane owned, or operated under arrangements entered into, by a flying club of which the person giving the instruction or conducting the test and the person receiving the instruction or undergoing the test are both members.
Aerodromes - public transport of passengers and instruction in flying
126 (1) An aircraft to which this paragraph applies shall not take off or land at a place in the United Kingdom other than:
(a) an aerodrome licensed under this Order for the take-off and landing of such aircraft; or
(b) a Government aerodrome notified as available for the take-off and landing of such aircraft, or in respect of which the person in charge of the aerodrome has given his permission for the particular aircraft to take off or land as the case may be; and in accordance with any conditions subject to which the aerodrome may have been licensed or notified, or subject to which such permission may have been given.
126 (1) An aircraft to which this paragraph applies shall not take off or land at a place in the United Kingdom other than:
(a) an aerodrome licensed under this Order for the take-off and landing of such aircraft; or
(b) a Government aerodrome notified as available for the take-off and landing of such aircraft, or in respect of which the person in charge of the aerodrome has given his permission for the particular aircraft to take off or land as the case may be; and in accordance with any conditions subject to which the aerodrome may have been licensed or notified, or subject to which such permission may have been given.
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Secondly, assuming that the flight is training or testing for the purpose of becoming qualified for the grant of a pilots licence or the inclusion of an aircraft rating, a night rating or a night qualification in a licence, the aircraft may not take off or land anywhere other than at a licensed aerodrome or a government aerodrome.
But not an IMC rating because that is not an aircraft rating and is not ab initio training and is not specifically mentioned
Probably because the guy already has a PPL and the flight will normally be to a licensed airfield with a published instrument approach
But not an IMC rating because that is not an aircraft rating and is not ab initio training and is not specifically mentioned
Probably because the guy already has a PPL and the flight will normally be to a licensed airfield with a published instrument approach
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recently in the local press re Monewden Airfield:
http://www.eadt.co.uk/content/eadt/n...A37%3A32%3A940
I think they are/were positioning over to beccles (licensed) to begin lessons. I think there are other quite a few other places that offer similar - so the CAA can hardly pretend it's news to them.
http://www.eadt.co.uk/content/eadt/n...A37%3A32%3A940
I think they are/were positioning over to beccles (licensed) to begin lessons. I think there are other quite a few other places that offer similar - so the CAA can hardly pretend it's news to them.
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Are you saying that all the freight carriers i have flown for then didnt need an AOC after all?
No, I am saying that an AOC is not required for flight instruction, as homeguard suggested. An AOC is required for public transport, which is when valuable consideration is given or promised for the carriage of passengers or cargo in an aircraft. Try reading the ANO a little more carefully - Article 157(3)(a) might be a good place to start.
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to be or not to be.......?
If we were to simply accept the extract from the ANO Schedule 8 that has been extracted, then we would need to assume that Instruction for a licence may only take place within a 'flying club' and even then when both are members of the same club.
The inference is, if the extract was the whole story, that it is not possible to give instruction for the gaining of a Pilots Licence/Rating except when given from one member to another within the environment of a 'club', do we really believe that?
If I do not want to be a 'clubby person' (sic) and an Instructor doesn't either, does it mean that no training for a licence can take place unless we swallow hard and grit our teeth and join up. Or, is there another way and if so what and then what regulations do we have to comply with to carry out the business?
The inference is, if the extract was the whole story, that it is not possible to give instruction for the gaining of a Pilots Licence/Rating except when given from one member to another within the environment of a 'club', do we really believe that?
If I do not want to be a 'clubby person' (sic) and an Instructor doesn't either, does it mean that no training for a licence can take place unless we swallow hard and grit our teeth and join up. Or, is there another way and if so what and then what regulations do we have to comply with to carry out the business?
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No, I am saying that an AOC is not required for flight instruction, as homeguard suggested. An AOC is required for public transport, which is when valuable consideration is given or promised for the carriage of passengers or cargo in an aircraft. Try reading the ANO a little more carefully - Article 157(3)(a) might be a good place to start.
But getting back to Aerial Work, it is my understanding that if you and the student are not members of a club and you take them flying for the purposes of letting the student handle the controls it is public transport and therefore you need an AOC, Ops manual etc. Wasnt there the case involving the two seat Spitfire 9?
I suppose if it came to the crunch you would have to prove that you and the student were a member of the same club that had been set up for the purpose of giving flying instruction. I wouldnt imagine that the bench would accept that if it was all done verbally and you met in the car park that it was a club. I would imagine to operate as a club you would have to have in place what one would expect a club to have, membership forms, a clubhose etc. I have always understood that is why passengers are joined into the club(even though it is a school). Lots of grey areas, i think!
Getting back to our friend who has read the ANO
No, I am saying that an AOC is not required for flight instruction, as homeguard suggested. An AOC is required for public transport, which is when valuable consideration is given or promised for the carriage of passengers or cargo in an aircraft. Try reading the ANO a little more carefully - Article 157(3)(a) might be a good place to start.
Try understanding the ANO a little more carefully. ****, now I am beginning to sound like you!
Last edited by llanfairpg; 6th Dec 2006 at 01:52.
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Without either one of these documents being valid and approved (AOC & Ops Manual) i cannot legally give flight instruction to the candidate.
Try understanding the ANO a little more carefully. ****, now I am beginning to sound like you!--------------------------------------------------------------------------------
Sorry but for PPL training you are recommended to have such documentation but it is only a recommendation. If you are teaching aircraft ratings or CPL and above then you are a FTO (as opposed to a Registered facility) and then the documents become mandatory (and you have to pay CAA a fee to assess your organisation and to police it).
Try understanding the ANO a little more carefully. ****, now I am beginning to sound like you!--------------------------------------------------------------------------------
Sorry but for PPL training you are recommended to have such documentation but it is only a recommendation. If you are teaching aircraft ratings or CPL and above then you are a FTO (as opposed to a Registered facility) and then the documents become mandatory (and you have to pay CAA a fee to assess your organisation and to police it).
There is a certain amount of thread creep here. The original question involved a PPL training flight from a temporarily unlicensed airfield. The correct answer to that question is that a PPL training flight must not take off or land anywhere other than a licensed or government airfield.
If transit from the unlicensed airfield to the licensed airfield is required before starting or after finishing the PPL training (or any other training or testing for a licence or aircraft rating) it must be conducted as a private flight, which means that no valuable consideration may be given for it. (i.e. the student may not legally be charged for the flight time in transit).
Then the creep started - homeguard suggested that
Let's assume that we are still talking about training for a licence or aircraft rating. There is no requirement for an AOC to be held in order to conduct flight training, such a certificate is required only for public transport. There are plenty of organisations out there training for licences and aircraft ratings without holding an AOC. Similarly there are plenty of organisations providing training without being a 'club', the TRTOs for which I freelance, for example, or OAT, FTE and other major training organisations.
The goalposts then shifted even further when llanfairpg asked
I have to say that I wasn't too sure which bit of the quote he was referring to but he seemed to suggest that carrying freight was not aerial work. In any event, the AOC in that case was clearly required for the public transport aspects of the flight, the fact that training was taking place being totally irrelevant (as Whopity has pointed out elsewhere). Of course, llanfairpg's example is even less relevant since whatever training he was providing on his public transport flights was obviously not training for the issue of a licence or aircraft rating.
llanfairpg went on to state
If this were true then every training flight conducted by OAT, FTE, etc., which are not 'clubs' and do not hold AOCs, would be illegal public transport - I think not!
To summarise -
Flights for the purpose of training or testing for the issue of a licence or aircraft rating may not take off or land other than at an airfield that is licensed for the purpose or is a government airfield.
An AOC is not required in order to provide training or testing for a licence or aircraft rating.
Training for a licence or aircraft rating does not have to take place within a 'club'.
The confusion in the latter case may be related to the the privileges of an FI who holds only a PPL. The privileges of a PPL do not include aerial work except for glider towing, para dropping or flight instruction and testing "in an aeroplane owned, or operated under arrangements entered into, by a flying club of which the person giving the instruction or conducting the test and the person receiving the instruction or undergoing the test are both members" Note that it is the qualification of the FI that requires the club environment, not the flight instruction.
If transit from the unlicensed airfield to the licensed airfield is required before starting or after finishing the PPL training (or any other training or testing for a licence or aircraft rating) it must be conducted as a private flight, which means that no valuable consideration may be given for it. (i.e. the student may not legally be charged for the flight time in transit).
Then the creep started - homeguard suggested that
....if you are acting outside of an AOC you must be exploiting the exemption given to training within a club
The goalposts then shifted even further when llanfairpg asked
Are you saying that all the freight carriers i have flown for then didn't need an AOC after all?
llanfairpg went on to state
...it is my understanding that if you and the student are not members of a club and you take them flying for the purposes of letting the student handle the controls it is public transport and therefore you need an AOC
To summarise -
Flights for the purpose of training or testing for the issue of a licence or aircraft rating may not take off or land other than at an airfield that is licensed for the purpose or is a government airfield.
An AOC is not required in order to provide training or testing for a licence or aircraft rating.
Training for a licence or aircraft rating does not have to take place within a 'club'.
The confusion in the latter case may be related to the the privileges of an FI who holds only a PPL. The privileges of a PPL do not include aerial work except for glider towing, para dropping or flight instruction and testing "in an aeroplane owned, or operated under arrangements entered into, by a flying club of which the person giving the instruction or conducting the test and the person receiving the instruction or undergoing the test are both members" Note that it is the qualification of the FI that requires the club environment, not the flight instruction.
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Thats probably because the original question has been answered.
Ah but you see you said FLIGHT INSTRUCTION you didnt say training for the issue of a licence rating or aircraft rating, read your own post. Your still wrong anyway because i can still (and do) provide training for an aircraft rating, Eg A320,that is an aircraft rating, I am looking at mine in my licence now. This is where you can tie yourself up in knots if you do not really understand the legislation. Remember that most training captains in airlines have never ever completed a flying instructors rating. What you should have said is that where a new group Eg single engine to multi training is taking place only an FI with a valid multi engine instructional endorsement can carry this out. EG If you had an only SEP rating or a type rating on a single engine aircraft you could not be given a rating on a multi unless you were being trained by a FI with the multi engine training endorsement. However if you already had a multi rating or a twin engined aircraft type rating any authorised training captain can convert you onto say the Airbus even if you had only previously flown say a Seneca(we do it all the time) but I can not pop over to the airline over the road and do a rating for you. Why not, different AOC and ops manual, once I have been accepted by the CAA and read the new ops manual I then can do your type rating with the new company.
This is what i actually said
But getting back to Aerial Work, it is my understanding that if you and the student are not members of a club and you take them flying for the purposes of letting the student handle the controls it is public transport and therefore you need an AOC, Ops manual etc. Wasnt there the case involving the two seat Spitfire 9?[/quote]
You have got me confused here and i think i am also confusing you so perhaps the best thing to do is start again with a new thread. I will think of an example and see what everyone says
But getting back to Aerial Work, it is my understanding that if you and the student are not members of a club and you take them flying for the purposes of letting the student handle the controls it is public transport and therefore you need an AOC, Ops manual etc. Wasnt there the case involving the two seat Spitfire 9?[/quote]
To summarise -
An AOC is not required in order to provide training or testing for a licence or aircraft rating. WRONG i cannot give you flight instruction for an A320 rating unless the company has a valid AOC and a CAA approved Ops Manual.
Training for a licence or aircraft rating does not have to take place within a 'club'.
The confusion in the latter case may be related to the the privileges of an FI who holds only a PPL. The privileges of a PPL do not include aerial work except for glider towing, para dropping or flight instruction and testing "in an aeroplane owned, or operated under arrangements entered into, by a flying club of which the person giving the instruction or conducting the test and the person receiving the instruction or undergoing the test are both members" Note that it is the qualification of the FI that requires the club environment, not the flight instruction.
An AOC is not required in order to provide training or testing for a licence or aircraft rating. WRONG i cannot give you flight instruction for an A320 rating unless the company has a valid AOC and a CAA approved Ops Manual.
Training for a licence or aircraft rating does not have to take place within a 'club'.
The confusion in the latter case may be related to the the privileges of an FI who holds only a PPL. The privileges of a PPL do not include aerial work except for glider towing, para dropping or flight instruction and testing "in an aeroplane owned, or operated under arrangements entered into, by a flying club of which the person giving the instruction or conducting the test and the person receiving the instruction or undergoing the test are both members" Note that it is the qualification of the FI that requires the club environment, not the flight instruction.
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Guys
The original thread asked - "Can the student log the transit part of the flight ?"
Any definitive answers on that ? My suspicion is that they can't but if they can that would be great
The original thread asked - "Can the student log the transit part of the flight ?"
Any definitive answers on that ? My suspicion is that they can't but if they can that would be great
I would have thought that would have been rather obvious. You are not a pilot, you are not training from a licensed aerodrome so what pray is there left to log other than a passenger flight?
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Whopity
I would have thought that would have been rather obvious
If we always applied logic to the rules of aviation as laid down by our betters that would be fantastic, unfortunately many of our whacky and nonsensical rules have no shred of logic, reason or common sense attached
OK So how about you are a student, you are flying with an instructor who is legally PIC and the flight is a private transit flight so you are not being charged (allegedly), the instructor has permitted you to fly the leg under his supervision and under his ppl license so why not log dual in your logbook ?
I would have thought that would have been rather obvious
If we always applied logic to the rules of aviation as laid down by our betters that would be fantastic, unfortunately many of our whacky and nonsensical rules have no shred of logic, reason or common sense attached
OK So how about you are a student, you are flying with an instructor who is legally PIC and the flight is a private transit flight so you are not being charged (allegedly), the instructor has permitted you to fly the leg under his supervision and under his ppl license so why not log dual in your logbook ?
Last edited by unfazed; 7th Dec 2006 at 09:44. Reason: more thoughts
because you have to log the place of embarkation Art 35 and if its not licensed, you will not be able to claim that flight for licence issue.
You can bet your life the student will log the entire flight time and put the intermediate licensed aerodrome as the point of embarkation and disembarkation. Nobody will ever notice unless they look at the Tech Log! Now if there is an accident, it will attract attention and an insurance company may well try to opt out of paying, by claiming that part of the flight was illegal!
You can bet your life the student will log the entire flight time and put the intermediate licensed aerodrome as the point of embarkation and disembarkation. Nobody will ever notice unless they look at the Tech Log! Now if there is an accident, it will attract attention and an insurance company may well try to opt out of paying, by claiming that part of the flight was illegal!