CRI allowed to offer SLMG/TMG conversion?
Thread Starter
Joined: Sep 2003
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From: South Norfolk, England
CRI allowed to offer SLMG/TMG conversion?
Hydothetical question.
As a PPL with TMG rating, could I gain a CRI and then offer conversion training to PPL SEP's? Also of course revalidation flights for SLMG and TMG, which I suppose would also cover SEP revalidation (cross credit)?
Further to that, if I had my own two seat CofA TMG could I do the flying in that? Do you then need to be a registered FBO or whatever it's called? or could you link to a flying school if you found one interested? I realise that without a CPL I couldn't charge for my time, but could I hire the aircraft out to those I've trained? What if I did have a CPL, could I charge for my time as a CRI or do you have to be a full FIR?
All just idea's basically sprouting from the difficulty I had finding somewhere local to validate my SLMG.
SS
As a PPL with TMG rating, could I gain a CRI and then offer conversion training to PPL SEP's? Also of course revalidation flights for SLMG and TMG, which I suppose would also cover SEP revalidation (cross credit)?
Further to that, if I had my own two seat CofA TMG could I do the flying in that? Do you then need to be a registered FBO or whatever it's called? or could you link to a flying school if you found one interested? I realise that without a CPL I couldn't charge for my time, but could I hire the aircraft out to those I've trained? What if I did have a CPL, could I charge for my time as a CRI or do you have to be a full FIR?
All just idea's basically sprouting from the difficulty I had finding somewhere local to validate my SLMG.
SS
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From: Gatwick
I have a CRI rating on my license, and I have a lot of time on the phone and writing emails to the CAA trying to work out what I can do and (more importantly) what I can't do with it. The long and short of it is that no-one is quite sure.
The list of things which a CRI is definitely allowed to do is pretty much:
As soon as you reach the point where the student holds no valid JAR (or ICAO) type/class ratings, all bets seem to be off. That would seem to exclude teaching PPL(A) holders one day beyond the end of the SEP validity period, pilots whose medical has lapsed, and also students who hold sub-ICAO licenses such as the NPPL(A), NPPL(M) and NPPL(SLMG). My understanding is that a JAR PPL(TMG) should be OK though since it is a full, ICAO recognised license when used with a JAR medical.
So far the CAA have been pondering my questions since October and haven't managed to give definitive answers. Until they do, I'm sticking to what's in the "definitely OK" list given above.
Interestingly, however, my CRI rating does not contain any clauses preventing me doing applied instrument training or aerobatics, as might appear on most freshly-minted FI(R) ratings. The renewal criteria are also a lot less onerous than those for an FI since I merely need to complete 10 hours (yes, ten) of instruction in the 12 months preceding the expiry date of my 3-year rating whereas a full FI must complete two out of a seminar, a flight test, and 100 hours (yes, one hundred) of instruction.
Can anyone spell mucking fuddle?
(Edited to correct my misunderstanding of the status of the TMG rating - since I don't fly them, I'd never looked before, and LASORS is not the easiest of bedtime reading material!)
The list of things which a CRI is definitely allowed to do is pretty much:
- club check rides provided that the student holds a valid and current SEP rating
- passenger currency rides (as a CRI, you're not a passenger) provided that the student holds a valid and current SEP rating
- the Biennial Flight With An Instructor provided that the student holds a valid and current SEP rating
- constant speed propellor, tail-wheel or other "complexity" differences training provided that the student holds a valid and current SEP rating (and you as the CRI have at least 10 hours PIC on that particular compexity)
As soon as you reach the point where the student holds no valid JAR (or ICAO) type/class ratings, all bets seem to be off. That would seem to exclude teaching PPL(A) holders one day beyond the end of the SEP validity period, pilots whose medical has lapsed, and also students who hold sub-ICAO licenses such as the NPPL(A), NPPL(M) and NPPL(SLMG). My understanding is that a JAR PPL(TMG) should be OK though since it is a full, ICAO recognised license when used with a JAR medical.
So far the CAA have been pondering my questions since October and haven't managed to give definitive answers. Until they do, I'm sticking to what's in the "definitely OK" list given above.
Interestingly, however, my CRI rating does not contain any clauses preventing me doing applied instrument training or aerobatics, as might appear on most freshly-minted FI(R) ratings. The renewal criteria are also a lot less onerous than those for an FI since I merely need to complete 10 hours (yes, ten) of instruction in the 12 months preceding the expiry date of my 3-year rating whereas a full FI must complete two out of a seminar, a flight test, and 100 hours (yes, one hundred) of instruction.
Can anyone spell mucking fuddle?
(Edited to correct my misunderstanding of the status of the TMG rating - since I don't fly them, I'd never looked before, and LASORS is not the easiest of bedtime reading material!)
Last edited by ModernDinosaur; 19th January 2008 at 00:36.
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From: UK
The privileges of a CRI are clearly written in JAR-FCL 1.375: to instruct licence holders for the issue of a type or class rating for single pilot aeroplanes.
The licence does not have to be valid to do this; therefore, you can do any of the things a FI does except give abinitio instruction to a non licence holder. If you only hold a PPL you cannot be remunerated for it.
The answer is Yes however in accordance with the latest ANO amendment
http://opsi.gov.uk/si/si2007/uksi_20073467_en_1
To convert a pilot to the SLMG he will need to pass a GSTwith an Examiner after you have finished the training, exactly as it used to be.
No but as this is a JAA rating; you would also have to hold a IRI rating in order to teach applied IF. The aerobatics is quite legal but then anyone can legally teach aerobatics as it is not for the issue of a licence or rating!
The licence does not have to be valid to do this; therefore, you can do any of the things a FI does except give abinitio instruction to a non licence holder. If you only hold a PPL you cannot be remunerated for it.
As a PPL with TMG rating, could I gain a CRI and then offer conversion training to PPL SEP's? Also of course revalidation flights for SLMG and TMG, which I suppose would also cover SEP revalidation (cross credit)?
http://opsi.gov.uk/si/si2007/uksi_20073467_en_1
To convert a pilot to the SLMG he will need to pass a GSTwith an Examiner after you have finished the training, exactly as it used to be.
my CRI rating does not contain any clauses preventing me doing applied instrument training or aerobatics, as might appear on most freshly-minted FI(R) ratings.
Thread Starter
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From: South Norfolk, England
The answer is Yes however in accordance with the latest ANO amendment
http://opsi.gov.uk/si/si2007/uksi_20073467_en_1
To convert a pilot to the SLMG he will need to pass a GSTwith an Examiner after you have finished the training, exactly as it used to be.
http://opsi.gov.uk/si/si2007/uksi_20073467_en_1
To convert a pilot to the SLMG he will need to pass a GSTwith an Examiner after you have finished the training, exactly as it used to be.
SS
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From: Quite near 'An aerodrome somewhere in England'
"To convert a pilot to the SLMG he will need to pass a GSTwith an Examiner after you have finished the training, exactly as it used to be."
Oh really? Please quote your specific reference.
Nothing of the sort was in the Consultation Response Document, neither was it in the Regulatory Impact Assessment.
NPPLs opened with SLMG Class Ratings only will obviously require a GST; those opened with a Microlight Class Rating to which the holder wishes to add a SLMG Class Rating must meet the requirements listed in NPPL/XC/REV 07 (which will be released to co-incide with both the ANO change and the AIC which is currently being drafted) - this also includes a SLMG GST.
However, for NPPL(SSEA) holders, addition of a SLMG Class Rating will not require a GST - unless someone has now included this without having consulted the NPPL P&SC.
Similarly, the addition of a SSEA Class Rating to an NPPL(SLMG) will not require a GST. But this is not an 'easy route to a JAR-FCL PPL(A)' as the specific requirements for that licence require defined dual and supervised solo time in aeroplanes conducted by a JAR-FCL FI(A).
Oh really? Please quote your specific reference.
Nothing of the sort was in the Consultation Response Document, neither was it in the Regulatory Impact Assessment.
NPPLs opened with SLMG Class Ratings only will obviously require a GST; those opened with a Microlight Class Rating to which the holder wishes to add a SLMG Class Rating must meet the requirements listed in NPPL/XC/REV 07 (which will be released to co-incide with both the ANO change and the AIC which is currently being drafted) - this also includes a SLMG GST.
However, for NPPL(SSEA) holders, addition of a SLMG Class Rating will not require a GST - unless someone has now included this without having consulted the NPPL P&SC.
Similarly, the addition of a SSEA Class Rating to an NPPL(SLMG) will not require a GST. But this is not an 'easy route to a JAR-FCL PPL(A)' as the specific requirements for that licence require defined dual and supervised solo time in aeroplanes conducted by a JAR-FCL FI(A).
Last edited by BEagle; 19th January 2008 at 08:23.
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From: Gatwick
Whoppity states:
My conversations and emails with the CAA indicate that this paragraph is not as clear as you might like for two reasons. First, it does not specify what TYPE of licence. TV license? NPPL? JAR license? The consensus thus far is that it means "JAR or other ICAO license". That rules out the sub-ICAO NPPL.
The second issue is more tricky. Is a license with no valid ratings still a license? Some of the people I've spoke with at the CAA seem to believe that as soon as the last rating expires on a license, the license itself ceases to be until a rating is re-applied. There are further questions as to whether this happens immediately, or after five years etc, and what happens when the SEP expires but the IMC is still valid.
Until the CAA make up their mind, clearly, on both of these issues, I for one will play safe with the people I train. I owe them that much professionalism.
As regards aerobatics, you're quite right that no formal license is required to teach aeros, however the CAA is very clear that a freshly-minted FI(R) may NOT teach aerobatics. No such restriction is written in my CRI.
As regards instrument training, an FI(R) rating again specifically excludes applied instrument (and night) training, but both restrictions can be lifted from the FI(R) rating without adding an IRI. However, no such restriction clause appears on my CRI rating.
The privileges of a CRI are clearly written in JAR-FCL 1.375: to instruct licence holders for the issue of a type or class rating for single pilot aeroplanes.
The second issue is more tricky. Is a license with no valid ratings still a license? Some of the people I've spoke with at the CAA seem to believe that as soon as the last rating expires on a license, the license itself ceases to be until a rating is re-applied. There are further questions as to whether this happens immediately, or after five years etc, and what happens when the SEP expires but the IMC is still valid.
Until the CAA make up their mind, clearly, on both of these issues, I for one will play safe with the people I train. I owe them that much professionalism.
As regards aerobatics, you're quite right that no formal license is required to teach aeros, however the CAA is very clear that a freshly-minted FI(R) may NOT teach aerobatics. No such restriction is written in my CRI.
As regards instrument training, an FI(R) rating again specifically excludes applied instrument (and night) training, but both restrictions can be lifted from the FI(R) rating without adding an IRI. However, no such restriction clause appears on my CRI rating.
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From: Quite near 'An aerodrome somewhere in England'
If you don't want to hear the answer, don't ask the question!
The CAA have never objected to CRI(SPA)s - such as 'PFA coaches' (or LAA-LAA coaches now) - conducting relevant NPPL conversion training for those who already hold a NPPL.
Hence there is an emergent NPPL route which uses Microlight instructors (who can be paid) for the NPPL(Microlight), then a CRI(SPA) (who cannot be paid without a CPL) to conduct SSEA conversion training......
The NPPL is issued by an ICAO member state. Don't stir things up unnecessarily please - it won't help anyone. And if you're that concerned, then become a JAR-FCL FI(A)......
You'll be asking the CAA to rule on the PIC/Pu/t issue for club checks next....
The CAA have never objected to CRI(SPA)s - such as 'PFA coaches' (or LAA-LAA coaches now) - conducting relevant NPPL conversion training for those who already hold a NPPL.
Hence there is an emergent NPPL route which uses Microlight instructors (who can be paid) for the NPPL(Microlight), then a CRI(SPA) (who cannot be paid without a CPL) to conduct SSEA conversion training......
The NPPL is issued by an ICAO member state. Don't stir things up unnecessarily please - it won't help anyone. And if you're that concerned, then become a JAR-FCL FI(A)......
You'll be asking the CAA to rule on the PIC/Pu/t issue for club checks next....
Thread Starter
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From: South Norfolk, England
Phew! I thought I'd said something stupid there somewhere.
What I'm trying to establish is whether long term (not enough spare cash for anything just yet). Is if it would be viable to buy a Superfalke, Gob109 or some such, and help cover it's costs by hiring it out to SLMG or TMG rated pilots. Unless you join a gliding club, or go to the one or two TMG schools in the country, there are few places in the South that offer either training or TMG hire. So, as I've always wanted to instruct but really don't want to spend £10K plus to jump through all the "OTT" hoops for a full FIR, the CRI seems a good way to go, and would allow me to do most of what I'd like to do. Of course all could change with EASA if they allow PPL's to instruct again. Getting the FIR would be far more attainable then to someone like me.
SS
What I'm trying to establish is whether long term (not enough spare cash for anything just yet). Is if it would be viable to buy a Superfalke, Gob109 or some such, and help cover it's costs by hiring it out to SLMG or TMG rated pilots. Unless you join a gliding club, or go to the one or two TMG schools in the country, there are few places in the South that offer either training or TMG hire. So, as I've always wanted to instruct but really don't want to spend £10K plus to jump through all the "OTT" hoops for a full FIR, the CRI seems a good way to go, and would allow me to do most of what I'd like to do. Of course all could change with EASA if they allow PPL's to instruct again. Getting the FIR would be far more attainable then to someone like me.
SS
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From: United Kingdom
A few misconceptions in ModernDinosaur's post require clarification.
There is no point looking in JAR-FCL for answers on non-JAA licences. JAR-FCL 1.005(a)(2) states, quite clearly "Whenever licences, ratings, authorisations, approvals or certificates are mentioned in JAR–FCL, these are meant to be licences, ratings, authorisations, approvals or certificates issued in accordance with JAR–FCL. In all other cases these documents are specified as e.g. ICAO or national licences." Thus, there is no lack of clarity - the only source of requirements relating to the NPPL is the ANO.
In regard to the validity of JAA licences, JAR-FCL 1.025(b)(1) states "The validity of the licence is determined by the validity of the ratings contained therein and the medical certificate" and so there is no question that a licence that does not include a valid type or class rating or does not include a valid medical certificate, is itself not valid. However, the privileges of a CRI make no mention of 'valid' in relation to the licence held and the CAA cannot, by their own admission, set requirements more stringent than those in JAR-FCL 1. Consequently, there is nothing to prevent a CRI giving instruction to the holder of an invalid licence.
There is less clarity regarding the situation when the licence becomes due for re-issue. JAR-FCL 1.025(c) states "The licence will be issued for a maximum period of 5 years."It could be inferred that, at the end of the 5 year period the licence cannot be re-issued unless it is first withdrawn, this happening automatically at the end of the 5 year period. Thus, if a pilot neglects to obtain a re-issue, it may be said that he no longer 'holds' the licence.
The CAA's position on aerobatic instruction is a nonsense. In law, any pilot, whether holding an instructor rating or not, may give instruction in aerobatics as it is not instruction leading to the issue of a licence or rating - such instruction is a privilege of the licence, not of the FI rating. Consequently, the 'No aerobatics' restriction attached to newly issued FI ratings is entirely worthless as the individual can, quite legally, give such instruction whilst choosing not to exercise the privileges of his FI rating and there is absolutely nothing the CAA can do about it. In fact, the CAA could be said to be acting illegally in seeking to remove a privilege previously held.
Applied instrument flying and night flying are not referred to in the privileges of the CRI because those privileges are restricted to instruction for a class or type rating and not for an instrument rating or night qualification. No instrument flying or night flying is included in the syllabus for the class or type rating - if instruction is required for revalidation/renewal of the instrument rating as well as the type rating, it may not be given by a CRI
There is no point looking in JAR-FCL for answers on non-JAA licences. JAR-FCL 1.005(a)(2) states, quite clearly "Whenever licences, ratings, authorisations, approvals or certificates are mentioned in JAR–FCL, these are meant to be licences, ratings, authorisations, approvals or certificates issued in accordance with JAR–FCL. In all other cases these documents are specified as e.g. ICAO or national licences." Thus, there is no lack of clarity - the only source of requirements relating to the NPPL is the ANO.
In regard to the validity of JAA licences, JAR-FCL 1.025(b)(1) states "The validity of the licence is determined by the validity of the ratings contained therein and the medical certificate" and so there is no question that a licence that does not include a valid type or class rating or does not include a valid medical certificate, is itself not valid. However, the privileges of a CRI make no mention of 'valid' in relation to the licence held and the CAA cannot, by their own admission, set requirements more stringent than those in JAR-FCL 1. Consequently, there is nothing to prevent a CRI giving instruction to the holder of an invalid licence.
There is less clarity regarding the situation when the licence becomes due for re-issue. JAR-FCL 1.025(c) states "The licence will be issued for a maximum period of 5 years."It could be inferred that, at the end of the 5 year period the licence cannot be re-issued unless it is first withdrawn, this happening automatically at the end of the 5 year period. Thus, if a pilot neglects to obtain a re-issue, it may be said that he no longer 'holds' the licence.
The CAA's position on aerobatic instruction is a nonsense. In law, any pilot, whether holding an instructor rating or not, may give instruction in aerobatics as it is not instruction leading to the issue of a licence or rating - such instruction is a privilege of the licence, not of the FI rating. Consequently, the 'No aerobatics' restriction attached to newly issued FI ratings is entirely worthless as the individual can, quite legally, give such instruction whilst choosing not to exercise the privileges of his FI rating and there is absolutely nothing the CAA can do about it. In fact, the CAA could be said to be acting illegally in seeking to remove a privilege previously held.
Applied instrument flying and night flying are not referred to in the privileges of the CRI because those privileges are restricted to instruction for a class or type rating and not for an instrument rating or night qualification. No instrument flying or night flying is included in the syllabus for the class or type rating - if instruction is required for revalidation/renewal of the instrument rating as well as the type rating, it may not be given by a CRI
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From: UK
Quite right however
this actually places a limitation on the holder of the rating and legally they cannot give aerobatic instruction whereas a person who does not have such a limitation can.
The reason you cannot hire SLMGs is because they predominantly operate on a Permit to Fly; to hire it out you will need to maintain the device to public transport standards; somewhat more costly.
The status of a licence that may have expired or whatever, is completely irrelevant; the point is that any person who has held a licence is not an ab initio student therefore, the extra safety precautions that are put into place by requiring a Flight Instructor to go through an AFI/FI(R) apprenticeship do not apply.
Consequently, the 'No aerobatics' restriction attached to newly issued FI ratings is entirely worthless as the individual can, quite legally
The reason you cannot hire SLMGs is because they predominantly operate on a Permit to Fly; to hire it out you will need to maintain the device to public transport standards; somewhat more costly.
The status of a licence that may have expired or whatever, is completely irrelevant; the point is that any person who has held a licence is not an ab initio student therefore, the extra safety precautions that are put into place by requiring a Flight Instructor to go through an AFI/FI(R) apprenticeship do not apply.
Last edited by Whopity; 19th January 2008 at 15:51.
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From: notts
Class Prejudice
The ANO actually saids;,
A Class Rating Instructor Rating shall entitle the holder to instruct LICENCE HOLDERS for the issue of a TYPE or CLASS Rating for single-pilot aeroplanes.
Now this section is poorly written I believe and worse, wide open to interpretaion.
To my understanding the CRI was created to allow a non-instructor to formally convert licence holders on to a type - some of which are a class on their own.
It was never intended that general FLYING instruction could be given but only instruction in the operation of a particular type or class for insertion into a licence if and when required. But the pilot undertaking the instruction must be ALREADY licenced.
Without a CPL no money/benefit or payment in kind for the instruction may be given.
s
The intention of the CRI explained to me by the CAA at the time the CRI was evolved was that commonsense could prevail. i.e a group of owners could appoint one member to do the CRI course and subsequently be the group checker and converter onto the aircraft. In some cases the conversion could be onto a unique type for which the possibilty of finding a qualified instructor with the knowledge and experience required could/would be rare- better then the non-instructor with the unique knowledge and experience to do it but only having undertaken a course in how the conduct of conversion training should be properly carried out.
However if the law is badly written it will be exploited and the best of luck to any who succeed.
A Class Rating Instructor Rating shall entitle the holder to instruct LICENCE HOLDERS for the issue of a TYPE or CLASS Rating for single-pilot aeroplanes.
Now this section is poorly written I believe and worse, wide open to interpretaion.
To my understanding the CRI was created to allow a non-instructor to formally convert licence holders on to a type - some of which are a class on their own.
It was never intended that general FLYING instruction could be given but only instruction in the operation of a particular type or class for insertion into a licence if and when required. But the pilot undertaking the instruction must be ALREADY licenced.
Without a CPL no money/benefit or payment in kind for the instruction may be given.
s
The intention of the CRI explained to me by the CAA at the time the CRI was evolved was that commonsense could prevail. i.e a group of owners could appoint one member to do the CRI course and subsequently be the group checker and converter onto the aircraft. In some cases the conversion could be onto a unique type for which the possibilty of finding a qualified instructor with the knowledge and experience required could/would be rare- better then the non-instructor with the unique knowledge and experience to do it but only having undertaken a course in how the conduct of conversion training should be properly carried out.
However if the law is badly written it will be exploited and the best of luck to any who succeed.
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From: East Sussex
HI SS, if you have trouble with your slmg or TMG renewal, drop me a PM and will sort you out, as a LAA PCS Coach(CRI and "R" Examiner) we have a CAA dispensation which allows a nominal charge to made for our time , provided you are part of the LAA PCS and the person you are training is a LAA member.
I'm just down the road at Lewes.
Will.
I'm just down the road at Lewes.
Will.
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From: United Kingdom
this actually places a limitation on the holder of the rating and legally they cannot give aerobatic instruction whereas a person who does not have such a limitation can.
There is nothing in the ANO that prevents the holder of a valid aeroplane licence from giving instruction in aerobatics, since it is not instruction leading to the issue of a licence or rating. If subjected to an appeal under Regulation 6, the CAA could be made to look extremely foolish in attempting to remove a privilege from an individual's licence on the sole grounds that he or she had gained an FI rating.
Thread Starter
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From: South Norfolk, England
Hi Will,
Thanks for the offer. Howver, it's not too much of an issue as my TMG can be renewed by a flight in an an SEP or SLMG. The problem was the initial issue, which in the end I did at Ringmer in their Falke. If I didn't have an old UK PPL A it would have been more awkward as I'd have had to have found a TMG rated instructor/examiner to do an LST. As it was, all I had to do was a one hour flight to validate my attached SLMG and then apply for a TMG.
BTW, you know me ... I'm Ivan Manley and fly a Slingsby Cadet motor glider .... single seat, so not easy to revalidate in it!
SS
Thanks for the offer. Howver, it's not too much of an issue as my TMG can be renewed by a flight in an an SEP or SLMG. The problem was the initial issue, which in the end I did at Ringmer in their Falke. If I didn't have an old UK PPL A it would have been more awkward as I'd have had to have found a TMG rated instructor/examiner to do an LST. As it was, all I had to do was a one hour flight to validate my attached SLMG and then apply for a TMG.
BTW, you know me ... I'm Ivan Manley and fly a Slingsby Cadet motor glider .... single seat, so not easy to revalidate in it!
SS
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From: UK
How is it logical to put a 'No aerobatics' restriction on an FI rating when the rating does not include the privilege in the first place?
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From: Quite near 'An aerodrome somewhere in England'
"we have a CAA dispensation which allows a nominal charge to made for our time , provided you are part of the LAA PCS and the person you are training is a LAA member."
Really? How can the CAA issue a dispensation for a non-CPL holder to receive remuneration for conducting JAR-FCL TMG flight instruction?
Really? How can the CAA issue a dispensation for a non-CPL holder to receive remuneration for conducting JAR-FCL TMG flight instruction?
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From: Down at the sharp pointy end, where all the weather is made.
And if you're that concerned, then become a JAR-FCL FI(A)......
You'll be asking the CAA to rule on the PIC/Pu/t issue for club checks next....
You'll be asking the CAA to rule on the PIC/Pu/t issue for club checks next....
Yes, I was, so I did. ( I went the CRI route, then did the FIC)
Yes, I really do wish that you would!!! And I'm not the only one!
Cheers,
TheOddOne
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From: heathrow
No, chum! Not at you. Your questions were sensible, but a lot of the answers can be found in LASORS.
If you are irritated by questions why be on PPrune.
People are obviously going to ask questions about topics that may be found written down somewhere, not everyone is born a know all.