Independent instructor under EASA?
Independent instructor under EASA?
Greetings
As it seems that independent instructors will need to become registered as RFs before 17 September 2012 (see CAA IN-2012/112) in order to continue instructing once the UK adopts Part-FCL, will their careers be short-lived, i.e. just until 8 April 2015 when all RFs have to be re-registered as ATOs, given the ATO requirements will be too onerous and expensive for one-man-band outfits?
Or, will indpendent instructors still be permitted to carry on as RFs if instructing for licences and ratings for use Annex II aircraft only? Clearly they won't be permitted, as an RF, to teach EASA Part-FCL licences (which will be acceptable for use on Annex II aircraft), but will they instead be permitted to teach national licences such as the NPPL for Annex II aircraft pilots, or will these national licences become a thing of the past as well?
Any advice much appreciated.
As it seems that independent instructors will need to become registered as RFs before 17 September 2012 (see CAA IN-2012/112) in order to continue instructing once the UK adopts Part-FCL, will their careers be short-lived, i.e. just until 8 April 2015 when all RFs have to be re-registered as ATOs, given the ATO requirements will be too onerous and expensive for one-man-band outfits?
Or, will indpendent instructors still be permitted to carry on as RFs if instructing for licences and ratings for use Annex II aircraft only? Clearly they won't be permitted, as an RF, to teach EASA Part-FCL licences (which will be acceptable for use on Annex II aircraft), but will they instead be permitted to teach national licences such as the NPPL for Annex II aircraft pilots, or will these national licences become a thing of the past as well?
Any advice much appreciated.
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Please see http://www.caa.co.uk/docs/33/srg_lts...tructorsv2.pdf
Its worth noting that any instructors have just 17 days (excluding today) to get an application in place - the cut off date for new RF's is 17th August
Its worth noting that any instructors have just 17 days (excluding today) to get an application in place - the cut off date for new RF's is 17th August
The IN relates specifically to instruction for the issue or renewal of aircraft ratings for EASA Part-FCL licences.
According to CAP 804, training for the NPPL(A) SSEA shall be conducted at an "organisation acceptable to the CAA", training for the NPPL(A) SLMG at an "approved BGA site" and there are no specific organisational requirements for the NPPL(A) Microlight. In no case is an RF mentioned and so it is logical to assume that there will be no requirement for registration in order to provide training for the NPPL(A). But then, when was anything involving CAA policy logical?
According to CAP 804, training for the NPPL(A) SSEA shall be conducted at an "organisation acceptable to the CAA", training for the NPPL(A) SLMG at an "approved BGA site" and there are no specific organisational requirements for the NPPL(A) Microlight. In no case is an RF mentioned and so it is logical to assume that there will be no requirement for registration in order to provide training for the NPPL(A). But then, when was anything involving CAA policy logical?
EASA confirmed that there is no reason why a RF cannot continue, or indeed to apply for registration, to conduct training for purely national licences / ratings.
In response to the following question from the Netherlands:
The EASA response was:
CAP 804 Section 5 Part A Subpart 1 Page 3 states that, for the NPPL (SSEA):
Although quite what an 'Air Training Organisation' is, I don't know......
In response to the following question from the Netherlands:
Can RF remain RF and train for national licences only?
Yes, training for JAR-compliant PPL will be possible during the opt-out period, and training for national licences for Annex II aircraft also beyond.
The course shall be undertaken at an Air Training Organisation within the UK or Isle of Man...
Last edited by BEagle; 31st Jul 2012 at 14:46.
So long as it has not expired you can do it with an examiner directly however; if it has expired, you will have to go to an ATO for an assessment, training and then the test, so you could say at least one flight on top of the test as a minimum cost at an IR approved ATO.
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Yes; I knew that if you leave it for more than 12+3 months then you have to go to an FTO/ATO.
But during the 3-month period between 12 and 12+3m you ought to be able to do it with a freelance IRE - is that right?
One can also renew between 9m and 12m and still preserve the original expiry date, I believe.
But during the 3-month period between 12 and 12+3m you ought to be able to do it with a freelance IRE - is that right?
One can also renew between 9m and 12m and still preserve the original expiry date, I believe.
Last edited by peterh337; 4th Aug 2012 at 16:45.
According to AMC1 FCL.625(c) , if the rating has expired by less than three months, no refresher training is required but you still need a certificate issued by an ATO to get the rating renewed. However, the stated opinion of the UK CAA (subject to approval by EASA) is that, within that three month period, the renewal may be certified by an IRE without reference to the Authority.
If the rating has expired by more than three months, there is mandatory refresher training, in accordance with AMC1 FCL.625(c), and the rating has to be re-issued by the Authority, for which they will require a fee. In the absence of any approved alternative means of compliance, the requirement is for 1 training session if the rating has expired by less than 1 year and 3 training sessions if the rating has expired by more than 1 but less than 7 years. 'Training session' has not been defined and , therefore, need not necessarily include any flying.
If the rating has expired by more than 7 years, the applicant is required to undergo the full training course for the issue of the IR (as well as re-taking the theoretical knowledge examinations).
If the rating has expired by more than three months, there is mandatory refresher training, in accordance with AMC1 FCL.625(c), and the rating has to be re-issued by the Authority, for which they will require a fee. In the absence of any approved alternative means of compliance, the requirement is for 1 training session if the rating has expired by less than 1 year and 3 training sessions if the rating has expired by more than 1 but less than 7 years. 'Training session' has not been defined and , therefore, need not necessarily include any flying.
If the rating has expired by more than 7 years, the applicant is required to undergo the full training course for the issue of the IR (as well as re-taking the theoretical knowledge examinations).
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Registering if based Overseas
Not sure if anyone else is in my position. I have a CRI rating and have conducted revalidation flights in Malaysia with JAA PPLs who have the experience and require the 1 hour with an Instructor. I have a Malaysian AFI rating which permits me to instruct on 9M registered aircraft.
I am independent and the Registration fee is more than I charged in the whole of last year so economically it is a non-starter.
Any advice on whether there is a solution - or do I just give up offering revalidation flights ?
I am independent and the Registration fee is more than I charged in the whole of last year so economically it is a non-starter.
Any advice on whether there is a solution - or do I just give up offering revalidation flights ?
Revalidation flights (the hour with an instructor) are not a problem so you will continue to be able to do them. Renewal flights require an examiner and are outside the scope of a CRI rating anyway, so not an issue. You will have to do a test to revalidate your CRI in the future, at least every 6 years.
Last edited by Whopity; 5th Aug 2012 at 07:35.
