Worth removing 'no applied Instruments' restriction?

[nick14]

I might have just found it in the FEH, to retain the privileges without the 10 hours and AoC must be taken.

I really should read before posting....

[Whopity]

Level Attitude

Could you provide a current reference for the above please.

AMC1 ORA.ATO.230(b) Training manual and operations manual Para D4
The sames as IEM No3 to JAR-FCL 1.055

[Level Attitude]

AMC1 ORA.ATO.230(b) Training manual and operations manual Para D4

Whopity,
Thank you for the reference, however I do not believe it is relevant.

ORA.ATO.230(b) Tells ATOs that they must ensure their Instructors are
'Up to Scratch', have a method of checking they remain so, and confirming
they teach a standardised course.

It says nothing about how to gain, or regain, Instructor Privileges
in the first place - that surely must be governed by Part-FCL - and
the question was:

What about those of us who already hold the Applied Instruments 'qualification' AND a current IR but for whatever reason have not instructed 10 hours for the IR (no reference to IMC under EASA) in the 12 months prior to revalidation?

[Level Attitude]

The reference you quote does indeed refer to conversion of existing qualifications
when the instructor converts his/her licence and ratings to Part-FCL.
The wording is far from clear.

Actually the wording is quite clear (even if we think it is non-sensical).

For 2) and 3) below they should have put "Previous Rating: FI(A) with privileges
to instruct for IMC / IR(A)". But they didn't so these conversion requirements apply.

1) Previous Rating: FI(A) No Applied IF
Part-FCL Rating: FI(A) without instrument instruction privileges
Conversion Requirements: Hold a valid FI(A) No Applied IF

2) Previous Rating: FI(A), IR(A)
Part-FCL Rating: FI(A) with the privilege to instruct for the IR(A)
Conversion Requirements: Hold a valid FI(A), IR(A)

3) Previous Rating: FI(A), IMC rating
Part-FCL Rating: FI(A) with the privilege to instruct for the IR(Restricted) – UK only
Conversion Requirements: Hold a valid FI(A) and a valid IMC rating prior to 8 April
2014; or a UK CPL(A)/ATPL(A) issued prior to 1 July 2000. The requirement of
Part-MED,MED.A.030(g) shall not apply to the IR(R)

[Bob Stinger]

FCL.915.IRI IRI – Prerequisites
An applicant for an IRI certificate shall:
(a) for an IRI(A):
(1) have completed at least 800 hours of flight time under IFR, of which at
least 400 hours shall be in aeroplanes; and
(2) in the case of applicants of an IRI(A) for multi-engine aeroplanes, meet the
requirements of paragraph FCL.915.CRI (a);

Does this mean its 800 as opposed to the 200 hrs being talked about on here?

[Whopity]

Its 800 hours to be a standalone IRI, and 200 hours if you are already a FI

FCL.905.FI FI — Privileges and conditions
(g) an IR in the appropriate aircraft category, provided that the FI has:
(1) at least 200 hours of flight time under IFR, of which up to 50 hours may be instrument ground time in an FFS, an FTD 2/3 or FNPT II;
(2) completed as a student pilot the IRI training course and has passed an assessment of competence for the IRI certificate; and
(3) in addition:
(i) for multi-engine aeroplanes, met the requirements for the issue of a CRI certificate;

[BEagle]

Level Attitude, you are quite incorrect.

Have you tried discussing the matter with the CAA?

To make it simple, if an FI is not currently qualified to instruct for the IMC rating / IR(R), they will have to wait until either:

1. They've achieved 200 hrs flight time under IFR and have completed the IRI course requirements; or
2. I've persuaded the CAA to re-assess the proposals put to them last year.

Bob Stinger, yes. If anyone really wants to be a standalone IRI, they will need to have achieved the hours figures you quote.

[172510]

From CAP 804: Flight time under Instrument Flight Rules (IFR)is "All flight time during which the aircraft is being operated under the Instrument Flight Rules."

What does it mean?
Under the hood with an instructor, you usually operate VFR. Does it count? I suppose so but it's not what the definition says.
You may elect to fly under IFR in VMC conditions, does it count? Does it count if you have an IMC rating, or should you have a full IR? Must you file a flight plan for the IFR time to count?
You may even fly under IFR rules in VMC condition without any instrument rating at all...

[Whopity]

You may even fly under IFR rules in VMC condition without any instrument rating at all...

That is still possible on a UK National licence but has never been legal on a JAA or EASA licence!

What does it mean?

It means what it says, flight in accordance with the Instrument Flight Rules so provided the flight was legal, any flight where you complied with the rules counts.
Assuming you flew under UK Rules: Rules 20 and 32 applied

Choice of VFR or IFR
20 (1) Subject to paragraph (2) an aircraft shall always be flown in accordance with the Visual
Flight Rules or the Instrument Flight Rules.

Instrument Flight Rules
32 (1) For flights within controlled airspace rules 33, 34, 35, 36 and 37 shall be the
Instrument Flight Rules.
(2) For flights outside controlled airspace rules 33 and 34 shall be the Instrument Flight
Rules.

If you held a JAA licence you should be aware of:

JAR–FCL 1.175 Circumstances in which
an IR(A) is required
(a) The holder of a pilot licence (A) shall
not act in any capacity as a pilot of an aeroplane
under Instrument Flight Rules (IFR), except as a
pilot undergoing skill testing or dual training,
unless the holder has an instrument rating
(IR(A)) appropriate to the category of aircraft
issued in accordance with JAR–FCL.
(b) In JAA Member States where national
legislation requires flight in accordance with IFR
under specified circumstances (e.g. at night),
the holder of a pilot licence may fly under IFR,
provided that pilot holds a qualification
appropriate to the circumstances, airspace and
flight conditions in which the flight is conducted.
National qualifications permitting pilots to fly in
accordance with IFR other than in VMC without
being the holder of a valid IR(A) shall be
restricted to use of the airspace of the State of
licence issue only.

IFR has nothing to do with Hoods or Weather!

[172510]

If I understand correctly your answer, for the 200 hours of flight time required:

- My 10 hours under the hood during my CPL training would only count if my instructor has a valid IR(A) or IMC rating, and the flights were executed under IFR rules. It's a captain's decision to fly under IFR if the conditions are met. Has my FI during my training logged the time while he was teaching me instrument flying under IFR? I doubt so. So the time under the hood probably does not count.

- The training for IMC rating probably counts, as the FI has probably logged the time as IFR flying. But if under VMC, the FI may elect to log under VFR, and in that case, the time would not count for the student.

- May an instructor log VFR navigation teaching (for PPL or CPL) under IFR? If above MSA, why not, is there any rule that forbids it? In that case, any FI would easily fly 200 hours under IFR, and the student could log IFR time as well.

[S-Works]

- May an instructor log VFR navigation teaching (for PPL or CPL) under IFR? If above MSA, why not, is there any rule that forbids it? In that case, any FI would easily fly 200 hours under IFR, and the student could log IFR time as well.

Since when has the PPL or the CPL been an IFR course?

This is not really difficult to understand guys. You need 200hours under IFR. To fly under IFR you need an IR. Most IMC Instructors do not hold an IR so that time can't be counted. The PPL and the CPL are VFR courses so I challenge you to explain to the CAA why you were conducting them under IFR.

You are talking about hours counting towards a qualification that allows you to teach others to fly under IFR in IMC conditions. In order to teach others you have to have the experience yourself in order to pass it on. Blagging IFR in VFR conditions does not exactly bring much experience to the table does it?

I am one of the rare people that Whoppity refers to that did the IRI(A) as a standalone rating when you needed 800hrs IFR or 200hrs sole reference to Instruments. It was not difficult to get the time over a couple of years and I think that I brought a lot of real IFR experience to my students that they benefited from.

As an FE its is easy to tell the IMC candidates that were taught by Instructors with real IFR flying experience...... Perhaps a bit of food for thought?

[BEagle]

Most IMC instructors do not hold an IR so that time can't be counted.

Untrue. As an IMC instructor, you do not need to hold an IR.

As an FE, I found it easy to tell which applicants had been trained by instructors with sound instrument flying skills and teaching ability, rather than by those who liked flying in straight lines playing airliners, with the occasional ILS now and again...

[S-Works]

Untrue. As an IMC instructor, you do not need to hold an IR.

I did not say that they did. Not sure how much IMC teaching I have done under an IFR flight plan though?

As an FE, I found it easy to tell which applicants had been trained by instructors with sound instrument flying skills and teaching ability, rather than by those who liked flying in straight lines playing airliners, with the occasional ILS now and again...

If that was a pop at my response then I think you will find that we are violently agreeing. My point was that trying to blag IFR time teaching PPL and CPL courses does not give real IFR experience.

[172510]

My point is that common sense would be that training under the hood should count towards the requirement, but that the rule does not say so. That's why I think it needs clarification.

[BEagle]

Not sure how much IMC teaching I have done under an IFR flight plan though?

What difference does a flight plan make? I've flown thousands of IMC hours without any such thing.

All IMC flight requires the aircraft to be flown under IFR; there seems to be a growing misconception that an IFR FPL is essential in order to comply with the Instrument Flight Rules. Which simply isn't true.

[172510]

In the UK, flying under IFR out of controlled airspace is a captain's decision, you don't have to tell anyone, you just decide you do, and provided you're above MSA and fly according to the quadrantal rule (rules 33 and 34), and have at least an IMC rating, it's legal. If the weather is fine, it's just like flying VFR, but you may legally log IFR time.

If you have an IMC rating, and fly above MSA according to the quadrantal rule don't forget to log IFR time even if the weather is fine

In some other countries, for instance France, you may not fly under IFR, even out of controlled airspace, without a flight plan.

[Level Attitude]

Untrue. As an IMC instructor, you do not need to hold an IR.

I did not say that they did

Bose, I think you did given you wrote:

To fly under IFR you need an IR. Most IMC Instructors do not hold an IR so that time can't be counted

Post 17Sept 12 an instrument qualification (IR or IMC/IR(R)) is required
to fly IFR. Prior to 17 Sept 12, provided they flew within their Licence
privileges plain PPLs could elect to fly IFR otside CAS (and indeed, prior to
June? 2012, it was mandatory to do so at night in theUK)

[Level Attitude]

If you have an IMC rating, and fly above MSA according to the quadrantal rule

What has the MSA got to do with the Quadrantal Rule?
(Transition Altitude perhaps?)

What has the Quadrantal Rule got to do with IFR flight?
(Semi-Circular Rule perhaps?)

[S-Works]

Post 17Sept 12 an instrument qualification (IR or IMC/IR(R)) is required
to fly IFR.

Fair comment.

However I still don't believe that teaching VFR courses and claiming to be IFR in order to fudge the numbers is legitimate whatever Beagle may think.

The requirements are there to ensure that experienced IFR pilots (read that as Instructors experienced in IFR operations in IMC including tracking and approaches) are eligible to teach for Instrument qualifications.

[Level Attitude]

My point is that common sense would be that training under the hood should count towards the requirement, but that the rule does not say so. That's why I think it needs clarification.

The rule is, and has always been, 200 hours IFR.

However, prior to 17 Sept 2012, the CAA agreed with your "common sense"
and gave a dispensation that "1 hour IF" would count as "4 hours IFR"

This dispensation ended on 17 Sept as EASA do not allow it.

The rules do not need clarification.
You may wish the rules were different, and want them changed, but
that is a very different issue...................