Worth removing 'no applied Instruments' restriction?

[MalteseJambo]

Dear all,

I have recently been considering removing this restriction on my FI license and was looking for some advice. I am aware of the planned changes to the IMC rating and the fact that it will become an IR(R) under EASA up until 2014; what happens after that is anybodies guess.

Will it be worth removing the restriction? given the uncertainty about the future of the rating perhaps people may not be too keen to do it; on the other hand will it lead to a flurry of people wanting to get it done so that they can obtain the license before the cut off date in 2014?

Any advice would be much appreciated.

Regards,

[Level Attitude]

A couple of questions as you say your location is Malta:

Is the UK CAA the Competent Authority for Malta?

Both IMC and IR(R) can (currently) only be attached to UK issued Licences,
and their Privileges are restricted to UK Airspace - would you have any
students?

If you have an IR yourself and have, or are likely to get, 200 hours
IFR Flight Time then you are entitled to train for the IR.

As EASA refuse to have any instrument qualification which is not
called "IR" then teaching for the:
"IR (Restricted)" or proposed "En-Route IR" would (should) keep your
privileges valid.

Whether it is worth removing your "No Applied Instrument" restriction
now is a question only you can answer but consider:
It is possible now. Will it be possible in the future (without further
requirements being thought up)

[Whopity]

Is the UK CAA the Competent Authority for Malta?

No it's the CAD Malta.

If you meet the qualification requirements to add IR instructional privileges to your FI rating then I would have thought it would be the obvious choice as there will soon be a severe shortage of FIs qualified to teach instrument flying. If you are not qualified then you are one of those caught in the trap.

[MalteseJambo]

Re. Level attitude; Appologies! Im now in the UK, instructing in the UK with a CAA(EASA) license - forgot to update my profile.

My only intention at the monent is to remove the restriction to teach IMC ratings; therefore my understanding is that i only require 10 hours of Instrument time (also have my instrument rating) is that Correct?

Regards

[Whopity]

You have left it too late see AIC W 109/2012 the rules changed and you now need 200 hours under IFR and an IR.

[Level Attitude]

AIC W 109/2012
Interesting! I hadn't seen this before. Thank you Whopity

It does however only explain that "1xIF = 4xIFR" will no longer apply
for the gaining of full IRI Privileges under Part-FCL.

MalteseJambo:
You have said you have an EASA Licence - In which case I would
assume you are completely governed by Part-FCL and would need to
comply fully with their requirements for full IRI privileges.

If you have a JAA (deemed to be EASA) Licence you could argue that you
could apply for IMC only teaching privileges based on the old UK requirements.

An email to the CAA asking the question might be in order.
[NB: They could reply that no one teaches for the IMC any more
(not strictly true ie revision instruction for existing holders) as
only IR(R)s are now issued]

You have not said what personal Instrument qualification you hold.

If you meet the requirements for IRI privileges it doesn't mean you
have to instruct for the IR. Just use it for teaching for the IMC/IR(R).
It's the same 5 hour course (though test might be different).

[Ex Oggie]

If you have a JAA (deemed to be EASA) Licence you could argue that you could apply for IMC only teaching privileges based on the old UK requirements.

It ain't going to happen! The IRI is an EASA qualification and EASA requirements have to be met.

It's the same 5 hour course (though test might be different).

An IRI test is an IRI test. Again, it has to meet the requirements. The course also consists of 10 hours technical training in addition to the 5 hours flight training.

[Level Attitude]

It ain't going to happen!

You may be correct - but for the 2 minutes it takes to email the
CAA and ask the question of them.....

The IRI is an EASA qualification and EASA requirements have to be met

True but, as you insisted on another thread, the IMC (and hence instructing for it) is a National Rating

NB: Has any FI who had IMC (but not IR) Instruction Privileges on their JAA
Licence lost those privileges on conversion to a Part-FCL Licence?

An IRI test is an IRI test. Again, it has to meet the requirements.

Your statement is completely true but:
An FI who does not meet IRI requirements, and only wished to teach
for the IMC, would be/would have been very unlikely to be asked to
demonstrate "Teaching planning and flying through CAS" as part of their
test to remove "No Applied IF" privileges.

[Whopity]

I am aware of an FI who completed the IRI Course prior to 17 Sep; the application was not submitted until after 17 Sept and the rating was refused on the grounds that the applicant did not meet the EASA requirement. So on that basis no chance!

[Rithalic]

I went though all of this last year, there were quite a few threads on it at the time.

Essentially my understanding is you have left it too late.

You now need to comply with the minimums required for the IRI.

Only the IRI seems to give privileges to new instructors Instruct for the IR and IMC Rating or IR/R in Easaspeak.

If you note on section 4 part P page 31 it does give the option:
Rating Previously issed under the ANO:
FI(A) IMC Rating

Part FCL Rating/Certificate:
FI(A) with the privilege to instruct for IR/R - UK Only.

Conversion Requirements:
Hold a Valid FI with a valid IMC rating PRIOR to 8 April 2014 or a UK CPL/ATPL issued prior to 1 July 2000


CAP804

http://www.caa.co.uk/docs/33/CAP804Jan2013.pdf

[2close]

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?

I assume that the Applied Instruments 'qualification' will also be revalidated but that the holder would not be able to teach for the IR only the IMC, which it is also assumed includes the IR(R).

How does one then requalify for instructing for the IR?

[Whopity]

To teach for the IR you would need undergo in house training at the ATO where you intend to teach for the IR as it has been for the past 13 years.

[Level Attitude]

Essentially my understanding is you have left it too late

Rithalic,
Thank you for providing the CAP804 references, but this is not what is written.

It says:

If you want this (when applying for your Part-FCL Licence):

Part FCL Rating/Certificate:
FI(A) with the privilege to instruct for IR/R - UK Only.

Then you need this on your previous Licence:

Conversion Requirements:
Hold a Valid FI with a valid IMC rating PRIOR to 8 April 2014 or a
UK CPL/ATPL issued prior to 1 July 2000

It does not even say you need to have done the course to remove
the "No Applied IF" restriction - it goes away automatically.

Daft - Perhaps
A mistake - Possibly

But current "plain" FIs who have an IMC rating (or IMC Licence privileges)
can now qualify to teach the IR(R) simply by converting to a
Part-FCL Licence.

[Level Attitude]

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?

Everything is an IR under EASA:

As EASA refuse to have any instrument qualification which is not
called "IR" then teaching for the:
"IR (Restricted)" or proposed "En-Route IR" would (should) keep your
(IRI) privileges valid.

[Level Attitude]

To teach for the IR you would need undergo in house training at the ATO where you intend to teach for the IR as it has been for the past 13 years.

Whopity,
Could you provide a current reference for the above please.
(13 years is a long time, but I no longer believe anything unless I have
seen it in writing that it applies in the UK post 17 September 2012)

[Rithalic]

Level Att.

If i'm mistaken then obviously my apologies. I'm not an expert and have no ties to the CAA and believe me have no warm feelings whatsoever about easa.

You do make an interesting point. However in order to teach the IMC prior to easa an fi would have to remove the no applied if restriction by doing the course, albeit with less hours (10 by sole reference to instruments).

Point to note it also says in that same section,

Rating previously issued: FI(A), IR(A)
Part FCL: FI(A) with the privilege to instruct for the IR(A)
Conversion Requirements: Hold a Valid FI(A), IR(A)

In order to allow ones privileges to carry over from JAR to EASA, you had to previously be entitled to teach the IR and or IMC via your FI rating and have a current IR or IMC rating.

This is further evidenced in the same table where it states the following:

Rating Previously Issued: FI(A) No Applied IF
Part FCL: FI(A) Without Instrument instruction Privileges
Conversion Requirement: Hold a Valid FI(A) No Applied IF

My understanding from this is that if you previously had the no applied if restriction you are now an easa instructor with no instrument instruction privileges. Just because you hold an ir/imc doesn't entitle you to teach it.

If you already had the privilege to instruct for the imc then you are now entitled to instruct for the IR/R.

As I said i could easily be wrong, this is simply my understanding of the text. The best people to speak to would be licencing at your friendly neighborhood authority.

[BEagle]

But current "plain" FIs who have an IMC rating (or IMC Licence privileges) can now qualify to teach the IR(R) simply by converting to a
Part-FCL Licence.

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.

Currently there is no reduction from the FCL.905.FI(g) requirements for IR instruction. Because EASA doesn't recognise any 'applied instrument' training for anything except the IR, for new FIs who wish to teach 'applied instrument' flying there is as yet no equivalent to the previous IMC rating instruction requirements for the IR(R).

AOPA proposed a solution to the CAA last year, based on the previous system but turned into EASA-speak; however, the CAA wasn't prepared to take it to EASA in case the big boys made them cry. Hence the only people who can instruct for the IMC rating or IR(R) are those who are already qualified to do so. We intend to revisit the situation once the outcome of current CAA / EASA discussions regarding continuance of the IR(R) is clear.

[MalteseJambo]

Thanks for all the advice guys; I had a feeling it would open a can of worms!

The fact that an instructor with an existing IMC is eligible to teach the IMC (with the required training) leads me to believe someone with an IR should also qualify to do so as well....Ive emailed the CAA to ask the question specifically.

Thanks again.

[S-Works]

The holder of an IR with either an IRI or the instrument restriction removed can teach for both the IMC and the IR.

[nick14]

I did hear that in order to teach for the IR the CAA required a certain number of hours instrument instruction time? Or is that just a rumour.

Also how do you retain the privilege to teach for the IR with out having te 10 hours instrument instruction time?