CRI(ME) Requirement for ME IR Instruction

[Timothy]

As many will know, an oversight was made by EASA, reflected in CAP804, whereby for an IRI to teach on ME aircraft he needed to meet the prerequisites of a CRI(ME), but didn't actually have to hold one.

This oversight has been amended, and the new wording is as follows:

38) In point (a) of FCL.915.IRI, paragraph (2) is replaced by the following:

(2) in the case of applicants of an IRI(A) for multi-engine aeroplanes, meet the requirements of paragraphs FCL.915.CRI(a), FCL.930.CRI and FCL.935;

So now it is clear that an IRI applicant must have a CRI(ME) to teach IR on ME.

However, I qualified as an IRI in the period when a CRI(ME) was not required and I do not have one.

I believe from the above that my rights to teach on ME are grandfathered and that I do not have to go and do a CRI(ME). Is that what others would agree? Should I get a definitive policy statement from the CAA? In which case who should I write to?

(I do not need a lecture on the good sense of having the CRI(ME). I have done the training electively with an independent, highly qualified instructor. This is only about legality and privileges, not wisdom.)

[S-Works]

Timothy, are you trying to circumvent the policy statement you were already given from the Head of Policy clearly stating that Grandfather rights did not apply and you needed to do a minimum of a CRI on the class that you wish to teach on?

This means that if you want to teach on SE and ME you must hold a CRI for both classes or an FI which includes ME privileges.

But if you want to write to the man who makes the policy again you have the address.

If you are going down the route of soliciting opinions you should probably post the whole story including the policy statement issued to you?

[Timothy]

The eMail from ***** said:

To elaborate further on my reply, this is what I have been told. The law will change between April and July next year to mean that the privileges of an IRI certificate used on SEP or MEP are only valid if the IRI holder also holds an instructor certificate that entitles him/her to give instruction for the Class rating. You can continue to instruct for ME IR privileges now (without holding class rating instructing privileges), but this is an error which is being corrected because it is agreed by both regulators and industry that it is a safety risk. The corrective change to the rule has been voted through by the EASA Committee and will come into force. Therefore IRI certificate holders who intend to teach for ME IR privileges should plan to obtain the relevant ME instructor rating as soon as is practicable - and it is strongly recommended that they do not deliver ME IR training until they do. They will not be able to continue into the future unless they do.

But he says "this is what I have been told" whereas the wording is different.

Maybe best if I just write back to ****, but I was just wondering if there was any knowledge or previous experience of this question being asked on here.

I am not trying to circumvent anything, and do wonder why you are so aggressive on this subject. It is as if you have a personal crusade to fight to get me and others to spend thousands of pounds. Why do you have a hat in the ring?

[Whopity]

I qualified as an IRI in the period when a CRI(ME) was not required and I do not have one.

It was a JAR-FCL requirement from July 1999! I doubt that you would be grandfathered on anything obtained prior to that especially as the IRI and CRI were not even invented then.

[Timothy]

I gained the qualification under EASA at the time when CAP804 did not make CRI(ME) a prerequisite, a position which still stands, incidentally.

Thus I have the qualification today to teach on ME. The new CAP804 only applies more stringent restrictions on applicants for IRIs and does not speak to qualifications of existing holders, so it would seem that there is no change.

[Whopity]

CAP804 has no legal status so if it was not an EASA requirement then it would seem there is little they can do retrospectively!

[S-Works]

I am not trying to circumvent anything, and do wonder why you are so aggressive on this subject. It is as if you have a personal crusade to fight to get me and others to spend thousands of pounds. Why do you have a hat in the ring?

I am not being aggressive at all, you know me well enough to not make that accusation. i also have no hat in the ring. When we asked for a policy statement, what came back was not ambiguous to me in any form and was what I had always believed from reading Part FCL. As Whoppity says CAP804 is a guide not the law.

You gained your rating under EASA and as such there is no grandfather rights. You have been told all your teaching is valid and that you now have to gain a minimum of a CRI rating on the class you wish to teach.

Even a man of your experience has something to learn and the CRI will give you the fundamentals of teaching for the Class rather than the IRI that concentrates only on the IR aspects.

Believe me when I tell you that I have been teaching and examining multi engine long enough that it will be worth it to you when a student does something stupid. it will also allow you to do the asymmetric work that is required if you do a CRI(ME).

[Timothy]

I made the point earlier that I have done the training electively, so that is not the matter under discussion.

I have no wish to teach for the ME Class Rating, only to be valid on IR ME, so formally going through a CRI(ME) course and test would be wasteful and time consuming.

Anyway, I have written to ****, I'll see what he says.

[S-Works]

I made the point earlier that I have done the training electively, so that is not the matter under discussion.

Clearly it is. If you have done the training then get it signed off and the problem is then resolved.

[Timothy]

No. To do the full CRI(ME) course at an ATO is a week out of my life, involves either renting an aircraft or getting my aircraft on the ATO books (a big paperwork exercise in its own right), doing ground training, particularly in briefing for things I have no desire to teach, and a Skills Test with a CAA examiner.

Total, including travel and hotel bills, about £4000 plus whatever is the opportunity cost of being away for a week, maybe another £3000.

Instead, I have been to an independent instructor (who is himself a CAA examiner and one of the most experienced people around) and he has taught me, on my own aircraft, what I need to know specifically for IR training on ME types. Total cost, maybe £700.

You can see the difference and why it is worth pushing back if there is no legal requirement?

[Charlie Foxtrot India]

Timothy, please do not publish private messages and emails or "out" people here.

[ifitaintboeing]

The wording of IRI in Part-FCL was an oversight which is being corrected. Under JAR-FCL the requirement was that you had to hold a current CRI/ME and IRI to teach for the MEP-IR. A stand alone IRI could only teach single-engine unless they also hold/held a CRI/ME or equivalent (FI with MEP privileges).

As such, there are no grandfather privileges since it was previously not permitted (under JAR-FCL or UK legislation). I understand that the privilege of the IRI is shortly to be amended to correct an error in EASA legislation returning it to the original intent. Once the wording is corrected, your IRI privileges will be reduced to that which they were originally intended until you have completed the CRI/ME course.

ifitaint...

[Whopity]

(2) in the case of applicants of an IRI(A) for multi-engine aeroplanes, meet the requirements of paragraphs FCL.915.CRI(a), FCL.930.CRI and FCL.935;

There is no IRA for multi-engine aeroplanes defined in the document! The IRI is not Class or Type specific.

FCL.905.IRI IRI — Privileges and conditions
(a) The privileges of an IRI are to instruct for the issue, revalidation and renewal of an IR on the appropriate aircraft category.

Therefore all it need say is what it said in JAR-FCL

(b) the issue of an IR(A) multi-engine
aeroplanes, provided that the instructor meets
the requirements of JAR-FCL 1.380(a).

The bit that was missed out.
As Part FCL says you need to be both an IRI and a CRI (ME) then that is what you require. As the training can only be conducted at an ATO they will check that you meet this requirement, elective training is not worth anything.
Have you already been conducting training at an ATO? If so, what does their Ops Manual say? If not, you could hardly claim grandfather rights!

[BEagle]

ifitaintboeing wrote:

The wording of IRI in Part-FCL was an oversight which is being corrected. Under JAR-FCL the requirement was that you had to hold a current CRI/ME and IRI to teach for the MEP-IR. A stand alone IRI could only teach single-engine unless they also hold/held a CRI/ME or equivalent (FI with MEP privileges).

However, Timothy's e-mail from ***** stated:

The law will change between April and July next year to mean that the privileges of an IRI certificate used on SEP or MEP are only valid if the IRI holder also holds an instructor certificate that entitles him/her to give instruction for the Class rating.

The implication in the e-mail being that the CRI requirement will also apply to IRIs conducting training on SEP aeroplanes. I trust that this is a CAA error and that IRI privileges will, in fact, be as stated by ifitaintboeing, restoring the situation which existed under JAR-FCL?

I'm not sure to what 'elective training' refers in this context; the ATO course requirement and Assessment of Competence requirements are quite clear to me.

Given that Timothy obtained his IRI(A) certificate in all good faith, I would hope that the CAA will grant maximum accreditation of elements already completed for the IRI(A) course towards the CRI(ME) certificate, such as the 35 hours of ground training and will require only those airborne elements of the CRI(ME) course which were not already completed during the IRI(A) course.

Whopity, as I'm sure you know (but others may not), a standalone IRI may conduct IMCR/IR(R) training outside an ATO provided that 'a syllabus recognised by the Civil Aviation Authority' is followed.

[Timothy]

As I said before, that opinion was written before the changes to wording were agreed, and I would say that those changes do not support what was written.

So we shouldn't get too worried about the opinion in the meantime. I have written for further clarification, which, I am sure, will be based on the regulations as they are actually agreed.

[S-Works]

Your issue will be around being able to teach towards an IR without holding a CRI as it will be the ops manual that governs the qualifications required. Our ops manual lists the qualification that must be held on order to teach for each of the courses that we offer.

This was included at the request of the CAS when I did the EASA compliant manuals and was the reason that the whole discussion with Timothy kicked off. My ops manuals requires an IRI to hold a minimum of a CRI and according to my flight ops inspector that all the ATOs will have to observe the new regulation.

This means that even if you win your battle and get some sort of grandfather right you will only be able to teach towards the IMC if that is acceptable to the CAA.

[Timothy]

All of the IMCR/IR(R), 30 out of the 40 hours required for a CBM IR and 5 of the 15 for the EIR can be taught independently of an ATO.

[BEagle]

Timothy wrote:

All of the IMCR/IR(R), 30 out of the 40 hours required for a CBM IR and 5 of the 15 for the EIR can be taught independently of an ATO.

While that it is true of the IMCR/IR(R) course, the only requirement being that 'a course recognised by the Authority' is followed, the AMC and GM for the EIR and C-bM IR has yet to be released. But if this follows the Draft Opinion, there will be a formal requirement for the EIR and C-bM IR courses to be approved, in common with all other courses for Part-FCL licences, ratings and certificates, even though freelance instructors may teach part of these courses.

As they will have to pay the CAA for course approval, it will be interesting to note how ATOs propose to manage the use of 'freelance' instructors for part of their courses, rather than using their own IRIs.

bose-x, does your ATO intend to provide EIR and C-bM IR courses and to accept that part of the training may be conducted by freelance IRIs?

[S-Works]

We will be offering the EIR and CBM in due course.

It is not planned for us to use any freelance IRIs. We have our own guys on staff who have to earn a living. They do this from our approvals which cost a huge amount of money to maintain and I can't see the company allowing a freelancer to gain the benefit of that time and expense while the internal guys sit idle.

Whilst the concept of a freelancer teaching for these ratings is laudable, the requirement for the courses to be approved as beagle points out means they will still need to be completed in an ATO. The cost of gaining approvals is likely to kill the freelance Instructors pretty much dead I suspect.

[BEagle]

There's also the not inconsiderable issue of ensuring that 'freelance' instructors are standardised within the ATO's training manual SOPs to consider.....

I wonder from whence EASA considers that all the IREs required to support the C-bM IR and EIR will come?