FIs signing Revalidation

[fireflybob]

Recently FIs can sign a Licence Revalidation (assuming 12 hours completed with one hour under instruction in the year before expiry) although the FI licence has to be endorsed to do so.

There seems to be a rumour on the ground that the FI can only sign the licence if they have also done the one hour dual also - is this correct?

Thanks for any help.

[Thatsthewaytodoit]

FI Signing Revalidations

IN - 2015/034 Promulgated this on 17th April 2015 s follows:

‘FCL.945 Obligations for instructors
Upon completion of the training flight for the revalidation of an
SEP or TMG class rating in accordance with FCL.740.A(b)(1)31
Regulation (EC) No. 1178/2011, amendment Regulations (EC) No.2015/445.
and only in the event of fulfilment of all the other revalidation
criteria required by FCL.740.A (b)(1) the instructor shall endorse the applicant’s licence with the new expiry date of the rating or certificate, if specifically authorised for that purpose by the competent authority responsible for the applicant’s licence'

Seems to me that the "word on the ground" is correct!

Hope this helps

TTWTDI

[fireflybob]

TTWTDI, many thanks - not got round to reading that IN yet!

[S-Works]

Correct, the FI may only sign the licence immediately after conducting the flight if all the other requirements have been met. They may not sign the revalidation of licence holders whom they have not conducted the flight for nor may they sign the licence at a later date.

That is still designated to examiners only according to the CAA.

[Duchess_Driver]

if specifically authorised for that purpose by the competent authority responsible for the applicant’s licence'

And that's what a lot of people I have spoke too seem to be missing as well. £53 for the privilege.

[dobbin1]

Upon completion of the training flight

is a bit vague. That wording would appear to allow a revalidation by the instructor at any time after the training flight is completed but before the rating expiry. It doesn't say that it has to happen on the same day.

Where did the "immediately" bit come from?

[BigEndBob]

Since when was the one hour dual with instructor a 'training flight'?
OK it might have been done towards some rating, but it just as well be a jolly, if not a missed opportunity to do a few things the recipient hasn't done for a while.
Also told at seminar that the hour doesn't have to be done in one flight.

[S-Works]

Where did the "immediately" bit come from?

From policy and standards after a query asking for explicit guidance as to what I was to allow my staff to do in terms of signing licences.

Apparently they intend to clarify the IN in due course.

This approval does not make an FI an Examiner, it is just meant to smooth the paperwork process.

[Captain Jock]

This all seems to be a right "guddle". In the introduction to IN 2015/034 it says that the amendment to the Aircrew Regulation has introduced a means to allow instructors to be specifically authorised to extend the validity of Single Engine Piston (SEP) and Touring Motor Glider (TMG) ratings when the holder complies with the requirements for "revalidation by experience".

Given that the "training flight" can take place at any time within the last 12 months prior to the expiry of the rating, and before the 12 hours flying are completed, the right of instructors to extend the validity of the rating, if the views being put forward about it only being authorised immediately after the "training flight" are indeed correct, is virtually worthless. Will the CAA refund my £53?

It will not be any easier for most pilots to have the validity of their rating extended because they are still going to have to find an Examiner to complete the paperwork rather than a much more readily available instructor. For everyone's sake the CAA must clarify the position quickly.

[BEagle]

The position is perfectly clear under FCL.945:

FCL.945 Obligations for instructors

Upon completion of the training flight for the revalidation of an SEP or TMG class rating in accordance with FCL.740.A (b)(1) and only in the event of fulfilment of all the other revalidation criteria required by FCL.740.A (b)(1) the instructor shall endorse the applicant's licence with the new expiry date of the rating or certificate, if specifically authorised for that purpose by the competent authority responsible for the applicant's licence.

[S-Works]

the right of instructors to extend the validity of the rating, if the views being put forward about it only being authorised immediately after the "training flight" are indeed correct, is virtually worthless. Will the CAA refund my £53?

It's not a right, it's a privilege......

[Captain Jock]

I acknowledge my poor choice of words; I was aware it was a privilege and not a right. Perhaps I should have read the IN more carefully and saved my money.

[Genghis the Engineer]

Originally Posted by BEagle

The position is perfectly clear under FCL.945:

Not disputing your citation or interpretation, but is there any good reason for this? It just reads to me like a restriction for the sake of having one.

G

[Level Attitude]

It's not a right, it's a privilege......

Unfortunately, the way it is written it is a 'duty' not a 'privilege':

FCL.945 Obligations for instructors
Upon completion of the training flight .... the instructor shall endorse the applicant's licence

It will not be any easier for most pilots to have the validity of their rating extended because they are still going to have to find an Examiner to complete the paperwork rather than a much more readily available instructor. For everyone's sake the CAA must clarify the position quickly.

From what I have read previously on PPRuNe there are plenty of pilots who never want to go anywhere near an Instructor or Examiner and have difficulty finding them when they want to Revalidate 'by Experience'. At least this change means they only have to find an Instructor.

Where did the "immediately" bit come from?

I think that is implied in the wording.
Say an aircraft group's rules said:
"After each flight the pilot shall ensure the aircraft is correctly tied down, the control locks are in place, the key is returned to the office and the paperwork is completed"
I don't think the group would be too happy if someone interpreted that as anytime in the next few days after the flight.

Since when was the one hour dual with instructor a 'training flight'?
OK it might have been done towards some rating, but it just as well be a jolly

Since Always by definition: The Instructor must be PIC and the student must be PUT (Pilot under Training).

Unlike a Test or Proficiency Check Pass, the Training cannot be for any Rating at all as it must take place in an SEP(A). If the content is so minimal that it ends up being a "Jolly" then the PUT has been 'short changed'; the Instructor should ascertain before flight what the student would like to achieve. I understand from previous Threads that EASA is considering suggesting/mandating the content.

Note: Although not a Test, if the Instructor deems the student's flying so poor that they require further Training they can refuse to sign the Log Book and therefore now, presumably, can also refuse to undertake the Revalidation action.

Probably not legalese enough, but my suggested wording would be:
'Provided all other requirements have been met, and the only experience requirement a candidate needs is one hour of dual instruction, then the Instructor who provides the one hour of instruction may also endorse the candidate's Licence provided they do so on the same day that the Instructional flight took place.'

[Mickey Kaye]

Well if this is the case its a shame and makes the regulations yet more complicated and will only result in yet more people flying illegally.

I thought the change would make things a lot better for the smaller out of the way airfields where getting hold of an examiner isn't easy.

I also can't see the logic why they didn't make the privileges exactly the same as that for examiners.

So when a licence holder who has meant the experience requirements and has alreaxy done the one hour dual goes to see a local FI for a signature he is told he can't do it. But if he then goes and does a further hour dual then the FI can sign it.

I think this is yet another regulatory failure.

People don't even know the difference between revaldatiom and renewal and this would now appear to be another layer of regulation that people won't understand.

Make the instructors privledges to revalidate by experience the same as examiners

[TheOddOne]

Make the instructors privledges to revalidate by experience the same as examiners

Quite. I might punt 53 quid on that, what we have now is more or less unusable, unless I tell our Club members to leave their reval flight until they've done 11 hours...

The other nonsense is that I sign the logbook of a LAPL pilot after we've done an hour's flight, as an instructor, no further action required.

TOO

Edited to say

I don't mean it's a nonsense that I sign the logbook, I mean it's a nonsense that I can complete the process for a LAPL holder, but not a PPL with SEP rating...

[nick14]

Some instructors have no clue on revalidation or renewal of their own qualifications let alone someone else's!

EASA are indeed proposing the content in the NPA that is under comment at present. Content will represent the content of the proficiency check from appendix 9 including a discussion on TEM.

[Genghis the Engineer]

Well somebody needs to try it out, and I am in three syndicates, only one of whom has a tame examiner to hand. In my experience, about 2/3 of biennials seem to be done towards the end of the year anyhow.

Here's the form if anybody wants a direct link. http://www.caa.co.uk/docs/33/SRG1133Issue12.pdf . The form itself is a bit of a headache, and hasn't been fully updated for the purpose as the explanatory notes don't actually tell you which bits of the form you have to fill out for the specific purpose (it does for various other purposes), so I just filled everything out that seemed faintly applicable - I'm sure that the number of my expired Transport Canada will be useful to CAA, despite it being in the last two forms I sent them as well.

I shall report back on whether it all works out, and what it says in the explanatory card that apparently I'll get sent at the same time.

G

[Level Attitude]

I don't mean it's a nonsense that I sign the logbook, I mean it's a nonsense that I can complete the process for a LAPL holder, but not a PPL with SEP rating...

There is no "process" for an LAPL Holder.
Carrying out an Instructional Flight with either an LAPL Holder or a PPL SEP Holder is old hat. They are the same - they are both Instructional Flights. So an Instructor may (should?) sign the Holder's Logbook.

Carrying out a Licensing Administrative Action - That is new for Instructors.

make the privileges exactly the same as that for examiners.

But Instructors are mere mortals, whereas Examiners have Magical Powers that enable them to ascertain immediately if a Dual Flight logged six months ago was indeed flown with the holder of a valid EASA Instructor Rating.

[S-Works]

But Instructors are mere mortals, whereas Examiners have Magical Powers that enable them to ascertain immediately if a Dual Flight logged six months ago was indeed flown with the holder of a valid EASA Instructor Rating.

Not really, it's just that we have demonstrated an understanding of our own privileges and Licencing regulations to a standardised level and the satisfaction of the authority. They trust us to show good judgement and integrity on their behalf.