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Minimum requirements

Old 25th Sep 2020, 08:56
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MJI
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Minimum requirements

Hi all,

I was hoping someone may be able to help me with a couple of queries relating to the minimum requirements query for an FI course. Iím planning to do this before doing a CPL/IR.

The two requirements I'm unsure about are-

1. have received at least 10 hours of instrument flight instruction on the appropriate aircraft category, of which not more than 5 hours may be instrument ground time in an FSTD;

Can the instrument appreciation hours I did as part of my PPL count towards this, or does it have to be specific IR training with an IR instructor?

2. completed at least 200 hours of flight time on aeroplanes or TMGs, of which 150 hours as PIC;

I donít have 200 hours SEP, but have a good few hundred hours instructing on TMGs as a VGS Instructor on the Grob 109b. I know I can use 30 of these towards by CPL, but can I use them the same in this instance?

Iíd really appreciate any advice from anyone with experience of either of these.
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Old 25th Sep 2020, 19:19
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You can't count any part of your PPL course towards the instrument training, but it could be training towards an IMC rating an IR or the BIFM module which would also count towards a future CPL and IR.
So long as you have a TMG Class rating I see no reason why your Vigilant time would not count towards the hours required.

Last edited by Whopity; 26th Sep 2020 at 10:35.
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Old 26th Sep 2020, 09:55
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MJI
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Thanks Whopity I thought that might be the case for the instrument side of things. Doing a BIFM and using it towards a CPL seems like the way to go then.

I donít have a TMG rating on my licence. Do you think that is a deal breaker with the hours? I could add one if needed.

Cheers again
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Old 26th Sep 2020, 18:29
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Originally Posted by Whopity View Post
You can't count any part of your PPL course towards the instrument training...
Why do you say this Whopity, the regulation doesn't appear to say or imply that the instrument training should be post-PPL only?
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Old 26th Sep 2020, 22:44
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Old rules die hard. Nationally it was not permitted to double count hours. The 10 hours referred to in the FI prerequisites is the same 10 hours that are included in the CPL and IR courses and which can be credited to either course. The hours from the PPL would not be credited to hours on another course, but as you say the regulation doesn't specifically prohibit it and the 10 hours need not be part of a course however; if you intend to go on to the CPL and or IR it might be an idea to obtain experience that can be credited to those requirements. In any event the ATO conducting the FI training will determine what is and isn't acceptable.
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Old 27th Sep 2020, 05:24
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You can’t be talking about more than an hour on the PPL surely. Why not just refresh to remove any doubt?
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Old 27th Sep 2020, 13:04
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MJI check with the ATO where you intend to do the FI. If you have a TMG rating then I don't see any reason to doubt the hours, but if you have never held one, someone could argue that they don't count.
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Old 28th Sep 2020, 17:53
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MJI
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Thanks Whopity . They're not sure either but are going to try and look into it. It's just a little frustrating that it doesn't seem straightforward to get a response from the CAA on it. I emailed them three months ago about something else and am still awaiting a response. I suspect a query about this would result in a similar response. I just don't have the budget to do the FI course and then have it bounced on application.
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Old 29th Sep 2020, 09:15
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The CAA is a regulator, their job is not to give guidance on the regulation, any more than a police station would give you guidance on the law. In the past they acted more like a consultant but those days are long gone and they no longer have appropriately qualified staff.
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Old 29th Sep 2020, 19:08
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Any comparison of the CAA with the police doesn't hold water. The police do not make rules and therefore nor do they need to explain them. The police do not examine people and organisations for their fitness to operate. The police do not grant and oversee approvals to operate or to educate and nor do the police issue licenses to anyone, a person or a body. The CAA have the power to withdraw or suspend approvals and licenses but the police do not have any such powers. The CAA may prosecute in a court of law but the police cannot.

There is every reason for the CAA to explain itself, it's rules, it's actions and decisions. They have a duty to educate in all of it's areas of responsibility because no one else can.
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Old 1st Oct 2020, 12:46
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The CAAs view:
Our main statutory functions are:
  • regulating civil aviation safety;
  • advising and assisting the Secretary of State on all civil aviation matters, including policy for the use of UK airspace so as to meet the needs of all users, having regard for national security, economic and environmental factors, while maintaining a high standard of safety;
  • the economic regulation of certain airports and of the provision of certain air traffic services;
  • the licensing of airlines, including assuring their financial fitness;
  • the licensing of air travel organisers;
  • enforcing general consumer protection law through Part 8 of the Enterprise Act and EU legislation, such as denied boarding compensation and persons with reduced mobility; and
  • the regulation of aviation security functions.
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Old 1st Oct 2020, 20:12
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You can see from the following what the law expects of the CAA and that they recognise this. Below is what they themselves say they should be doing. They are currently struggling to achieve their responsibilities. [the bold blocking on text is mine]

Better Regulation

Information on our principles of Better Regulation

Our principles are reinforced by the government's Better Regulation framework and its Regulators' Code, to which all UK regulators must comply. The Code's core principles are:
  • Proportionality - Regulators should intervene only when necessary; remedies should be appropriate to the risk posed, and costs identified and minimised.
  • Accountability - Regulators should be able to justify decisions and be subject to public scrutiny
  • Consistency - Government rules and standards must be joined up and implemented fairly
  • Transparency - Regulators should be open and keep regulations simple and user-friendly
  • Targeting - Regulation should be focussed on the problem and minimise side effects
Our recent work to improve the regulatory environment in aviation:In support of these principles we publish:
  • clear guidance on how to apply for, or renew, Certificates, Licences and Approvals and we define clearly the terms or privileges of Certificates, Licences and Approvals;
  • the charges applicable to the grant and renewal of Certificates, Licences and Approvals;
Additionally, to assist in clear understanding, we provide written and/or oral advice about any of the foregoing and in respect of our interpretation of requirements.
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Old 2nd Oct 2020, 09:36
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The simple fact is, you are not likely to get a response from the CAA if you ask them a question that should be answered by an ATO. The ATO is unlikely to get an answer even if they go to their FOI. An ATO can do an assessment, deceide on a course of action and notify their FOI who will either agree or not. Even then the licencing people may have a different opinion when its all submitted.
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Old 2nd Oct 2020, 10:02
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MJI
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I'm not a CAA basher, but do think this is ludicrous (but I won't rant). If they are under-resourced, I would support them saying Joe Bloggs off of the street can't call them, but the fact an ATO can't do this either is madness.

In my limited experience, the reality is that ATOs don't know the answers to these questions either and they're not going to put themselves out on a limb.

There are loads of ex-VGS guys kicking around in professional aviation, so I'm sure someone must have trodden this path before me.

Some of the legal language used to add caveats in other CAA publications demonstrates they can do this when they want to to be specific. In this case, it's a straight forward statement, that if read literally, I have multiples of the hours required.

Who makes the final decision on matters such are these?

If my application gets bounced and I'm £8k+ down, is there an appeals process? Or should I say, is there an appeals process that gets you anywhere?
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Old 2nd Oct 2020, 18:32
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The ATO is the training expert and it is their responsibility to make an assessment and generate a report on how they wish to proceed. In my experience all they have to do is send this report to their FOI and get the approval to carry on. So long as their assesment is based upon the regulation there is no reason for anyone to question it.
Many ATOs are reluctant to read the regulation and make decisions, possibly because they have had someone else to do it for them in the past.
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Old 2nd Oct 2020, 19:36
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MJI
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Thanks Whopity the ATO Iím planning to use are looking into it, so Iíll go back and suggest that. I appreciate your advice
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Old 2nd Oct 2020, 22:21
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What people need to understand is that there is a fundamental difference between the CAA of, say, 15 years ago and what we have now, thanks in no small measure to EASA. Back in the day, one could expect that all levels of management had at least a passing knowledge of some area of aviation and front line staff would have been at the top of their game, probably having been examiners of some considerable experience before being seduced to the dark side. These days, middle and senior management have, generally speaking, close to zero experience of aviation and the worker bees have, at best, a somewhat tenuous grasp of the realities of flight training. Arguably, of course, if the only requirement of an inspector is now to tick the appropriate boxes in a computer generated checklist, a tenuous grasp is all that is necessary.

The really worrying thing is that, in just a few months, this bunch of daisies is expected to re-adopt the mantle of Regulator when most are barely capable of regulating their own bowel movements. God help us all!
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Old 3rd Oct 2020, 10:34
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I know of a person who counted their instrument time from their PPL towards the 10 hour instrument requirement for FI issue. No problems at all.
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Old 3rd Oct 2020, 14:55
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On all of this, it seems, the law is in such a state of chaos that it matters little to understand it. A knowledge of the CAA clerk's check sheet of tick boxes will, perhaps, contains the clues of what is to be considered true or false at least for pragmatism purposes.

Not only the CAA but many organisations love creating a "frequently asked questions" section but before anyone has asked a question. They are almost certainly compiled by some spare person, with little else to do, who is therefore tasked with the job. I rarely if ever find an FAQ that answers my questions. I write all this because the CAA are taking months to answer a simple query such as the ones in question here. If only the CAA would provide their information in a clear, comprehensive and unambiguous form so giving themselves more time to to deal with complex matters. Keeping the website up to date and correct will go a long way also.

Requiring the ATOs to provide the answers is an impossible task if they don't know either. Of course we have to understand that those within the organisation themselves rarely talk to each other so why will they keep their ATOs informed and up to date. Its probably unlikely that they keep their FOIs up to date.
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Old 17th Oct 2020, 22:34
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I rarely if ever find an FAQ that answers my questions. I write all this because the CAA are taking months to answer a simple query such as the ones in question here.
It takes a long time to interpolate between all their FAQs in an attempt to answer a question which few understand let alone know the answer to!
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