Medical for CRI?

[Mogwi]

I have trawled through the UK CAA regs and failed to find an answer to the question of medical requirements to exercise the privileges of a Class Rating Instructor. Can it be done on a Self Declaration or is a Class 2 required?

There answer must be somewhere but I couldn’t find it for the life of me.

Mog

[MrAverage]

If an FI can it should be possible. However, it's my understanding that the declaration can only be made if a Class II was previously held at some time.

Happy to corrected............

[Mogwi]

Originally Posted by MrAverage

If an FI can it should be possible. However, it's my understanding that the declaration can only be made if a Class II was previously held at some time.

Happy to corrected............

Yes, A1G1Z1, Class 1, then Class 2 held for 60-odd years but dropped to Self Declaration recently because of difficulty contacting AME for renewal. Contemplating wether it is worth the faff to renew my CRI after 12 years.

Mog

[BEagle]

Dave, it depends on whether you hold a Part-FCL licence or a national licence issued under the ANO. At the time of writing, any instruction by Part-FCL instructor certificate holders requires at least a Part-MED Class 2 certificate.

If you need to revalidate a currently valid CRI certificate included in a Part-FCL licence, you can do so without holding any medical - but you can't exercise the privileges unless you hold a valid Class 2 medical.

AOPA has recommended to the CAA that a CRI should be permitted to exercise his/her privileges with a PMD. Hopefully we'll know more in the New Year!

[Mogwi]

VMT Beags, I am running both Part-FCL and national licences, so it looks like I can still exercise the privileges of the national CRI rating at least.

Tootle-pip!

Mog

[BEagle]

Well, 5 weeks ago the CAA issued the following statement:

We are planning changes to the regulations that currently allow flight instruction on SEP/TMG aircraft (Part 21 and non-Part 21) by instructors who have made a Pilot Medical Declaration (PMD) instead of holding a Class 2 Medical Certificate.

We intend to amend the regulations to protect the standard of the Part-FCL PPL and ensure students can choose training with medically certified instructors.

A formal consultation will begin in the coming months. Pilots may continue to apply for ANO licence conversions but should be aware that PMD-based instruction privileges may be withdrawn.

Nothing more since then. Of course any formal consultation will take a while for responses to be reviewed, after which implementing regulatory changes won't be a quick process.....

[ASRAAMTOO]

The CAA are moving remarkably fast ( for them) and the consultation process for this is now open. If you have a view I suggest you take part in the consultation!

[BEagle]

See CAP 3218 at the link on this CA webpage: https://consultations.caa.co.uk/ga/p...eid=4c424d6fb4

Dave - Proposal 1.7 states:

'We propose that FI or CRI holders with a PMD may provide instruction towards:
- The NPPL(A) and associated class ratings
- Revalidation and renewal of existing class ratings; and
- Differences training associated with an existing rating.'

Note that the 'existing class ratings' may be included in any CAA-issued licence, not just the NPPL(A)!

So if the consultation responses agree with this proposal, you will soon be permitted to exercise the privileges of a CRI class rating without needing to hold a Class 2 medical certificate.

[Kemble Pitts]

Thanks for the link to the consultation. For what its worth, I have responded as follows:

The proposed changes are inconsistent, both between ANO and Part FCL licences and between NPPL and PPL. For the sake of clarity they should be fully aligned otherwise confusion will remain.

If a pilot with an ANO licence and a PMD can fly an aircraft with a MAUW of 5700kg, why can't a similar person holding a Part FCL licence and a PMD? They both should be allowed to as there is no evidence to suggest otherwise.

If an FI with a PMD can instruct towards an NPPL, why can he/she not instruct for the similar PPL? The suggestion that this is due to the fact that a PPL applicant must hold a Class 2 medical is not defensible: there is no statistical difference between the accident rate for pilots holding a medical versus those flying with a PMD. The PPL applicant should not require a Class 2 medical either. Given that the new PPL holder can let his/her Class 2 medical lapse on the day the PPL arrives in the post and then fly using a PMD only, shows that the Authority has little regard for the real need for the Class 2 medical in the first place. 'ICAO recommends it' is no defence, simply file Differences against the ICAO recommendations as is done in several other cases (e.g. the 500 ft rule).

The logical course of action is to allow both the PPL student and his instructor to operate on a PMD. Also, as is the case currently for an ANO FI/CRI, allow ANO and FCL instructors to instruct for additional Ratings on NPPL and PPL. Again, there is no evidence to suggest otherwise. Flight safety regulations must be consistent and based on evidence otherwise they become discredited.

[BEagle]

Kemble Pitts, the CAA stated the following decision following the 2023 PMD consultation (see CAP 3059):

Phase 2 Consultation Outcome – CAA Decision no.1
We will remove the 5700kg category and restrict the PMD to at or less than 2000kg category

Para 8 of the CAP 3218 introduction makes it clear that the current consultation does not supersed the earlier consultation. The ANO Art.163 amendment proposals will tidy up the current regulations, but when the CAP 3059 changes are introduced, it is likely that pilots with a PMD will restricted to aircraft of up to 2000kg MTOM.

[Genghis the Engineer]

Originally Posted by BEagle

See CAP 3218 at the link on this CA webpage: https://consultations.caa.co.uk/ga/p...eid=4c424d6fb4

Dave - Proposal 1.7 states:

Note that the 'existing class ratings' may be included in any CAA-issued licence, not just the NPPL(A)!

So if the consultation responses agree with this proposal, you will soon be permitted to exercise the privileges of a CRI class rating without needing to hold a Class 2 medical certificate.

I flagged it in my own response to the consultation, but this wording could imply that a CRI could now instruct for the NPPL(A). I'm sure that's not CAA's intention, and the ambiguous wording would be best not there.

G

[BEagle]

Genghis the Engineer - although we're waiting for the updated version of CAP 3181 to be released, it was clear from the earlier Licensing and Training documents that the CAA intends that the holder of an NPPL(A) will be able to add additional aeroplane Class Ratings by Differences Training alone. This may be delivered by 'an instructor', although it isn't yet clear whether that includes CRIs.

There was certainly no intention for ab initio training to be conducted by CRIs.

[rarelyathome]

Nor should there be - a CRI is not an FI (I know you know that better than most BEagle).

[Genghis the Engineer]

The difference, between instructing "for" the NPPL (FI territory only), and instructing "the holder of" an NPPL (FIs and CRIs).

G

[Mogwi]

Thanks BEAGS et al. I have now renewed my Class 2, so will be covered either way. Now to resurrect my DA!

Mog

[BEagle]

Good to hear that Mog! I owe you for making my holding officer time at Wildenrath in Jul/Aug 1975 so enjoyable!

[Mogwi]

‘Twas a pleasure and a privilege me dear chasp!

Mog

[BristolScout]

It's a refined form of madness to suggest that a PMD FI is ok to teach to NPPL but not PPL. The instructor/student interaction is identical for both licences and the syllabuses very similar. This seems to represent the current stove-pipe mentality within the CAA. There is a massive pilot shortage on the horizon with very few new instructors coming into the system as the young talent is being syphoned into modular commercial courses. Driving the older instructor cadre into retirement with unnecessary bureaucracy is hardly going to help.