This might be a can of worms, everyone seems to have a differing opinion on this. - You can because it is not specifically prohibited (Whopity) - You can if certain requirements are met (BEagle) - You cannot because it is not specifically allowed (Me) I think EASA did not specifically prohibit Class Rating instruction at night by a CRI because they never envisaged anyone would think they were allowed to. A CRI is only allowed to teach to the Class rating syllabus: Part-FCL Appendix 9 Training, skill test and proficiency check for MPL, ATPL, type and class ratings, and proficiency check for IRs A General CONTENT OF THE TRAINING, SKILL TEST/PROFICIENCY CHECK 4. Unless otherwise determined in the operational suitability data established in accordance with Part-21, the syllabus of flight instruction shall comply with this Appendix. believe that all mandatory Class Rating test items can be taught/tested at night, including: SINGLE-PILOTAEROPLANES, EXCEPT FOR HIGH PERFORMANCE COMPLEX AEROPLANES 2.2 Steep Turns 2.3 Stalling 5.2 Simulated EFATO (single engine only) 5.3 Simulated Forced Landing Before anyone else points it out there is also: "4.7 Night go-around and landing (if applicable)" But this is not a mandatory test item and I cannot think of a Class rating to which it is applicable. (Certainly not SEP or MEP) |
Therefore, if you believe a CRI is entitled to instruct at night, you must also believe that all mandatory Class Rating test items can be taught/tested at night Your contention, as I understand it, is that because the Regulation does not specifically state that a CRI may instruct at night then he may not. Would you, for the same reason then, say that an IRI may not instruct for the instrument rating at night or that a TRI may not carry out any part of the type rating syllabus at night (e.g. ILS approach)? In any case, there is nothing to prevent steep turns or stalling being taught on those nights when there is a clear horizon or to prevent a PFL to, for example, a lit runway. |
I wasn't sure either way hence the question. I would never conduct training that I am unsure of the legalities of until I had evidence to support that.
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some elements of the class rating syllabus should sometimes not be taught at night does not mean that none of it can at night? I believe the privileges of an instructor cannot just allow instruction towards Licence/Rating issue, renewal or revalidation - they must permit instruction of any elements of a Licence/Rating syllabus to anybody at any time. If that were not the case then a "whole can of worms" would open up: eg: An aerobatic instructor could not give aerobatic instruction to someone who already holds an aerobatic Rating and club check outs would not be allowed on SEP holders during the first year of their Rating validity. However Instruction can only be given if the privileges held are not trumped by another requirement. FCL.810Night rating (a)Aeroplanes, TMGs, airships. (1)If the privileges of an LAPL or a PPL for aeroplanes, TMGs or airships are to be exercised in VFR conditions at night, applicants shall have completed a training course at an ATO. The course shall comprise: (i)theoretical knowledge instruction; (ii)at least 5 hours of flight time in the appropriate aircraft category at night, including at least 3 hours of dual instruction, including at least 1 hour of cross-country with... part of any other, that I can see). Therefore VFR at night instruction to LAPL or PPL holders requires the privilege to instruct for the night Rating. To answer your specific questions: An IRI may instruct IFR at night, not VFR A TRI may instruct at night if the approved Type Rating course states it. The legislation does appears to state that only CPL FIs can instruct CPL holders VFR at night!!! because the Regulation does not specifically state that a CRI may instruct at night then he may not CPL privileges do not state they can be exercised at night - but to gain a CPL night training is required. CRI do not state the privileges can be exercised at night. But to gain a CRI no night instruction training/competence testing required. And all Instructor privileges in EASA seem to require a demonstration of competence. |
CRI do not state the privileges can be exercised at night. But to gain a CRI no night instruction training/competence testing required. |
What, exactly, does that 1hr entail to lift an FI's night restriction? and yes, that's to teach ab-initio and existing PPL holders at night.
For someone with a PPL wishing to do a night rating I'm sure there's CRI's who (perhaps with the 1hr 'course') would be willing and perfectly able. I'm a CRI and come this winter I'll be asked again by a few people if I can do the night rating course for them. 7700 |
The one hour involves demonstrating to an FIC instructor the ability to teach at night. Pre JAA it was somewhat more comprehensive but now its just a tick in the box. That said, as it is a rating that is not included in the CRI privileges you do not have the option to teach those who do not already hold the rating.
If it were not for the UK there would not even be an hour required. As the Night Rating involves sending a student first solo at night, a FI rating is required for ab-initio training. |
While the wording says "has demonstrated the ability to instruct at night", I would hope it would be a bit more.
In my case [I did it as part of my FI course, not separately] it was
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CPL privileges do not state they can be exercised at night - but to gain a CPL night training is required. |
I would hope it would be a bit more. |
Do any ATOs have approved syllabi for SEP or MEP which includes training at night? I believe the privileges of an instructor cannot just allow instruction towards Licence/Rating issue, renewal or revalidation - they must permit instruction of any elements of a Licence/Rating syllabus to anybody at any time. An IRI may instruct IFR at night, not VFR A TRI may instruct at night if the approved Type Rating course states it. |
CPL privileges do not state they can be exercised at night - but to gain a CPL night training is required. FCL.315 CPL — Training course An applicant for a CPL shall have completed theoretical knowledge instruction and flight instruction at an ATO, in accordance with Appendix 3 to this Part. and Landings - If a medical does not allow PIC at night then the training requirements for CPL issue cannot be met. |
I believe the privileges of an instructor cannot just allow instruction towards Licence/Rating issue, renewal or revalidation - they must permit instruction of any elements of a Licence/Rating syllabus to anybody at any time. A twin needs a twenty minute positioning flight. The pilot happens to be an MEP CRI and they take along another club member (PPL SEP Holder) for company. The PPL holder cannot believe their luck when they are put in the LHS and the pilot lets them do most of the flying whilst going in to "instructor" mode. The flight was definiteley not for Rating Renewal or Revalidation as no Rating is held. It is also not for Rating issue as it wasn't flown under the auspices of an MEP ATO. Can the CRI tell the other pilot to record the flight as 20min MEP PUT? I think YES, because the CRI was Instructing according to the MEP syllabus. The point I was making is that it is irrelevant whether the "student" has a valid Night Rating or not as any VFR Instruction at night would be according to the Night Rating syllabus and, therefore, any Instructor would need the privilege to Instruct for the Night Rating. But the privileges at FCL.905.IRI do not specifically include instruction at night unless there is an additional requirement from another privilege's syllabus. In this case LAPL/PPL VFR instruction at night is a privilege listed in the Night Rating requirement. Are you saying that an IRI may, for example, teach a non-precision approach at night up until the point that the aircraft reaches MDA and/or IFR is cancelled but may not then teach the subsequent circle to land under VFR? Don't cancel IFR. There is no difference, that I can see, to flying a visual circle to land IFR as there is VFR. Once again, the privileges at FCL.905.TRI do not specifically include instruction at night |
Can the CRI tell the other pilot to record the flight as 20min MEP PUT? it wasn't flown under the auspices of an MEP ATO. |
LA - Your arguments are becoming more and more convoluted as you insist on reading requirements and restrictions into the regulation that simply are not there. Your contention is that a CRI cannot instruct at night because the privileges of a CRI certificate do not specifically say that he can. It is true that a CRI cannot instruct for the night rating but he can give any instruction within the privileges granted by FCL.905.CRI either by day or by night (provided he holds a night rating or night qualification). For example, he could quite safely conduct differences training for VP props or SLPC at night, or some parts of the MEP class rating.
In the case of the class rating, there might be a restriction imposed by the ATO under whose approval he was operating but this is a matter for the ATO as the approval itself does not restrict instruction to daylight only. Differences training, however, does not need to be done within an ATO, nor does it need to be approved and so, in this case, it is entirely at the CRI's discretion when he conducts the training. Similarly an IRI is not constrained to teaching only under IFR by night - for example, there is nothing to prevent him from conducting the whole of the BIFM at night under VFR (apart, perhaps, from the instrument appreciation aspects) . The same applies to a TRI, who may choose to teach any part of the type rating syllabus at night, with the approval of the ATO under whose approval he is operating. |
All traiing for a licence or rating must be conducted at an ATO to use this flight towards Rating Issue. All Instructor privileges are written in Part-FCL as privileges to conduct the required training towards a Licensing Administrative Action. It does not say you can only conduct training which would, or could, lead to a Licensing Action. If this was the case who could give aerobatic instruction to someone who already holds an Aerobatic rating? An aerobatic instructor would seem to be the appropriate Instructor Certificate - but this only gives the privilege to Instruct for the Rating (not aerobatics in general). |
So if someone holds a rating they cannot be PUT for the same rating??
If what I understand by that statement then club checkout could not occur not could an instructor be asked by a rates pilot to go up with him for a confidence boost? Say an aerobatic rated pilot hasn't done any aeros for a while an wants to be supervised by an instructor? |
So if someone holds a rating they cannot be PUT for the same rating?? I specifically chose the Aerobatic Rating as an example to ask the question because, once issued, it never needs to be Revalidated or Renewed. Most Ratings (eg SEP) do need to be Revalidated/Renewed so any training could be towards that. LA - Your arguments are becoming more and more convoluted by what was written in primary legislation. It is obvious that there is nothing in there that would currently convince either of us of the other's point of view - therefore, having had a good, long discussion on the subject, it is probably time to move on. |
If you follow the letter of the regulations as they are written, there are so many things that nobody can instruct for, because it is mentioned nowhere in the instructor privileges.
For example, there is no paragraph saying that an FI or CRI can do familiarisation or differences training... So you can either argue that nobody can give that training, file reports whenever you see somebody doing that sort of illegal instruction, and refuse to accept any differences sign-offs issued since EASA part FCL came into force, or you apply some common sense and carry on as normal. |
Familiarisation and differences training extends the privileges of a class rating (or type rating) and can therefore be taken as being within the privileges of both an FI, and a CRI (or a TRI). More significant is the fact that no instructor certificate includes the privilege to instruct for the MCCI certificate, so where will all the MCCIs come from? (Don't panic, the UK has already filed a derogation).
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