FIs signing Revalidation
 

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.

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

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

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.

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

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?

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.

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.

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.

The position is perfectly clear under FCL.945:

:rolleyes:

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

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.

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

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

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 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.'

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

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...

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.

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

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.

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.:rolleyes:

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.

Restricting instructor revalidation to individuals that you have actually flown the training flight with makes some sense. At least the instructor knows for sure that the training flight was legitimate. I have no idea how examiners varify the identity and qualification of an instructor that they do not personally know, and who could be based anywhere in EASA land. I personally would not want this responsibility.

Restricting instructor revalidation to immediately after the training flight makes it almost useless. The vast majority of revalidation candidates that I fly with try to get the training flight over with early in the 12 month period and do not yet have their 12 hours logged. I flew with someone this weekend who still needed an hour of P1 time before he can revalidate. He was planning to complete it this week, but now he will have to seek out an Examiner (who may not know me from Adam) to sign him off because apparently I cannot be trusted to have a record of my own flights or recognise my own signature in someone's log book.

Do we really want to encourage people to leave the instructional flight right to the end of their SEP rating validity?

What happens if the training flight was actually three flights?

If the purpose of this was to take some of the pressure off examiners, then it has missed the mark. I already have this "obligation" on my licence, but I suspect it will be rarely used and I wish now I had not bothered with it.

You need to re read the regulation. ALL of the revalidation requirements need to be met before the licence can be signed. That means if it's split over more than one flight it is signed after the final flight that completes the requirements.......

Now I refer you back to my comment about the differences between examiners and authorising an Instructor to do a limited Licencing action on behalf of the authority......

I have read the regulations. The point I was making about the three flights is that two of these could have been 11 months ago. Apparently I can be trusted to recognise my own signature on these flights, but not if it was a single 1 hour flight yesterday. Where is the logic there?

I have re-read your comments about the differences between examiners and instructors, but I'm afraid I don't see anything there that explains how it is better for an examiner to verify the qualifications of a potentially unknown FI than for the FI himself to recognise his own log book entry and signature on a past flight.

I don't understand why people are getting so steamed up about this.

If a pilot has met all other requirements and just needs to finish off the training flying, then he/she won't need to find an examiner for a signature, provided that the instructor has the FCL.945 endorsement in his/her certificate.

EASA is proposing to ease the training flying, so that it will no longer be '3 flights with the same instructor' - it will simply require a total of not less than 1 hour of refresher training accumulated with as many instructors and in as many flights as the pilot wishes.

That should make compliance even simpler - provided instructors actually understand the scope of their privileges. Which clearly many don't, even today.....:rolleyes:

then why would you not have signed the flight off on completion of the requirements yesterday....

People really are making a meal of this......

Joe Bloggs did a training flight with me yesterday. At the end of that flight he still needed one hour of PIC time to meet the requirements. He flies that hour today, but I now cannot revalidate his rating so he has to go on the usual examiner hunt before his rating expires.

It's a silly restriction that severely limits the utility of the "obligation". What's the point of introducing something intended to reduce the bureaucracy of the revalidation process only to trammel it with a restriction that makes it unlikely to be used?

When I applied for it, I did not interpret "upon completion of the training flight" as meaning "immediately following the completion of the training flight". Had I done so, I would have realised that the "obligation" would be almost useless and I would have saved the £53. My mistake.

IMHO it's a much deeper problem than Beagle and nick14 have mentioned.
There are a large number of instructors floating about who have somehow gained the privilege without gaining anywhere near the required knowledge, skill or the correct attitude. Or perhaps they had it once but have not bothered to maintain it. My worry is that some of these will fill in the form, pay £53 (no training required) and then revalidate pilots incorrectly.

Its been happening since 1999 the only difference is the £53! In most cases they signed the rating and no paperwork was completed or it would have been noticed.

An Examiner can extend the validity of an SEP providing all the requirements for revalidation by experience are met. The introduction to IN 2015/034 says its purpose is to allow authorised instructors to do the same. If that is indeed the purpose why was FCL 945 not written to make that clear? If it was clear,this thread would never have started.

I agree - IF this is correct interpretation of the requirements.

Has anybody yet seen the explanatory card which CAA are apparently going to send us with re-issued licence? That may explain much.

G

There was nothing in with my new licence when I received it a few days ago.

It was nothing to do with Examiners, it was to aid pilots who have difficulty in locating an Examiner in a timely manner (there being more Instructors than Examiners). It is still a 'relaxation' of the rules - even if this new, additional, method of Revalidation does not go as far as you would like.

The wording is not the best so I am not saying you should have understood it; I agree with Mr Average that it is completely bonkers for the CAA to give someone an additional privilege (or obligation) without some evidence that they understand the privilege and how to apply it.

For those Instructors who will gain it "automatically" upon Issue or Revalidation - they should not unless there is some evidence that this has been discussed (at a Seminar or with an FIE). For those wanting it badly enough that they will pay £53 for the benefit the same should apply.

Guess it is all too late now !

That's me - and I shall certainly read any instructions carefully and discuss it with my friendly neighbourhood examiner before I use it.


Clear written procedures would certainly do however - we all do many things as pilots which weren't explicitly taught, relying upon good documentation.

G

I was taught this as part of my CRI course and I believe it should be the norm on all instructor courses not only for your own privileges but to advise students and other pilots about their own administration.

Quote:

That's me - and I shall certainly read any instructions carefully and discuss it with my friendly neighbourhood examiner before I use it.


Genghis
Hypothetical question.


A person buys a share in your Condor Group but has not a tail wheel sign off.
Person requires a revalidation for SEP A and having flown a C152 for more than 12hrs in the last, etc, requires your obligation as a CRI to sign the licence.
You complete a 1hr training exercise in the Condor in which you demonstrate both the take off and landing.
Would you sign that person's licence in able to fly the C152 booked tomorrow ?

If I may be so bold to answer in Genghis' absence:

In the example you have quoted, the requirements have been met, so there's no reason not to sign the Licence for the revalidation of the SEP Class rating.

It matters not what that person is going to fly tomorrow, so long as it's included in the class rating you have revalidated.


MJ:ok:

This was introduced as a result of much work behind the scenes by the LAA to re-introduce authorisation for CAA Revalidation Examiners to sign EASA licences following withdrawal of these privileges at the introduction of EASA in September 2012. The LAA pursued this primarily to assist those pilots who might have difficulty locating an EASA Flight Examiner following completion of their training flight. A number of routes were explored with the CAA, where this was found to be the most satisfactory solution.

CAP 804 now includes some details of FCL.945 privileges under Section 4 Part J, Subpart 1 Page 6. It is clear that the guidance provided to those who have been issued with FCL.945 privileges is inadequate.

ifitaint...

FIs signing Revalidation
 

TREs used to be able to sign a revalidation by experience. I believe that privilege disappeared with EASA. Have any of the recent relaxations restored it?

I wrote to the CAA to inform them that Standards Document 24(A) was incorrect when the latest version was published; the FEH was also incorrect at that time. The FEH has been amended following a number of e-mails :) and now contains the correct statement which allows ANY UK examiner with an EASA Part-FCL Examiner certificate (including TRE) to sign for revalidation by experience in a UK licence.

See 'Who can certify' in Table 4C in the FEH, where the date of this publication is after the date of issue of SD24. PM me if needed for a copy of the e-mail from CAA policy (which was agreed as OK for distribution) confirming this.

ifitaint...

1 hour instruction, it's not a test and for the purposes of SEP revalidation no minimum standard of flying needs to be demonstrated - so yes.

However, he's still not yet signed off for tailwheel, and he'll certainly need rather more time before I authorise him to fly PiC in the syndicate jet.

G