New instructor questions

@AsICFIT I can only provide you with the information I can find in Part FCL. I do not know if there are any specific UK regulations since the UK is no longer an EASA member state.

However, I would appreciate references to any kind of regulation (EASA/UK) that states a restricted FI has to be under supervision for all types of instruction. As I fresh FI myself, I have FCL.945 privileges, and I can perform revalidation flights with valid SEP holders. The Swedish CAA is perfectly happy with this interpretation.

AsICFIT wrote:

Have you been supervised by an unrestricted instructor at an ATO/DTO during this time?

No. Right out of training.

AsICFIT wrote:

The fact that FCL.910.FI (a) (1-4) exists as a set of criteria begs the question, why does it not just say ‘all instruction’ if a restricted FI can’t do anything without being employed by an ATO or a DTO?

For EASA (don’t know whether there is a UK deviation…):
It doesn’t say “all instruction” because it does not mean “all instruction”. It lists the set of cases in which supervision by an FI at an ATO/DTO is required. All other cases outside this set do NOT require the FI(R) to be supervised by an FI at an ATO/DTO.

The “spirit” of this restriction is to prevent newly rated FI(R) sending students on their first solo without the supervision. If you think of it this way, it makes sense that, holding FCL.945 privilege, you’re allowed to revalidate an SEP because the applicant already holds a licence with valid rating and has hence flown solo before! This reasoning has no value on its own since many times the regulation is worded in a way that one can clearly go against its “spirit” while also complying.

Regarding misconceptions. If you google FCL.945 (in the UK at least), the very first link directs you to a PDF (an info sheet by an ATO) in which one can read the following:

This big red statement is technically not correct because in the following case the training flight is not required in the first place when within the 12 months preceding the expiry of the rating the applicant

• has flown 12 hours total flight time in the relevant class, of which 6 as PIC, AND
• has completed 12 take-offs and 12 landings in the relevant class, AND
• has passed a CR/TR proficiency check, or skill test or assessment of competence in any other class or type of aeroplane.

The FCL.945 FI can review the evidence, be happy with the fact that the flight is NOT required, and then endorse the licence. Please someone correct me if I am wrong here.

To complicate things even further: some logbooks don’t have a column to log take-offs. And some pilots don’t bother logging take-offs and landings at all. An instructor even told me once when he saw my logbook: “You still log landings? Stop doing that!”
A flight is possible without any take-off or landing comprising of a taxi out of the parking towards the runway with the INTENTION of departing, and then aborting the flight with a return to parking. This is logged as PIC flight time. One could theoretically log 12 such hours and no take-offs/landings…

Alpha_Floor wrote:

And some pilots don’t bother logging take-offs and landings at all. An instructor even told me once when he saw my logbook: “You still log landings? Stop doing that!”

Weird. How can you demonstrate compliance with currency requirements expressed as number of landings if you don’t log landings?

Airborne_Again wrote:

How can you demonstrate compliance with currency requirements expressed as number of landings if you don’t log landings?

I ask the same question of the cross-country time requirements for the issue of ratings/licences. The EASA FCL.050 logbook does not include a column to log cross-country time. It doesn’t include a column to log take-offs either. I guess both the cross-country time and the take-offs have to go in column 12 “remarks and endorsements”.
The layout of the EASA FCL.050 logbook was clearly not very well thought through! (or as the Germans would say: durchdacht)

Alpha_Floor wrote:

I ask the same question of the cross-country time requirements for the issue of ratings/licences. The EASA FCL.050 logbook does not include a column to log cross-country time. It doesn’t include a column to log take-offs either. I guess both the cross-country time and the take-offs have to go in column 12 “remarks and endorsements”.

There is usually one take-off for each landing, but in any case I don’t know of any currency or other requirements relating to take-offs. You’re right about cross-country time.

Takeoff/landing for 90 days pax currency, is unrestricted instructor exempt when taking two pob student/pax?

I am sure one need to count their takeoffs & landings for some ratings,
- FCL.1005.FE, mountain rating examiner require 500 takeoff/landing while instructing to be a mountain examiner
- FCL.805, Bannertow rating 200 PIC landing after licence, Aerotow rating 60 landings (in FCL, I am not sure if it’s PIC after licence issue as well, in my case it was way easier to grandfather this under BGA than FCL, 10h flights and about 30 AT and you have the logbook signature)

The mountain rating is very odd and way too big, unless both instructor & student log the same landing (which I understand is ok)

Alpha_Floor wrote:

The FCL.945 FI can review the evidence, be happy with the fact that the flight is NOT required, and then endorse the license. Please someone correct me if I am wrong here.

Not in Sweden, an FCL.945 FI can only revalidate a SEP rating if (s)he has completed the revalidation flight with the SEP holder, and of course, reviewed and verified all documentation.

What you mention can be done by a PC examiner or the applicant by providing relevant proof to the authorities.

Reference: https://www.transportstyrelsen.se/globalassets/global/luftfart/certifikat_och_utbildning/handbok-forlangning-behorighet.pdf
Local copy: handbok_forlangning_behorighet_pdf

FCL910 is quite clear:

(a) An FI shall have his or her privileges limited to conducting flight instruction under the supervision of an FI for the same category of aircraft nominated by the DTO or the ATO for this purpose, in the following cases:
(1) for the issue of the PPL and LAPL;
(2) in all integrated courses at PPL level, in case of aeroplanes and helicopters;
(3) for class and type ratings for single-pilot, single-engine aircraft, except for single-pilot high-performance complex aeroplanes;

Para 3 does not refer to the issue of a class or type nor does it mention revalidation therefore, it applies to all instructional activites related to type and class ratings.

Differences training and dual training of qualified pilots does not have to be conducted at an ATO or DTO, but a Restricted FI is still required to have supervision because it is instruction towards an additional privilege within a class rating or towards the revalidation of a class rating and the entry in the students log book must be signed by the instructor in accordance with AMC.FCL 050 para (b)(4)

(4) instruction time: a summary of all time logged by an applicant for a licence or rating as flight instruction, instrument flight instruction, instrument ground time, etc., may be logged if certified by the appropriately rated or authorised instructor from whom it was received;

The requirements for logging are delegated to the NAA in FCL.050

The pilot shall keep a reliable record of the details of all flights flown in a form and manner established by the competent authority.

In the UK that is Art 228 of the ANO 2016. There is no legal requirement to log IFR time, Navigation or the number of landings/take-offs. The pilot may do so if he wishes.