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Can an FI without CPL theory do an SEP class rating revalidation of a full PPL holder?

DavidC wrote:

An FI who has no CPL theory cannot revalidate the SEP class rating on a PPL, but a CRI with FCL945 (but no FI) can

I also believe this to be correct.

That doesn’t make sense. At least for the SEP class, the CRI training course should be a subset of the FI training course so I can’t see any reason why an FI without the CPL TK shouldn’t be allowed to do everything a SEP CRI can do. Oh well, at least it should be trivial to add the CRI rating if you already have the FI one.

ESKC (Uppsala/Sundbro), Sweden

Yes, especially as the CPL TK is a ridiculous amount of work, and > 90% of it is irrelevant to GA flying

It is a purely restrictive practice pushed by industry interests. EASA was going to abolish the CPL requirement (during my “save the IMC Rating” days I was at one of Eric Sivel’s conferences where he said a PPL will be able to train a PPL) but there was too much pushback from vested interests so a political compromise was done of sitting the exams which is most of the work of a CPL (the rest is just a bit of VFR flying).

Administrator
Shoreham EGKA, United Kingdom

LAPL does not have SEP class rating with 2Y validity, it has rolling licence currency with 1h dual with instructor (not “1h exam” or “1h refresher” to validate 2 years SEP), as such there is no privilege to “revalidate LAPL class rating”, one only need “1h dual” and the LAPL pilot self revalidate his licence privileges on rolling currency against the past 24 months

I have seen few LAPL (without SEP printed by NAA) but SEP rating was signed by instructor with 2 years expiry date (apparently it’s not an issue in some countries)

It’s not clear how LAPL embedded restriction become restriction to perform FCL945 signoff for PPL, one can see how CAA chose to interpret it that way?

It seems NAA have different views on “2Y SEP signoff for LAPL”, FCL945 for FI who are restricted LAPL without TK and if CRI is embedded in FI licence

Worth checking the answers with the boss

Last Edited by Ibra at 27 Jan 08:01
Paris/Essex, France/UK, United Kingdom

Airborne_Again wrote:

That doesn’t make sense. At least for the SEP class, the CRI training course should be a subset of the FI training course so I can’t see any reason why an FI without the CPL TK shouldn’t be allowed to do everything a SEP CRI can do. Oh well, at least it should be trivial to add the CRI rating if you already have the FI one.

And in the regulatroy dream world when did that mean anything.

Actually it isn’t always trivial to add a CRI rating. The hour requirements for a CRI are higher than that of a FI so some people are simply not able. Of course this can be added at a later date but you have to do the full CRI flying course although I’m pretty sure get an hours reduction off the ground school requirement.

Another problems is not all ATO’s have permission to teach for the CRI only the FI.

Also the UK didn’t adopt the CRI(TMG) so FI (TMG) can’t obtain a CRI(TMG). And I’m really not sure of the reverence of CPL TK for TMG’s.

Last Edited by Bathman at 27 Jan 08:52

Peter wrote:

It is a purely restrictive practice pushed by industry interests. EASA was going to abolish the CPL requirement (during my “save the IMC Rating” days I was at one of Eric Sivel’s conferences where he said a PPL will be able to train a PPL) but there was too much pushback from vested interests so a political compromise was done of sitting the exams which is most of the work of a CPL (the rest is just a bit of VFR flying).

We have had this discussion before. It is a fact that ICAO requires an FI to have the CPL TK (but not an actual CPL). Thus the EASA requirement is exactly ICAO compliant.

If it were not, there is a risk that non-EASA countries would not accept EASA PPLs in their airspace as they could have been trained by an FI not meeting ICAO requirements. As the LAPL is not an ICAO license, the same problem does not arise with training for the LAPL.

ESKC (Uppsala/Sundbro), Sweden

Ibra wrote:

If you dig into “FI without CPL TK” you will find there is lot to it than revalidation of PPL/SEP, how about converting LAPL(TMG) to PPL(SEP)? adding Night Rating to LAPL or PPL pilot? adding Aeros Rating to LAPL or PPL pilot? doing variantes TW, RG, VP signoff for pilote with PPL(SEP)? club checkout for pilote with PPL(SEP)?

Of course what happens in the field is completely different.

I do know of LAPL FI’s that have been incorrectly been issued with 945 privileges. I also know LAPL FI’s who have been signing ratings pages as they simply didn’t know they couldn’t. I also know of numerous ATO’s that until recently told LAPL FI’s that they didn’t need a CRI rating to sign off SEP ratings.

LAPL(TMG) to PPL(SEP) – You need CPL TK to go from LAPL to PPL. Although the LAPL FI could add TMG privileges to the LAPL.

Night Rating to LAPL or PPL pilot. I have seen dozens (probably hundreds) of night ratings attached to LAPL’s and PPL’s by LAPL FI’s. In fact a school close to me its their policy to use LAPL FI’s to add night ratings to all licences

The rest just gets to complicated for something that really should be very simple.

A LAPL FI can teach for all aspects of the NPPL.

Last Edited by Bathman at 27 Jan 08:48

Bathman wrote:

Actually it isn’t always trivial to add a CRI rating. The hour requirements for a CRI are higher than that of a FI so some people are simply not able

For FI(R), Restricted, it’s easy to do the maths 300h for CRI = 200h for FI(R) + 100h get ‘R removed’
For FI, LAPL only, well someone decided to get ‘L removed’ you need full blown CRI course…

Bathman wrote:

Another problems is not all ATO’s have permission to teach for the CRI only the FI. Also the UK didn’t adopt the CRI(TMG) so FI (TMG) can’t obtain a CRI(TMG). And I’m really not sure of the reverence of CPL TK for TMG’s.

There is no CRI(TMG) or FI in EASA land or CAA land, there is CRI/SE and CRI/ME (FI/SE and FI/ME) but the privileges are restricted:
- You need 15h PIC on type/class that you plan to teach on (you need TMG to teach TMG)
- You need 1h from RHS with an FI/CRI qualified on type/class (you need to find someone who teach TMG to teach you to tech TMG)
- You need CRI/ME for multi-engines and CRI/SE for single engines (TMG, SEPL, SEPS MEP, SET, MET…)

You only need initial AoC in SE and AoC in ME then you can cross credit AoC ME into AoC in SE later on

The CAA posted this:

http://publicapps.caa.co.uk/docs/33/SafetyNotice2018007..pdf

After this accident where ‘Chief Flying Instructor’ (FAA terms in UK?) was doing revalidation of TMG class rating without holding TMG, never flown TMG or HK36 before

https://assets.publishing.service.gov.uk/media/5f5a403dd3bf7f723c19cac7/HK36_TC_Super_Dimona_G-FMKA_12-18.pdf

Last Edited by Ibra at 27 Jan 10:54
Paris/Essex, France/UK, United Kingdom

DavidC wrote:

I don’t believe the examiner charged extra but can’t recall if the CAA required an extra fee.

In my case, there was no additional ATO or examiner fee for CRI paperwork (in addition to FI Assessment of Competence and associated paperwork).

As for the UK CAA, they received two payments: one for CRI, the other for FI. I suspect that under the old paper-based application form on which you could tick both FI and CRI, you could have escaped with just one fee. The instructor applications are now online and an online application can be used for only one rating, so there is no way to avoid paying twice if you are applying for two ratings. The application does not submit until payment is successfully processed.

FI/IRI (London/South East)
EGKB (Biggin Hill), United Kingdom
18 Posts
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