Harry Karlsson posted in General Aviation
FI(A) privileges according to Part-FCL.
As Opinion 05/2017 was filtered into Part-FCL there was consideration towards FI(A) holders who do not have a (national) commercial pilot history or a commercial pilot license. In Finland, these persons generally only hold a PPL(A) due to medical and age reasons. As a rule they have not even converted their long time ago acquired national CPL privileges into EASA licenses. Some of them have fulfilled the age old ICAO CPL knowledge requirement during their FI(A) courses as an addendum to the instructor course.
As new instructors are emerging who do NOT hold or have held commercial licenses there will be a diversification of instructors arising in the future, as the requirements for a CPL license or the required knowledge will prevent them even from attempting to remove the LAPL only limitation from their licenses. We will have retirement age "senior" instructors and Young instructors, but no path to cross the abyss.
As a result, as GA people are reluctant to switch from PPL(A) holders to LAPL(A), there is a possible lack of instructors who are proficient and not legally qualified to extend SEP(land) or SEP(sea) privileges. The LAPL only FI(A) privilege is interpreted as to limiting to only LAPL license instruction and nothing further AFAIK.
The Part-FCL limitations will also put an end to separate Class rating instruction, as the group of pilots who are legally able to instruct in SEA class rating will be scarce in the future.
The purpose of the opinion was to improve GA instruction in general, but the result ended quite short of the runway.
The Opinion 05/2017 can be deemed a failure as far instructor privileges for PPL(A) license holders are considered.
Thanks for taking the time to start a discussion, hopefully we can help with the following clarifications:
- In your message, you refer to the ICAO CPL theoretical knowledge requirement. It is indeed this ICAO Standard for instructors that makes it necessary for Part-FCL to require the CPL theoretical knowledge from applicants for an FI certificate. Only in the case of FIs who solely instruct for the LAPL, it is not necessary to comply with this ICAO Standard, since the LAPL itself is not an ICAO-compliant licence. For any other kind of instruction (e.g. PPL or class rating privileges), the ICAO Standard applies and therefore cannot be simply deleted from Part-FCL.
- Nevertheless, EASA Opinion No 05/2017 resulted in Regulation (EU) 2019/1747 (amending Regulation (EU) No 1178/2011) and contained an amendment to point FCL.915.FI in order to make the demonstration of CPL theoretical knowledge for FI applicants “more accessible”.
- Currently, EASA is working on a complete revision of Part-FCL requirements for instructors and examiners (Rulemaking Task (RMT) RMT.0194). One of the objectives of this RMT is to make the FI certificate in general more accessible to pilots with a GA background. In order to address the shortage of instructors that has been reported mainly for the flight training at PPL level, the qualification process would be more tailored on the priviledges to be sought. In this context, the syllabus for the CPL theoretical knowledge (that is often seen as a “barrier” for GA pilots who wish to become instructors) is planned to be revised significantly.
Best Rgds
The EASA GA Roadmap Team
Thanks for this discussion. This is my case: I am EASA FCL.PPA-00003-LIN PPL(A) holder issued by Bulgarian DG CAA with valid endorsements: SEP(Land), MEP(Lend), NVFR and FI(A). My FI(A) has been limited to LAPL(A) student pilots only. It is possible to be instructor in ATO or to use a privilege of D-TO. After recognition procedure according State rules I am recognized FI(M) class A as per my NPPL(M).
Nevertheless this is obstacle to become FE(A) or then FIE(A) according EASA standard. If there is some one to show me what is the procedure to do this, where is written this is possible without CPL theory?
Best regards
EASA made the theoretical requirements (LO:s to be exact) way too demanding, considering that a "great" aviation nation (FAA reg) is doing commercial pilot LO:s with much less fuss.
The demand for the number of questions in the ECQB has made the learning of aeronautical information a process of remembering minute details without understanding the context.
The processing of the answered TK questions also leads to actively forgetting the items, once a person have passed the exams. There are several examples of this, which has led EASA to create one more subject for the ATO:s to divulge into, the instruction of the learning process as a new subject for the CPL/ATPL subjects. This new subject has partly been construed by the industry, as they have found out the hard way, that 250 hour ATPL frozen FO:s simply cannot their trade as they get into the right seat.
In the future the CPL req also inhibits persons to acquire FE privileges, this will also be an issue in the near future, because as an average the Examiners are senior citizens and they are already having issues pertaining to their medical certificates.
I'm trying to understand if the discussion was triggered by a recent change, or by the fact that to get an FI(A) rating on a PPL(A) licence you need to pass the CPL theoretical exam. I've known only one instructor who had a PPL(A), but he was a legacy CPL holder so he had passed the CPL theory.
Thinking "performance based" I would indeed dare to say the full CPL theory is overkill for PPL flight instruction.
I have to say that you very rarely hear about PPL(A) holders getting a n FI(A) rating. This could be because of the theoretical knowledge requirement. Most FI's here have a CPL or ATPL.
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