FI LAPL only
Is it correct to say that the privileges of the FI-LAPL only, are limited to: teaching for the LAPL licence. No additional ratings can be taught nor renewed. No bi-annual training flight other that for LAPL (no PPL bi annual training flight). The FI LAPL only can do the difference-training for LAPL not any other licence. The FI LAPL only can carry out familiarisation training.
That should be not true. The limitation is only for basic training. LAPL approved, PPL not. But beyond PPL some of the training could be done. Like variant, class. We have an instructor who has PPL licence only, with FI AND CRI endorsement.
"FI-LAPL" is not an official term. I assume you mean an FI who holds a PPL(A) and has not have passed the CPL theoretical knowledge examination.
FCL.915.FI(b)(2)(i) does say that such an FI can do "training for the LAPL(A) only", but this is a bit odd if you compare FI privileges with CRI privileges. A CRI can hold a PPL(A) without the CPL TK and can issue, revalidate and renew class ratings and also train for aerobatic and aerotow ratings. So arguably an FI without CPL TK should also be able to do that.
Maybe, as Zoltán suggests, a PPL FI without CPL TK needs the CRI rating in addition to the FI rating, but that should only be a formality.
No instructor may 'renew' class ratings - only an Examiner may do that. Revalidation may be completed with an FI or CRI with FCL.945 privileges within the appropriate limitations.
An FI who is restricted to LAPL only instruction may provide any training for the LAPL holder, such as SEP conversion for a LAPL holder with a TMG Class Rating, a Night, Aerobatic or Towing rating if so qualified and 'differences training' for a LAPL holder, but not for a PPL holder. 'Familiarisation' is not 'training' per se and no instructor is legally required.
SEP Class Rating refresher flight training for a PPL holder may not be conducted by an FI who is restricted to LAPL instruction, but may be conducted by a CRI. Which is why AOPA(UK) strongly recommends that a pilot who is receiving FI training for an FI certificate restricted to the LAPL should also apply for a CRI certificate provided that he/she meets the CRI experience prerequisites.
The general approach in Part-FCL is that privileges of a particular instructor certificate are set out in detailed and exhaustive lists, where all licences and associated ratings for which instruction can be given are listed (see for example point FCL.905.FI or point FCL.905.TRI). In this context, we at EASA understand the reference to “LAPL(A) only” in point FCL.915.FI(b)(2)(i) in such way that the privileges of such an instructor are in fact limited to providing instruction towards the LAPL(A) and do not include privileges to instruct for additional ratings, such as the towing or the aerobatic rating. A review of this provision is already noted down for the ongoing EASA Rulemaking Task (RMT) RMT.0194 which at the moment is comprehensively revising Part-FCL Subpart J.
Dear Mr. KUCHER,
To me, this EASA interpretation of “LAPL only (and nothing else)“ makes no sense at all. And every instructor or examiner I have consulted, do also think so.
We are not talking LAPL, PPL, CPL or ATPL, we are talking about the revalidation of a CLASS RATING SEP, about which FCL.740.A states: “refresher training of at least 1 hour of total flight time with a flight instructor (FI)”.
Nowhere is mentioned that any other restrictions apply for the FI giving the refresher training. It is clear that the FI should have the SEP rating him- or herself of course. If a “LAPL only” can not give the refresher training for a PPL SEP holder, why can a LAPL & PPL instructor provide refresher training for CPL or ATPL SEP holders? It makes no sense.
Apparently the “passed CPL knowledge examination” is not the issue here, because one can obtain a CRI without this examination. The FI training course encompasses everything (and much more!) the CRI course also encompasses. For instance, a minimum of 30 versus only 3 hours flight instruction for CRI. And a minimum of 125 hours of theoretical training versus only 35 hours of theoretical training for CRI. All theory and practical flying subjects required for CRI are contained within the FI syllabus. I myself specifically opted for the FI course instead of the CRI course to have more training and flight hours, and to become a better instructor then by just doing CRI. I comply with the minimum hours required as per the pre-requisites for CRI. I understood beforehand as a “PPL-FI without CPL theory certificate” that I could only train LAPL students “ab-initio”. This was clear to me.
But again, we are talking about a CR SEP revalidation, not about operating as a FI in a LAPL (or PPL) syllabus. There is no “next higher” level of knowledge regarding SEP CR’s!
Denying the FI “LAPL only” the privilege of performing SEP training flights also severely hinders the FI in gathering valuable experience to become a better FI and pilot overall.
I can’t find any reference in Part-FCL on how I should have foreseen this, in my opinion questionable and arbitrary, restriction. To me it feels like the rules of the game are being changed whilst playing.
If it were to make any sense at all, I would accept it. But given my reasons stated above, I can only see the current “EASA understanding” as unreasonable, unnecessarily complicating, and of no value whatsoever to enhance safety, and possibly even counteracts this for the FI in question. I hope that the outcome RMT.0194 will eventually clear up this issue.
Let’s make rules easier, whilst addressing real safety issues in aviation!
My understanding is that a FI without CPL theory is limited to provide initial training to issue an LAPL(A) but other than that you have full privileges and conditions (FCL.905.FI FI) which include to conduct flight instruction for the issue (as I said limited to LAPL), revalidation or renewal.
In the other hand, I consider that it is a tremendous error only allow to FI with CPL Theory to conduct training to PPL students because there are a excellent PPL FI without CPL theory whising to conduct this training which do not see the FI job as a a mandatory step to get an airline job, on the contrary, they are pilots who are passionate about teaching (of course I can not generalize).
Can Christian tell us if there is this issue on the EASA table or it is something that will not change. Many thanks.
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