I Think all FCL are not applied (understood) in the proper way.
With the old regulation for example the FI was able to teach on the simulstor, today with this regulation you must have a SFI.
All this regulation are wrong applied (understood),because the regulation give you to be a SFI without to be a FI !
You could be for example a CRI without to be a FI also if you old only a PPL !
There's no reason that a FI is not allowed to teach on sim,but FCL alllow if you are not a FI to get the SFI rating( this is very logic ) This is for me the proper way to apply the FCL.
In the same way if you are a FI you don't need to have the CRI rating ! At the end the FI is the highest rating, and for me you should nor need to old all the other rating such as CRI,SFI because they are implied on FI rating.
I
Dear Mr Cortelletti,
thank you for your message.
We wish to inform you that the holder of a flight instructor (FI) certificate, within the scope of privileges of that certificate, is of course entitled to provide instruction not only on aircraft but also on appropriate FSTDs. For such purposes, it is not necessary for an FI certificate holder to additionally hold an SFI or STI certificate.
For the scope of privileges of an FI certificate holder, please refer to point FCL.905.FI of Annex I (Part-FCL) to Regulation (EU) No 1178/2011.
We hope this helps.
Best regards
Christian Kucher
Flight Crew Licensing Expert, EASA
Dear Christian,
Thank you very much for your quick reply.
Renato
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