Regulation (EU) 2020/359
Except as provided in point FCL.835, operations under IFR on an aeroplane, helicopter, airship or powered-lift aircraft shall be conducted only by holders of a PPL, CPL, MPL and ATPL with an IR appropriate to the category of aircraft or, if an IR appropriate to the category of aircraft is not available, only while undergoing skill testing or dual instruction.
FCL.605 IR – Privileges and conditions
Regulation (EU) 2021/2227
(a) Privileges
The privileges of holders of an IR are to fly aircraft under IFR, including PBN operations, with a minimum decision height of:
(1) no less than 200 ft (60 m);
(2) less than 200 ft (60 m), provided that they are authorised to do so in accordance with Annex V (Part-SPA) to Regulation (EU) No 965/2012.
(b) Conditions
(1) Holders of an IR shall exercise their privileges in accordance with the conditions established in Appendix 8 to this Annex.
(2) To exercise privileges as PIC under IFR in multi-pilot operation in helicopters, holders of an IR(H) shall have at least 70 hours of instrument time, of which up to 30 hours may be instrument ground time.
FCL.610 IR – Prerequisites and crediting
Regulation (EU) No 245/2014
Applicants for an IR shall:
(a) hold:
(1) at least a PPL in the appropriate aircraft category, and:
(i) the privileges to fly at night in accordance with FCL.810, if the IR privileges will be used at night; or
(ii) an ATPL in another category of aircraft; or
(2) a CPL, in the appropriate aircraft category;
(b) have completed at least 50 hours of cross-country flight time as PIC in aeroplanes, TMGs, helicopters or airships, of which at least 10 or, in the case of airships, 20 hours shall be in the relevant aircraft category.
(c) Helicopters only. Applicants who have completed an ATP(H)/IR, ATP(H), CPL(H)/IR or CPL(H) integrated training course shall be exempted from the requirement in (b).
FCL.615 IR – Theoretical knowledge and flight instruction
Regulation (EU) 2018/1974
(a) Course
Applicants for an IR shall have completed a course of theoretical knowledge and flight instruction at an ATO. The course shall be:
(1) an integrated training course which includes training for the IR, in accordance with Appendix 3 to this Annex (Part-FCL); or
(2) a modular course in accordance with Appendix 6 to this Annex (Part-FCL).
(b) Examination
Applicants shall demonstrate a level of theoretical knowledge appropriate to the privileges granted in the following subjects:
(1) air law;
(2) aircraft general knowledge — instrumentation;
(3) flight planning and monitoring;
(4) human performance;
(5) meteorology;
(6) radio navigation; and
(7) communications.;
AMC1 FCL.310; FCL.515(b); FCL.615(b); FCL.835(d) Theoretical knowledge examinations
ED Decision 2020/018/R
LEARNING OBJECTIVES FOR ATPL, CPL, IR, CB-IR(A) and BIR
(a) Aeroplanes and helicopters
GENERAL
In the tables of this AMC, the applicable LOs for each ATPL, CPL, IR, CB-IR(A) are marked with an ‘X’, and for the BIR exam and BIR BK with the number 1, 2 or 3 (corresponding to the modules as mentioned in FCL.835 ‘Basic instrument rating (BIR)’.
The LOs define the subject knowledge and applied knowledge, skills and attitudes that a student pilot should have assimilated during the theoretical knowledge course.
The LOs are intended to be used by an approved training organisation (ATO) when developing the Part-FCL theoretical knowledge elements of the appropriate course. It should be noted, however, that the LOs do not provide a ready-made ground training syllabus for individual ATOs, and should not be seen by organisations as a substitute for a thorough course design. Adherence to the LOs should become part of the ATO’s compliance monitoring scheme as required by ORA.GEN.200(a)(6).
ATOs are required to produce a training plan for each of their courses based on the instructional systems design (ISD) methodology as specified in AMC2 ORA.ATO.230.
Additional guidance on the meaning and taxonomy of the verbs used in the LOs can be found in GM1 FCL.310; FCL.515(b); FCL.615(b); FCL.835(d).
TRAINING AIMS
After completion of the training, a student pilot should:
— be able to understand and apply the subject knowledge in order to be able to identify and manage threats and errors effectively;
— meet at least the Area 100 KSA minimum standard.
INTERPRETATION
The abbreviations used are ICAO abbreviations listed in ICAO Doc 8400 ‘ICAO Abbreviations and Codes’, or those listed in GM1 FCL.010.
Where a LO refers to a definition, e.g. ‘Define the following terms’ or ‘Define and understand’ or ‘Explain the definitions in ...’, candidates are also expected to be able to recognise a given definition.
Below is a table showing the short references to applicable legislation and standards:
Reference |
Legislation/Standard |
The Basic Regulation |
Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 |
The Aircrew Regulation |
Commission Regulation (EU) No 1178/2011 of 3 November 2011 (as amended) |
Part-FCL |
Annex I to Commission Regulation (EU) No 1178/2011 of 3 November 2011 (as amended) |
Part-MED |
Annex IV to Commission Regulation (EU) No 1178/2011 of 3 November 2011 (as amended) |
CS-23, AMC & GM to CS-23, CS-25, CS-27, CS-29, CS-E and CS-Definitions |
Refer to the respective EASA Certification Specifications / AMC & GM |
Single European Sky Regulations |
Regulation (EC) No 549/2004 of the European Parliament and of the Council of 10 March 2004 laying down the framework for the creation of the single European sky (the framework Regulation) Regulation (EC) No 550/2004 of the European Parliament and of the Council of 10 March 2004 on the provision of air navigation services in the single European sky (the service provision Regulation) Regulation (EC) No 551/2004 of the European Parliament and of the Council of 10 March 2004 on the organisation and use of the airspace in the single European sky (the airspace Regulation) Regulation (EC) No 552/2004 of the European Parliament and of the Council of 10 March 2004 on the interoperability of the European Air Traffic Management network (the interoperability Regulation) |
Passenger Rights Regulation |
Regulation (EC) No 261/2004 of the European Parliament and of the Council of 11 February 2004 establishing common rules on compensation and assistance to passengers in the event of denied boarding and of cancellation or long delay of flights, and repealing Regulation (EEC) No 295/91 |
RTCA/EUROCAE |
Refers to correspondingly numbered documents issued by the Radio Technical Commission for Aeronautics/ European Organisation for Civil Aviation Equipment |
ITU Radio Regulation |
International Telecommunication Union Radio Regulation |
NASA TM-85652 |
National Aeronautics and Space Administration — Technical Memorandum 85652 |
‘Applicable operational requirements’ refers to, for the ATPL(A), CPL(A), ATPL(H)/IR, ATPL(H)/VFR, CPL(H), IR and CBIR, Annexes I, II, III, IV, V and VIII to Commission Regulation (EU) No 965/2012 of 5 October 2012 (as amended). For the BIR, it refers to Annexes I, II, V and VII to that Regulation.
The General Student Pilot Route Manual (GSPRM) contains planning data plus aerodrome and approach charts that may be used in theoretical knowledge training courses. The guidelines on its content can be found in this AMC, before the LO table for Subject 033 ‘Flight planning and monitoring’.
Excerpts from any aircraft manuals including but not limited to CAP 696, 697 and 698 for aeroplanes, and CAP 758 for helicopters may be used in training. Where questions refer to excerpts from aircraft manuals, the associated aircraft data will be provided in the examinations.
Some numerical data (e.g. speeds, altitudes/levels and masses) used in questions for theoretical knowledge examinations may not be representative for helicopter operations, but the data is satisfactory for the calculations required.
Note: In all subject areas, the term ‘mass’ is used to describe a quantity of matter, and ‘weight’ when describing the force. However, the term ‘weight’ is normally used in aviation to colloquially describe mass. The pilot should always note the units to determine whether the term ‘weight’ is being used to describe a force (e.g. unit newton) or quantity of matter (e.g. unit kilogram).
DETAILED THEORETICAL KNOWLEDGE SYLLABUS AND LOs FOR ATPL, CPL, IR, CB-IR(A) and BIR
GENERAL
The detailed theoretical knowledge syllabus outlines the topics that should be taught and examined in order to meet the theoretical knowledge requirements appropriate to ATPL, MPL, CPL, IR, CB-IR(A) and BIR.
For each topic in the detailed theoretical knowledge syllabus, one or more LOs are set out in the appendices as shown below:
— Appendix 021 AIRCRAFT GENERAL KNOWLEDGE – AIRFRAME, SYSTEMS AND POWER PLANT
— Appendix 022 AIRCRAFT GENERAL KNOWLEDGE – INSTRUMENTATION
— Appendix 031 FLIGHT PERFORMANCE AND PLANNING – MASS AND BALANCE
— Appendix 032 FLIGHT PERFORMANCE AND PLANNING – PERFORMANCE – AEROPLANES
— Appendix 033 FLIGHT PERFORMANCE AND PLANNING – FLIGHT PLANNING AND MONITORING
— Appendix 034 FLIGHT PERFORMANCE AND PLANNING – PERFORMANCE – HELICOPTERS
— Appendix 040 HUMAN PERFORMANCE AND LIMITATIONS
— Appendix 061 NAVIGATION – GENERAL NAVIGATION
— Appendix 062 NAVIGATION – RADIO NAVIGATION
— Appendix 070 OPERATIONAL PROCEDURES
— Appendix 081 PRINCIPLES OF FLIGHT – AEROPLANES
— Appendix 082 PRINCIPLES OF FLIGHT – HELICOPTERS
— Appendix 090 RADIO COMMUNICATIONS
— Appendix AREA 100 KNOWLEGDE, SKILLS AND ATTITUDES (KSA)
(b) Airships
SYLLABUS OF THEORETICAL KNOWLEDGE FOR CPL AND IR
The applicable items for each licence or rating are marked with ‘x’. An ‘x’ on the main title of a subject means that all the subdivisions are applicable.'
|
CPL |
IR |
|
1. |
AIR LAW AND ATC PROCEDURES |
x |
|
|
INTERNATIONAL LAW: CONVENTIONS, AGREEMENTS AND ORGANISATIONS |
|
|
|
AIRWORTHINESS OF AIRCRAFT |
|
|
|
AIRCRAFT NATIONALITY AND REGISTRATION MARKS |
|
|
|
PERSONNEL LICENSING |
|
x |
|
RULES OF THE AIR |
|
x |
|
PROCEDURES FOR AIR NAVIGATION SERVICES: AIRCRAFT OPERATIONS |
|
x |
|
AIR TRAFFIC SERVICES AND AIR TRAFFIC MANAGEMENT |
|
x |
|
AERONAUTICAL INFORMATION SERVICE |
|
x |
|
AERODROMES |
|
x |
|
FACILITATION |
|
|
|
SEARCH AND RESCUE |
|
|
|
SECURITY |
|
|
|
AIRCRAFT ACCIDENT AND INCIDENT INVESTIGATION |
|
|
2. |
AIRSHIP GENERAL KNOWLEDGE: ENVELOPE, AIRFRAME AND SYSTEMS, ELECTRICS, POWERPLANT AND EMERGENCY EQUIPMENT |
x |
|
|
DESIGN, MATERIALS, LOADS AND STRESSES |
|
|
|
ENVELOPE AND AIRBAGS |
|
|
|
FRAMEWORK |
|
|
|
GONDOLA |
|
|
|
FLIGHT CONTROLS |
|
|
|
LANDING GEAR |
|
|
|
HYDRAULICS AND PNEUMATICS |
|
|
|
HEATING AND AIR CONDITIONING |
|
|
|
FUEL SYSTEM |
|
|
|
PISTON ENGINES |
|
|
|
TURBINE ENGINES (BASICS) |
|
|
|
ELECTRICS |
|
|
|
FIRE PROTECTION AND DETECTION SYSTEMS |
|
|
|
MAINTENANCE |
|
|
3. |
AIRSHIP GENERAL KNOWLEDGE: INSTRUMENTATION |
x |
|
|
SENSORS AND INSTRUMENTS |
|
|
|
MEASUREMENT OF AIR DATA AND GAS PARAMETERS |
|
|
|
MAGNETISM: DIRECT READING COMPASS AND FLUX VALVE |
|
|
|
GYROSCOPIC INSTRUMENTS |
|
|
|
COMMUNICATION SYSTEMS |
|
|
|
ALERTING SYSTEMS |
|
|
|
INTEGRATED INSTRUMENTS: ELECTRONIC DISPLAYS |
|
|
|
FLIGHT MANAGEMENT SYSTEM (GENERAL BASICS) |
|
|
|
DIGITAL CIRCUITS AND COMPUTERS |
|
|
4. |
FLIGHT PERFORMANCE AND PLANNING |
x |
|
4.1. |
MASS AND BALANCE: AIRSHIPS |
x |
|
|
PURPOSE OF MASS AND BALANCE CONSIDERATIONS |
|
|
|
LOADING |
|
|
|
FUNDAMENTALS OF CG CALCULATIONS |
|
|
|
MASS AND BALANCE DETAILS OF AIRCRAFT |
|
|
|
DETERMINATION OF CG POSITION |
|
|
|
PASSENGER, CARGO AND BALLAST HANDLING |
|
|
4.2. |
FLIGHT PLANNING AND FLIGHT MONITORING |
|
|
|
FLIGHT PLANNING FOR VFR FLIGHTS |
x |
|
|
FLIGHT PLANNING FOR IFR FLIGHTS |
|
x |
|
FUEL PLANNING |
x |
x |
|
PRE-FLIGHT PREPARATION |
x |
x |
|
ATS FLIGHT PLAN |
x |
x |
|
FLIGHT MONITORING AND IN-FLIGHT RE-PLANNING |
x |
x |
4.3. |
PERFORMANCE: AIRSHIPS |
x |
|
|
AIRWORTHINESS REQUIREMENTS |
|
|
|
BASICS OF AIRSHIP PERFORMANCE |
|
|
|
DEFINITIONS AND TERMS |
|
|
|
STAGES OF FLIGHT |
|
|
|
USE OF FLIGHT MANUAL |
|
|
5. |
HUMAN PERFORMANCE |
x |
|
|
HUMAN FACTORS: BASIC CONCEPTS |
|
|
|
BASIC AVIATION PHYSIOLOGY AND HEALTH MAINTENANCE |
|
|
|
BASIC AVIATION PSYCHOLOGY |
|
|
6. |
METEOROLOGY |
x |
|
|
THE ATMOSPHERE |
|
|
|
WIND |
|
|
|
THERMODYNAMICS |
|
|
|
CLOUDS AND FOG |
|
|
|
PRECIPITATION |
|
|
|
AIR MASSES AND FRONTS |
|
|
|
PRESSURE SYSTEMS |
|
|
|
CLIMATOLOGY |
|
|
|
FLIGHT HAZARDS |
|
|
|
METEOROLOGICAL INFORMATION |
|
|
7. |
NAVIGATION |
|
|
7.1. |
GENERAL NAVIGATION |
x |
|
|
BASICS OF NAVIGATION |
|
|
|
MAGNETISM AND COMPASSES |
|
|
|
CHARTS |
|
|
|
DR NAVIGATION |
|
|
|
IN-FLIGHT NAVIGATION |
|
|
7.2. |
RADIO NAVIGATION |
|
|
|
BASIC RADIO PROPAGATION THEORY |
x |
x |
|
RADIO AIDS |
x |
x |
|
RADAR |
x |
x |
|
INTENTIONALLY LEFT BLANK |
|
|
|
AREA NAVIGATION SYSTEMS AND RNAV/FMS |
|
x |
|
GNSS |
x |
x |
8. |
OPERATIONAL PROCEDURES AIRSHIP |
x |
|
|
GENERAL REQUIREMENTS |
|
|
|
SPECIAL OPERATIONAL PROCEDURES AND HAZARDS (GENERAL ASPECTS) |
|
|
|
EMERGENCY PROCEDURES |
|
|
9. |
PRINCIPLES OF FLIGHT |
x |
|
9.1. |
PRINCIPLES OF FLIGHT: AIRSHIPS |
x |
|
|
BASICS OF AEROSTATICS |
|
|
|
BASICS OF SUBSONIC AERODYNAMICS |
|
|
|
AERODYNAMICS OF AIRSHIPS |
|
|
|
STABILITY |
|
|
|
CONTROLLABILITY |
|
|
|
LIMITATIONS |
|
|
|
PROPELLERS |
|
|
|
BASICS OF AIRSHIP FLIGHT MECHANICS |
|
|
10. |
COMMUNICATIONS |
|
|
10.1. |
VFR COMMUNICATIONS |
x |
|
|
DEFINITIONS |
x |
|
|
GENERAL OPERATING PROCEDURES |
x |
|
|
RELEVANT WEATHER INFORMATION TERMS (VFR) |
x |
|
|
ACTION REQUIRED TO BE TAKEN IN CASE OF COMMUNICATION FAILURE |
x |
|
|
DISTRESS AND URGENCY PROCEDURES |
x |
|
|
GENERAL PRINCIPLES OF VHF PROPAGATION AND ALLOCATION OF FREQUENCIES |
x |
|
10.2. |
IFR COMMUNICATIONS |
|
|
|
DEFINITIONS |
|
x |
|
GENERAL OPERATING PROCEDURES |
|
x |
|
ACTION REQUIRED TO BE TAKEN IN CASE OF COMMUNICATION FAILURE |
|
x |
|
DISTRESS AND URGENCY PROCEDURES |
|
x |
|
RELEVANT WEATHER INFORMATION TERMS (IFR) |
|
x |
|
GENERAL PRINCIPLES OF VHF PROPAGATION AND ALLOCATION OF FREQUENCIES |
|
x |
|
MORSE CODE |
|
x |
GM1 FCL.310; FCL.515(b); FCL.615(b); FCL.835(d) Theoretical knowledge examinations
ED Decision 2020/018/R
EXPLANATION OF THE VERBS USED IN THE BENJAMIN BLOOM TAXONOMY
(a) The depth or level of learning to be achieved during the training and the corresponding level of attainment to be examined or assessed is based on the following taxonomy. In each case, the level of knowledge or skill is signified by the learning objective (LO) verb.
(b) The majority of the LOs relate to the cognitive domain. The taxonomy described by B. Bloom (1956) and Anderson & Krathwohl (2001) has been used as the standard.
(c) The six sequential increasing levels of required cognitive learning are identified by the LO verb. Hence the lowest level ‘remember’ is signified by verbs such as ‘state’, ‘list’, ‘define’ and ‘recall’ whilst the next higher level of ‘understand’ is signified by verbs such as ‘describe’ and ‘explain’. The third level of ‘apply’ is signified by the verbs ‘calculate’, ‘interpret’, ‘relate’ and ‘solve’. However, the higher levels of ‘analyse’, which would be signified by the verbs ‘plan’ or ‘discuss’ and ‘evaluate’ and ‘create’ are less common due at least partially to questions presently possible in the ECQB examination.
(d) The LOs used in Area 100 KSA differ in that they require a combination of knowledge and skills. However, the ‘skill’ level does not relate to Bloom’s psychomotor taxonomy but is more closely aligned to the higher taxonomy levels required in medicine, because knowledge and skills must be combined by the student pilot in a strategy.
(e) The verbs ‘demonstrate’ and ‘show’, with their meanings defined below, have therefore been used to supplement the cognitive LO verbs for the Area 100 KSA LOs.
(1) ‘Demonstrate’ means the selection and use of the appropriate knowledge, skills and attitudes within a strategy to achieve an effective outcome. It signifies a high taxonomy level and would normally be assessed using multiple indicators from more than one core competency.
(2) ‘Show’ means the attainment of knowledge, skill or attitude. It signifies a lower taxonomy level than ‘demonstrate’ and would normally be assessed by a single indicator.’
AMC1 FCL.615(b) IR – Theoretical knowledge and flight instruction
ED Decision 2020/018/R
SYLLABUS OF THEORETICAL KNOWLEDGE FOR THE IR FOLLOWING THE COMPETENCY-BASED MODULAR COURSE AND BIR
(a) The syllabus for the theoretical knowledge instruction and examination for the ATPL, MPL, CPL and IR in AMC1 FCL.310; FCL.515(b); FCL.615(b), FCL.835(d) should be used for the CB-IR(A) and the BIR respectively.
(b) Aspects related to threat and error management (TEM) should be included in an integrated manner, taking into account the particular risks associated to the licence and the activity.
(c) An applicant who has completed a modular IR(A) course according to Appendix 6 Section A and passed the IR(A) theoretical knowledge examination should be fully credited towards the requirements of theoretical knowledge instruction and examination for a competency-based IR(A) or EIR within the validity period of the examination. An applicant wishing to transfer to a competency-based IR(A) or BIR course during a modular IR(A) course should be credited towards the requirements of theoretical knowledge instruction and examination for a competency-based IR(A) or BIR for those subjects or theory items already completed.
Regulation (EU) 2021/2227
Applicants for an IR shall pass a skill test in accordance with Appendix 7 to this Annex to demonstrate their ability to perform the relevant procedures and manoeuvres with a degree of competency appropriate to the privileges granted.
FCL.625 IR – Validity, revalidation and renewal
Regulation (EU) 2020/2193
(a) Validity
An IR shall be valid for 1 year.
(b) Revalidation
(1) An IR shall be revalidated within the 3 months immediately preceding its expiry date by complying with the revalidation criteria for the relevant aircraft category.
(2) If applicants choose to fulfil the revalidation requirements earlier than prescribed in point (1), the new validity period shall commence from the date of the proficiency check.
(3) Applicants who fail to pass the relevant section of an IR proficiency check before the expiry date of the IR shall exercise the IR privileges only if they have passed the IR proficiency check.
(4) Applicants for the revalidation of an IR shall receive full credits for the proficiency check as required in this Subpart when they complete EBT practical assessment in accordance with Appendix 10 related to the IR at an EBT operator.
(c) Renewal
If an IR has expired, in order to renew their privileges, applicants shall comply with all of the following:
(1) in order to determine whether refresher training is necessary for the applicant to reach the level of proficiency needed to pass the instrument element of the skill test in accordance with Appendix 9, they shall undergo an assessment at either of the following organisations:
(i) at an ATO;
(ii) at an EBT operator that is specifically approved for such refresher training;
(2) if deemed necessary by the organisation providing the assessment in accordance with point (1), they shall complete refresher training at that organisation;
(3) after complying with point (1) and, as applicable, point (2), they shall pass a proficiency check in accordance with Appendix 9 or complete EBT practical assessment in accordance with Appendix 10 in the relevant aircraft category. That EBT practical assessment may be combined with the refresher training specified in point (2);
(4) they shall hold the relevant class or type rating unless specified otherwise in this Annex.
(d) If the IR has not been revalidated or renewed in the preceding 7 years, applicants for the IR shall pass again the IR theoretical knowledge examination and skill test.
(e) Holders of a valid IR on a pilot licence issued by a third country in accordance with Annex 1 to the Chicago Convention shall be exempted from complying with the requirements in points (c)(1), (c)(2) and (d) when renewing the IR privileges contained in licences issued in accordance with this Annex.
(f) The proficiency check specified in point (c)(3) may be combined with a proficiency check performed for the renewal of the relevant class or type rating.
AMC1 FCL.625(c) IR – Validity, revalidation and renewal
ED Decision 2017/022/R
RENEWAL OF INSTRUMENT RATING AT AN APPROVED TRAINING ORGANISATION (ATO): REFRESHER TRAINING
(a) The objective of the refresher training at an ATO is to reach the level of proficiency needed to pass the instrument rating proficiency check, as described in Appendix 9, or the instrument rating skill test as described in Appendix 7 to Part-FCL, as applicable. The amount of refresher training needed should be determined by the ATO on a case-by-case basis, taking into account the following factors:
(1) the experience of the applicant;
(2) the amount of time elapsed since the privileges of the rating were last used;
(3) the complexity of the aircraft;
(4) whether the applicant has a current rating on another aircraft type or class; and
(5) where considered necessary, the performance of the applicant during a simulated proficiency check for the rating in a flight simulation training device (FSTD) or an aircraft of a relevant type or class.
The amount of training needed to reach the desired level of competency should increase with the time elapsed since the privileges of the rating were last used.
(b) Once the ATO has determined the needs of the applicant, it should develop an individual training programme based on the ATO’s approved course for the rating and focusing on those aspects where the applicant has shown the greatest needs. Theoretical-knowledge instruction should be included, as necessary. The performance of the applicant should be reviewed during the training, and additional instruction should be provided where necessary to reach the standard required for the proficiency check.
(c) After successful completion of the training, the ATO should provide a training completion certificate to the applicant, which describes the evaluation of the factors listed under (a) above and the training received, and includes a statement that the training has been successfully completed. The training completion certificate should be presented to the examiner prior to the proficiency check. Following the successful renewal of the rating, the training completion certificate and examiner report form should be submitted to the competent authority.
(d) Taking into account the factors listed in (a) above, an ATO may also decide that the applicant already possesses the required level of proficiency and that no refresher training is necessary. In such a case, the certificate or other documental evidence referred to in point (c) above should contain a respective statement including sufficient reasoning.