I occassionally get asked about this but it's not my area...
Am I right in the following?
Currently, NO freelance instructing is allowed towards any ab initio license or rating in JAA/EASA-land.
Every instructor doing any ab initio instruction has to work via an RF (for PPL, night or the UK IMCR) or an FTO (CPL, IR). These will all be called "ATO" soon.
However, if the CBM IR ever arrives, a freelance IRI might be able to do training towards the 30hrs "instrument time" required for the CBM IR (if/when that arrives). That's if the student has not already logged those 30 hrs some other way (e.g. using IMCR privileges). The other 10hrs of the CBM IR will have to be done at the ATO.
What are the proposed training requirements for the EIR?
Some revalidation work can be done freelance. The PPL and IMCR revals can be done freelance. The JAA/EASA IR annual reval flight can be done by a freelance CRE/IRR or FE but only if the IR has not lapsed by more than 3 months otherwise you are back into the clutches of an ATO.
The obvious question is how easy it is for a freelance/casual instructor to get himself/herself "attached" to an ATO. Presumably the ATO has a very limited commercial incentive to have a load of freelance instructors on its books, unless it charges them decent money.
The obvious question is how easy it is for a freelance/casual instructor to get himself/herself "attached" to an ATO. Presumably the ATO has a very limited commercial incentive to have a load of freelance instructors on its books, unless it charges them decent money.
I've been doing just that lately, not that I do a great deal of instructing - but at around 45hrs pa certainly enough to justify my existence and instructors rating (in my case, a CRI rather than IRI), and I enjoy it.
I suspect that if I'd just turned up and asked, I'd have been told to turf off. But, I was already a known quantity to both of the schools that I've been freelancing with, and in both cases I'm able to do it because I have skills that most schools don't have in-house. Specifically familiarity with a lot of unusual / permit types and a willingness to instruct on them, plus a familiarity with what it takes to turn microlight into light aeroplane pilots. So I'm really not in competition with anybody else.
From what I can see, instructors who can do "standard stuff" - trial flights, basic NPPL/PPL on common Piper/Cessna types, are fine as staff members if they manage to get a job, but have little potential as freelancers.
An IRI sits somewhere in between I think: particularly as EASA seems hellbent on making becoming an IRI particularly difficult, I think that the qualification will be quite a good one for freelancers, particularly if they're able to competently teach on the less common types - such as your TB20 for example, which would be rather unfamiliar to the majority of conventional-background FIs. Certainly I have a friend who does a good line of IMC training in a smallish school (where I do occasional NPPL(M)-->NPPL(SSEA) conversions, leaving the staff FIs to get on with the core business of PPL training).
G
The problem for IRI freelancers will be to support the quantity of paperwork currently required, or find an ATO willing to do so. I'm currently doing an IR in exactly this scenario (TB20, 'freelance' instructor working within an ATO) and the paperwork has been a real limitation.
Both I and my instructor are based at Gloucestershire but we are unable to do our training there unless the ATO updates their paperwork to include Glos as an additional location. This will probably require an inspection by the CAA to ensure that appropriate facilities (presumably blackboards) are available. Our original plan to clear off to France for a weekend at a time, taking advantage of the cheap approach fees and other benefits, had to be abandoned. We have both had to base ourselves in hotels near the ATO at considerable extra expense.
I don't blame the ATO, as there's not much reason to encourage them to do all this paperwork. And if another student wanted to be based elsewhere with another freelance IRI, it would all have to happen again.
My instructor is working on getting approval for a more generic ops manual for his own ATO, but it's an upstream swim as you can imagine. The intention is to have an umbrella organisation for the freelance IRI scenario. But then you have to consider how you quality assure the freelancers so they don't get the umbrella org into trouble with the CAA. It's all quite a minefield.
Is it true that the UK CAA does not allow IR training to take place outside the UK?
I vaguely recall hearing somewhere that the usual cost-saving approach of flying approaches to Calais or Dieppe is not allowed within the JAA/EASA IR training, via a UK FTO.
Every instructor doing any ab initio instruction has to work via an RF (for PPL, night or the UK IMCR)
Not IMC that's nothing to do with EASA!
Some revalidation work can be done freelance.
All revalidation work can be done freelance and differences training
a freelance IRI might be able to do training towards the 30hrs "instrument time" required
An interesting one if there are any IRIs left!
What are the proposed training requirements for the EIR?
All approved training for a rating must be conducted at an ATO. Approval cost for an IR is currently £1941 + £7431 to assess the FNPTII
The JAA/EASA IR annual reval flight can be done by a freelance CRE/IRR or FE but only if the IR has not lapsed by more than 3 months
If it has lapsed by even an hour, it is now a Renewal and requires an ATO sign off!
The obvious question is how easy it is for a freelance/casual instructor to get himself/herself "attached" to an ATO
Virtually all FIs are self employed, so "attached" is a rather loose word. In many cases former freelance FIs can actually bring work to an ATO that they normally would not have had so it can be advantageous
If it has lapsed by even an hour, it is now a Renewal and requires an ATO sign off!
What happened to the 3 month bit? From my JAA IR writeup:
According to AMC1 FCL.625(c), if the rating has expired by less than three months, no refresher training is required but you still need a certificate issued by an ATO to get the rating renewed. If the period of expiry is less than 3 months there are no recommended minimum requirements for refresher training. However, you will still have to obtain a certificate from an ATO to confirm either that they determined that no training was required or that the required training has been completed.
If the rating has expired by more than three months, there is mandatory refresher training, in accordance with AMC1 FCL.625(c), and the rating has to be re-issued by the CAA, for which there is a fee. In the absence of any approved alternative means of compliance, the requirement is for 1 training session if the rating has expired by less than 1 year and 3 training sessions if the rating has expired by more than 1 but less than 7 years. "Training session" has not been defined and therefore need not necessarily include any flying.
If the rating has expired by more than 7 years, the applicant is required to undergo the full training course for the issue of the IR (as well as re-taking the IR exams).
I suppose what you are saying, now that I have actually read what I had written 
is that between zero and 3 months the ATO has to get involved with the signoff, but they cannot refuse to do that signature. Whereas after 3 months they can determine you need more training, etc.
I wonder how well this works in practice, because e.g. I know for a fact that an FTO can simply refuse to sign a 170A course completion certificate and there is no way you can force them to do it - notwithstanding the fact that they are obliged to give it to you once you have completed the approved 50/55hr course (and then you can book the IRT directly with the CAA, etc).
However, you will still have to obtain a certificate from an ATO to confirm either that they determined that no training was required or that the required training has been completed.
You said it!
notwithstanding the fact that they are obliged to give it to you once you have completed the approved 50/55hr course
Under EASA the candidate must "satisfactorily complete the course as certified on the course completion certificate (in old money F170A) The candidate has no right to claim the course is finished on completion of the minimum hours! It is finished when the ATO specify that the required standard has been reached. The emphasis is placed on the ATO to decide what if any training is necessary and make the test recommendation. Gone are the days of ringing the CAA for an assessment, they don't know anything about training! The ATO is under no obligation to do anything, they decide whether or not they will sign the form. The point is that without it the Examiner cannot conduct the test.
This is potentially quite nasty... thanks for pointing it out, Tumbleweed.
1 day over and if they "don't like your face" you are screwed into a potentially unlimited amount of "flight training" with an FTO instructor.
I recall seeing postings from persons purporting to work in the FTO business who claimed the signoff will be just a formality, which is why I never took any notice of this.
Does anybody have actual experience of their recent IR revalidation, past the 365-day point? I revalidated mine ~6 months ago but didn't go over the deadline. What is the process they use to "determine" you need retraining?
Peter, what is the 'CBM' IR and how is it proposed to work?
Scratch that, I've just read the PPL/IR slides.
