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What can an IRI instruct for (and on what aircraft)

I am an EASA FI/IRI and also hold a 61.75 FAA Airman Certificate with PPL and IR privileges.

So I can and have instructed for both CB-IR and IR(R) ratings at an ATO and DTO respectively, on EASA aircraft, which is clearly within scope of this instructor rating.

But this thread and this thread, explore the wider scope of what is/isn’t allowed and I wondered what the actual limits are. I’ve made my best guess below and would appreciate any corrections/clarifications/confirmation from others.

IR(R)/IMC
I believe I can instruct the entire course outside a DTO, anywhere in the world (subject to employment visa etc. if I was paid). This can be on any EASA registered aircraft, including a group share/privately owned or a Permit aircraft, so long as it is IFR approved. It doesn’t have to be owned/operated by the student. Some of the early training could be done on a VFR only aircraft.

It’s also possible for me to instruct for the IR(R) on an N-Reg (or other non-EASA country aircraft), without requiring permission from the Department of Transport. If someone other than an owner is being trained, then the last 100 hour service must have been done by a certified engineer.

CB-IR
Any training outside the 10 hour minimum with an ATO, which counts towards the 40 hour minimum IFR required. Can be flown on an EASA or N-Reg (only within UK because I don’t have FAA CFII). It is generally a good idea that the training records and checks etc. are in the same format as the subsequent ATO training to make it more seamless/productive, but the training itself is not constrained to the ATO’s declared airfield base (or country). This can be ab-initio or for anyone with an IR(R) or FAA IR (including if lapsed).

FAA IR
I believe I could also instruct anyone with an FAA PPL (including piggyback) towards the FAA IR, and the hours would count. This can be in an EASA, N-Reg or other third country aircraft anywhere outside the USA. The final few hours and sign-off as ready for test must be done by an FAA CFI. I have little experience of what’s required for an FAA IR initial skill test, so I wouldn’t advertise myself for anything other than the basic IF skillset.

QUALIFIED/LAPSED IR PILOTS
For EASA-Reg, any instructional flight as PIC plus any (mentoring) flight where I am not PIC, including as safety pilot.
For N-Reg, instructional flights only in the UK (using my EASA FI/IRI rating) plus I can act as Safety Pilot only where I would be legal as PIC, but not in an aircraft (eg complex/type rating) that I don’t have. I can’t conduct an FAA IPC (Instrument Proficiency Check) or EASA IR revalidation which require FAA CFII or EASA CRI/IRE ratings.

EGBJ, United Kingdom

To the extent that I know this, I agree, except I would re-phrase the following

FAA IR
I believe I could also instruct anyone with an FAA PPL (including piggyback) towards the FAA IR, and the hours would count. This can be in an EASA, N-Reg or other third country aircraft anywhere outside the USA. The final few hours and sign-off as ready for test must be done by an FAA CFI. I have little experience of what’s required for an FAA IR initial skill test, so I wouldn’t advertise myself for anything other than the basic IF skillset.

as:

FAA IR
I could also instruct anyone towards the FAA PPL or the FAA IR, doing the required exercises, and the hours would count. Instrument training is acceptable towards the FAA IR even if the pilot did not have the FAA PPL at the time of the flights. The FAA accepts all training done outside the US, with no time limit, and doesn’t care whether it was done within a “school” – even if such training would have to be done via a school if it was to be admissible towards EASA licenses/ratings. Having each lesson signed off by the FI is probably a good idea. This can be in an EASA, N-Reg or other third country aircraft anywhere outside the USA. The final few hours and sign-off as ready for test must be done by an FAA CFI (for the FAA PPL) or an FAA CFII (for the FAA IR). I have little experience of what’s required for an FAA IR initial skill test, so I wouldn’t advertise myself for anything other than the basic IF skillset. Note that the European options for an FAA checkride are severely limited nowadays and the only known DPE has his own extremely specific requirements which practically preclude this type of route.

Administrator
Shoreham EGKA, United Kingdom

DavidC wrote:

If someone other than an owner is being trained, then the last 100 hour service must have been done by a certified engineer.

Could you expand on this as this effectively means a flying school could use an N reg aircraft and I’ve never known that to be the case.

An N-reg requires a 100hr service if a person being trained is not the owner. I don’t recall if money needs to be involved also. @ncyankee may know more.

So, US schools all need the 100hr service, and if you have a busy PA28 then you might see seven of these and then the Annual They can however choose to use a plane just for self fly hire (not for training) and then they don’t need the 100hr service (which is almost a full Annual).

this effectively means a flying school could use an N reg aircraft and I’ve never known that to be the case

That’s correct, because if you tried that, the CAA will come round and shut you down

Actually it hangs on this stuff. A school will never get that permission. In fact I wonder if you could even train in say an F-reg or a D-reg; I’ve never seen such a case even though I have a vague recollection that the CAA permission is not required for EU-regs. @tumbleweed or @Qalupalik might recall more.

Administrator
Shoreham EGKA, United Kingdom

DavidC wrote:

If someone other than an owner is being trained, then the last 100 hour service must have been done by a certified engineer.

That is not a correct interpretation of the regulation quoted below for convenience.

91.409 (b) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection and been approved for return to service in accordance with part 43 of this chapter or has received an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. The 100-hour limitation may be exceeded by not more than 10 hours while en route to reach a place where the inspection can be done. The excess time used to reach a place where the inspection can be
done must be included in computing the next 100 hours of time in service.

See this legal interpretation by the FAA general counsel: here local copy

The 100 hour requirement would apply if the school or FBO renting the aircraft also used one of their instructors, contracted or employed by the FBO/School. The same would be true if a free-lance instructor offered an aircraft or rent that he/she owned and provided the instruction.

Charging for instruction is not the issue.

KUZA

What an excellent response from the Chief Counsel. The chances of getting something like that from some CAA over here is approximately minus zero.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

I’ve never seen such a case even though I have a vague recollection that the CAA permission is not required for EU-regs.

Don’t know about UK, but my OY reg piper was accepted for ATO in Estonia without any problems.

EETU, Estonia
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