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Training to the IMCR on N Reg

The AOC requirement established in 14 CFR 119 applies to most US-registered civil aircraft wherever they may be. The student instruction exemption from needing an AOC, according to the Chief Counsel opinion given to W W Grannis on 3 Aug 2017, is conditional upon the flight training being towards a rating or certificate established in 14 CFR 61. Only an authorized (sic) instructor may give such flight training.

A person who holds a instructor certificate granted by a Contracting State, who does not hold an appropriate US flight instructor certificate, is an authorized instructor for the purpose of giving flight training towards a certificate or rating established in 14 CFR 61 but only outside the US. See 14 CFR 61.41.

The relevant point for the OP is that the flight training should be creditable towards a US instrument rating. And for the wider community the proposed operation would not be permitted in the US without the appropriate US flight instructor certificate.

Last Edited by Qalupalik at 31 Aug 11:44
London, United Kingdom

For completeness, AIUI, the above post seems to be related to training in an N-reg, if not towards a Part 61 license, requiring a US AOC unless done outside US airspace. So the OP’s proposal is fine.

Administrator
Shoreham EGKA, United Kingdom

The flight should not be a dual purpose operation and the flight training should be creditable towards a certificate or rating in 14 CFR 61. The latter requirement covers the “student instruction” exemption, 14 CFR 119.1(e), from needing an air operator certificate: see a relevant interpretation from the Office of the Chief Counsel here.

London, United Kingdom

Thank you all, very helpful.

EGKB Biggin Hill

The 91.409 100 hour inspection requirement would not apply because the aircraft used for training is provided by the customer and not by you.

Yes; very true. I did spot that but then I forgot The 100hr check is not required unless you train others in your plane.

Administrator
Shoreham EGKA, United Kingdom

In US registry, 91.109 requires that if one is doing simulated instrument, there must be a rated safety pilot. Anytime your 61.75 is valid, you would qualify and if it contains Instrument privileges, you should be able to act as PIC under IFR. IFR relates to the rules, not the conditions, so filing an IFR flightplan and operating under IFR would require you to be PIC. Under the FAA logging provisions, as long as you are acting as PIC and a required crew member, you can log PIC. You would be a required crew member anytime you are operating under IFR or when you are the safety pilot.

I don’t believe that 61.41 would apply, because you are not providing training for a rating under part 61 of the FAR.

The 91.409 100 hour inspection requirement would not apply because the aircraft used for training is provided by the customer and not by you.

So there should be no issues with respect to FAR and it is totally dependent on on the CAA requirements.

KUZA, United States

The plane needs a 100hr service (google the FARs for “100hr” to get the reference). There is no other FAA requirement.

No DfT/CAA permission is required – search EuroGA for CAA permission. This changed about a year ago.

Check the insurance, obviously.

In actual IMC you will need to be PIC.

Administrator
Shoreham EGKA, United Kingdom

Hi Tim, having explored this myself last year before a share in the N-reg disappears, what I say bellow mostly from my discussions with an ATO near London

Timothy wrote:

Do I need permission, from DfT or CAA, to train on the N Reg?

I was told yes (arial work stuff)

Timothy wrote:

Does the IMCR examiner need permission to examine on it?

I was told yes (not sure where this comes from), but as alternative they suggested to do the test in another similar G-reg aircraft

Last Edited by Ibra at 29 Aug 12:05
Paris/Essex, France/UK, United Kingdom

I have an EASA IRI and an FAA PPL with no instructor ratings.

My student has an EASA PPL, but nothing FAA. He has an N Reg Reims Rocket C172.

Do I need permission, from DfT or CAA, to train on the N Reg? Does the IMCR examiner need permission to examine on it?

To be honest, I am looking for a straight factual answer rather than a long discussion on the rights and wrongs.

EGKB Biggin Hill
9 Posts
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