[Human Factor]

As a non-affiliated FI(R) & CRI with minimal opportunity to become affiliated due to the day job, it is difficult to acquire the 25 "supervised" solos (and hard enough to acquire the 100 hours instructing time!!).

While I appreciate there necessarily needs to be an upgrade experience requirement and the 100 hours instructing time is not unreasonable, perhaps some thought should be given to flexing the 25 supervised solos requirement based upon the overall experience of the FI(R).

[AndyR]

I'd agree. I'd gained 450 hours instructing by the time I got my 25 supervised solos. I often wondered why I couldn't count those sent on their first tailwheel solos. Same sort of decision making.

[Hmmnnn]

I often wondered why I couldn't count those sent on their first tailwheel solos. Same sort of decision making.

The answer is easy:
Assuming a valid Licence/Rating Holder then either:
1) You had already Signed Off their Differences Training so they were fully qualified and legally required no Instructor input or supervision; or
2) You had not Signed Off their Differences Training and they were flying illegally.

There is no requirement for 'solo' flight for any Class or Differences Training that I can think of and so no way for any Instructor to 'authorise' such a flight

Of course, if they were not yet a holder of a valid Licence then, as an FI, you could authorise their solo flight as part of the training requirements for Licence issue.

[AndyR]

Yes, my bad wording. However, allowing someone to go fly on their own in something requiring sometimes very different handling from the aircraft they're used to requires the same sort of decision making as that for first solo. Are they going to get themselves and aircraft back on the ground in one piece? Are they going to cope with any emergency?
One could apply the same to a type rating or a test. You're signing someone off as capable of flying something without an instructor on board, albeit that with TW (etc) it is their first flight post differences training. In essence it is still a first solo. Hope that's clearer...

[allout]

"There is no requirement for 'solo' flight for any Class or Differences Training ....."

Indeed.
There's no requirement for dual either.

Class Rating, FCL.725(a) simply specifies '... a training course at an ATO'.
Differences training, FCL.135.A(b) & FCL.710(a), is similar, without the ATO bit.

Elsewhere, throughout Part-FCL, there are many examples of training packages that require both dual and supervised solo.

Please, what indicates that Class Rating or differences training require dual flight training, but not supervised solo training?

[Hmmnnn]

"There is no requirement for 'solo' flight for any Class or Differences Training ....."

Indeed.
There's no requirement for dual either.
Yes there is

Class Rating, FCL.725(a) simply specifies '... a training course at an ATO'.
Differences training, FCL.135.A(b) & FCL.710(a), is similar, without the ATO bit.

Elsewhere, throughout Part-FCL, there are many examples of training packages that require both dual and supervised solo.
No there is not.
It is either Dual Training required or Supervised Solo Experience required

Please, what indicates that Class Rating or differences training require dual flight training, but not supervised solo training? See below

FCL.040 Exercise of the privileges of licences
The exercise of the privileges granted by a licence shall be dependent upon the validity of the ratings contained therein, if applicable, and of the medical certificate.

If a Licence is held then a valid rating is mandatory to act as PIC.

FCL.710 Class and type ratings — variants
(a) In order to extend his/her privileges to another variant of aircraft within one class or type rating, the pilot shall undertake differences or familiarisation training

In an Aircraft: Training = DUAL

As compared with:

FCL.210.A PPL(A) — Experience requirements and crediting
(a) Applicants for a PPL(A) shall have completed at least 45 hours of flight instruction in aeroplanes, 5 of which may have been completed in an FSTD, including at least:
(1) 25 hours of dual flight instruction; and
(2) 10 hours of supervised solo flight time, including at least 5 hours of solo cross-country flight time with at least 1 cross-country flight of at least 270 km (150 nm)

Minimum Experience requirements = 45 Hours Total Flight Time, that must include 10 Hours Solo Flight Time (that must include 5 Hours of Solo Nav, including at least one 270 km flight) and 25 Hours of Dual Training
Same argument for the Night Rating (There are some Dual Training requirements listed as part of the required Experience requirements, which also include some supervised Solo requirements - 5 x T/O & Lndg).

All Class Rating Instruction requires Dual Training, none require Solo Experience.

FCL.720.A Experience requirements and prerequisites for the issue of class or type ratings — aeroplanes
(a) Single-pilot multi-engine aeroplanes. An applicant ... shall have completed at least 70 hours as PIC on aeroplanes.
(b) Single-pilot high performance non-complex aeroplanes. Before starting flight training, an applicant ... shall:
(1) have at least 200 hours of total flying experience, of which 70 hours as PIC on aeroplanes

These are the only two examples I can find that have any experience requirements - but it is not a requirement for the Class Rating being trained for (indeed (b) says they must have met the requirement before even starting the course); so the only way an Instructor could act as supervisor for the gaining of this experience requirement is if the 'student' did not hold a valid Licence (and preferably that the Solo PIC was required for Licence Issue)

[allout]

Thank you Hmmnnn, useful,

Can we be sure that "Training = DUAL"?

The extract you quoted says that 'flight instruction' includes both 'dual flight instruction' and 'supervised solo'

FCL.210.A PPL(A) — Experience requirements and crediting
(a) Applicants for a PPL(A) shall have completed at least 45 hours of flight instruction in aeroplanes, 5 of which may have been completed in an FSTD, including at least:
(1) 25 hours of dual flight instruction; and
(2) 10 hours of supervised solo flight time, including ..............................

[Paul_Sengupta]

Indeed Hmmnnn, you seem to have posted something contradicting what you want to say.

It seems that if "dual flight instruction" is needed, they're quite categorical about that and state it explicitly. For differences or familiarisation training they deliberately (or not) leave out "dual flight instruction".

[Hmmnnn]

Indeed Hmmnnn, you seem to have posted something contradicting what you want to say.

It seems that if "dual flight instruction" is needed, they're quite categorical about that and state it explicitly. For differences or familiarisation training they deliberately (or not) leave out "dual flight instruction".

Not so, although I do agree it would have been better if EASA had used more consistent language throughout Part-FCL.

'Flight Instruction', 'Dual Flight Instruction' and 'Supervised Solo Flight Time' are terms that are only used in Part-FCL when describing Licence or Night Rating requirements (none of which fall within the remit of a CRI).

The requirements for Class Ratings are all listed as 'Training'.
DUAL = PUT = Pilot Under Training.

Why would any Instructor (even if they truly believed it would be useful) think they had the authority to override Part-FCL.040 unless this was expressly permitted in a different section of Part-FCL? Why limit this imagined authority to solo flight only? Why not let the student take a friend along for moral support?

[allout]

Thank you again, Hmmmnn, once again useful.
Could I quote some dry extracts before adding a personal bit?

"Why would any Instructor (even if they truly believed it would be useful) think they had the authority to override Part-FCL.040 unless this was expressly permitted in a different section of Part-FCL?"

Here's FCL.040 in full:
FCL.040 Exercise of the privileges of licences
The exercise of the privileges granted by a licence shall be dependent upon the validity of the ratings contained therein, if applicable, and of the medical certificate.

Here's the very first clause of the common requirements for class & type ratings (Section 1 of Subpart H), again in full:

FCL.700 Circumstances in which class or type ratings are required
(a) Except in the case of the LAPL, SPL and BPL, holders of a pilot licence shall not act in any capacity as pilots of an aircraft unless they have a valid and appropriate class or type rating, except when undergoing skill tests, or proficiency checks for renewal of class or type ratings, or receiving flight instruction.

As we have already seen, in Part-FCL:
Flight instruction = Dual flight instruction + supervised solo flight time

This formulation is specific (& consistent) across many training courses:
FCL.110.A & FCL.135.A & FCL.110.H & FCL.135.H & FCL.110.S & FCL.135.S & FCL.110.B & FCL.210.A & FCL.210.H & FCL.210.As & FCL.210.B

Please, why conclude that the unspecified training required by FCL.725(a) should exclude supervised solo?

Last quote now:
FCL.905.CRI CRI — Privileges and conditions
(a) The privileges of a CRI are to instruct for:
(1) the issue, revalidation or renewal of a class or type rating for non-complex non-high performance single-pilot aeroplanes, when the privileges sought by the applicant are to fly in single-pilot operations;

Please, why conclude that this instruction should not include flight instruction for class ratings?
..... and we've seen what flight instruction includes .....

Now the personal bit:
Having been involved in flying training for a long time now, I repeatedly see students learn far more from solo flying than when with an instructor.

[Hmmnnn]

Hello allout,

FCL.040 Exercise of the privileges of licences
The exercise of the privileges granted by a licence shall be dependent upon the validity of the ratings contained therein, if applicable, and of the medical certificate.

An LAPL/PPL Holder flying PIC at night without a Night Rating, any Licence Holder flying PIC in IMC without some form of Instrument Qualification or any PPL/CPL/ATPL Holder flying any aircraft PIC for which they do not hold a Class Rating can not be exercising their Licence privileges. Effectively their Licence is not valid for that flight and CRIs do not have the privilege to instruct for Licences.

Please, why conclude that the unspecified training required by FCL.725(a) should exclude supervised solo?

Because of FCL.040 which is very clear. Because the ability for FIs to authorise supervised solo flight is clearly stated, but it takes a great deal of wishful interpretation to believe that CRIs may authorise any form of unqualified PIC flight.

Do you also believe that IRIs may authorise solo flight in to IMC for pilots without a valid Instrument Qualification?

I repeatedly see students learn far more from solo flying than when with an instructor

I agree, which is why a PPL is often called a 'Licence to Learn', but this is experience gaining, not training. I've even benefitted myself from practicing various required course elements as PIC - but I was fully qualified to be PIC in the aircraft at the time.

Having been involved in flying training for a long time now

Genuine question:
Are you, perhaps, relying on what, in your experience, has always been done rather than what the rules, from 17/09/12, allow to be done?

[Paul_Sengupta]

The requirements for Class Ratings are all listed as 'Training'.
DUAL = PUT = Pilot Under Training.

I agree that dual flight training IS training. But I also suggest that ground training is also training. So is going down the gym and using a rowing machine. It says "the pilot shall undertake differences or familiarisation training". So the pilot needs to be trained in what the differences are. Logic doesn't work the other way round, that because dual flight training is training, that all training is dual flight training. That isn't how English or logic works.

I'm not saying it isn't a good idea or that for a particular person it isn't deemed necessary, just that it doesn't specifically say "dual flight instruction".

I'm just arguing semantics here, I doubt that most people would forgo the pleasure of dual flight instruction for something like tailwheel, but for something like glass panel, flight instruction for the differences is perhaps unnecessary.

[Hmmnnn]

In the UK a Class Rating Instructor has never had the privilege to authorise unqualified (solo) flight:

CAP393 ANO 14 April 2010
Flight crew licence requirement – Exception for solo flying training
52 (1) A person may act as pilot in command of an aircraft for the purpose of becoming qualified for the grant or renewal of a pilot's licence or the inclusion or variation of any rating in a pilot's licence within the United Kingdom, the Channel Islands and the Isle of Man, without being the holder of an appropriate licence granted or rendered valid under this Order, if the conditions in paragraph (2) are satisfied.
(2) The conditions referred to in paragraph (1) are that:
(f) the person acts in accordance with instructions given by another person holding a pilot's licence granted under this Order or a JAA licence, in each case being a licence which includes a flight instructor rating, a flying instructor's rating or an assistant flying instructor's rating entitling that other person to give instruction in flying the type of aircraft being flown.

and they still don't:

1) Non-EASA

CAP393 ANO May 2014
Flight crew licence requirement – Exception for solo flying training in non-EASA aircraft
52 (1) A person may act as pilot in command of a non-EASA aircraft for the purpose of becoming qualified for the grant or renewal of a pilot’s licence or the inclusion or variation of any rating in a pilot’s licence within the United Kingdom, the Channel Islands and the Isle of Man, without being the holder of an appropriate licence granted or rendered valid under this Order, if the conditions in paragraph (2) are satisfied.
(2) The conditions referred to in paragraph (1) are that:
(f) the person acts in accordance with instructions given by another person holding a pilot’s licence granted under this Order or a Part-FCL licence, in each case being a licence which includes a flight instructor rating, a flying instructor’s rating or an assistant flying instructor’s rating entitling that other person to give instruction in flying the type of aircraft being flown.

2) EASA

FCL.040 Exercise of the privileges of licences
The exercise of the privileges granted by a licence shall be dependent upon the validity of the ratings contained therein, if applicable, and of the medical certificate.

[172510]

LAPL give more opportunities for supervised solo.
Strange that solo is authorised to regain recency, or to train to a different variant, for a LAPL holder and not for a PPL holder

Difference training:
FCL.135.A LAPL(A) — Extension of privileges to another class or variant of aeroplane
(a) The privileges of an LAPL(A) shall be limited to the class and variant of aeroplanes or TMG in which the skill test was taken. This limitation may be removed when the pilot has completed in another class the requirements below:
(1) 3 hours of flight instruction, including: (i) 10 dual take-offs and landings, and
(ii) 10 supervised solo take-offs and landings.

FCL.140.A LAPL(A) — Recency requirements
(a) Holders of an LAPL (A) shall only exercise the privileges of their licence when they have completed, in the last 24 months, as pilots of aeroplanes or TMG:
(1) at least 12 hours of flight time as PIC, including 12 take-offs and landings; and
(2) refresher training of at least 1 hour of total flight time with an instructor.
(b) Holders of an LAPL(A) who do not comply with the requirements in (a) shall:
(1) undertake a proficiency check with an examiner before they resume the exercise of the privileges of their licence; or
(2) perform the additional flight time or take-offs and landings, flying dual or solo under the supervision of an instructor, in order to fulfil the requirements in (a).

For instance a PPL SEP who wants TW is not allowed to fly solo under supervision. He must have his logbook signed off for good if he wants to fly as PIC, solo or not.
A LAPL who wants TW must fly solo under supervision first.
In very similar cases, solo is mandatory for LAPL and forbidden for PPL.
Does it make sense?

[Hmmnnn]

LAPL give more opportunities for supervised solo. Theoretically, possibly yes for an FI

Strange that solo is authorised to regain recency, or to train to a different variant not sure that it is, for a LAPL holder and not for a PPL holder Recency is a Licence requirement for LAPL whereas a PPL must have a valid Rating - different rules (the way Part-FCL is written even a pass in a Proficiency Check for an LAPL holder does not remove the requirement to still meet the Recency requirements)

A LAPL who wants TW must fly solo under supervision first. No
In very similar cases, solo is mandatory for LAPL and forbidden for PPL.No
Does it make sense? Yes, but...........

FCL.135.A LAPL(A) is very badly written (so you need to read it in its entirety) in that Paragraph(a) states the class and variant limitations in the first sentence then, in the second sentence states how to add the privilege for another class (including the requirement to pass a Skill Test).
Any instruction for this class privilege extension to the Licence (not Class Rating) would need to be given by an FI.

How to add privileges for variants is stated separately in Paragraph(b)
No solo is required and a CRI is certainly an 'appropriate' Instructor Rating for this training

FCL.135.A LAPL(A) — Extension of privileges to another class or variant of aeroplane
(a) The privileges of an LAPL(A) shall be limited to the class and variant of aeroplanes or TMG in which the skill test was taken. This limitation may be removed when the pilot has completed in another class the requirements below:

(1) 3 hours of flight instruction, including:
__(i) 10 dual take-offs and landings; and
__(ii) 10 supervised solo take-offs and landings.
(2) a skill test to demonstrate an adequate level of practical skill in the new class…..

(b) Before the holder of an LAPL can exercise the privileges of the licence on another variant of aeroplane than the one used for the skill test, the pilot shall undertake differences or familiarisation training. The differences training shall be entered in the pilot’s logbook or equivalent document and signed by the instructor.