Today I received my Ground and Revalidation Examiner authorisation from the CAA as an early Christmas present. This will allow me to conduct theory exams at the two flying clubs where I instruct (but not elsewhere), having been sponsored by both.
Ground and Revalidation Examiner approval process
The CAA turned this around in a couple of weeks. Application sent by email on 9th December, card charged on 23rd, paperwork by post received 24th. There is no receipt provided which would have been handy when reclaiming the fee from the clubs. Since the authorisation can’t be used anywhere other than the sponsoring clubs, it does seem reasonable to reclaim it.
This is not for the commercial theory exams (CPL, IR and ATPL) held at a few tightly regulated locations around the country but instead for PPL/LAPL exams which are also valid for the NPPL(SSEA and SLMG) as well as the IRR. An online eExam system was introduced last year which handles all these apart from the IRR theory exam that remains on paper.
I’m trying to be objective as I learn more about the process and the way students prepare for theory tests. Although I instruct regularly, I have not yet been very involved in the running of exams.
CAA Standards Document 11 details the requirements for Ground Examiner authorisation, with user guides for the system spread across several CAP1903 documents.
For flying schools, CAA authorisation is required as follows
- Any Approved or Designated Training Organisation (ATO/DTO) can apply to the CAA to conduct theory exams.
- A Custodian of Examination Papers (CEP), typically the Head of Training or Chief Flying Instructor, supervises the administration and safeguards any written papers.
- Additional Ground Examiners can be authorised to conduct the exams in the absence of the Custodian.
As you would expect, a separate application must be made for each of the above and a fee paid.
I was sent a “Licensing Certificate” in the post, clearly marked “This is not a Licence”, although it does look remarkably like one. The subtle distinction between being licensed or authorised is lost on me. A bit like that between Certified and Certificated Flight Instructors in the USA. At least it didn’t involve reprinting my flying licence rating page with the usual ~£100 fee and the added risk of errors.
There was also a separate smaller piece of paper that listed the Ground Examiner Authorisation, stating which DTOs it was valid for and the expiry date three years from now.
It seems to me that this could do with a refresh to make it more easily comprehensible. It references dates in 2012 and 2015 after which privileges are withdrawn, JAA licences (which all expired in 2017) and includes authorisation for exams towards Seaplane Ratings (which I am not qualified to instruct for) but excludes those towards Microlight Ratings. It also doesn’t explicitly mention whether I can certify Identification Documents, Licence Rating pages or exam results used for licence and rating applications.
It also doesn’t mention what to do next. I forwarded my authorisation certificate to both club CFIs. Apparently an email must be sent to the CAA by each club asking them to add me to their list of authorised examiners but they are closed until next year. This doesn’t seem particularly efficient or joined up thinking to me – surely this is what the previous paper form was requesting. I’m really not sure what the value of the paper certificate is in an online world.
My Instructor Rating Part-FCL 945 privileges already allow me to endorse the licence of pilots revalidation their SEP rating by experience but only where I have given the mandatory one hour of instruction. The privileges of Revalidation Examiner extends this to situations where I haven’t given that instruction, but only for non Part-FCL licences (i.e. NPPL), and makes it clear that I can’t sign my own.
The key privileges of this authorisation are:
a) I can conduct LAPL/PPL/NPPL/IMC theory exams at the named flying clubs
b) I can certify ID and Licence Rating pages for UK pilot licence applications
c) I can endorse NPPL licences for revalidation by experience (Microlight/SSEA/SLMG) regardless of whether I have flown the instructor hour with them or not, but not my own.
The main changes with the introduction of eExams are that:
- Students must pre-register for an account on the CAA portal, then register for eExam service, then request membership of their ATO/DTO. Each student can only be associated with one club at any time.
- Exams are conducted online using a dedicated PC or tablet, rather than on paper
- Examiners must hold a Ground Examiner Authorisation in addition to any other Examiner or Instructor privileges. It is no longer permitted to delegate the conduct of exams to a trusted administrator. Ground examiners must either be qualified Flight Instructors (CRI is not sufficient) or have passed a Ground Instructor course at an ATO.
- A completely new question bank has been written with the intention of improving both quality and relevance. It was also thought this would make it harder for practice question banks to match the real questions.
- The CAA charge a fee for each exam taken online, currently £10, paid in advance by the ATO/DTO.
- A previous EASA requirement that PPL exams needed to be taken in a maximum of six 10-day sittings no longer applies. They can be spread out over up to 18 months between first and last, thereafter a further 24 months before completing the LAPL/PPL course, taking the skill test and applying for the licence.
Conflict of interest
While there’s quite a lot of specific guidance for Examiners conducting skill tests, relatively little is said for Ground Examinations. For example, the Flight Examiner’s Handbook bars skill tests where the examiner has also instructed more than 25% of the course (ref Part-FCL.1005) or whenever they feel their objectivity may be affected.
That doesn’t seem to be the case for Ground Examinations, and I’ve come across one dedicated theory training organisation where the same person appears to deliver all theory instruction and examinations.
So I don’t see any reason why I can’t conduct theory exams for my own students, as long as they aren’t close relatives or have some other close financial ties, regardless of how much airborne or ground instruction has been given.
I am aware that I have been put in a trusted position and that the critical factor is to ensure the integrity and security of the examination process – in other words, no cheating!
A quick survey of flying club price lists reveals rates mostly around £30-£40 with a few nearer £60 per exam. When you consider that £10 goes directly to the CAA, that additional IT equipment is required and that the exams must be supervised by a qualified ground examiner then I’m actually quite surprised more clubs haven’t increased their rates.
I believe I can now certify pilot ID and licence rating pages in support of their licence applications to the CAA, which will help when the CFI isn’t around to help. A quirk of CAA guidance is that while Ground Examiners can certify theory exam results, regular skill test flight examiners can’t unless they are also Ground Examiners, CFI or Head of Training.
It’s unclear exactly what happens next. I believe it will require someone at the CAA to register me on their system and issue login details. The CFI of each club has offered to provide some training and effectively supervise me conducting my first few exams before letting me run loose on my own. Both have said this will add flexibility by allowing any club students to take exams when they aren’t around.
[Update: The CAA responded to an email request to issue login details within a couple of hours. I’ve now got two separate logins, each with a separate email address to differentiate between the two clubs. The confirmation email contained further information including links to user guides]