Flight Instructor Revalidation

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A UK flight instructor rating expires after three years. Assuming you are actively instructing, you can revalidate the first time by attending a two day refresher course. On each alternate expiry, you must revalidate through an Assessment of Competence with an examiner. These are not called Skill Tests or Check Rides, but effectively have the same outcome – if you are not up to standard, then you fail.

Today it was time to face the music and take the Assessment of Competence.

Regulatory requirements for revalidation

The UK regulatory requirements for instructor revalidation and renewal can be found here and is copied below. (Last year the CAA made some progress in making the UK version of Part-FCL more accessible online).

FCL.940.FI FI — Revalidation and renewal

(1)  To revalidate an FI certificate, holders shall fulfil at least two out of the three following requirements before the expiry date of the FI certificate:

(i)  they have completed:

(A) in the case of an FI(A) and an FI(H), at least 50 hours of flight instruction in the appropriate aircraft category as FIs, TRIs, CRIs, IRIs, MIs or examiners. If the privileges to instruct for the IR are to be revalidated, at least 10 of those hours shall be flight instruction for an IR and shall have been completed in the period of 12 months immediately preceding the expiry date of the FI certificate;

(B) in the case of an FI(As), at least 20 hours of flight instruction in airships as FIs, IRIs or as examiners. If the privileges to instruct for the IR are to be revalidated, 10 of those hours shall be flight instruction for an IR and shall have been completed in the period of 12 months immediately preceding the expiry date of the FI certificate;

(C) Provision repealed before document was retained.

(D) Provision repealed before document was retained.

(ii)  they have completed instructor refresher training as an FI at an ATO or at the competent authority. FI(B)s and FI(S)s may complete this instructor refresher training at a DTO;

(iii)  they have passed an assessment of competence in accordance with point FCL.935 in the period of 12 months immediately preceding the expiry date of the FI certificate.

(2)  For at least each alternate revalidation, in the case of FI(A) or FI(H), or each third revalidation, in the case of FI(As), holders of the relevant FI certificate shall pass an assessment of competence in accordance with point FCL.935.

Over the past six years, I’ve given just over 1,500 hours of in-flight instruction of which several hundred hours were towards an IR or IRR. My logbook excludes hundreds of hours of coaching and instruction on uncertified simulators, and any time supervising student solo flights or authorising qualified newly minted club members. I haven’t logged the required 10 hours of IR instructing at an ATO this past year and time instructing IRR pilots at a DTO or independently just doesn’t count.

My FIE (Flight Instructor Examiner) clarified that this just means that some IR instruction must be demonstrated during the AoC which would now include an instrument approach.

A day on the ground

I arranged a date with an FIE, booking out a club briefing room and aircraft for the whole day and scheduling a 30 minute instrument training slot with ATC. Perhaps I could have flown this in my TB20, but thought that using a club PA28 would be more representative of what I actually instruct in. My rating expires at the end of February, but I wanted to complete this in plenty of time. Winter isn’t normally so busy with students, but risks bad weather.

The weather on the appointed day was unflyable but we met up anyway and spent time on the ground portion of the assessment. This involved my delivering a “Long Brief”. One of the fairly recent regulatory changes has been guidance from the CAA for GPS Fix Substitution, whereby aircraft not fitted with ADF or DME can make use of GPS instead. The guidance also clarifies when GPS overlays can be used to fly an approach, requiring the traditional ground aids (NDB, ILS, VOR) to be used from the final approach fix to the missed approach point.

I had prepared a slide presentation which I walked through illustrating three scenarios for the same ILS procedure at Gloucester – first with traditional instruments, then with GPS OBS for the outbound leg, and finally using a GPS Overlay. My student (ie the examiner) asked a number of pertinent questions. It was helpful to me to validate and clarify a few of the issues around this change, and confirm my understanding. The UK has a policy of limiting the features available for initial IR tests but during revalidation it is permitted to fly one of the two approaches using the autopilot, and its not unusual for newly qualified pilots not to fully appreciate some of the nuances of doing that. I find that this is the sort of exercise that is really useful to be taught and practiced in a simulator, ideally one that has been closely tailored to that of your own aircraft.

I also delivered a short brief, as if I was about to go flying with a PPL on a typical flight for one of the early/basic lessons.

The examiner asked me a number of questions from the CPL theory syllabus, covering each of the topics in turn. These were all quite relevant and useful rather than esoteric – he wasn’t trying to catch me out, just ensure that I remained up to speed with the important and safety critical side of GA flying.

The time passed quite quickly, and it was past lunchtime by the time we’d finished. We had done all we could apart from the flight itself.

AoC flight

The guidance is for a flight of somewhere around 1 hour 45 minutes, and we logged exactly that time. It seemed to go quite quickly, and I recall delivering the lesson to the examiner (who sits in the left hand seat, just like a student). He fed back and illustrated a number of points to explain and sharpen up on the finer points. We also demonstrated and flew some stalls, including a departure stall (where you climb at full power but bank too much). This is apparently not an uncommon issue and is a variation on the full power stall which I had been demonstrating by just flying straight ahead as taught to me in the USA. Definitely a learning point.

We returned to land with me pattering an instrument approach while flying from the right hand seat. The wind conditions were really quite challenging (around 30 knots at altitude, decreasing to about 12-15 on the ground). ATC was very busy and we had to delay for some time while awaiting our approach clearance. I managed to fly this down to minima within limits and remember the key points in the sequence.

Afterwards, the examiner confirmed that I had passed and we spent some time filling in various forms (which seem to involve mostly scoring out the irrelevant sections). The rating section on my licence was signed (now valid through to 2027). As a CPL licence holder, I can upload the relevant forms to the CAA portal and update the expiry date for my rating online. I still managed to get that wrong (it accepted today as the new date of expiry), but subsequently corrected that.

Tests are often daunting, but I found the experience quite useful and the feedback on the topics we discussed and flew were both relevant and appropriate. It’s good that we have a high standard of pragmatic examiners available to us.

Comparison with the FAA scheme

I don’t think this post would be complete without a comparison with the FAA system used in the USA and elsewhere.

FAA instructors must first complete more training, gaining both a CPL and IR rating before they can start an FI course. There is a separate theory exam for flight instructors, a practical training course and a checkride. This last can be quite difficult to arrange (there are fewer examiners available), and it is said can be quite expensive. Prices are privately agreed with each examiner, and some are said to charge more than the UK IR skill test. The practical checkride is very extensive, again taking a full day and involving a lot of time on the ground. The pass rate is not high – first time passes in particular are more unusual.

The more advanced instrument instructor rating (CFI-I) requires a further extensive training course, theory and practical exam.

However, once passed there is no need to see an examiner ever again. Many additional privileges, including that to train instructors, are granted purely on hours of instruction given.

There are several different ways to renew an FAA FI certificate:

  • Take an online Flight Instructor Refresher Course (eFIRC)
  • Attend an approved Flight Instructor Refresher Course (FIRC).
  • Take a practical test with the FAA or an authorized designated examiner.
  • Present a record of training showing that during the past 24 months you have endorsed at least five students for a practical test, and at least 80 percent (four students) passed on the first attempt.
  • Present a record that shows within the past 24 months that you have served as a company check pilot, chief flight instructor, company check airman, or flight instructor in a Part 121 or Part 135 operation, or in a position involving the regular evaluation of pilots in which the FAA inspector is acquainted with the duties and responsibilities of the position, and has satisfactory knowledge of its current pilot training, certification, and standards.

Note that time logged for instruction is not a requirement. Instead it’s endorsing students for test that counts, so in my case I would easily have satisfied that requirement and not even needed to do any refresher training.

The majority of FAA FIs never revalidate. It is said that about 2/3rds of the approximately 12,000 active FAA instructors are transitioning towards their ATPL commercial ticket which requires 1,500 hours. So they qualify as instructors, fly as much as they can, and then move on as soon as they clock up the required time. The remaining 1/3rd are more career instructors, including commercial pilots who instruct part time.

Of those who need to renew, I suspect that most use an online course, taken on demand, in chunks when convenient. As with other online learning tools, candidates must take and pass a progress test for each section to show they have understood it. There are typically eight sections of two hours each. The more frequent revalidation, together with higher investment into the teaching materials justified by the much larger audience, means this material is of high quality, relevance and timeliness. Sporty’s even offer their course free to instructors.

Poor quality instruction is dealt with by local FSDO inspectors, who visit instructors getting poor pass rates or where issues have been reported.

The FAA has even suggested that FI ratings could become valid for life, removing the requirement for revalidation where instructors can demonstrate recent successful student outcomes.

The different approaches each have their benefits and disadvantages. I don’t think that a flight refresher course every six years is good enough and would prefer that the CAA publish more useful and relevant information. There is a publication called Training.Com, but this has become very infrequent and seems to contain mostly banal regulatory technical detail.

Good for another three years

Overall, a great outcome and as always, quite a relief to know I am qualified to instruct for some years ahead.

If I wasn’t an instrument instructor, I could revalidate for a further three years (until 2030) by delivering 50 hours of instruction and attending a flight instructor seminar this year. The requirement to revalidate my instrument instructor privileges means that I must either instruct 10 hours towards an IR at an ATO in the third year of my rating or I will need to take a full AoC again.

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