Division 2.1 Need

The UK informed that they interpreted JAR-FCL in the past as allowing SFIs to act as tutors on SFI courses after having conducted a specific tutor course followed by an assessment of competence. The UK further described that with the implementation of Part-FCL and the introduction of a more specific wording the privilege to teach applicants for an SFI certificate is granted only to Type Rating Instructors (TRIs) with 3 years of experience as TRIs. In the UK many SFI certified by the UK and working in the role of teaching applicants for an SFI certificate cannot comply with the requirement to become a TRI with 3 years of experience. They will therefore be unable to continue to act as tutors in SFI courses. The UK further specified that many of the current SFIs would be unable to fulfil the TRI requirements for medical reasons.

The UK concluded, based on an assessment of the actual situation, that there is an insufficient number of TRIs to teach a sufficient number of applicants for an SFI certificate and to meet the industry’s training needs. As a result, there will be a shortage of qualified instructors to provide this training which would cause a serious disruption to the training of pilots, particular in the business/corporate aircraft domain. It is therefore necessary to grant the privilege to the SFI that do not fulfil the requirement of having at least 3 years of experience as TRI, to provide instruction for the SFI applicants. The Agency agreed with the justification provided by the UK on the need for this derogation.