UK CAA IR Fiasco

[Fart Master]

There was a thread on this forum a while ago regarding a rule change made in LASORS 2010 regarding UK IR holders who, in effect, had their IR's taken away from them. I have set up a petition as a few of us are taking legal advice to see if we can challenge the way in which the CAA handled this, the info below should flesh the case out...

Dear fellow Aviators,

This information pertains to any pilot who has been issued a UK CAA professional licence (JAR or National) and have moved abroad to work under another ICAO licence;

If you possess a UK issued professional licence the publication to refer to is a manual called LASORS (LICENSING, ADMINISTRATION and STANDARDISATION,
OPERATING REQUIREMENTS and SAFETY), this publication is valid until 1st July 2012 at which point CAP 804 will come into force as its replacement under EU-OPS. CAP 804 is the UK CAA's version of Part-FCL (Previously called JAR-FCL).These 2 documents lay out how to attain, maintain and if necessary revalidate your licence.

The matter to which I draw your attention pertains to holders of a UK CAA issued Instrument Rating (IR), more specifically, the requirements for renewing that rating. Up to and including LASORS 2008 there was a clause in Section E of the publication that took into account the utilisation of your ICAO (In this case non UK) or military IR. I quote/paraphrase directly from LASORS 2008;

"To renew an IR(A) that has expired by more than 7 years, applicants must: ...For multi-pilot aircraft pass a type rating skill test with or observed by a UK CAA Flight Operations Training Inspector. Applicants will also be required to retake the IR(A) theoretical knowledge examinations. "

However, and most importantly for the affected pilots (Mostly expats);

"...where IR privileges have been exercised in another category of aircraft (i.e. UK/JAR IR(H)) or under the privileges of an ICAO licence (Aeroplanes and Helicopters) or under a UK military IR qualification (fixed-wing or rotary), the renewal requirements will be based on the expiry date of that IR."

In other words as long as you kept your other ICAO IR valid your UK IR was safe from the 7 year renewal rule and most importantly we wouldn't have to undergo the ridiculous requirement to resist the 7 theory exams, the very same exams on which our CPL/ATPL's are predicated.

Now the bad news, WITHOUT ANY PRIOR WARNING, the CAA removed the ICAO/Military caveat, in an instant rendering 100's of UK issued IR's invalid. The authority state that the rule shouldn't have been there in the first place and was therefor removed, this despite all the other JAR authorities entering into the spirit of the agreement and renewing licences/IR's that had expired by more than 7 years when the pilot produced reasonable proof that he/she had stayed current, for example, flown for an airline. The CAA took the rule at face value and applied it literally, with no thought of the consequences. They have in effect taken away our careers as a licence without an IR is basically worthless. When queried recently as to why they didn't pre warn us of the impending change, and after all they are very quick to criticise us for not referring to the CAA website for these matters, the reply was.... They didn't want to potentially upset our families in case we were deceased. So you see what we're up against... Nuff said really. Although not confirmed, it may be the case that you have to go to an approved school to do your ground studies, obviously completely unacceptable given most of our circumstances.

I haven't got enough space to go into all the details and futile attempts we have made to get the CAA to see sense, so what a few of us are doing is taking legal advice to challenge, not the rule change itself, but the way in which the change was implemented, in effect, without any warning. We have also sent our case to an MP who has stated he will pass it onto the Minister of Transport. The CAA have admitted 'that they could have communicated the change better', the implication being that there was some communication in the first place, which was not the case.

Without even considering the fact that they are treating professional pilots like novices, consideration is also being given to legally pursuing the costs that the authority have in effect imposed on us if we have to do the 7 ground exams. Ground courses, costs of books, exam fees and other incidental costs. As we all know money is a big part of the CAA's thinking, so several hundred pilots multiplied by several thousands of pounds costs each may get them to pay attention and not hide behind their rule books?

So, what can you could do to help? An online petition has been created to add weight to our cause, the link is below, and I ask that you add your signature and a message if you wish. Equally important is that you spread the word to other affect colleagues who don't read PPRuNe. We are preparing and planning to lodge a legal complaint prior to the introduction of CAP 804 so that we have date stamped our claim based on LASORS regulations. Even pilots who don't plan to return to EASA land should be encouraged to sign up, as you never know what path your career may take.

Personal enquiries/complaints to the CAA, your MP and EASA should also be a consideration to keep the pressure up on the authority.

Good luck!

Chris.

The link is;

Petition: UK Civil Aviation Authority: Temp approval for affected pilots to renew their IR without resitting exams | Change.org (http://www.change.org/petitions/uk-civil-aviation-authority-temp-approval-for-affected-pilots-to-renew-their-ir-without-resitting-exams)

[blagger]

17 Sep now not July.

[Fart Master]

Thx, have just seen it in the CAA website, so it gives us more time to put our case together.

Thx.

Ps sign the petition as well if it's not too much of a hassle :ok:

[Airmagnet]

Petition signed!

[Farfrompuken]

Signed.

I was down at the CAA having a related but subtly different nightmare a few months ago; they were misreading their own LASORS in my case but refused to concede.

Whilst there, a Cathay TRI/E was told his JAA ATPL was no longer valid due to this 7 year rule; his HK ATPL was issued on the basis of his JAA ATPL, so in effect he'd lost his licences!!

The remedy; just go out and retake the ground exams, re-sit an IR!!!!

I think his solution was to pay for an FAA licence instead!

The people who spoke to me on the front desk at the CAA were Engineering specialists; they had no FCL specialists available. They appear to be having their own crisis, chances are if you've read the rules, you'll know more than the person on the 'phone at the CAA! What's worrying is that there was no concession whatsoever in mine or the other chap's case.

IMHO The Mil pilot makes up such a small % of the CAA's revenue that in their mind it's not worth their while to look after that body of people.

[dat581]

Good to see the Mother Country's CAA makes life as difficult as possible just like the CASA downunder! :ugh:

[Fart Master]

FFP'em, agreed, the whole thing is a shambles. That's why we are going down the legal route, it might provide a little 'focus' to the situation.

We are still putting the case together. Update to follow as and when.

FM

[BEagle]

LASORS 2008:

Renewal of an IR (A)

The requirements to renew an IR(A) are based on the period of time elapsed since the rating expired i.e. calculated from the date of expiry of the most recent IR(A) proficiency check entered in the licence.

However, where IR privileges have been exercised in another category of aircraft (i.e. UK/JAR IR(H)) or under the privileges of an ICAO licence (Aeroplanes and Helicopters) or under a UK military IR qualification (fixed-wing or rotary), the renewal requirements will be based on the expiry date of that IR.

LASORS 2010:

Renewal of an IR(A)

The requirements to renew an IR(A) are based on the period of time elapsed since the rating expired i.e. calculated from the date of expiry of the most recent IR(A) proficiency check entered in the licence.

Where less than 7 years have elapsed since the IR(A) expired but IR privileges have been exercised since in another category of aircraft (i.e. UK/JAR IR(H)) or under the privileges of an ICAO licence (Aeroplanes and Helicopters) or under a military IR qualification (fixed-wing or rotary), the renewal requirements for the IR(A) will be based on the expiry of that other IR.

If more than 7 years have elapsed since the IR(A) expired, no credit will be given for any other IR rating or qualification, and the terms set out below for more than 7 years since expiry shall apply.

To renew an IR(A) that has expired by more than 7 years, applicants must:

For single-pilot aircraft pass an IR(A) skill test in an aeroplane with a UK CAA Staff Flight Examiner.

For multi-pilot aircraft pass a type rating skill test with or observed by a UK CAA Flight Operations Training Inspector.

Applicants will also be required to retake the IR(A) theoretical knowledge examinations.

No warning was given of this change and it isn't even highlighted in the 'changes from LASORS 2008' references to sections A 12 'Credit for Military Service' or E 1.2 'IR(A) Flying Training / Experience Requirements'.

The CAA made such a balls-up of LASORS 2010 that they had to release AIC 043/2011 'Amendments to LASORS 2010' which did at least include the following:

21 Section E1.5, page E/7 - Renewal of an IR(A)

The second from last paragraph is expanded to include more detailed information regarding the accreditation scheme. The paragraph is replaced with the following:

Applicants will be required to complete theoretical knowledge instruction through an approved training provider. The amount of instruction will be at the discretion of the Head of Training. Where a QSP(A) or ex QSP(A) (as defined in section D3) can show that he/she can fulfil the criteria to claim credits under the one of the accreditation schemes set out in D3.3 for the grant of a JAR-FCL CPL(A) with IR(A), then he/she can, alternatively, follow that scheme's arrangements to fulfil the theoretical knowledge requirements for renewing the IR(A).

The CAA could quite easily have continued the earlier agreement under JAR-FCL1.020:

JAR–FCL 1.020 Credit for military service
()
Military flight crew members applying for licences and ratings specified in JAR–FCL shall apply to the Authority of the State for which they serve(d). The knowledge, experience and skill gained in military service will be credited towards the relevant requirements of JAR–FCL licences and ratings at the discretion of the Authority. The policy for the credit given shall be reported to the JAA.

Note the words 'at the discretion of the Authority'. Why did they not exercise such discretion?

In addition, the CAA delayed introduction of part-FCL from 8 April 2012 to 30 June 2012 and later to 17 September 2012. All other part-FCL changes have been delayed to the same date, yet no similar delay has been allowed for Military Accreditation. Why??

Good luck with your case, this certainly deserves a legal challenge. If you can get an MP involved to put a formal question through the Secretary of State, the CAA will be obliged to take what they term 'orange folder action' in order to provide the answer within a fixed time period - which involves a lot of work for them!

[BEagle]

Applicants will also be required to retake the IR(A) theoretical knowledge examinations.

But it doesn't say that applicants have to pass the exams....:E

[Fart Master]

Haha, good point BEagle. We've contacted one MP who's going to pass on the information to the MoT, probably a dry hole, but you never know...

[Whopity]

A point that you should be aware of is that LASORS has never had any legal status, it has always been a guidance document. The underlying rules have been JAR-FCL Part 1 (not law in the UK) and now Part FCL Regulation 1178/2011 (EU Law). Even CAP 804 is not a legal document, it reiterates other rules which it muddles with policy and guidance.

Sadly, this shambolic mess has come about by allowing people with no relevant knowledge or experience to play about with rules they clearly don't understand.

[Chugalug2]

Signed. Good luck guys. Why do I just know that it is only the UK that has taken such arbitrary action against their own pilots?

[BEagle]

A point that you should be aware of is that LASORS has never had any legal status, it has always been a guidance document.

Much like the Highway Code....:rolleyes:

[2close]

Just picked this thread up gents,

If you are going down the legal route, you may also want to look into the fact that some idiot(s), quite probably plural and I am being kind, when constructing EU Regulation 1178/2011 for EASA Part-FCL, together with the AMC/GM and subsequently CAP 804 appears to have totally omitted any process for converting an ICAO IR into an EASA Part-FCL IR. I cannot believe for one second this is by accident.

The old CPL process has been somewhat modified in that an applicant for converting an ICAO CPL into its EASA equivalent must now attend an Approved Training Organisation and be assessed; the ATO must then forward a recommendation of training to the CAA who must rubber-stamp it with their own approval before the training can go ahead......mmm, I wonder whether there will be a further contribution required to the CAA Staff Final Salary Scheme Pension Fund, err, sorry I mean a charge.

However, there is no similar IR process in place and any credits available from holding a non-EASA ICAO IR can, according to the CAA, only be applied to an integrated CPL/IR course and not any modular IR. In short, the full IR course must be taken, less any credits for holding an EASA Part-FCL CPL, with its impending cost.

Appendix 6 to Part-FCL (Modular IR course) has no conversion process outlined within, neither has Part Q.

There is a validation process which permits the holder of an ICAO ATPL or CPL/IR to fly on Commercial Air Transport ops for one year only, with a single extension of one further year, provided that the person can demonstrate that they have commenced a course of study towards the theoretical knowledge requirements for licence conversion.

However, the old 15 hour IR conversion requirement has simply vanished into thin air, without a 'by-your-leave'.

Sorry to be the bearer of bad news but I thought it better that anyone who is holding an ICAO CPL/IR only should be aware of the full story and not be thinking it's a case of doing the theory exams only.

But hey, more good news, I've lost my CPL altogether thanks to EASA! :mad:

Great, innit?

[BillieBob]

There is a validation process which permits the holder of an ICAO ATPL or CPL/IR to fly on Commercial Air Transport ops for one year only, with a single extension of one further yearWhere does it say the extension is limited to one further year? My copy says "This extension shall cover the period of time necessary for the licence to be issued in accordance with Part-FCL."

[Alex Whittingham]

When putting together your legal case you might look at the requirements for the likes of the CAA to consult with industry before introducing a change. It used to be called the BERR code. It requires regulators generally to conduct risk assessments etc and consult before changing regulations.

[Fart Master]

Just a wee update;

As things stand we are still in talks with a law company and the government. I have a couple of small requests of everybody who is involved/affected by this ruling;

1. We have received a reply from the government. The Minister of Transport is now aware of our case. The first letter we received contained 2 interesting points. Firstly she admitted that the guidance that the CAA provided was in error. An admission of guilt? Secondly she stated that the rules had been in place for 12 years, we can only assume that she was referring to the creation of JAR? We're not exactly sure what she means. Anyway, we have written back to the MP requesting more information whilst also fleshing out our case. This includes informing them that there is a petition online. I think this will make them realise that we are serious in regards to this matter. So my request to you is to get as many to sign up as possible. Our thanks in advance.

2. As we are now approaching the point where we may be looking at taking legal action, the two of us leading the case would appreciate any other legal angles in addition to what has already been provided, that you feel may be appropriate to help us apply pressure to the CAA/Govt.

One thing is for sure if we give up now then we're guarenteed not to have a favourable outcome. If you are willing, keep writing letters/e-mails or phone to show your displeasure at what is going on.

Chris:ok:

[jayteeto]

Military training was cut cut and cut some more around the time I went through. I had to take all the ATPL exams when I had years of service and thousands of hours. There were no exemptions in the 1990s available to the likes of me. When I took all the exams I learned a LOT of stuff that the military didnt teach me. I learned a lot of guff as well!
In my opinion, military pilots need to do these exams, ONCE! This 7 year rule is just another CAA 'hoop' to jump through, thought up by european minded blunties........

[BEagle]

Fart master, don't be smoke-screened by the revised 'Revalidation of Part-FCL Instrument Rating' accreditation criteria (which may or may not be included in Section 4 part O of amendment 1 to CAP 804, to be released in 2 days time) - your argument is with the illogical changes introduced in LASORS 2010!

jayteeto, how right you are about the progressive dumbing-down of military theoretical knowledge instruction! For example, I was taught (and examined in) in PofF to a greater level for my PFB in 1971 than I was at CFS 20 years later.

For example, OCU groundschool for the Vickers FunBus was significantly dumbed down after some Stn Cdr decided that he didn't like it being so comprehensive.....:\

Any holding officer waiting to start flying training would be well advised to study for EASA CPL ground exams......in my view....:mad:

[A and C]

THe CAA lost all my CPL exam results but to make up for that they sent me another guys IMC rating........

[mad_jock]

CPL are you sure about that BEagle.

Means if you then want to go airlines you have to do the whole of the ATPL's again.

[Fart Master]

The next piece of good news I've just discovered is that if you need to put a Multi Pilot aircraft type on your ATPL you need to have a JAR IR....therefore when I go to the CAA to put my A330 on my UK licence I presumably will be handed back a CPL without an IR...Good innit:mad:

[Fart Master]

I have just spoken to someone who works for the government and asked what the affected pilots should do. His answer was to write to your MP, even if you don't live in the UK. If you have property include your address in your letter of protest.

Also mention that the Transport Ministry has in some way admitted some degree of error, in that they admit the CAA's 'guidance was in error'

Time is short, even if it's just a couple of paragraphs it will help. The change.org page can also be copied and pasted.

FM.

[BEagle]

Fart Master - any progess on this?

[Fart Master]

Hi,

Just a quick update for those of you not in the petition, we are expecting a decision on the matter in the next few weeks. A proposal has been sent to EASA and is in the process of being presented to the European Commission.

I'll get back to you as soon as we have some news,

C.

[Fart Master]

Hi,

For those of you not signed up to the petition this is what I emailed everyone 3 days ago;

Greetings,

It seems to have been a long but interesting road dealing with this case. I would like to have made a dramatic announcement just to add to the suspense, but quite simply, due to everybody's efforts we've won! As I read things the CAA have adopted our proposals 100%

As I've mentioned before the CAA have been keeping me abreast of developments and said that they were waiting for Brussels to rubber stamp the derogation (Read partial exemption) as EASA had already approved it. I received 2 e-mails from licencing managers last night confirming the law will be integrated. I've been in possession of this derogation for a while but for obvious reasons didn't release it. Now I can, it's attached to the bottom of the e-mail. The exemption will be published in the 'Official Record series 4' on the CAA website very soon.

So where does this leave us? We are all now in the position of being able to keep our EASA ATPL's as we can now add/renew/revalidate a multi crew type on our licences, which had not been possible before without an IR. However under EASA regulations people may have to go to an ATO for an assessment if they want to put a new type on their licence.....But that's another issue.

If there are any more developments I'll let you know. Good luck with your CAA dealings! My thanks to all of you who phoned/wrote/harassed the CAA and especially to others who kept things moving along as well. You know who you are...

Cheers,

Chris.

DEROGATION PROPOSAL.

Proposed Article 14(6) derogation in respect of Annex I to Regulation (EU) 1178/2011 - Part-FCL - Part-FCL.625IR(c) and (d), for pilots who hold instrument ratings in accordance with the requirements of third countries.

1. Context:
The requirements for the renewal of an Instrument Rating (IR) are set out in Annex I to Regulation (EU) 1178/2011, ‘Part-FCL’ as follows:
“FCL.625 IR — Validity, revalidation and renewal
(c) Renewal. If an IR has expired, in order to renew their privileges applicants shall:
(1) go through refresher training at an ATO to reach the level of proficiency needed to pass the instrument element of the skill test in accordance with Appendix 9 to this Part; and
(2) complete a proficiency check in accordance with Appendix 9 to this Part, in the relevant aircraft category.
(d) If the IR has not been revalidated or renewed within the preceding 7 years, the holder will be required to pass again the IR theoretical knowledge examination and skill test”.
These requirements are similar (but not identical to) the previous requirements of JAR-FCL. The UK CAA believes that the requirements of FCL.625 IR(d) were created for the case where a licence holder ceases to fly under Instrument Flight Rules (IFR) for 7 years. The rule does not take into account the possibility that the licence holder may have been flying under IFR using an Instrument Rating (IR) held on a 3rd country licence during the 7 year period which has been renewed during that period and which is therefore valid.

2. The issue:
The UK CAA is aware that a number of pilots with licences issued by EU States have been flying with 3rd country airlines using licences issued by the States where those airlines are based. These pilots have allowed their European Instrument Ratings to lapse, in the expectation that for the subsequent renewal of their European IRs the assessment of their recency of use of the rating would be based on the status of their 3rd country IRs.
It has been the past practice of the UK CAA to accept that if a pilot holds, or has recently held, an equivalent Instrument Rating on another ICAO Annex I compliant licence, that the requirements for revalidation of the UK-issued IR would be based upon the validity/expiry of the 3rd country ICAO Annex I compliant IR. The UK CAA understands that France, Ireland, Denmark, Belgium and the Netherlands have allowed similar arrangements for the holders of JAR-FCL licences.

The UK CAA has received a number of applications for the renewal of IRs from the holders of UK-issued licences who have allowed their IRs to lapse by more than 7 years. These applicants state that they either hold a current and equivalent 3rd country IR or that their 3rd country IR has lapsed by less than 7 years. Accordingly, they argue that they should not be required to re-take the Instrument Rating theoretical knowledge examinations or to undertake training at an ATO. They are objecting strongly to Part-FCL.625 IR requiring them to re-train and to re-take examinations, especially as many of them are currently acting as pilots for Commercial Air Transport flights into airports within the Community for 3rd country airlines using their 3rd country licences with Instrument Ratings.

The requirements of FCL.625 IR(c) and (d) appear to be intended to apply additional training and testing requirements depending upon the period of time since the pilot last used the privileges of the Instrument Rating. The UK CAA believes that it is incorrect and disproportionate to require a pilot who has a current, or recently lapsed, ICAO Annex I compliant IR from another country, to re-take the theoretical knowledge examinations to renew a European IR that has lapsed by more than 7 years; i.e. it is not appropriate to apply the same requirements to a pilot with recent IFR experience as would be applied to a pilot who has not flown under IFR for more than 7 years. It is difficult to see how doing this will affect safety when these pilots are flying or have been flying recently using their third country issued IRs.

Similarly, the UK CAA considers that if the European IR has lapsed by less than 7 years, but the pilot holds a current (non-expired) ICAO Annex I compliant IR on another licence, then the requirement to undertake training at an ATO before taking the renewal Proficiency Check should not apply.

3. The need for derogation:
Around 30 pilots currently flying with third country operators (using third country licences with IRs issued in accordance with ICAO Annex 1) have written to the UK CAA and/or to the UK Department for Transport to complain about the requirement to re-take the theoretical knowledge examinations before their UK-issued IRs can be renewed. Three of these pilots created an on-line petition during 2012, and by August it had attracted 500 supporters. Applying FCL.625(c) and (d), without any recognition that the third country IRs may have been renewed or revalidated during the preceding 7 years, requires these pilots to undertake re-training and to re-sit the theoretical knowledge examinations in addition to passing the proficiency check; (flying skills test). This does not acknowledge that they may have been recently flying commercial air transport flights into Europe for these third country airlines. These complainants assert that to require them to do this would impose needless hardship on them – by requiring them to undertake costly and time-consuming courses and examinations. It may also cause them to lose their livelihoods if the airlines in question refuse to employ them whilst they do this. It seems likely that there will be a similar need affecting pilots from some other Member States as and when those States implement Part FCL.

4. Proposed derogation:
It is proposed that derogation be permitted under Article 14(6) of Regulation 216/2008 so that where a pilot holds or has held a 3rd country ICAO Annex I compliant Instrument Rating, the expiry date of that 3rd country IR shall be used as the date of expiry of the IR for the purposes of FCL.625IR(c) and (d):
“In accordance with Article 14(6) of Regulation (EC) 216/2008 of the European Parliament and of the Council the United Kingdom CAA will derogate from FCL.625 IR(c) and (d) of Annex I to Regulation (EU) No. 1178/2011 so that where a pilot holds or has held an Instrument Rating issued by a third country and that rating is compliant with Annex I to the Convention on International Civil Aviation, the applicability of FCL.625 IR(c) and (d) may be based on the validity dates of the Instrument Rating of that other country. This derogation is subject to the following conditions:

(i) a pilot with a current and valid 3rd country IR shall complete the revalidation requirements of FCL.625(b) and the aircraft category specific requirements for revalidation of the Part-FCL IR; meaning that he must pass the proficiency check, but is not required to undergo training or to re-take the theoretical knowledge examinations; and

(ii) a pilot who held a 3rd country IR that is no longer valid but had been revalidated or renewed within the preceding 7 years shall comply with the renewal requirements of FCL.625 IR(c), but is not required to re-take the theoretical knowledge examinations.”

An equivalent level of safety is maintained with this derogation because the necessity to apply the requirements of FCL.625 IR (c) and (d) is determined by how recently the pilot had the privilege of flying an aircraft under the Instrument Flight Rules. The State of Issue of the Instrument Rating that is used to carry out those flights under IFR does not affect the experience and practice gained through undertaking such flights.

Clear? If not PM me and I'll try to clarify things,

Chris.

[Mach the Knife]

That's great for the chaps with civ licences operating overseas. Does not appear to help the many Mil pilots sat with ATPL or Frozen ATPL with IR that has lapsed by more than 7 years. That are a lot of us that were counting our Mil Green IR or IRE status as counting. Which I subsequently found out was not allowed.

[LOMCEVAK]

I have raised with the CAA Head of Licensing and Training Policy the issue of military IRs in the context of the credit for ICAO licences and he has said that he will ask a member of his staff to discuss this with 22 Group. I will post any replies that I receive from him.

[Mach the Knife]

Thanks for the update, shame it will be reliant on a timely and well staffed response from the admin black hole known as 22(Trg)Gp.

[Tester07]

Best of luck, Dave.

[BEagle]

Well, it's good to see that a 14(6) has at last been raised for this ridiculous situation.

It would be good if the military Green IR would also be allowed. But as has been said, that relies on 22Gp...... Who seem to delight in saying 'No'.

When the wretchedly inadequate Part O first appeared in CAP 804, following outrage expressed 'on Internet bulletin boards', they actually sent round a whinge-o-gram stating that it wasn't fair for people to complain...:rolleyes:

Well, what the **** did they expect?

[Knockando1997]

Knighthoods at least I should think..

or perhaps a signed photogragh of the BEagle to hang in the 22 Gp corridors of power?

[Meo245]

Well done Fart Master. I'm in the group wanting to renew a rating expired by more than seven years as I'm working outside the EU. Do we know if the exemption to be published by the CAA will be on this page:

List of Official Record Series 4 - Miscellaneous | Publications | About the CAA (http://www.caa.co.uk/application.aspx?catid=33&pagetype=65&appid=11&mode=list&type=sercat&id=17)