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pipertommy
25th Oct 2012, 10:05
Hi, I have just received my Easa license this morning. And I have IR (R) on it. I understand it is basically IMCr with a new title. And all the restricted privileges.
I have a lapsed ME/IR, so does actually count as an IR which absolves my need to renew my IR prior the 5 year cut off ? Has my IR (sep) been renewed by this new title, as I was going to renew my IR in a SEP anyway.......
Bet this is a long shot. Lol

Whopity
25th Oct 2012, 10:23
Has my IR (sep) been renewed by this new title,No it does not! you will have to renew it by going to an ATO and completing training as required followed by the test. If you have not renewed or revalidated it in the past 7 years you will have to retake all of the exams and undergo considerable training to get it back so I suggest you renew your IR(SE) before that happens.

pipertommy
25th Oct 2012, 10:37
Lol. Thought so. It's only been out for a couple of years. IMCr suited my FI work. Renewing it in a few months.
Thanks for the reply !

bookworm
26th Oct 2012, 14:13
I have a lapsed ME/IR, so does actually count as an IR which absolves my need to renew my IR prior the 5 year cut off ? Has my IR (sep) been renewed by this new title, as I was going to renew my IR in a SEP anyway.......

In the conversion report on the IMCr -> IR(R), the UK CAA was, IMHO, supposed to include a process for lifting the restriction. While that might be "do the entire EASA Part-FCL IR from scratch", it could have been something more like "do the skills test". I haven't seen the conversion report, so don't know what was included.

BEagle
26th Oct 2012, 14:42
As I understand it, any IR(R) to 'competency-based' IR conversion criteria will only be considered once the NPA 2011-16 CRD has been released, received a response, progressed through comitology and eventually into law. Similarly, an IR(R) conversion to include EIR privileges will be considered if the EIR becomes law.

So don't hold your breath.....:hmm:

peterh337
26th Oct 2012, 15:05
If you have not renewed or revalidated it in the past 7 years you will have to retake all of the exams and undergo considerable training to get it back

What is happening to UK airline pilots who have been working in say USA or HK and who want to come back?

Is there no route for them, or is giving up flying their only option?

Virtually nobody is actually going to do the 7 exams and the 55hrs training...

pipertommy
26th Oct 2012, 18:42
Basically it's another loose end.

ASRAAM
26th Oct 2012, 18:42
My buddy has just put a new rating on his UK ATPL, this has triggered the issue of an EASA licence. The EASA licence includes as an expired rating an IR(r). Effectively losing the IMC rating that was formerly contained within the UKATPL. Not sure why the rating was listed as expired as obviously it was current on the UKATPL. Speculation suggests that it was because there was no test date.

I am about to renew my UK ATPL as it expires in December and would very much like to keep my IMC rating or a valid IR(r). Anyone got any suggestions of the best way of achieving this

Level Attitude
26th Oct 2012, 21:21
If you hold an SP IR then the last time you passed the test in an aircraft will also
count as the test for an IMC / IR(R) and you can apply for an IR(R) on the basis
of this pass valid for 25 months from the date of test.
However you say you hold an ATPL which implies you have an MP IR.

In which case take the Test!

This makes good sense - No matter how qualified and experienced you are
in flying IFR and IMC Approaches in Controlled Airspace in a Multi Crew
enviroment with an aircraft with all the kit - including IFR approved GPS.

This is not the same as flying IMC Single Pilot in Class G in (say) a very basically
equipped PA28 followed by a Procedural Approach in to a non-radar airfield.

Skills are different and hence need to be separately assessed

BEagle
27th Oct 2012, 07:27
What is happening to UK airline pilots who have been working in say USA or HK and who want to come back?

If they have JAR-FCL licences, they change the State of Issue to somewhere which has an NAA more sensible than the UK CAA, such as the Republic of Ireland, which does recognise the validity of ICAO IRs.

However you say you hold an ATPL which implies you have an MP IR.


If the licence was a UK (non JAR-FCL) ATPL(A), it included embedded IMCr privileges which never needed to be renewed. So the IR(R) validity period should therefore be 25 months starting from the date of licence conversion.

Whopity
27th Oct 2012, 08:03
From CAP804:
3.3.4 Part-FCL Restricted Instrument Rating
Where a licence containing a valid IMC rating or IMC privileges is replaced with a Part-
FCL licence, the IMC rating privileges may be preserved as a restricted Instrument
Rating. This will appear on the licence as IR (Restricted).

BEagle
27th Oct 2012, 08:48
Indeed, Whopity.

In theory then, since EASA Part-FCL is not supposed to remove any existing privileges :rolleyes: the IR(R) included in a converted UK (non JAR-FCL) CPL(A) or ATPL(A) should be non-expiring.....:hmm:

However, the minimum validity must surely be 25 months from the date of conversion? Nothing to do with the date of any previous IR(A).

ASRAAM
27th Oct 2012, 09:24
Glad to see you are all finding this as difficult as I am to sort out! For the record, my current IR is MP, although my original test some years ago was SP. I have held a rating continiously since the original test. (This used to be relevant as it meant I could just do an SEP IR without assessment or course).

Level , I appreciate your point that it's a different skill, that's why my current SEP flying really only requires an IMC rating. If I was planning on taking an SEP into controlled airspace etc I would plan some refresher flying followed by a proper SEP SP IR. I feel content that my existing skills will cope with the privileges granted by an IMC rating.

If I am going to have to take a test to validate my IR(r) then I may as well do the full IR.

One option I had considered was paying the extra to renew my UK ATPL as well as this should give me IMC privileges until 2015 and will will work out cheaper than an IR(r) test.

I was rather hoping though, that someone had already persuaded the CAA to issue an ATPL with a non expiring IR(r).

peterh337
28th Oct 2012, 10:50
If they have JAR-FCL licences, they change the State of Issue to somewhere which has an NAA more sensible than the UK CAA, such as the Republic of Ireland, which does recognise the validity of ICAO IRs.

Are you saying that if you have a JAA IR which is outside its revalidation (so it needs a renewal) but you are current on another ICAO IR, you can change to Irish residence and recover the JAA IR?

What would be the procedure for that?

Surely you need to live in Ireland, or something like that, because under the new rules the State issuing the license needs to also hold your medical records.

BEagle
28th Oct 2012, 11:11
See CAP 804 Part I Section 3.

Other Member States have been more generous than the CAA with respect to IR recognition. The CAA changed from:

LASORS2008: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.

to LASORS2010: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.


without any warning or justification. The IAA are aware of this absurd situation and are, I understand, quite happy for pilots with UK-issued JAR-FCL licences to change their State of Issue to the Republic of Ireland, in order to avoid the absurd nonsense of retaking exams after 7 years of JAR-FCL IR expiry even though IR privileges are being exercised on other ICAO licences.

mad_jock
28th Oct 2012, 11:48
And once you have it back you can just transfer back.

Will be cheaper than doing the exams again.

peterh337
29th Oct 2012, 09:47
Priceless info, Beagle, thank you :ok:

I will update my tome on this topic (http://www.peter2000.co.uk/aviation/jaa-ir/) :)

Will be cheaper than doing the exams again.

...not to mention the 55hrs at an FTO, followed by the JAA IR flight test, most of which not many long-time airline pilots, flying "computer planes" all day, will find very easy...

Whopity
29th Oct 2012, 22:52
EASA have now published the CRD (http://hub.easa.europa.eu/crt/docs/viewcrdpdf/id_135) of NPA-2011-16 "Qualifications for flying in Instrument Meteorological Conditions"

BEagle
29th Oct 2012, 23:11
FAA IR holders wishing to convert to an EASA Part-FCL C-B IR(A) will no doubt be interested to note that EASA has accepted my IAOPA Europe proposals in full.... See Comment 506 and the associated response.

We still have the FCL.600(b) battle to win, particularly as regards the issue of new IR(R)s after Apr 2014.....:mad:

Mickey Kaye
30th Oct 2012, 08:53
Had a bit of a skim read and overall I feel quite positive about it.

One aspect that I'm not over keen on is the 200 hours of IFR time before you can instruct for the EIR/CBIR as that disadvantages career instructors.

Whopity
30th Oct 2012, 10:28
Which is exactly why the UK CAA established the 4:1 rule in 1999 because 50 hours by sole reference to instruments was worth more than 200 hours in VMC on an IFR flight!

peterh337
30th Oct 2012, 11:17
We still have the FCL.600(b) battle to win, particularly as regards the issue of new IR(R)s after Apr 2014

I have been trying to work out a plausible IMCR to EASA IR conversion route.

I wonder if there is a drafting error (http://www.euroga.org/forums/flying/130-fcl-008-crd-published) on page 790.

bookworm
30th Oct 2012, 19:07
FAA IR holders wishing to convert to an EASA Part-FCL C-B IR(A) will no doubt be interested to note that EASA has accepted my IAOPA Europe proposals in full.... See Comment 506 and the associated response.

Indeed it looks as if many commenters identified the need for an oral exam instead of writtens (a "P.Holy" for example in comment 16) and for the reduction of the 100 hours to a more modest figure. I understand that it was broadly supported by FCL.008 group members.

We still have the FCL.600(b) battle to win, particularly as regards the issue of new IR(R)s after Apr 2014....

What news on that BEagle? AOPAs (517), Europe Air Sports (1459) and PPL/IR Europe's (73) comments supporting the introduction of FCL.600(b) were 'noted', or 'not accepted'. What's the plan?

BEagle
30th Oct 2012, 23:02
Which is exactly why the UK CAA established the 4:1 rule in 1999 because 50 hours by sole reference to instruments was worth more than 200 hours in VMC on an IFR flight!

Whopity, the CAA are already concerned about the availability of sufficient IRIs, thanks to this excessive requirement - and the loss of the 4:1 rule...:\

What news on that BEagle? AOPAs (517), Europe Air Sports (1459) and PPL/IR Europe's (73) comments supporting the introduction of FCL.600(b) were 'noted', or 'not accepted'. What's the plan?

Quite a few others made similar proposals, including the UK CAA (427). We will now work on a strategy to escalate the issue - but it's too early to advise what that's going to be.

The Agency has failed both to comply with the EASA management board’s call for greater rulemaking flexibility and to note the Commission’s flexible response in other areas of aviation legislation; the Agency has also failed to recognise that there is no safety case for the absence of the provisions of JAR-FCL 1.175(b) in FCL.600 IR – General.

hooligan88b
31st Oct 2012, 14:08
How is the 200 hours IFR to be measured? If one has >= 200 hours in the 'sole reference to instruments' column is this sufficient? Or do you need to show time in class A airspace (and if so how would you go about that?).
I hold a current SP IR and instruct for IMC but I may well be looking at instructing for EIR at some future point.

Whopity
31st Oct 2012, 15:42
How is the 200 hours IFR to be measured?For an FIat least 200 hours of flight time under IFR, of which up to 50 hours may be instrument ground time in an FFS, an FTD 2/3 or FNPT II;As there has never been any requirement to log time in accordance with IFR, for some, it will be difficult to prove. There is no requirement for any time to be by sole reference to instruments which makes a nonsense of the requirement!
the CAA are already concerned about the availability of sufficient IRIs, thanks to this excessive requirementHowever; their IN introducing the change contained even more ridiculous gold plated requirements. I note it has now disappeared!

cessnapete
1st Nov 2012, 18:03
A member of our group is carrying out his IMC Rating training in our aircraft at a local aero club. The old ADF in the aircraft has developed an expensive fault. We wish to remove it as it weighs a ton, and will never be used in the real world.( We have an IFR radio fit with GPS)
The local flying instructor insists that ADF is still in the IMCR training sylabus.
As an ADF is now no longer legally required for IFR flight, presumably he is wrong, and a VOR or GPS approuch will fit the non precision requirement.
On the CAA website I can only find the revalidation requirements, that state the non precision approach can be ADF or GPS or VOR.
Can I get the definative answer before we repair the ADF set.

Whopity
1st Nov 2012, 19:07
The local flying instructor insists that ADF is still in the IMCR training syllabus.The ADF has never been a mandatory requirement in the IMC syllabus. The syllabus was designed to allow pilots to fly IFR in an aeroplane using the equipment fitted to that aircraft. The syllabus requires that a pilot is trained and tested to a level of proficiency in 2 approach types. Nowhere does it say that one must be ADF.

cessnapete
1st Nov 2012, 19:20
Thanks, thats what I thought. I will get back to the instructor tomorrow who was insistant today, that we could not use our aircraft without a functioning ADF for the IMCR training.
That will save a bunch of training as the ADF requirement takes up a disproportionate amount of flight time.
It did seem odd that training was required for a radio aid no longer legally required for IFR.

Whopity
1st Nov 2012, 19:31
Looking back at the original syllabus in CAP53 App H dated Sept 1991

Departure and En Route The candidate to be trained in the use of at least 2 from VOR, VDF or ADF

Approach and Let Downs Candidates are to be trained in at least 2 instrument approach procedures using VOR, ADF, ILS, radar or VDF one of which must be pilot interpreted.

peterh337
1st Nov 2012, 20:49
The ADF is no longer a required carriage item for enroute IFR in CAS.

The "problem" is that many approaches involve an NDB as a locator, and if you fly procedurally (no radar) then you need to be able to deal with it there.

Of course nearly everybody uses a GPS to fly NDB (or VOR) approaches, but that is a different debate :)

To say that the IMCR does not need to teach NDBs is a tacit acceptance of not only universal GPS use but also of the US-style GPS substitution for the ADF which is not AFAIK formally available anywhere in Europe. I have no issue with that, because that is how I fly, but I do wish they became open about it instead of beating about the bush.

I am not an instructor but if I was teaching the IMCR I would make sure the student can fly every approach plate I stick under his nose :)

Whopity
1st Nov 2012, 21:34
It is important to understand the origin of the IMC rating. It was introduced to compensate for changes in the law that prohibited pilots from flying in IMC outside controlled airspace, glider pilots retained that right. The IMC was variable in that it did not mandate equipment or approaches but allowed alternatives with the recommendation of additional training if different approaches are to be flown. In practical terms it is very difficult to complete IMC training without ADF even though it is not mandated especially as VDF has now largely disappeared.

BristolScout
2nd Nov 2012, 09:21
I had to carry out NDB tracking and an ADF approach on my recent Instructor renewal. The last time I did that was on the previous renewal six years ago. It worked both times, which perhaps says something for the level of awareness that this spatially tricky exercise hammered into those of us old enough to have used it as a routine letdown. It's sadly true that there isn't sufficient time in the IMC syllabus to teach it to a satisfactory level, especially as the NDBs are being turned off in a lot of places. Heigh Ho, switch on the GPS.