Teaching for the IMC rating

[RTN11]

I have the "no applied instruments" restiction removed on my FI(A) rating, but my IMC rating has just lapsed.

I have a current MPA-IR, but am I right in thinking that I need to renew the IMC in order to instruct instrument flying on a single pilot aircraft, as you cannot instruct towards a rating you don't hold?

[nick14]

I would say so, you need to have current single pilot privileges.

[Ex Oggie]

Pretty much correct. It would make sense for someone with your skills set to renew the SPA/IR as it shouldn't involve much more in the PC than for the IR(R) if you did it SE.

That way you get 12 months IR and 25 months IR(R). That could be useful if you have the opportunity to teach for the IR, and also you get more for about the same amount of money.

XO

[RTN11]

Thanks for the replies.

Hadn't considered doing the SPA-SE-IR, as I originally had a SPA-ME-IR. I guess if I did it now it would be an initial issue which would incur more of a fee from the CAA?

In CAP804 it clearly states that if you have held an IR in the last 5 years, then no training is required, just a test to gain an IMC rating. For the full EASA IR it states that an ATO would need to come up with an individual training plan, obviously this ATO wants me to instruct IMC so it's in their interest, but is 0 flying hours accepted by the CAA for the issue of a SPA-SE-IR?

[Whopity]

I guess if I did it now it would be an initial issue which would incur more of a fee from the CAA?It can't be an initial issue if you have already held the privilege, its just a renewal of the SP privileges.

[BillieBob]

...but is 0 flying hours accepted by the CAA for the issue of a SPA-SE-IR?The amount of refresher training required to reach the standard to pass the proficiency check is entirely at the discretion of the ATO. Neither the examiner nor the CAA have the right to question the ATO's decision.

[Level Attitude]

To instruct for a Rating the Instructor must hold a valid Rating that, as a minimum, gives the same privileges as the Rating being taught.

I have a current MPA-IR, but am I right in thinking that I need to renew the IMC in order to instruct instrument flying on a single pilot aircraftAs an MPA-IR is not valid for SPA then, at least, an IMC Rating needs to be held in order to instruct for the IMC Rating.

Pedantic Semantics: RTN11, from what you have written do you, in fact, mean that your IR(Restricted) has lapsed. Most Instrument training will be done on EASA aircraft and an IMC Rating is not valid for these.

The amount of refresher training required to reach the standard to pass the proficiency check is entirely at the discretion of the ATOThis is quite true but the question does arise as to whether this is a Renewal or is, in fact, an Initial Issue?

It can't be an initial issue if you have already held the privilegeThis is not correct - Holding the privilege to do something is not the same as holding a specific Licence/Rating.

EG an FI holder includes the same privileges as those of a CRI SEP holder, but they do not hold a (stand alone) CRI Certificate - they could get one but would need to apply to the CAA for Initial Issue.

Only the CAA can add a new Rating to a Licence, Examiners can only Revalidate or Renew ones which are already present, they cannot write in new ones.

So the question is:
Is an 'IR-SP-ME class/SE' a single Rating or is it an abbreviated way of writing 'IR-SP-ME class' and 'IR-SP-SE class' and therefore an Examiner may Renew simply the 'IR-SP-SE' class on its own.

[Whopity]

Most Instrument training will be done on EASA aircraft and an IMC Rating is not valid for these.Could you please point me at any document that states that holders of JAA licence with an IMC rating included in it, is no longer valid! When the JAA licence is replaced, the IMC if valid will be replaced with an IR(R), but there are still a good many JAA (now deemed to be EASA licences) that contain IMC ratings and indeed are being used in EASA aircraft.

[Ex Oggie]

So the question is:
Is an 'IR-SP-ME class/SE' a single Rating or is it an abbreviated way of writing 'IR-SP-ME class' and 'IR-SP-SE class' and therefore an Examiner may Renew simply the 'IR-SP-SE' class on its own.

It is the SPA-IR that is being renewed, not the class rating, so no problem provided it is on the front of the licence. The examiner can sign it up. If it's on the back, just admin at the CAA post PC. I see where you are coming from, but the IR-ME has the greater privilages anyway.

Done plenty of these with no problem so far. Just go fly the profile and see what happens. If you are up to standard-pass; if not-training event.

XO

[RTN11]

Most Instrument training will be done on EASA aircraft and an IMC Rating is not valid for these.

Not sure where you're getting that from. An IMC or IR(R) rating is perfectly valid in the UK on EASA aircaft, just not valid outside the UK.

My SPA-ME-IR is perhaps 3 years out of date, and no longer properly endorsed on my EASA ATPL, as it had expired when I applied, so is just listed as a previous rating. Therefore, either way the paperwork needs to go to the CAA. Will discuss it with the examiner and see what comes up.

Thanks for all the advice.

[BillieBob]

This is quite true but the question does arise as to whether this is a Renewal or is, in fact, an Initial Issue?There is no question, the OP holds an instrument rating and the fact that, most recently, the privileges of that rating were exercised on an MPA is not relevant.

It is likely that the rating was first earned on an MEP, which would have included SEP privileges, but, in any event, all that is required is to renew the IR privileges - the nature of those privileges is determined by the aircraft on which the proficiency check is conducted.

Think about it this way - does the holder of an SPA-ME-IR have to pass another IR skill test to extend the privileges of his IR to a MPA type? No, he has to pass a type rating skill test which includes revalidation or renewal of the IR with MPA privileges on the specific type.

[Level Attitude]

Not sure where you're getting that from. An IMC or IR(R) rating is perfectly valid in the UK on EASA aircaft, just not valid outside the UK.An IMC Rating can only be held on a UK national licence and these are only valid for LAPL privileges on EASA aircraft.

RTN11, from what you had written I had assumed you had an actual Part-FCL Licence however, since you now state you have an expired "SPA-ME-IR", then I would now assume you have a JAA (deemed to be EASA) Licence.

Could you please point me at any document that states that holders of JAA licence with an IMC rating included in it, is no longer valid! When the JAA licence is replaced, the IMC if valid will be replaced with an IR(R), but there are still a good many JAA (now deemed to be EASA licences) that contain IMC ratings and indeed are being used in EASA aircraft.Since an IMC Rating cannot be held on an EASA Licence then this must also be deemed to be an IR(R).

I did say "Pedantic Semantics', but I have found that to be most necessary when dealing with all matters EASA.

It is the SPA-IR that is being renewed, not the class rating, so no problemIt is likely that the rating was first earned on an MEP, which would have included SEP privileges, but, in any event, all that is required is to renew the IR privileges - the nature of those privileges is determined by the aircraft on which the proficiency check is conductedI know it is nothing to do with the actual Class Rating but this was the nub of my question given that 'IR-SP-ME class/SE' is exactly how the IR is written in the 'Section XII Certificate of Revalidation' part of a Part-FCL Licence.

Think about it this way - does the holder of an SPA-ME-IR have to pass another IR skill test to extend the privileges of his IR to a MPA type? No, he has to pass a type rating skill test which includes revalidation or renewal of the IR with MPA privileges on the specific type.Sorry BB, I think this paragraph is full of holes:
Yes the holder of an SPA-ME-IR does have to pass a Skill Test to obtain an MPA-IR. Certainly the IR element of the Skill Test is contained within the Type Rating test (which is why MPA-IRs are Type specific?). As it was a Skill Test the Rating will need to be issued, for a fee, by the CAA. Once held the MPA-IR can be Revalidated or Renewed alongside the Type Rating Proficiency Checks.

[RTN11]

Sorry Level Attitude, but you've got that completely the wrong way round.

Extract from CAP 804 Part 5 Section E

The IMC Rating is a national rating and can only be endorsed onto a UK aeroplane
licence. When training for the issue of a UK Instrument Meteorological Conditions
(IMC) Rating a syllabus recognised by the Civil Aviation Authority must be followed.
Training for the IMC rating is permitted outside the UK provided that the flying training
is conducted by an organisation that is approved by the UK Civil Aviation Authority for
such purposes. Instruction on the course may only be given by an IRI or by an FI who is
qualified to teach applied instrument flying.
In agreement with EASA, UK JAA and National licences which contained the UK IMC
rating for Aeroplanes issued prior to 8 April 2014 that are converted to EASA licences
will retain IMC privileges. On a Part-FCL licence the UK (IMC) appears as IR (Restricted).
The revalidation/renewal requirements of the IMC Rating shall apply to all IR (Restricted)
Ratings.
An IMC rating can continue to be added to a UK (non-JAR, non Part-FCL) PPL(A), CPL(A)
or ATPL(A) for use in non-EASA aeroplanes.
The IMC rating can be added to a UK issued Part-FCL PPL(A), CPL(A) or ATPL(A) in the
form of an Instrument rating with restriction (IR(R)) until at least 8th April 2017, and
potentially 8th April 2019. The IR(R) may be used in EASA aeroplanes and non-EASA
aeroplanes within the UK.

It cannot be issued on an LAPL, but can be issued on any EASA Part FCL licence, to be clear I have an EASA ATPL.

The IR(R) may be used in EASA aeroplanes and non-EASA
aeroplanes within the UK

[Level Attitude]

Sorry Level Attitude, but you've got that completely the wrong way round.No, I haven't - and your quote from CAP804 supports this.

Yes an IMC Rating and an IR(R) have the same training, test, renewal, etc requirements as each other and they give the same privileges. However whilst an IR(R) is valid in both EASA and Annex II aircraft an IMC Rating is only valid in Annex II aircraft.

CAP804 clearly states that an IMC Rating can be attached to a Part-FCL Licence in the form of an IR(R)

Using the term 'IMC Rating' loosely in the club house is fine, but when asking Licensing questions (who may instruct whom and in what) one has to be specific.

Look at your Part-FCL Licence, it will not say that you have an IMC Rating(actually it will also not say that you have an expired "SPA-ME-IR").

Strange as it may seem, I was originally trying to be helpful - Assuming you had both a Part- FCL Licence with and expired IR(R) and a UK Licence with an expired IMC Rating. If you had just Renewed the IMC on the UK Licence you would be limited to only instructing in Annex II aircraft.

[RTN11]

Sorry for the confusion, had our wires crossed there. I meant IR(R) all along, perhaps should have been more specific.

[Whopity]

Training for the IMC rating is permitted outside the UK provided that the flying training
is conducted by an organisation that is approved by the UK Civil Aviation Authority for
such purposes. Instruction on the course may only be given by an IRI or by an FI who is
qualified to teach applied instrument flying. However IN 2015-009 adds a restriction to that: 4.3 In addition, the CAA will authorise instructors to instruct for the IMC Rating/IR(R) if they comply with the following:
a) the instructor must hold a Part-FCL aeroplane licence issued by the UK CAA;

[nick14]

New regulation now in force also means that you must hold the relevant class rating when revalidating/renewing an IR. if you want the ME/IR then you will need an ME SPA class to associate it with. I guess this will be best done on the MEP. If you just want the SE/IR then it's not an issue as you already hold an SEP.

[Level Attitude]

Sorry for the confusion, had our wires crossed there. I meant IR(R) all along, perhaps should have been more specific.Given I had twice used the word "pedantic" that was, sort of, my point. :)

4.3 In addition, the CAA will authorise instructors to instruct for the IMC Rating/IR(R) if they comply with the following:
a) the instructor must hold a Part-FCL aeroplane licence issued by the UK CAA;Whilst accepting this might cause some inconvenience to a few UK Licence holders living abroad - Quite right too!

'Johnny (EASA) Foreigner'' did not, and do not, want an IMCR/IR(R) so why should they have the privilege to Instruct for a Rating that is only valid in UK airspace and can only be attached to a UK issued Licence!

[Whopity]

Whilst accepting this might cause some inconvenience to a few UK Licence holders living abroad - Quite right too! And all the UK based pilots who work for Ryan Air!

[BEagle]

Level Attitude wrote:
'Johnny (EASA) Foreigner'' did not, and do not, want an IMCR/IR(R)

To quote from Independence Day: Albert Nimzicki: Uh... excuse me, Mr. President? That's not entirely accurate.

Watch this space........

[Level 400]

New regulation now in force also means that you must hold the relevant class rating when revalidating/renewing an IR. if you want the ME/IR then you will need an ME SPA class to associate it with. I guess this will be best done on the MEP. If you just want the SE/IR then it's not an issue as you already hold an SEP.

Previously, it has been possible to revalidate MEIR every other year in an FNPT 2, which has kept it current for those, such as fATPL holders looking for their first job, who are required to have a current MEIR to start a type rating, but who do not necessarily need a current MEP rating to start this training. .


Does this mean that an Examiner will not be able to revalidate an MEIR in the FNPT2 now unless the applicant can demonstrate possession of a current MEP class rating, which of course cannot be completed in the FNPT2?
Where is this 'new regulation now in force' published?


Level 400

[BillieBob]

Don't panic just yet, the proposed amendment is in NPA 2014-29 and has some way to go before it becomes effective, if indeed it does. The revised requirement reads:

FCL.625.A IR(A) — Revalidation
(a) Revalidation. Applicants for the revalidation of an IR(A):
(1) when combined with the revalidation of a class or type rating, shall pass a proficiency check in accordance with Appendix 9 to this Part;
(2) when not combined with the revalidation of a class or type rating, shall:
(i) for single-pilot aeroplanes, complete section 3b and those parts of section 1 relevant to the intended flight, of the proficiency check prescribed in Appendix 9 to this Part; or
(ii) for multi-engine aeroplanes, complete section 6 of the proficiency check for single-pilot aeroplanes in accordance with Appendix 9 to this Part by sole reference to instruments.; and
(iii) hold the relevant valid class or type rating.
(3) An FNPT II or an FFS representing the relevant class or type of aeroplane may be used in the case of paragraph (2), but at least each alternate proficiency check for the revalidation of an IR(A) in these circumstances shall be performed in an aeroplane.
(b) Cross-credit shall be given in accordance with Appendix 8 to this Part.
If agreed, this will indeed mean that, as you cannot combine the revalidation of a class rating in an FNPT II, you will not be able to revalidate/renew an MEP IR(A) in an FNPT II unless you hold a valid MEP class rating.

The consultation period for NPA 2014-29 has been extended to 17 May and so there is still time to comment on the proposal.

[Level Attitude]

New regulation now in force also means that you must hold the relevant class rating when revalidating/renewing an IR. if you want the ME/IR then you will need an ME SPA class to associate it with. I guess this will be best done on the MEP. If you just want the SE/IR then it's not an issue as you already hold an SEP.

Previously, it has been possible to revalidate MEIR every other year in an FNPT 2, which has kept it current for those, such as fATPL holders looking for their first job, who are required to have a current MEIR to start a type rating, but who do not necessarily need a current MEP rating to start this training. .

Does this mean that an Examiner will not be able to revalidate an MEIR in the FNPT2 now unless the applicant can demonstrate possession of a current MEP class rating, which of course cannot be completed in the FNPT2?Assuming someone wants to hold an 'IR-SP-ME class/SE' (often referred to as an 'ME-IR' for brevity) but not to exercise its privileges then this 'new' rule doesn't really change anything:

1) Revalidation and Renewal are Administrative Actions (not Skill Tests or Proficiency Checks).
2) Revalidations can occur up to 3 months prior to expiry of a Rating.
3) Renewals are valid for 1 year plus the remainder of the month in which the PC was passed.

For example:
A Pilot holds a valid MEP and a valid IR-SP-ME class/SE, both of which expire on 30 June 2015.

Sometime between 01 April and 30 June 2015 the Pilot passes an ME-IR Proficiency Check in a Simulator - They have a valid MEP, so they get their ME-IR Revalidated.

After 30 June their MEP has expired so they can no longer exercise the privileges of their valid ME-IR.

Sometime between 01 and 30 June 2016 they pass a combined MEP/ME-IR Proficiency Check in an aeroplane. The Examiner Renews the MEP first then second, as a valid MEP is now held, they Revalidate the ME-IR.

Pilot again has current MEP and ME-IR, both now valid until 30 June 2017.

The 2 year cycle can repeat ad nauseum.............