Originally Posted by
Reverserbucket
a PPL with no IR and without an ATPL issued cannot retain ATPL credits indefinitely.
I agree.
Originally Posted by
Reverserbucket
a PPL with ATPL TK credits could undertake an FI course in 20 years from now but would not maintain the original ATPL credits unless they held an IR and had renewed it at least every 7 years.
I agree.
Originally Posted by
Reverserbucket
Same for a Type Rating - the intention of Part-FCL is that the credits are valid at the time of course commencement.
Is it though? What does 'valid' mean? Intention is all well and good, but what is written is:
have passed the ATPL(A) theoretical knowledge examinations in accordance with this Part;
Not much there to deconstruct..
have passed indicates just that, no mention of a period of validity.
In accordance with this part I take to mean in accordance with Part-FCL. The only mention of validity is FCL.025, but that only mentions licences and the IR/EIR, not type ratings or class ratings. Since there is an explanatory note in the flight instructor section regarding validity, that would indicate it is an interpretation, so it's quite possible that the same could apply to type ratings. Since it's such an unlikely scenario perhaps no one has asked the question yet?