I have already spoken with the CAA about the poorly worded ORS4 no.1299.
The 'short term exemption' until June is simply because that will tide the UK over until the current nonsense of the UK/EU exit has been clarified - which will hopefully have been achieved by then. It will then be the 'legal mechanism' of either the Aircrew Regulation amendment or, should the UK be stupid enough to leave EASA, whatever UK Statutory Instrument is introduced as a result, which will facilitate extension of the IR(R) until 2021.
The 'PPL' wording is daft. Yes, a CPL or ATPL holder giving flight instruction may do so using FCL.205.A privileges and if necessary, those of the IR(R). The Aircrew Regulation does not restrict the use of Art.4(8) exemptions in the manner stated at para 5 i) of ORS4 no. 1299, so either this is auric embellishment or for some historical reason.
The earlier IN-2015/009 included the following:
Important Note:
Applicants for and holders of the IMC Rating or IR(R) must maintain a PPL(A) or higher aeroplane licence. A LAPL(A) is not sufficient.
