It was a piece of utter stupidity from the CAA. The
only 3 month requirement concerns revalidation by
proficiency check!
Their ANO drafter screwed up the JAR requirement and incorrectly misinterprted that, irrespective of when in the second 12 month period the revalidation requirements were met, the
signature itself had to wait until the final 3 months.....
LASORS 2005, 2006 and 2007 state:
If revalidating by flying experience, and providing
the examiner signs the Certificate of Revalidation
page within the 3 months prior to the rating
expiry, the validity of the revalidated rating will be
calculated from the date of expiry of the
preceding rating.
Whereas it used to state (before 2005):
If revalidating by flying experience, and
providing the examiner signs the Certificate of
Revalidation page within the 12 months prior to
the rating expiry, the validity of the revalidated
rating will be calculated from the date of expiry
of the preceding rating.
Unfortunately the CAA (who, incidentally, confirmed that their interpretation is NOT required under JAR-FCL) cannot be bothered to sort out their own ANO error as that might throw some doubt on their own competence to interpret regulations correctly. I have asked, but have had no success
- so the stupid error remains.