Perhaps AIC W 053/2011 might throw a little more light on the situation.
Whopity, I know that you take some delight in finding fault with the efforts of the Authority, but can you please try and keep things simple?
Anyway, a short history lesson:
Once upon a time, if you lost your Class 2 Medical, your only option was to obtain an NPPL (SSEA). But the CAA, realising that the double whammy of losing your medical
and having to pay for a whole new licence was a bit harsh, generously came up with an Exemption to allow the holders of a current, valid pilot licence with a current, valid SEP Class Rating to continue to fly, but limited to SSEA-level privileges only. This Exemption was also available to those who chose not to hold a Class 2 Medical, even though they could.
This Exemption, known as ORS4 No 711, was introduced in Sep 2008; it didn’t require any paperwork and would apply until the licence, if a JAR-FCL pilot licence, was due for re-issue. Because the CAA had no power to exempt pilots from the requirement to hold a Class 2 Medical for a JAR-FCL pilot licence re-issue, the pilot would then need to obtain a NPPL (SSEA) at that point. But ‘old-style’ UK PPL holders could carry on until they hung up their flying boots, merely revalidating their SEP Class Ratings as they always had. Simple.
An option, though, was to obtain the SSEA Class Rating itself. Due to the differing revalidation requirements for SSEA and SEP Class Ratings, in certain circumstances it was of more benefit to some pilots to hold an SSEA Class Rating, so this option was quite handy. But there was no compulsion - and fewactually understood the difference anyway.
ORS4 No 711 was routinely re-issued in September 2009 as ORS4 No 756, with no changes. But it had been observed that some smart-arsed barrack room lawyers were advising pilots to exploit the Exemption for a purpose which was wholly contrary to the spirit of the original. People were appearing with long expired SEP Class Ratings and renewing them rather than obtaining a NPPL(SSEA). Despite being advised not to abuse the Authority’s generosity, they wouldn’t be told....a tale of the goose and the golden egg was about to follow.
I recommended to the Authority that all that was really necessary was to spell out quit clearly that the Exemption only applied to holders of valid SEP Class Ratings wishing to revalidate, but they decided to go one step further and only to allow use of the Exemption until the pilot licence was due for re-issue or the SEP Class Rating was due for revalidation, whichever came first. If the pilot held a UK pilot licence, the pilot would then need to obtain an SSEA Class Rating or to obtain a NPPL(SSEA); however, this option did not apply to JAR-FCL pilot licence holders who would need to obtain a NPPL(SSEA). A further complication arose for those who had previously exercised Microlight and/or SLMG privileges on an SEP Class Rating - when the SEP Class Rating reached its end of validity point, to continue flying Microlights and/or SLMGs, the pilot would also need the relevant Class Rating as an SSEA Class Rating is not valid for Microlight and/or SLMG privileges. These changes were introduced under ORS4 No 816 in September 2010; unfortunately this also meant an increase in cost as the SSEA Class Rating (and/or Microlight and SLMG Class Ratings) would not be issued free of charge. You can thank the barrack room lawyers for that.
A recent small tweak has been introduced under AIC W 053.2011, which now states:
The privileges of an SEP rating may only be exercised if the licence holder has a valid JAR-FCL Class 1 or 2 Medical Certificate. An aeroplane licence (other than an NPPL(A)) cannot be issued or re-issued, unless the applicant/holder has a valid JAA Class 1 or 2 Medical Certificate. An SEP rating cannot be revalidated or renewed unless the holder has a Class 1 or 2 Medical Certificate that is valid or, in the case of revalidation, was valid within the 12 months preceding the date of revalidation; (this is to allow for the case where a pilot has complied with the revalidation requirements but becomes temporarily unfit before the SEP rating is revalidated).
Whether ORS4 no 816 will be re-issued with the imminent arrival of €urocracy is not yet known.