LASORS 2008:
Renewal of an IR (A)
The requirements to renew an IR(A) are based on the period of time elapsed since the rating expired i.e. calculated from the date of expiry of the most recent IR(A) proficiency check entered in the licence.
However, where IR privileges have been exercised in another category of aircraft (i.e. UK/JAR IR(H)) or under the privileges of an ICAO licence (Aeroplanes and Helicopters) or under a UK military IR qualification (fixed-wing or rotary), the renewal requirements will be based on the expiry date of that IR.
LASORS 2010:
Renewal of an IR(A)
The requirements to renew an IR(A) are based on the period of time elapsed since the rating expired i.e. calculated from the date of expiry of the most recent IR(A) proficiency check entered in the licence.
Where less than 7 years have elapsed since the IR(A) expired but IR privileges have been exercised since in another category of aircraft (i.e. UK/JAR IR(H)) or under the privileges of an ICAO licence (Aeroplanes and Helicopters) or under a military IR qualification (fixed-wing or rotary), the renewal requirements for the IR(A) will be based on the expiry of that other IR.
If more than 7 years have elapsed since the IR(A) expired, no credit will be given for any other IR rating or qualification, and the terms set out below for more than 7 years since expiry shall apply.
To renew an IR(A) that has expired by more than 7 years, applicants must:
For single-pilot aircraft pass an IR(A) skill test in an aeroplane with a UK CAA Staff Flight Examiner.
For multi-pilot aircraft pass a type rating skill test with or observed by a UK CAA Flight Operations Training Inspector.
Applicants will also be required to retake the IR(A) theoretical knowledge examinations.
No warning was given of this change and it isn't even highlighted in the 'changes from LASORS 2008' references to sections A 12 'Credit for Military Service' or E 1.2 'IR(A) Flying Training / Experience Requirements'.
The CAA made such a balls-up of LASORS 2010 that they had to release AIC 043/2011 'Amendments to LASORS 2010' which did at least include the following:
21 Section E1.5, page E/7 - Renewal of an IR(A)
The second from last paragraph is expanded to include more detailed information regarding the accreditation scheme. The paragraph is replaced with the following:
Applicants will be required to complete theoretical knowledge instruction through an approved training provider. The amount of instruction will be at the discretion of the Head of Training. Where a QSP(A) or ex QSP(A) (as defined in section D3) can show that he/she can fulfil the criteria to claim credits under the one of the accreditation schemes set out in D3.3 for the grant of a JAR-FCL CPL(A) with IR(A), then he/she can, alternatively, follow that scheme's arrangements to fulfil the theoretical knowledge requirements for renewing the IR(A).
The CAA could quite easily have continued the earlier agreement under JAR-FCL1.020:
JAR–FCL 1.020 Credit for military service
()
Military flight crew members applying for licences and ratings specified in JAR–FCL shall apply to the Authority of the State for which they serve(d). The knowledge, experience and skill gained in military service will be credited towards the relevant requirements of JAR–FCL licences and ratings at the discretion of the Authority. The policy for the credit given shall be reported to the JAA.
Note the words 'at the discretion of the Authority'. Why did they not exercise such discretion?
In addition, the CAA delayed introduction of part-FCL from 8 April 2012 to 30 June 2012 and later to 17 September 2012.
All other part-FCL changes have been delayed to the same date, yet no similar delay has been allowed for Military Accreditation. Why??
Good luck with your case, this certainly deserves a legal challenge. If you can get an MP involved to put a formal question through the Secretary of State, the CAA will be obliged to take what they term 'orange folder action' in order to provide the answer within a fixed time period - which involves a lot of work for them!