Looks like an enormous coo for the Training Organizations & CAA to make stacks of filthy lucre. Fight this one really hard or trump up the cash & time. Absolute disgrace when compared to other professions. Doctors, Lawyers, Accounts execs do not have to renew basic skill qualifications when returning to the UK from long stints abroad. And three years is just inane.
However, Regulation is Regulation & Standards are Standards. We have rarely been able to exchange one licence for another. an ICAO licence was good because most Regulators acknowledged the standard and issued validations or issued a member country licence. The old UK CAA ATPL was long considered (by the UKCAA) to be the most outstanding & sought after licence. Of course the US FAA laughed out loud if we presented the UK version in exchange for a FAA ATR. So, in good diplomatic tradition, we laughed at them if they tried to reciprocate.
Once you have the Uk licence, I appreciate the current discussion is about renewing it after a period of not exercising it's own, unique, privilages. This is where the Regulators really take a long hard look at what you have been doing. In the past, it was sufficient to show that you were in regular practice , on type, with an ICAO operator. Just five years ago, I approached the UK CAA asking to renew my 10 year UK ATPL. For type inclusion, I needed to show what I had been doing with type checks etc. All previous types were shown in Part 1 but for a "valid" type rating, I was required to do a prof check with a UK CAA approved Type examiner.
We have developed through the JAA validation & now the EASA debacle. I submit that the Regulatory Authorities are looking too hard at the renewal process & rubbing their hands with glee at the thought of vastly enhanced fee revenue.