vaughan111, if you are an AOPA member, you may read an article on this subject in the current issue of
General Aviation:
All’s well that ends well!
We recently received a query from one of our members, a retired airline captain, who was attempting to convert his UK ATPL(A), which was about to expire, to a Part-FCL pilot licence. Our member holds an SEP Class Rating and a valid Part-Med Class 1 medical certificate. He was informed by the CAA that his UK ATPL(A) could not be converted to a Part-FCL ATPL(A) and wished us to advise him accordingly.
We reminded him that, under part-FCL, an ATPL(A) may only be issued to pilots whose existing licence includes a valid Type Rating for a multi-pilot aeroplane. As his didn’t, he would only be able to be issued with a Part-FCL CPL(A). We further advised him to remind the CAA that, as his UK Professional Aeroplane Pilot Licence includes embedded IMC rating privileges, his new Part-FCL CPL(A) should include an Instrument Rating (Restricted).
Following our advice, our member contacted the CAA further. Subsequently, he received his Part-FCL CPL(A), but the IR(R) had been issued as an ‘expired rating’, because his UK ATPL(A) did not include a valid IMC rating certificate of test. Fortunately our member had taken the prudent step of concomitant renewal of his UK ATPL(A), so that he didn’t lose any IMC privileges provided that he exercised them using his green book rather than his little blue one.
We then advised him that, as stated in CAP 804:
3.3.3 UK National Professional Aeroplane Licence Holders
IMC Rating privileges are contained within UK CPL(A) and ATPL(A) licences; (this does not include JAR-FCL or Part-FCL licences). There is no requirement for a separate IMC Certificate of Test for these licences.
Hardly surprising therefore, that his UK ATPL(A) didn’t include an IMC Rating Certificate of Test!
In our opinion, we considered that his IR(R) should have been issued with a 25 month validity from the end of the month of the date of issue of his Part-FCL CPL(A). On our member’s behalf, we wrote to Ray Elgy, the CAA’s Head of Licensing and Training Standards, asking him to investigate the matter further. Within less than a working day, Ray came back to us, confirming that we were correct in our opinion and that he had taken action to re-brief the Licensing Team accordingly.
Our member was very glad to receive this news!
The reason we’re publicising this is not to ‘score points against the CAA’, with whom we have a very good working relationship, but to make other members aware that IR(R)s issued on the basis of IMC privileges embedded in UK non-JAR ATPL(A) and CPL(A) licences should be issued with a 25 month validity from the end of the month of the date of licence issue.
AOPA wishes to thank Ray Elgy publicly for his kind attention to this matter, which will be of benefit to many of our other members.
I suggest that you invite the licensing team member to contact HoL&TS (Ray Elgy) who will ensure that his previous direction is followed correctly!