Whopity
That is the way I interpreted it as well. However, I have had the following correspondance with the CAA:
I said:
FCL.625 IR says
'(d) If the IR has not been revalidated or renewed within the preceding 7 years, the holder will be required to pass again the IR theoretical knowledge examination and skill test.'
7 years from the last revalidation/renewal date is actually only 6 years from the date of expiry. This implies that if you do not renew within 6 years from the expiry date, you have to redo all your TK exams.
CAA Policy said:
As we have said before, the start date of the 7 years is the day that the IR becomes invalid. The wording in the regulation states ‘ If the IR has not been revalidated or renewed’ i.e. has become expired, there is nothing in the text of FCL.625(d) referring to the last test the individual completed. An IR is valid for one year from the date of the skills test (normally valid to the end of the calendar month).
If the individual does not revalidate on or before the stated expiry date of the IR, then the individual then has a 7 year period to renew the IR purely on the basis of flight training with an ATO (if required) and the issue of a course completion certificate, plus a skills test with an IRE.
On the anniversary of allowing the IR to expire for 7 years and thereafter the individual will be required to re-take the theoretical examinations, undertake flight training with an ATO and the issue of a course completion certificate, plus a skills test with an IRE.
I then questioned the fact that he seerns to imply that if it is a renewal the test has to be done with an IRE, not an IR renewal examiner, and the fact that he refers to a renewal done within the 7 year period as a skill test, not a proficiency check.
Policy replied
Yes you are correct in that it is a Proficiency Check with an Examiner with appropriate coverage for revalidation/renewal, if the licence is expired even by a day the individual is required to be recommended for the Proficiency Check with an Examiner by an ATO, therefore the ATO is required to conduct an assessment of the individual before issuing a course competition certificate, (the course competition certificate can state that no training is required if the rating is expired by a short period).
The individual whose IR has not expired can of course go directly to the relevant Examiner for their Proficiency Check, as they are not required to be recommended by an ATO.
They do not quite answer the question about a normal renewal having to be done with an IRE, but I take it as read that an IRR examiner can do the test.
By the way, the 5 year rule where the renewal test has to be done by an IRE if it has expired by more than 5 years went away when EASA was implemented.
Linda Mollison