Don't panic just yet, the
proposed amendment is in NPA 2014-29 and has some way to go before it becomes effective, if indeed it does. The revised requirement reads:
FCL.625.A IR(A) — Revalidation
(a) Revalidation. Applicants for the revalidation of an IR(A):
(1) when combined with the revalidation of a class or type rating, shall pass a proficiency check in accordance with Appendix 9 to this Part;
(2) when not combined with the revalidation of a class or type rating, shall:
(i) for single-pilot aeroplanes, complete section 3b and those parts of section 1 relevant to the intended flight, of the proficiency check prescribed in Appendix 9 to this Part; or
(ii) for multi-engine aeroplanes, complete section 6 of the proficiency check for single-pilot aeroplanes in accordance with Appendix 9 to this Part by sole reference to instruments.; and
(iii) hold the relevant valid class or type rating.
(3) An FNPT II or an FFS representing the relevant class or type of aeroplane may be used in the case of paragraph (2), but at least each alternate proficiency check for the revalidation of an IR(A) in these circumstances shall be performed in an aeroplane.
(b) Cross-credit shall be given in accordance with Appendix 8 to this Part.
If agreed, this will indeed mean that, as you cannot combine the revalidation of a class rating in an FNPT II, you will not be able to revalidate/renew an MEP IR(A) in an FNPT II unless you hold a valid MEP class rating.
The consultation period for NPA 2014-29 has been extended to 17 May and so there is still time to comment on the proposal.