Do NOT let your JAA IR lapse...

[peterh337]

I know this has recently been mentioned here in passing, but it is worth drawing attention to it properly:

Keeping the JAA IR Valid

To be valid for flying, the JAA IR must be renewed every year with an IR Examiner. The examiner can be a freelance one. The cost varies; a typical figure for a freelance IRE is about £150, plus the aircraft. The renewal of an MEIR in a rented twin will therefore cost c. £1000.

Every 2nd revewal can be done in a simulator, which is usually of little interest to aircraft owners since the sim usually costs more than their own aircraft.

In the past, a JAA IR did not expire (in the sense of being able to "wake it up" purely by doing a renewal with an IRE, not for flying privileges) if you were flying on the privileges of any ICAO IR. This was a great concession for pilots who were living/working outside Europe.

EASA's gold plating bureaucrats have ended this and imposed a strict regime whereby after 7 years of not renewing you have to re-do the whole IR - theory exams, flight training, and the flight test.

The reference is in AMC1 FCL.625(c); the full 562 page tome is here
http://easa.europa.eu/agency-measures/docs/agency-decisions/2011/2011-016-R/AMC%20and%20GM%20to%20Part-FCL.pdf

and the relevant page is 226. Many airline pilots, working abroad, have been hit by this measure which doesn't appear to have any basis in safety since re-doing the ab initio IR training will be of no relevance whatever to them.

Even allowing the IR to lapse for more than 3 months invokes the ominous "minimum of three training sessions" which means blowing some time and money at an FTO.

This is going to screw UK commercial pilots working outside the EU (or otherwise flying on non-JAA ICAO papers). But it also affects anybody who gets the JAA IR now, as an insurance policy against the EASA anti-N-reg moves, but (flying on e.g. FAA papers) decides to not spend time and money renewing it until the EASA position has firmed up.

I wonder what has brought this about. Was it lobbying by the FTOs, who are trying to generate regular IR renewal business?

[BEagle]

One of the EASA generic requirements is that the maintenance of any qualification requires a periodic demonstration of skill proportionate to the qualification.

The EASA IR requires annual revalidation; even under JAR-FCL, for the UK IMCR there is a 2-yearly mandatory re-test with an authorised examiner.

However, you can maintain a private FAA IR by 'experience' without any requirement for periodic retest. Presumably that's why it cannot be used to maintain a part-FCL IR(A) - it doesn't meet standard EASA requirements.

[mad_jock]

They also won't let you use LPC's for type ratings either done in the sim.

How do the keep FAA type ratings current?

[peterh337]

Beagle - while you are right in that in the past, the FAA IR 6/6/ rolling currency could alone be used to support the JAA IR (in the sense of not having to redo the exams and the flight training and the IRT), it is also the case that a foreign IR which is renewed annually will not support it either, and that includes an FAA IR kept current with an annual IPC.

So this measure is a pure moneymaking perversion, because they could have done it so that to keep the JAA IR current you needed to do an IPC (i.e. the 6/6 rolling currency is not enough). There is already a precedent for that, in the way you get the IMCR on the back of an ICAO IR, for £70. The CAA demands a recent IPC on the FAA IR; they refuse to recognise the rolling currency option.

How do the keep FAA type ratings current?

You can do the 6/6 rolling currency, or an IPC. Aircraft owners, who tend to fly a lot, use the 6/6, while renters tend to do IPCs because doing 6 approaches in the past 6 months requires rather more flying. But the FAA IR itself never expires so no matter what, you do not have to re-do the IR exam and the initial test with a DPE.

Ultimately this is "only money", in the form of paying an IRE every year.

[mad_jock]

Aye but what do the 7500kg plus pilots do?

[peterh337]

No idea; presumably what airline/jet pilots everywhere do. Recurrent training, or whatever the Type Rating involves. It will be in Part 122, Part 135 or whatever.

[mad_jock]

We do an IR test every year called an LPC with TRE. And a OPC every 6 months which is virtually the same thing

[italianjon]

How does that affect SEIR/MEIR validity in the terms of LPCs?

Let me explain, so I want to do my full IR. I have looked into ground schools and done lots of research, with the aim of one day sitting making some cash from this flying malarky ;)

Anyway some suggestions that I had recently was to do the course and test and get the MEIR, which will be valid on an SEP. I can use that for pleasure flying and then keep an SEIR valid each year. That way if someone ever offered me a way out of the office and on to a flight deck I could go and do an LPC on an ME, instead of the conversion course.

Is this still valid, or is it worth waiting to see how EASA chop and change things...

I guess the question is do I start studying for ATPL Exams in the next couple of weeks, with the aim of doing CPL/MEIR next year, or do I wait...

[BillieBob]

The detailed requirements for refresher training are contained in an AMC. Whilst this remains the only AMC related to the actual legal requirement (FCL.625(c)), under EU rules its contents are mandatory. However, any person or organisation is at liberty to propose an alternative means of compliance that, if accepted by the competent authority, may be used to meet the legal requirement. For example, one could propose an alternative means of compliance that recognised the maintenance of an ICAO IR - something worded along the lines of the relevant paragraph in the current edition of LASORS might meet with CAA approval.

[Dan Winterland]

"EASA's gold plating bureaucrats have ended this and imposed a strict regime whereby after 7 years of not renewing you have to re-do the whole IR - theory exams, flight training, and the flight test."

This is actually JAR FCL 1-185 being directly translated into EASA FCL and has been around since 2005. Except that the CAA failed to notice it and only introduced it in LASORS 2010 - which incidently, they didn't get round to publishing until April 2011!

"while you are right in that in the past, the FAA IR 6/6/ rolling currency could alone be used to support the JAA IR (in the sense of not having to redo the exams and the flight training and the IRT), it is also the case that a foreign IR which is renewed annually will not support it either, and that includes an FAA IR kept current with an annual IPC."

This is the CAA's interpretation of JAR FCL 1-185 which specifies the 7 year limit. I have it on good authority (from one of the complilers of JAR FCL) that it was only meant to refer to an instrument rating and not just the JAR IR. Unfortunately, this isn't what it says. The CAA chose to include the caveat that no non JAR or military IR would be included in this statement - despite constantly referencing JAR FCL as the master and overiding document. It was clearly interpreted this way to increase revenue,

However, it has had an opposite effect, as the many UK pilots flying overseas as expats on foreign licences have looked at it and though "sod it - too difficult" and have just let their original licences lapse. Interestingly, nearly every other JAR member state has not been interpreting JAR FCL 1-185 this way and has been considering non JAR IRs as experience.

However, from April this year, the CAA are just the EASA agents in the UK and will not have any right to interpret EASA FCL. It will be interesting to see how they do this - but if they continue thier unilateral stance, they will be facing some form of legal action!

The CAA are a shambles and not serving the pilot community or the industry well.

[Clearedils]

Pilots of aircraft >5700kgs mostly renew both their JAR/EASA and FAA ratings at the same time if the FAA examiner is dual rated. Tests are very similar.

[peterh337]

That would be logical, if you can find a JAA IRE and an FAA CFII in the same person (one does the same with JAA+FAA medicals) but it doesn't help in this case where one would be after keeping the JAA IR valid via the FAA IR 6/6 rolling currency option, which involves no extra cost.