IR renewal on a private aircraft

[mannios]

Hi
Is it posible to renew your SE IR on a private aircraft?
Thanks in advance

[S-Works]

Yes. There are certain conditions to be met of the examiner is charging you but otherwise its not a problem.

[peterh337]

Yes; I did the whole FAA to JAA IR conversion in my TB20.

The writeup is on my website (sorry cant post a URL with the steve jobs piece i am writing this on, without a lot of work).

You are very limited as to which FTO will want to touch you with a bargepole, but for a renewal it doesnt matter because it can be done with a freelance IRE etc.

[BillieBob]

...but for a renewal it doesnt matter because it can be done with a freelance IRE etc.Provided it is done by 17 Sep. Thereafter, all renewals (but not revalidations) have to be done through an ATO.

[peterh337]

Presumably, you mean that a "revalidation" is what you do between "t minus 3m" and "t plus 3m", whereas a "renewal" is what you do after "t plus 3m", where "t" is the anniversary of your IR skills test.

I don't think many people realise that if they let their IR lapse to the t+3m point, they get captured by an FTO/ATO, and they are back in the "need one more flight, I think" situation which they were so glad to escape from all those years ago :) This also has a big effect for private aircraft owners because if they let it go to t+3m they will be very limited as to which ATO is willing to process them. Most FTOs/ATOs do not work with customer aircraft, and the vast majority of non UK ones won't touch an N-reg.

I also don't think many people realise that flying on an ICAO IR no longer preserves the JAA IR, and after 7 years you have to do the IR exams, the 50/55hrs dual training, and the skills test all over again :ugh: This is one of the biggest pieces of stupidity to come out of EASA.

Not many people realise just how tightly EASA has shafted the private IR community with the above moves, and I am not talking about N-reg. A private JAA IR holder can no longer afford to let the renewal lapse "for a bit" because he is temporarily unable to get his hands on a suitable aircraft (and renting a different type for the renewal will definitely cost him a packet due to type-retraining costs) or is happy to not fly IFR for a few months.

This stretches to "trivia" like GPS database updates. A lot of people stretch their update subscription in the winter because they may not be doing many Eurocontrol flights then. But if your reval comes up in the winter, you have to update the database for the flight.

Or you do what the FTOs have been doing for years, to avoid having to teach GPS approaches, which is to say to the FE "the database is not current so we have to fly conventionally only" :yuk:

I cannot help thinking the FTO industry has been behind this, as a quid pro quo (a revenge, more likely) for getting their revenues "thinned" by the CBM IR proposal.

[BillieBob]

Presumably, you mean that a "revalidation" is what you do between "t minus 3m" and "t plus 3m", whereas a "renewal" is what you do after "t plus 3m", where "t" is the anniversary of your IR skills test.No, revalidation is what you do up until the point that the rating expires and renewal is what you do thereafter. I see where you're coming from, Peter, but I don't think the interpretation is correct. You need to distinguish between Part-FCL, which is 'hard' law and the AMCs & GM.

The 'hard' law in this case is FCL.625 IR, which says, without exception, that "If an IR has expired, ... applicants shall go through refresher training at an ATO...". That requirement having been established, the AMC allows that, in some cases, the time since expiry will be so short that the ATO may determine that no refresher training is necessary and, as guidance, suggests that this may be the case up to 3 months after expiry. However, this is not a blanket exemption and the determination must still be made by an ATO in order to comply with the 'hard' law.

I have heard a rumour that the UK CAA intends to allow IREs to sign off IR renewals up to the 3 month point without reference to an ATO and only after that will applicants need to present a certificate from the ATO for renewal of the rating by the Authority. This, however, does not appear to be compliant with either Part-FCL or the AMC.

[peterh337]

If I understand you right BB, you reckon that for all of EASA-land one has to renew (if the ATO stuff is to be avoided) between t-3m and t, whereas for the UK it appears that one will be able to do it between t-3m and t+3m?

(t is the anniversary of the original IR issue)

I didn't realise the JAA IR expires at t. The CAA FE did tell me all this but I forgot.

[Whopity]

I didn't realise the JAA IR expires at t.It doesn't, it expires at midnight on the day before "t" thereafter it is by definition a renewal.