ICAO IR + CPL to EASA CONVERSION impossible?

[portos8]

Reading EU Commission Regulation 1178/2011 (http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:311:0001:0193:EN:PDF) that states the EASA rules concerning the conversion of ICAO IR and licenses to EASA in Annex 3 (page L311/171) I can not find that it is allowed anymore to convert the IR or CPL. Validations are allowed for twice one year only. What it seems to state is that if someone has a CPL he or she can only convert this to a PPL. The IR can not be converted anymore at all, and the full MEP (L) course has to be done again completely if the holder has not completed 100 hours on class.
It states:
"A PPL/BPL/SPL, a CPL or ATPL licence issued in compliance with the requirements of Annex 1 to the Chicago
Convention by a third country may be converted into a Part-FCL PPL/BPL/SPL with a single-pilot class or type
rating by the competent authority of a Member State "
And concerning the class or type rating conversion:
C. ACCEPTANCE OF CLASS AND TYPE RATINGS
1. A valid class or type rating contained in a licence issued by a third country may be inserted in a Part-FCL licence
provided that the applicant:
(i) for aeroplane class ratings, 100 hours of flight experience as a pilot in that class;
(ii) for aeroplane type ratings, 500 hours of flight experience as a pilot in that type.
Nothing was mentioned that a IR can be converted.

So please correct me if I am wrong with this, but according to what I am reading here I draw the following conclusions:
Under EASA Part-FCL (which will be active from next week in all EU states) an ICAO CPL can not be converted into a EASA CPL, the ICAO IR can not be converted into EASA (not even with a conversion program) and the MEP (L) can only be converted if the applicant has at least 100 hours of MEP (L) class hours.

So anyone training for CPL ME/IR outside Europe wanting to convert the non-EASA license to EASA will not be able to do this? This is the end of the US/SA/Oz/NZ route for modular students from Europe?

[BigGrecian]

You are correct on the class ratings.

Article 8 covers ICAO > EASA in the beginning of the regulations :

Without prejudice to Article 12 of Regulation (EC) No 216/2008 and where
there are no agreements concluded between the Union and a third country
covering pilot licensing, Member States may accept third country licences,
and associated medical certificates issued by or on behalf of third countries,
in accordance with the provisions of Annex III to this Regulation.
(2) Applicants for Part–FCL licences already holding at least an equivalent
licence, rating or certificate issued in accordance with Annex 1 to the
Chicago Convention by a third country shall comply with all the requirements
of Annex I to this Regulation, except that the requirements of course
duration, number of lessons and specific training hours may be reduced.
(3) The credit given to the applicant shall be determined by the Member State to
which the pilot applies on the basis of a recommendation from an approved
training organisation

Part 4) and 5) Cover ATPLs and Type ratings but I didn't include those parts.

The syllabus for the training has to be written down by the head of training after assessment of your experience Under the UK system the HoT has to submit the plan to the CAA for approval first before conversion training can take place.

So in real terms the training has reduced as it used to require 15 hours for the IR - now no minimum set - it just has to be acceptable to the authority and head of training of the school.

So no major changes!

[portos8]

Thank you

The syllabus for the training has to be written down by the head of training after assessment of your experience Under the UK system the HoT has to submit the plan to the CAA for approval first before conversion training can take place.

Does 1178/2011 not overrule this?

[BigGrecian]

It does mention it.

Article 8 and later on covers it.

The reference is part 3 :

(3) The credit given to the applicant shall be determined by the Member State to which the pilot applies on the basis of a recommendation from an approved training organisation


In the UK the head of training makes that recommendation to the authority. This is also true in Poland and I don't see why it would be different in any other EASA state.

I think the intention is to include the instrument rating - the UK and Poland both have alternative means of compliance which covers the IR as well - see CAP 804: Flight Crew Licensing: Mandatory Requirements, Policy and Guidance | Publications | About the CAA (http://www.caa.co.uk/cap804) page 534

The UK do actually have a minimum duration of 15 hours if you do not submit a written recommendation.

[portos8]

Ok thank you, I have been reading it now properly. So also for the CPL the ATO can recommend a minimum amount of hours? Would a combined test for IR + CPL be possible based on this approved training program?