View Full Version : IR (R) on a part FCL ATPL

6th Apr 2013, 10:20
Is or has anyone had problems getting the CAA to put a IR(R)onto a Part FCL (EASA) ATPL?
I have applied, and been issued with, a part fcl atpl, basedon my soon to expire uk jar atpl. I also hold a valid uk cpl.
As I instruct for the IMC (R), my only single pilot instrumentprivileges have been those contained in the uk cpl, my atpl has only multipilot ir privileges.
When my part fcl arrived, it showed the IR(R) as an expiredrating.
I have contacted the CAA, and my case has been passed to atechnical officer, and I have had no response.
CAP 804 states that if you have a UK cpl you should becredited with a IR(R).

6th Apr 2013, 11:00
I think the issue is that they are not giving you the IR(R) because your IR is MP and they have forgotten about the inbuilt privileges.

The table of conversion criteria in CAP804 Section 4 Part P page 31 states that to instruct for the IR(R) the holder must:
Hold a valid FI(A) and a valid IMC
rating prior to 8 April 2014; or a
UK CPL(A)/ATPL(A) issued prior
to 1 July 2000. Therefore they should issue the rating. They issued mine but, I do hold a SP IR as well.

6th Apr 2013, 14:53
I meet those criteria, so I don't see what the problem is withthe CAA, and why it has to be referred to a 'technical officer'. In my correspondenceto them I even quoted the very same CAP 804 reference.

6th Apr 2013, 15:42
I obtained a PPL when my ATPL expired last year, it did not come with an IMC rating. I also have a valid IR. I queried this at the time with CAA, as I will let my IR lapse on expiry next year, and would like the embedded IMC Rating from my ATPL.
They replied that I would have to take the IMC Rating flight test but would be exempted from the exams before the IMC R( IR(R in EASA) could be issued.
How stupid is that when I have a valid full IR! I E Mailed CAA licencing over two months ago to clarify the situation, as it is incorrect that the flight test is required. I am still waiting for a reply.

6th Apr 2013, 22:52
The ATPL has no inbuilt IMC privileges.

In order to add an IMC, or IR(R) to an ATPL you simply complete the IMC skills test, you receive a credit against all training and ground exams.

If you hold a Multi Pilot IR, this offers zero privileges when operating as single pilot.

It's worth bearing in mind however, you historically could apply for an IMC rating at the same time as your singe pilot IR - the skills test, and exams covers both. It used to be just a couple of extra £'s. I believe it's the same under EASA

6th Apr 2013, 23:13
The ATPL has no inbuilt IMC privileges.The reference is to a UK National ATPL which has inbuilt privileges:
ANO Schedule 7
The holder of an Airline Transport Pilot's Licence (Aeroplanes) is entitled to exercise the
privileges of a United Kingdom Commercial Pilot's Licence (Aeroplanes) except that the
restriction at sub-paragraph (4)(f) of those privileges does not apply.

(1) The holder of a Commercial Pilot's Licence (Aeroplanes) is entitled to exercise the
privileges of a United Kingdom Private Pilot's Licence (Aeroplanes) which includes an
instrument meteorological conditions rating (aeroplanes) and a night rating
(aeroplanes) or night qualification (aeroplane).

7th Apr 2013, 07:26
vaughan111, if you are an AOPA member, you may read an article on this subject in the current issue of General Aviation:

All’s well that ends well!

We recently received a query from one of our members, a retired airline captain, who was attempting to convert his UK ATPL(A), which was about to expire, to a Part-FCL pilot licence. Our member holds an SEP Class Rating and a valid Part-Med Class 1 medical certificate. He was informed by the CAA that his UK ATPL(A) could not be converted to a Part-FCL ATPL(A) and wished us to advise him accordingly.

We reminded him that, under part-FCL, an ATPL(A) may only be issued to pilots whose existing licence includes a valid Type Rating for a multi-pilot aeroplane. As his didn’t, he would only be able to be issued with a Part-FCL CPL(A). We further advised him to remind the CAA that, as his UK Professional Aeroplane Pilot Licence includes embedded IMC rating privileges, his new Part-FCL CPL(A) should include an Instrument Rating (Restricted).

Following our advice, our member contacted the CAA further. Subsequently, he received his Part-FCL CPL(A), but the IR(R) had been issued as an ‘expired rating’, because his UK ATPL(A) did not include a valid IMC rating certificate of test. Fortunately our member had taken the prudent step of concomitant renewal of his UK ATPL(A), so that he didn’t lose any IMC privileges provided that he exercised them using his green book rather than his little blue one.

We then advised him that, as stated in CAP 804:

3.3.3 UK National Professional Aeroplane Licence Holders

IMC Rating privileges are contained within UK CPL(A) and ATPL(A) licences; (this does not include JAR-FCL or Part-FCL licences). There is no requirement for a separate IMC Certificate of Test for these licences.

Hardly surprising therefore, that his UK ATPL(A) didn’t include an IMC Rating Certificate of Test!

In our opinion, we considered that his IR(R) should have been issued with a 25 month validity from the end of the month of the date of issue of his Part-FCL CPL(A). On our member’s behalf, we wrote to Ray Elgy, the CAA’s Head of Licensing and Training Standards, asking him to investigate the matter further. Within less than a working day, Ray came back to us, confirming that we were correct in our opinion and that he had taken action to re-brief the Licensing Team accordingly.

Our member was very glad to receive this news!

The reason we’re publicising this is not to ‘score points against the CAA’, with whom we have a very good working relationship, but to make other members aware that IR(R)s issued on the basis of IMC privileges embedded in UK non-JAR ATPL(A) and CPL(A) licences should be issued with a 25 month validity from the end of the month of the date of licence issue.

AOPA wishes to thank Ray Elgy publicly for his kind attention to this matter, which will be of benefit to many of our other members.
I suggest that you invite the licensing team member to contact HoL&TS (Ray Elgy) who will ensure that his previous direction is followed correctly!

7th Apr 2013, 08:00

It might be worth formally asking L&TS for a note to be added to CAP804 to reflect this policy.


7th Apr 2013, 08:36
I do hold a SP IR.
Good luck with your dealings with CAA. When I read Beagles note in my AOPA magazine I E mailed CAA Fcl and pointed out the error ref CAP 804 3.3.3
regarding the non issue of my IR(R) This was in addition to a previous query 5 weeks ago.
No replies, they don't appear to answer EMails anymore.

7th Apr 2013, 09:33

What is really annoying is that my Part FCL was issued really quickly and my initial enquiry about the IR(R) was responded to fast too, then it was transfered to the 'technical officer' and nothing...

It needs to be sorted by mid April when my UK CPL expires, as no IR(R) is shown on my ATPL, and I will not be able to continue teaching the IMC.

I have even flown and passed an IMC test, but obviously this cannot be signed onto the ATPL as no valid IR(R) is shown on the licence.

If I cannot teach IMC, it seems that the CAA are killing the IMC rating via the back door.

7th Apr 2013, 10:19
When converting to a Part FCL licence its well worth retaining a National licence, with the inbuilt privileges, this is charged at an extra £35. It is an ICAO licence and who knows what might happen to the EU in the months ahead.

Courtney Mil
7th Apr 2013, 11:14
BEags, am I right in thinking that was post number 20,000? Impressive, my friend!!!

7th Apr 2013, 11:43
Actually, it was around 22500 as the first 2500-ish were lost in a server crash many moons ago. But I'm not actually that fussed about such things, mon vieux!

Keep putting that Australian child in his place over on the Mil thread!