CIVIL IRs, the 7 year rule and military IRs - Good News!!

[BEagle]

The CAA has now released http://www.caa.co.uk/docs/33/lts_sarg_Amd%20to%20Renew%20IR%20lapsed%20by%20more%207%20ye arv1_July2013.pdf which basically restores the previous policy which existed before LASORS 2010.

If you've obtained a JAR-FCL ATPL, are still in the military and have a valid, unrestricted Green rating, this policy change will be of significant benefit! As it also will if you've left HM'sFC, but held an unrestricted Green rating which expired less than 7 years ago.

[Ken Scott]

This is good news & what I had been hoping would happen, particularly after the ruling was changed for civil pilots.

I presume that a hearty 'good show' is due to Rich S at 22 Gp for his efforts with this.

Common sense has won the day.

[Solent Trout]

Nice to have some good news for a change. I have a question though:

In the past you would have sent your ATPL to the CAA with your logbook containing your Mil Green Rating and in exchange for a small fee would have your licence revalidated for another 5 years.

With an un-expiring EASA licence is this process no longer required i.e. you simply need to ensure you don't go outside 7 years since your Mil IR?

Anyone know the answer?

Cheers

[BEagle]

In the past you would have sent your ATPL to the CAA with your logbook containing your Mil Green Rating and in exchange for a small fee would have your licence revalidated for another 5 years.


Not quite.

The old requirement for licence re-issue was:

A UK or JAR-FCL ATPL will be re-issued for a further period (5 or 10 years validity as appropriate to the licence held) if the applicant:

1. Holds a JAR-FCL Class 1 medical certificate valid for the first day of issue of the new licence.

2. Has held for any class or type rating included in the licence a Certificate of Revalidation the validity of which has not expired by more than 5 years; or
holds a current and valid non UK issued ICAO Annex 1 compliant pilot licence and is flying an aircraft type, using that licence, which is also included in the
applicant’s UK issued licence; or

is a Qualified Service Pilot in Her Majesty’s Armed Forces who is in current flying practice on a military type appropriate to the licence held (i.e. an
aeroplane for re-issue of an aeroplane pilot licence or a helicopter for re-issue of a helicopter pilot licence).

Now that Part-FCL licences are lifetime, there is no 're-issue' requirement for the licence itself once it has been converted to Part-FCL. Obviously, to use the licence privileges, you must hold a valid Type or Class Rating - and a valid IR or IR(R) if IFR privileges are to be exercised.

[Mach the Knife]

Question is though, will they re-visit applications already denied? I tried to convert a UK ATPL to JAA 2 years ago and had it refused on the 7 year rule. At that time my last mil IR was just under 5 years old but my Civ IR was 8 years old so my ATPL with Perf A became a CPL with no IR and no frozen ATPL privileges. My last unrestricted Green IR expired 7 years ago next month, this might be a rush!

[Dan Winterland]

Rush - get the application in now!

The same applies to the civil IR. It seems the new ruling on both go hand in hand. But I think it will be safe to say that there will be no retrospective rulings on previous cases which fell outside the rules at the time.




Most of the good work was done by "Fartmaster" who led the campaign against the CAA's interpretation on 625 regarding the 7 year rule. The CAA states that the re-interpretation was a "De-rogation" but in reality, they have just started to follow other European agencies by including non JAA ratings, including military. We warned the CAA that they ran the risk of losing up to UK 1500 licenced pilots off their books, but they didn't think it would happen. But when UK pilots started having their EASA ATPLs issued in Ireland and France this year, they realised it would happen. I suspect it was this which prompted the ruling.

[BEagle]

But when UK pilots started having their EASA ATPLs issued in Ireland and France this year....

I think it was at the May 2011 EASA Part-FCL Partnership Group meeting that I discussed this with an IAA member. He told me that several pilots had changed their 'State of Licence Issue' to Ireland as a result of their more pragmatic interpretation of the requirements....and would be happy to welcome further applications as necessary.

I passed this information on to 'Fartmaster', which confirmed what he'd already established.

This is indeed as derogation, Dan, as the action has been taken under the provisions of Article 14(6) of the Aircrew Regulation; because EASA has recommended the Article 14(6) proposal and due to the time it takes for a 14(6) to be formally agreed, the CAA has raised an Article 14(4) exemption of its own, allowing the new policy to be adopted for UK-issued IRs with immediate effect. A future EASA working group should then bring it into the Regulation proper.

There are now a quite absurd number of Article 14(4) and Article 14(6) exemptions in place - which only goes to show how fundamentally unfit for purpose the whole €urocratic farce of EASA really is!

[Chugalug2]

Does that nice Mr Farage know about this shambles? It nicely encapsulates why the UK should either quit the EEC or otherwise take a lead role in ensuring its output is compatible with the real world. Our own bureaucrats do not live in the real world but have always been moderated in their excesses by Parliament. However, when they are busy enforcing Euro Regs it seems that nothing or no-one can stand in their way, save it seems the phlegmatic Irish and those here who fought the good fight. Well done to all of you, a blow for England and St George! :ok:

[Dan Winterland]

It's actually more about how individual nations interpret Part FCL. The CAA picked up on the 7 year rule, I suspect because they thought it would make them money in exams and revalidations. It's backfired and the result is that some pilots thought "sod it" and let their UK issued JAA licences lapse. Others are going to other agencies.

The crazy thing is, the guy who wrote the 7 year rule actually said that it was only intened for those piots who had no IR at all, but when it was translated from French into English, the intention was lost. And the CAA decided to interpret it thieir way when other nation's aviation authorities took it as it was intended.

The next battle is how the CAA intend to put third county's ratings on a UK issued license. We are still waiting for a reply. But while the CAA dithers, more of their revenue is transferring overseas.

The Irish AA are indeed pragmatic and in my dealings with them, I have been very impressed. They don't tell you to go away and read their idea of the regulations and make a guess, only to have them come up with a different interpretation when you make your application.

[VinRouge]

Just to confirm, if I gat my easa atpl, as long as I maintain a green rating, my atpl will not lapse? Will this be for certain multis types ie a330 or does it apply to types no longer on the register, ie c130j?

[BEagle]

Are you referring to the initial issue of a part-FCL ATPL, or to the conversion of an existing JAR-FCL ATPL?

All part-FCL pilot licences are 'lifetime'; however, class and/or type ratings and IRs contained therein have to be revalidated as appropriate in order for a licence holder to exercise privileges on that class / type, or renewed if they've lapsed. The major change refers to the renewal of civil IRs and the '7 year rule' applicable to re-taking the theoretical knowledge exams - the clock for which now starts ticking, as far as military pilots are concerned, when their unrestricted Green Rating expires.

[VinRouge]

Its to do with initial issue and trying to avoid getting a licence paying for a cpl ir then having to renew a cpl ir on a type down at exeter as i approach the time to leave...

So to get this right, you can't use your green rating to remain within validation time for the part-fcl holder to exercise priveledges? Before easa, as far as I was concerned, if I held an atpl and as long as my green rating hadn't gone out of date on the J, I could still use it to get a job. This seemed to change the minute the Europeans took over as I understand it, they took the j off the civvy register.

[jpboy]

Beags,

Great news, I understand the background to the 7 year license re-issue problem and not meaning to drift but may I expand a little on your comment to avoid any confusion for those about to leave the Forces aiming for the airlines?

A UK or JAR-FCL ATPL will be re-issued for a further period (5 or 10 years validity as appropriate to the licence held) if the applicant:

is a Qualified Service Pilot in Her Majesty’s Armed Forces who is in current flying practice on a military type appropriate to the licence held (i.e. an aeroplane for re-issue of an aeroplane pilot licence or a helicopter for re-issue of a helicopter pilot licence).

To avoid doubt the pre-requisite experience to start a type rating course for a candidates first multi pilot aeroplane (ie. first airline job) is a multi-engined IR. Most QSPs will have had to fly a twin for the IR, if that rating remains current then job done. But if that twin rating has lapsed and a QSP candidate is using their Green mil rating to keep the ATPL current then it has to be a Green multi-engined rating at course start date.

I spent months attempting to reason with the CAA on behalf of QSPs and received different interpretations dependant on who answered the phone. At one point I was assured a Green rating on a Tutor was sufficient for an ATPL candidate (lapsed Seneca IR) to start a 737 type rating course for the Policy Department at the CAA to overturn the advice and state;

This morning we discussed the ME IR which is one of the pre-requisites in order to gain the first MPA Type rating. You highlighted the LASORS 2010 text of para F4.1 b) which includes the following: “A UK QSP who has held a Green IR within the preceding 5yrs is deemed to hold a ‘current and valid’ IR.” I confirmed that given the paragraph starts with ; “Hold a current and valid Multi Engine IR…….” it is reasonable to assume that all subsequent IR references would be in relation to Multi engine IRs, even though this may not be specifically stipulated. The requirement of holding a current and valid ME IR, or in the case of a QSP, a ME green IR (within the last 5yrs) has been, and is Policy.

It came close to shafting our candidates. I would hate to see history repeat itself.

Great news nontheless and well done to all who worked hard for commonsense to prevail.

[The English Passenger]

Jpboy,

Not trying to be selfish and appreciate that this does not apply to a lot of people.

If I read your post correctly does that mean that as I hold a JAR ATPL that is less than 7 years old when I leave and that I will leave with a current IR on the KingAir, a multi engine aeroplane, that I do not need to spend any more of my cash on any other type ratings or IRs????

Regards,

English Passenger

[jpboy]

The English Passenger,

I've not read the full link to the 7 year renewal statement from the CAA. However, assuming the fine contributors (esp Beags) are correct then my read is that yep your King Air multi-engined rating meets the pre-requisite to start your first multi pilot type rating. This obviously assumes you passed a multi-engined IR at some point in the last 7 years for license issue.

The multi-engined rating must be current at your course start date so whilst not sexy an IRT as close as possible to your final day would be ideal.

Good luck

ps. This also assumes the CAA Policy Department haven't changed their stance in the eighteen months since I last did battle with them. Our lot are about to recruit again, if we end up on the same merry-go-round I'll officially be threaders!

[The English Passenger]

Thanks jpboy. Multi IR was done 2.5 years ago on 4 engine jet so validity on the IR is fine..... Who are "your lot" that are about to start recruiting? Always nice to have a heads up!

[StopStart]

Just to add to one of the few threads that actually belong in the Military Forum these days (rather than Aviation History & Nostalgia or Spotters Balcony) I'd recommend that those still "in" but seeking to exercise their recently reconfirmed ATPLs keep a close eye on the Terms and Endearment forum. Admittedly there's almost as much irrelevant toss in there as there is on this forum however you will pick up notifications of recruitment.

Jet2 currently recruiting non-TR pilots and you can possibly expect some limited recruitment from Mr Branson's mob in the near future.

[Ken Scott]

Just to add to one of the few threads that actually belong in the Military Forum these days

Steady on StopStart, next you'll be implying that posters should have some connection to the military which would leave these forums empty!

[jpboy]

Hi English Patient,

Please don't confuse validity with currency.

At the start date for your first multi-pilot aeroplane (MPA) course you must have a current multi-engine rating ie. within the last year (or is it 13 months? Been a while and airline LPC/OPCs last a year).

Sounds like any airline course won't be your first MPA so may not apply to you. As with all these issues a written confirmation from the CAA FCL is the only certain way of knowing. Apply/ask with plenty of time to go as their turnaround time for paperwork is months not days due to workload.

Good luck, esp when dealing with the CAA!

[The English Passenger]

Thanks jpboy. Good advice. As with all these things, one takes info on here as guidance. I will seek clarification from the training dept of any employer who I am fortunate enough to impress enough to get a job offer from, as well as the Campaign Against Aviation.

My reading of the rules in CAP804 along with the new note leads me to believe that my JAR ATPL issued on a multi pilot multi engine aircraft in January 11 will be valid as such until Jan 15 with no further action as I will have held a green IR on that ac type in the previous 5 years and a green IR on the kingair valid when I leave.

I was initially under the impression from the CAA that I would have to convert my license to a EASA Part FCL by April 14 at a cost of £140, but digging into CAP804, Section 2 part C page 2 para 2.5 states that fully compliant JAR-FCL licences issued before Sep 12 automatically become EASA part FCLs and that physical replacement is not required until calendar expiry and that process must be done NLT 08 Apr 18, or in my case on 5 year expiry in Jan 16.

Even if the worst happens and the validity is not correct I will just spend some resettlement money on doing a kingair civilian IRT before I leave.

[jpboy]

Sounds as though you are well placed English Patient, all the best.

One last thing. I was liaising with the CAA on behalf of the training dept when I had the conflicting advice from them. Many airline don't actually do the OCU's themselves choosing to let Type Rating Training Organisations (TRTO) shoulder the financial burden of Sims etc. The TRTOs were getting different answers from the CAA to the same questions I was asking regarding Green Ratings, it was a shambles.

My point is that in civvie street the onus is on the individual to ensure they are fully qualified for any training course as per their CV. Training Depts and TRTOs have due dilligence, but my best advice is to apply and hopefully present at interview fully squared away with no awkward questions regarding ratings or license outstanding.

Final, final thing if you are available IMMEDIATELY put it in big bold letters under your name on the CV :ok:

[The English Passenger]

Jpboy,

Thanks very much... Great advice

[FFP]

Is anyone aware of a business / service that exists to help those with ATPLs/CPLs navigate through the requirements and advise on what needs to be done ? I have a fairly complicated situation that I'm sure the CAA will answer with "Refer to CAP804" and I'd be quite happy to pay someone who could decipher the rules and apply them to me.

The likes of BEagle provide great information and frankly the time involved in working out such positions is worthy of reward IMO.

[Wildbluewander]

Hi Mach

Did you get a response from the CAA? I tried to resurrect my ATPL last Oct and was stunned when i was informed i would have to redo some exams having completed the whole shebang back in 2000. I see now that this may no longer be the case. My last unrestricted IRT was done on 16 Dec 06 on a C130K which by my maths make me still within the 7 year rule and a very similar situation to yourself, however, it still seems to be a bit of a lottery as to whether I come up with the right answer. If you have any reflections of useful info I would be very grateful. PM me if its easier. Thanks!

[Ascoteer]

So I'm right in saying that if I have a licence opened with a type rating on an EASA approved RAF aircraft, this rule will not keep my type rating current each yar...?

Cheers! :ok:

[Mach the Knife]

I did get a response from the CAA. It was very comprehensive and came back quite quickly. They would not allow the renewal I did 2 years ago as the rules then did not allow it. They did confirm that what I had done then would be valid if I did it now within the 7 years since my last unrestricted Green expired. They also confirmed that if I let the IR go by more than 7 years I would have lost the ATPL Theory too and would therefore need to do ALL of the academics again to get the frozen ATPL. Additionally they confirmed that my Tutor green rating "no GAT in Class A" as issued these days was in fact worthless for the 7 year rule. I have just redone my MEP class rating and ME-SPA-IR and will be dropping into Aviation House very soon. Hopefully what I have will be sufficient, I'd hate to have wasted another grand.

[Wildbluewander]

Thanks for taking the time to reply, it sounds as if we are in the same situation. I now have 4 months before I lose the lot then, time for action!! Where did you do your flying and would you recommend them? PM me if you prefer!

On the subject of hopefully a quick renewal anyone got any recommendations for schools? Also, what type of aircraft? Probably opening a can of worms and digressing but any help appreciated. Thanks!

[Mach the Knife]

4 months, luxury! I had 3 weeks from finding out the 7 year rule now applied to Mil IRs. I went through Airways Flight Training at Exeter, and they were once again brilliant. Good assessment of what I needed to satisfy training to the satisfaction of the ATO before test. Then a comprehensive test of IF and ME handling. The ac is a bit tired but perfect for the job and actually quite easy to fly if you are in current handling, not autopilot manipulating practice. I would have no hesitation in recommending them.

[Wildbluewander]

No pressure then bud!

Just to confirm it is 7 years from the unrestricted green expiry as I was told today it was 7 years from issue which is critical for me. I took my last IRT on 20 Dec 06 so I reckon on your say I'm still okay but just want to make sure again!

I will speak to Exeter as they're only a bit down the road from me and get that booked after my medical next week at Gatwick. Not going to count any chickens on that one. I haven't flown for 6 years so I will probably need a bit, of a refresher. I had thought about doing it all on a DA42 because of the FADEC and Garmin toys but I'm used to pulleys, levers and steam so it may be best to delay my arrival in the brave new world until another time.

Thanks again for your help.

[Mach the Knife]

I had a frantic and quite productive e mail exchange with the CAA and asked some very specific questions. They have confirmed that the renewal needs to be done within 7 years of the expiry of your last unrestricted green rating. The Tutor for example is worthless for exemption purposes. They have also confirmed that they recognise the mil validity of 13 months. If you have previously had a SPA MEIR, then the renewal requires a precision and a non precision approach with some other ancillaries like holds, UPs and steep turns. I did the whole thing with an NDB and VOR/DME to ILS. Not sure you need to be paying for a swept up techy ac.

[Wildbluewander]

More good news and on a Friday as well, time for more beer and curry.

Did my IRT on a Herc K so that should be alright I assume. 13 months gives me until January, luxury.

What does SPA mean, I'm not to up on the jargon I'm afraid?

How many hours did you have and did you use the sim? Take your point about techy stick with the good old needle chase I think.

[Mach the Knife]

Single Pilot Aircraft. I have not been fortunate enough to have to regularly share my cockpit with another qualified pilot. Take a day and try to read through CAP804, it should point you roughly in the right direction. Also worth e mailing the CAA to clarify what you need to do, they were pretty good at getting back to me. I think you are in a different situation to me, I was after a CPL/IR with ATPL Theory, not a full on ATPL. First time I've been unhappy about all the fast jet flying.

[Wildbluewander]

Thanks for that and I see what you did there ;) i'd swap my hours for yours I'm sure!

I emailed the CAA at the beginning of the week so will hopefully hear soon, if not I have my Class 1 a week today so may drop in for a chat whilst I'm there.

CAP804 is a good idea but I know it will be time I will never get back. Truth is I joined to fly planes and that's all I want to do now. As someone pointed out earlier isn't there someone who is good at this :mad: who can just do it for us? Oh woe is me.

[BEagle]

From the source document:

http://i14.photobucket.com/albums/a341/nw969/IRstuff_zpsc76f2b3f.jpg (http://s14.photobucket.com/user/nw969/media/IRstuff_zpsc76f2b3f.jpg.html)

The 7 years is clearly not from the date of issue - the Unrestricted Green IR must have been valid in the 7 years before the date of application.

[Wildbluewander]

That's great BEagle thanks for clarifying that. Very glad I didn't spend time and money redoing the exams last year! Thanks once again to yourself and others who have given their time and effort into getting this matter resolved. I'm very grateful and will happily chuck some money in the pot for your favoured charity, just let me know, after the time and money you've saved me its the least I could do.