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Genghis the Engineer
6th Jul 2019, 22:44
Does anybody know the answer to this, it keeps exercising my mind.

Amongst other ratings I hold a UK CPL, EASA CPL, and UK IR(R).

The IR(R) is listed on my EASA CP, it is not listed on my UK CPL. When I queried this a couple of years ago with CAA, they told me that this was because UK professional licences contain embedded IMCR (sic) privileges.

Now, as I've never allowed the IMCR/IR(R) to go out of currency, it has never been an issue. But what I have never been able to find is the *legal* requirement to be able to exercise those privileges? Common sense says you should be within 25 months on a rating revalidation test, which I always am *but* those are only ever shown on my EASA licence, not my UK CPL.

Let's say I tore up my EASA CPL and simply used the UK CPL to, say, fly a CofA Bulldog (a stupid thing to do, but possible). How would I, or anybody else, ever show that I am legally permitted to exercise those IR(R) privileges?

It doesn't strictly matter in the real world, but I'd be interested if anybody knows.

G

BEagle
7th Jul 2019, 07:15
A valid legacy UK professional licence includes IMCR non-expiring privileges. These may be used on non-EASA aeroplanes provided they are not restricted to VMC only.

A Part-FCL CPL issued on conversion from a legacy UK CPL should be issued with an IR(R), which is only valid for 25 months. When the first few Part-FCL CPLs were issued on conversion, the CAA omitted to include the IR(R), but if the licence was returned this error could be corrected - free of charge, if I recall correctly. That was because as the AOPA representative on such matters, I had pointed out the problem to the then Head of Licensing who subsequently admitted that I was correct - he didn't know that the UK CPL included IMCR privileges.

BillieBob
7th Jul 2019, 10:04
How would I, or anybody else, ever show that I am legally permitted to exercise those IR(R) privileges?
Simple, you refer to Schedule 8 of the ANO
ANO Schedule 8
Commercial Pilots Licence (Aeroplanes)
Privileges:
(1) The holder of a Commercial Pilotís Licence (Aeroplanes) is entitledó
(a) to exercise the privileges of a United Kingdom Private Pilotís Licence (Aeroplanes) which includes an instrument meteorological conditions rating (aeroplanes) and a night rating (aeroplanes) or night qualification (aeroplane);
There are no revalidation requirements as it is not a separate rating; if the licence is valid, the IMC privileges are valid.

Genghis the Engineer
8th Jul 2019, 10:12
Well there's a powerful privilege, it would be foolhardy to abuse!

G

Whopity
8th Jul 2019, 12:21
Now if you were exercising the PPL privileges contained in such a licence, does that have any bearing on the IMC privileges in that licence?

Genghis the Engineer
8th Jul 2019, 12:28
To exercise the PPL privileges I need to be in currency for my biennial to keep the SEP rating current....

G

BillieBob
8th Jul 2019, 15:50
Now if you were exercising the PPL privileges contained in such a licence, does that have any bearing on the IMC privileges in that licence? No. You are exercising the privileges 'of a PPL which includes an IMC Rating'.

Whopity
8th Jul 2019, 15:52
No such thing as a biennial, you could have done a prof check in the class or any other type or class.

Whopity
8th Jul 2019, 15:54
No. You are exercising the privileges 'of a PPL which includes an IMC Rating'.
That was my take on it.

Genghis the Engineer
8th Jul 2019, 18:09
No such thing as a biennial, you could have done a prof check in the class or any other type or class.

No such thing as "Group A" either, but everybody knows what it means.

Anyhow, people seem to have cleared up the question, and I'm grateful for that.

G

custardpsc
8th Jul 2019, 20:13
I have a similar question to Genghis - I believe that the holder of an FAA IR can be given an IR(R) on an EASA licence. But how does one account for revalidation/currency - is it a one off deal and you then have to keep it current ? or permanent like the CPL privilege ?

BigEndBob
8th Jul 2019, 20:47
I surrendered my UK ATPL for the Easa CPL.
If i ask the CAA to issue me back my UK CPL, can i then use non expiring IMCr IR(R) privileges.
Can i also do IMC training and tests for those wishing to use their UK PPL .

Genghis the Engineer
8th Jul 2019, 22:25
I can answer half of that Bob. It's a nominal fee (I think £42 last I looked) and a form to get issued a parallel UK CPL. You can then run the two together, and just ask examiners to sign both after you have done rating revalidations. The UK CPL will not list the IR(R) as it's considered embedded - and the currency requirements seem to have been addressed above. For now at least you can use a UK licence to fly EASA aeroplanes, and for non-EASA aeroplanes (such as the Bulldog I mentioned up the top) that privilege should never expire.

Somebody who knows more about that (and your own qualifications) than me can answer the bit about training and testing.

G

Whopity
8th Jul 2019, 22:27
With the exception of a UK Professional lience the only way to keep the IR(R) current is by Proficiency Check. In any event the IMC on a UK CPL/ATPL would only be valid on Annex 1 aircraft.

If i ask the CAA to issue me back my UK CPL, can i then use non expiring IMCr IR(R) privileges. Yes in an aircraft that that licence is valid on i.e. Annex1

Genghis the Engineer
8th Jul 2019, 22:37
I have a similar question to Genghis - I believe that the holder of an FAA IR can be given an IR(R) on an EASA licence. But how does one account for revalidation/currency - is it a one off deal and you then have to keep it current ? or permanent like the CPL privilege ?

I don't believe that this is the case.

What you can do, if you have an FAA / ICAO IR *and* at least 50hrs logged IFR (note, whilst the FAA is interested only in time by sole reference to instruments, EASA has separate uses for that, and time under IFR, so there's value in logging both these days), you can present straight for an EASA IR skill test. Of course, do that, and you'll almost certainly fail it, but hopefully a day or two with a good IRI should iron out any gaps in EASA knowledge and get you ready. Various people are advertising courses to do just that. Then you are in the standard EASA revalidation test cycle.

G

Genghis the Engineer
8th Jul 2019, 22:43
Can I suggest that as sooner or later EASA will change it's Annex numbers again, we should just say "EASA" or "non-EASA" ?

G

custardpsc
16th Jul 2019, 09:42
I don't believe that this is the case.

What you can do, if you have an FAA / ICAO IR *and* at least 50hrs logged IFR (note, whilst the FAA is interested only in time by sole reference to instruments, EASA has separate uses for that, and time under IFR, so there's value in logging both these days), you can present straight for an EASA IR skill test. Of course, do that, and you'll almost certainly fail it, but hopefully a day or two with a good IRI should iron out any gaps in EASA knowledge and get you ready. Various people are advertising courses to do just that. Then you are in the standard EASA revalidation test cycle.

G

Thanks, I did know that and have already moved in the competency based direction. However the statement did arise ( form a respected CFI) that the CAA would grant an IMC rating on the basis of a FAA IR and was curious to know how it might work. I'll do a bit more digging !

Genghis the Engineer
16th Jul 2019, 10:40
Do report back. Whilst not of any immediate value to me, it would be interesting to know, and bound to be a useful gem of information some day.

G

Whopity
16th Jul 2019, 10:58
However the statement did arise ( form a respected CFI) that the CAA would grant an IMC rating on the basis of a FAA IR and was curious to know how it might work. I'll do a bit more digging !
This was the case back in the 80/90s before the introduction of JAR-FCL in 1999. It may have even extended beyond that date, but I have not come across any case of it occuring in the last 15 years.

custardpsc
21st Jul 2019, 19:35
Thanks - that likely explains it... and if anyone has any suggestions for an instructor who can do the competency based IR in a relatively intensive fashion I'd be grateful. I have looked at the usual suspects already.

custardpsc
1st Aug 2019, 03:23
Genghis - I did find this sentence whilst looking at third country licence verification process - so it seems that this is still a possibility.

"Instrument Rating (Restricted) where applied for on the basis of a Third Country single pilot instrument rating "

BEagle
1st Aug 2019, 07:18
Current policy is still as per CAP804:
An applicant who holds an ICAO IR(A) or military green Instrument Rating (Aeroplanes) and has passed a single-pilot IR test in the 24 months preceding the date of application for the IMC Rating / IR (Restricted) will be credited with a pass in the initial IMC Rating/ IR (Restricted) Skill Test and the written examination. The applicant must apply for the issue of the IMC rating within 24 months of the last IR test passed, The IMC Rating / IR(Restricted) will be valid for 25 months after the last day of the month in which the last IR test was successfully passed.

( Apologies for the font - the latest PPRuNe software still doesn't include user-selectable font size / type... :ugh: )

custardpsc
12th Aug 2019, 10:54
Beagle - thank you, I should have known it was in CAP804. Now I just need to figure out how this applies if one already held an IR(R) that was expired.. ie if my IR test/proficiency checks could be used to validate my IR(R) for my already held expired IR(R) ....

Fleyer
9th Sep 2019, 15:03
Hi all,

Can someone clarify what is required for an FI (with an MEP/CPL/IR) to teach IR(R) - the old IMC rating?

Many schools quote the following:

Pre-Course Requirements
Hold a valid IR(R) and an unrestricted FI rating;
Completed at least 10 hours flight time by sole reference to instruments in an aeroplane, Full Flight simulator, Flight Training Device (FTD) 2/3 or Flight Navigation Procedure Trainer (FNPT)II.

I am assuming I can teach IR(R) if I "only" have an IR and not an IR(R)? Also if I have an IR, I automatically fulfill the 10 hour requirement?

Would appreciate if someone could clarify.

Many thanks

Whopity
9th Sep 2019, 21:17
Hold a valid IR(R) and an unrestricted FI rating;] This is a rather outdated concept going back to National ratings.
To teach for the IMC or IR a FI must have embedded IRI privileges, this is indicated in section XII of the licence under FI with a (g) for the IR and (g)(IRR) for the IMC-IRR simply holding an IR is not enough.
Completed at least 10 hours flight time by sole reference to instruments in an aeroplane This is a prerequisite to undertake a FI Course FCL.915.FI.FI. You must also hold a UK issued licence to teach for the IRR as it is an exclusive UK rating.

Mickey Kaye
10th Sep 2019, 06:34
While we are on the subject. FAA CPL/IR and has a EASA PPL, SEP, IMC, FI but no CPL TK and No Easa IR. Are they able to teach for the IMC? as IN 2016-082 states (my bold):

4.3
In addition, the CAA will authorise instructors to instruct for the IMC Rating/IR(R) if they satisfy the following requirements:
a) hold a Part-FCL aeroplane licence issued by the UK CAA; and
b) hold a Flight Instructor (Aeroplane) (FI(A)) without supervisory restriction, qualified to instruct for the single pilot class rating for the class or type of aeroplane which the IR(R) instruction is to be conducted in; and
c) hold a valid IR(R) rating or IR(A) (not En-route Instrument Rating (EIR)) on the Part- FCL licence; and
d) have passed all TK examinations either for the issue of a CPL(A) or IRI(A), subject to the same time limitations stated in Part-FCL Annex I; and
e) have completed at least 10 hours flight time by sole reference to instruments in an aeroplane, Full Flight Simulator (FFS), Flight Training Device (FTD) 2/3 or Flight Navigation Procedure Trainer (FNPT) II; and
f) have completed the course as specified in FCL.905.FI(g) as detailed in FCL.930.IRI; and
g) have passed an Assessment of Competence to instruct for the IR(R) with a Flight Instructor Examiner (FIE) as specified in FCL.905.FI(g).
Note: The course specified in FCL.905.FI(g) may be completed for the purpose of qualifying to instruct for the IR(R) without having the prerequisite IFR experience for the issue of the FCL.905.FI(g) privileges.

Also I have no idea what IRI(TK) is. As far as I know there is no such thing?

Whopity
10th Sep 2019, 07:30
Also I have no idea what IRI(TK) is. As far as I know there is no such thing? Which really goes to show the level of knowledge of the author of the IN! But, very easy to achieve!

BEagle
10th Sep 2019, 07:54
If you have not passed the CPL exams, your instruction is limited to LAPL level. This also includes any ratings which may be included in a LAPL if you are additionally qualified (e.g. the Aerobatic Rating). But an IR(R) cannot be included in a LAPL, so you cannot provide instruction for the IR(R) as the minimum licence level in which an IR(R) can be included is the PPL(A).

Whopity
10th Sep 2019, 08:32
If you have not passed the CPL exams, your instruction is limited to LAPL level. However; if you held an FI rating prior to EASA without CPL level knowledge then you are not restricted to LAPL, this apllies to quite a few AFIs and EX RAF QFIs who obtained a FI rating on a PPL. Under JARs they could not let such a rating lapse more than 5 years without having to complete the CPL TK, but this ceased under EASA.

Fleyer
10th Sep 2019, 10:06
Thanks for your replies! So in a nutshell, if I have an EASA ME CPL IR FI, with a SOLI that is not the UK, the only way to teach IR(R) in the UK is to transfer my SOLI to UK CAA. Then do I need to go through IR(R) course to put it on my licence?

Is there a document that details all these regulations? Could not find the answer in ANO.

Whopity
10th Sep 2019, 15:21
A lot of this information was promulgatewed by Information Notice try IN2016-82 (http://publicapps.caa.co.uk/docs/33/InformationNotice2016082..pdf)
You would need to trasfer your SOLI to the UK and you would need to complete the IRI course if you have not already done so.

Mickey Kaye
10th Sep 2019, 17:05
Which really goes to show the level of knowledge of the author of the IN! But, very easy to achieve!

Ok so how do you achieve it?

Whopity
10th Sep 2019, 19:58
There is nothing to achieve!