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new IR rule....7 years

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Old 21st Oct 2013, 14:05
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new IR rule....7 years

Hi, a question regards the IR and change to 5yr rule for revalidation.
I hold an expired ME/IR and want to renew it as SE/IR, it expired May 2009.
Is it correct that 5 year rule has gone and replaced by 7 year rule. After which all ground exams must be taken.
I plan to renew either this winter or next year if I went past 5 year ( next may ) Do I need to fly with a CAA staff examiner again ?? Curious really.
Thanks.
Any recommendations for revalidating in south west...thinking Aeros.
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Old 21st Oct 2013, 15:31
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Why don't you ask Aeros as they will have the facts about 5 - 7.
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Old 21st Oct 2013, 16:15
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Cheers, justing wanting the rules on the subject.
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Old 21st Oct 2013, 16:45
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I hold an expired ME/IR and want to renew it as SE/IR, it expired May 2009.
FCL.625 IR — Validity, revalidation and renewal
(d) If the IR has not been revalidated or renewed within the preceding 7 years, the holder will be required to pass again the IR theoretical knowledge examination and skill test.
The 7 years began with your last revalidation/renewal in 2008,therefore; you have until May 2015 to renew it before you have to resit the exams etc. No requirement to test with CAA Examiner after 5 years.
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Old 21st Oct 2013, 16:53
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Fantastic ! Thank you for the reply.
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Old 22nd Oct 2013, 06:42
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Whopity

That is the way I interpreted it as well. However, I have had the following correspondance with the CAA:

I said:

FCL.625 IR says

'(d) If the IR has not been revalidated or renewed within the preceding 7 years, the holder will be required to pass again the IR theoretical knowledge examination and skill test.'

7 years from the last revalidation/renewal date is actually only 6 years from the date of expiry. This implies that if you do not renew within 6 years from the expiry date, you have to redo all your TK exams.
CAA Policy said:

As we have said before, the start date of the 7 years is the day that the IR becomes invalid. The wording in the regulation states ‘ If the IR has not been revalidated or renewed’ i.e. has become expired, there is nothing in the text of FCL.625(d) referring to the last test the individual completed. An IR is valid for one year from the date of the skills test (normally valid to the end of the calendar month).

If the individual does not revalidate on or before the stated expiry date of the IR, then the individual then has a 7 year period to renew the IR purely on the basis of flight training with an ATO (if required) and the issue of a course completion certificate, plus a skills test with an IRE.

On the anniversary of allowing the IR to expire for 7 years and thereafter the individual will be required to re-take the theoretical examinations, undertake flight training with an ATO and the issue of a course completion certificate, plus a skills test with an IRE.
I then questioned the fact that he seerns to imply that if it is a renewal the test has to be done with an IRE, not an IR renewal examiner, and the fact that he refers to a renewal done within the 7 year period as a skill test, not a proficiency check.

Policy replied

Yes you are correct in that it is a Proficiency Check with an Examiner with appropriate coverage for revalidation/renewal, if the licence is expired even by a day the individual is required to be recommended for the Proficiency Check with an Examiner by an ATO, therefore the ATO is required to conduct an assessment of the individual before issuing a course competition certificate, (the course competition certificate can state that no training is required if the rating is expired by a short period).

The individual whose IR has not expired can of course go directly to the relevant Examiner for their Proficiency Check, as they are not required to be recommended by an ATO.
They do not quite answer the question about a normal renewal having to be done with an IRE, but I take it as read that an IRR examiner can do the test.

By the way, the 5 year rule where the renewal test has to be done by an IRE if it has expired by more than 5 years went away when EASA was implemented.

Linda Mollison

Last edited by Linda Mollison; 22nd Oct 2013 at 06:44.
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Old 22nd Oct 2013, 07:04
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According to EASA the IRRE is going to have to go as there is no such rating under EASA. It will just be a straight IRE.
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Old 22nd Oct 2013, 07:41
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Bose-x

For IRR examiner, please read CRE with IRR privileges which does exist under EASA (FCL.1005 CRE).

Linda Mollison
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Old 22nd Oct 2013, 07:50
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Linda,

many thanks for the clarification, effectively that was the interpretation used for the past 12 years. With CAP 804, Policy really has no excuse for not promulgating the interpretation that is currently applied.
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Old 22nd Oct 2013, 16:25
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So, the CAA interprets "If the IR has not been revalidated or renewed within the preceding 7 years" as "If the IR has not been revalidated or renewed in the preceding 8 years" Now I understand why it takes a 'certain kind of person' to work there.
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Old 22nd Oct 2013, 19:29
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Thanks everyone. Lol
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Old 23rd Oct 2013, 11:31
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FCL.625 IR says

'(d) If the IR has not been revalidated or renewed within the preceding 7 years, the holder will be required to pass again the IR theoretical knowledge examination and skill test.'
Read as a revalidation or renewal is required on or after the date of expiry it makes prefect sense.

Why would the 7 year revalidation or renewal period for an IR start to run whilst the rating in question is still current?

Having said that, with many legal statements the more you read something the more confusing it becomes!!!

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Old 23rd Oct 2013, 13:04
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Then why not write if the rating has expired by more than 7 years. That makes more sense.

Oh well at least we know now.
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Old 23rd Oct 2013, 14:04
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Then why not write if the rating has expired by more than 7 years. That makes more sense.
Because it would have had to have expired (or be about to) to require revalidating or renewing in the first place.

I agree though, no evidence of the Plain English Campaign in the CAA or EASA!
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Old 25th Oct 2013, 15:21
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Its not the CAA that has worded the Aircrew Regulation, but the committee based in Cologne, but EASA will be more than happy to point out, that industry had the chance to change the wording, when we read the NPA (so its our fault).
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Old 5th Nov 2013, 19:18
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Why would the 7 year revalidation or renewal period for an IR start to run whilst the rating in question is still current?

-----------------------------------------------------------------

The rule starts once the IR expired, that the rules europeans commisars created from their fantasy to screw you as much as they can .

In any case that rule is for ATPl frozen. If you got a frozen ATPL you need to renew the IR once every 7 years to don't lose the ATPL theoretical exam otherwise you should make the exam again if you let the IR expire and you renew after 7 years.
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