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ATPL validity period with valid IR and FI....

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ATPL validity period with valid IR and FI....

Old 18th Mar 2016, 15:14
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ATPL validity period with valid IR and FI....

Good afternoon,
I'm having a problem with my ATPL THEORETICAL validity period . I took my ATPL theoretical knowledge exams on March the 22nd 2013. In October 2014 I took my FI and in March 2016 I took the IR. I also have FAA CPL/IR. Now......as for my understanding on the EASA 1178 FCL.025, I should still have 7 years for the CPL before my ATPL validity expires. Do you agree or I have 3 days before the written exams expire and I have to take them again (or at least those related to the CPL)?
Thank you in advance.
ironside71 is offline  
Old 18th Mar 2016, 15:21
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What bit of FCL.025(c)(2) are you struggling with?
Mustapha Cuppa is offline  
Old 18th Mar 2016, 15:27
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Would you confirm that I still have 7 years before my ATPL THEORETICAL expires?
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Old 18th Mar 2016, 15:29
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I don't see how one can interpret the Regulation in any other way.
Mustapha Cuppa is offline  
Old 18th Mar 2016, 15:32
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Neither do I but at the moment I'm in Italy and an Italian CAA Flight Examiner Told me that I should have taken both the IR AND the CPL before the 36 months. Thank you
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Old 18th Mar 2016, 15:37
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I may have misunderstood. Are you saying that you do not have a CPL?
Mustapha Cuppa is offline  
Old 18th Mar 2016, 15:43
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Yes. I don't have a CPL yet.
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Old 18th Mar 2016, 15:51
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In that case, I fear the Italian examiner may be correct. I refer to FCL.025(c)(1)(ii) which talks about 36 months for the issue of a CPL or IR. Even though you obtained the IR within the 36 month period, the Regulation does not seem to "reset the clock" for the 36 month period to start from when you obtained your IR.

FCL.025(c)(2) only provides for the issue of the ATPL. There is no suggestion for the the 7 year period applying to the issue of a CPL even if, as in your case, you hold an IR.
Mustapha Cuppa is offline  
Old 18th Mar 2016, 15:58
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Ok.....thank you very much. Very clear and .......it makes sense.
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Old 18th Mar 2016, 18:31
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Sadly, your exams expire shortly. We encounter this all the time with students in the same situation. When you have a valid CPL & IR then the exams remain valid for life if you keep the IR current and 7 years if you don't.
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Old 19th Mar 2016, 15:18
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GipsyMagpie
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Ouch, didn't cotton on to that one. Well worth knowing.
 
Old 20th Mar 2016, 00:18
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In theory you have until the end of this month to complete your CPL training, test for it, and to apply for it. If you have already started training, this -might- be possible but I imagine it will be highly unlikely.

If you are unable to complete your training, you will remain as a PPL/IR. If you wish to complete a CPL at a later date, you will need to sit all of the CPL exams again. This would limit you to only ever being able to be a CPL/IR and you would never be able to "unfreeze" to become an ATPL holder. If you wish to be able to complete your ATPL at a later date, you will need to complete the ATPL exams again. There may be some small reduction in requirements due to the fact you have a current IR. For example if you had a CPL but no IR, when you resit the ATPLs you are exempt from the VFR Comms exam. I don't know what the exemptions might be, if any, in your case, without looking it up however I would recommend referring to CAP 804 in the first instance.
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Old 20th Mar 2016, 08:15
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In theory you have until the end of this month to complete your CPL training, test for it, and to apply for it.
Can you provide a reference for this?
Mustapha Cuppa is offline  
Old 20th Mar 2016, 13:51
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FCL.025
(b) Pass standards(2) Unless otherwise determined in this Part, an applicant has successfully completed the required theoretical knowledge examination for the appropriate pilot licence or rating when he/she has passed all the required examination papers within a period of 18 months counted from the end of the calendar month when the applicant first attempted an examination.
Para (c) which lays down the 36 month validity does not specify any alternative method of calculation therefore; it is fair to conclude that validity dates are measured to the end of the relevant month.
Whopity is offline  
Old 20th Mar 2016, 15:08
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Whilst I agree that the 18 month period to gather all the TK exams together is effectively until the end of the month as laid out in FCL.025(b)(2), I am not at all sure that this can be rolled forward onto the date for the issuance of a CPL (or IR or EIR).

FCL.025(c)(1)(iii) clearly states "...shall be counted from the day when the pilot successfully completes the theoretical knowledge examination..."

My interpretation is that the 18 month TK completion period starts at the end of the first month that the candidate attempted his/her first examination. The period for the issuance of the CPL etc is, however, a separate matter and relies on the date of completion of the TK exams.

Or to put it another way, the 18 month period explicitly starts at the end of the month of the first attempt. The 36 month period explicitly starts from the day of TK exam completion.

Happy to be proved wrong. Perhaps if someone has successfully obtained a CPL, IR or EIR more than 36 months after the date of completion of TK exams but up to the end of that month, they could let us know.
Mustapha Cuppa is offline  
Old 20th Mar 2016, 15:23
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Looks like you might be right on that one, Mustapha. However this is a quibble about 9 days in the case of the OP. Fact is, anyone that leaves it to the last day to apply for their CPL has probably messed up somewhere. My guess is the OP simply didn't understand the basic principle of 36 months from completion of exams to get their CPL and IR issued, whether or not it was from the date of the final exam or the last day of the month of the final exam.

Last edited by fwjc; 20th Mar 2016 at 15:35.
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Old 20th Mar 2016, 22:41
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Knowledge, if unused, will be forgotten, become stale or out of date. It is therefore a good idea to have a time limit between passing aviation theoretical exams and gaining the initial issue of a Licence or Rating (in the OP’s case 36months for a CPL and/or IR).

Initial issue of an ATPL requires experience that takes time and can only be gained by a CPL/IR holder; and it would not be practical to ask an Airline Pilot to take time off from work in order to take another set of exams. Most co-pilots will apply for their ATPL as soon as they meet the experience requirements and they will, therefore, be current in (for want of a better term) ‘ATPL level flying’– Why within 7 years of holding a valid IR is used I do not know, but it seemsto work?

If you wish to complete a CPL at a later date, you will need to sit all of the CPL exams again. This would limit you to only ever being able to be a CPL/IR and you would never be able to "unfreeze" to become an ATPL holder. If you wish to be able to complete your ATPL at a later date, you will need to complete the ATPL exams again.
fwjc
I do not think this is correct. The OP has valid passes in ATPL Theory exams and a valid IR. Therefore the exams will be valid for ATPL issue for at least another 7 years.

CPL Theory exams to gain their initial CPL seems sensible – and not all of them will necessarily need to be taken as credit is, I believe, possible for the holder of a valid IR.

Maybe none of them need to be taken as the OP states he holds a valid FAA CPL – Is there not a conversion process to an EASA CPL for this? No time limit provided the FAA CPL is valid?

Caveat: I have not had time to check through all the Regs.




Level Attitude is offline  
Old 21st Mar 2016, 09:07
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Level Attitude is correct:
The completion of the airline transport licence (ATPL) theoretical knowledge examinations will remain valid for the issue of an ATPL for a period of 7 years from the last validity date of an IR entered in the licence. (FCL.025(c)(2)(i))
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