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Query ref validity date of ATPL's - 7 year IR renewal limit

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Query ref validity date of ATPL's - 7 year IR renewal limit

Old 5th Oct 2017, 14:43
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Question Query ref validity date of ATPL's - 7 year IR renewal limit

Hi Folks,

I have not renewed my IR in 5+ years

I know that there is a limit of 7 years before ATPL exams expire.

Can an instructor or flight examiner confirm the following. The 7 year expiry date is it based on the expiry date of the last IR or the actual test date of the last IR.

Thank you for your help.
Stobart
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Old 5th Oct 2017, 15:28
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I would have thought it would be from the expiry date, but there are people on her better placed to advise.

What I dont understand are you saying that the ATPL expires after seven years since expiry or the ATPL exams based on you holding a CPL?
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Old 5th Oct 2017, 16:04
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The limit is 7 years from last expiry. The following is the extract from Part FCL.635 IR

(c) Renewal. If an IR has expired, in order to renew their privileges applicants shall:
(1) go through refresher training at an ATO to reach the level of proficiency needed to pass the instrument element of the skill test in accordance with Appendix 9 to this Part; and
(2) complete a proficiency check in accordance with Appendix 9 to this Part, in the relevant aircraft category.

(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 skill test can only be done by an IRE not an IRRE

Hope its of some help
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Old 5th Oct 2017, 16:29
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The skill test can only be done by an IRE not an IRRE
Not to my knowledge.
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Old 5th Oct 2017, 21:03
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(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.
However; FCL.010 says
"Skill test" means the demonstration of skill for a licence or rating issue, including such oral examination as may be required.
Having held the rating already, it must be a Prof Check
"Proficiency check" means the demonstration of skill to revalidate or renew ratings, and including such oral examination as may be required.
In the days of old, the UK CAA required an initial re-test if the IR had expired more than 5 years. One could interpret:
to pass again the IR theoretical knowledge examination and skill test.
as meaning an initial IR skill re-test with an IRE is required.
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Old 6th Oct 2017, 10:55
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Incorrect. We are doing stuff like this all the time and its accepted but the CAA as a proficiency check and done frequently by IRRE's. Of course a stupid situation created by the CAA where they have a difference between an IRE and IRRE unlike anywhere else in Europe.
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Old 6th Oct 2017, 11:10
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Althold ... How can you retake the IR theorectical exams if you did not take them in the first place?
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Old 6th Oct 2017, 16:25
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Hi all!

I'm in a similar position. I'm looking to renew my multi engine IR which expired 4 years ago. I recall there used to be a rule where if the IR had expired 5 or more years ago, then a CAA examiner would be examining the renewal. I remember reading this in LASORS. Now I'm reading about this 7 year rule.

So is the 5 year rule now out? Or are both the 5 and 7 year rules in place?

Basically, if I left my IR renewal until next year when 5 years are up, due to funds, would I need to to do more during the renewal test?

Thanks so much!

Gabby.
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Old 7th Oct 2017, 12:19
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We are doing stuff like this all the time
That's interesting because so far, I have not come across anyone who has let the IR expire by more than 7 years and tried to renew it.
How can you retake the IR theorectical exams if you did not take them in the first place?
I have always wondered about that!
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Old 8th Oct 2017, 09:59
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What is the difference between an IRE and IRRE. I thought there were CAA Staff Examiners and IRE's, it is difficult to keep up with this nonsense.

There is an equally crazy thread on here , where someone who does meet the requirements on a different issue, the CAA will not refund his fee, because it is his fault he did understand the regulations. Basically they told him his 1179 was valid, then told him is was not!

From what I can see, the IR therectical exams are likely to fall below ATPL theory, so I cant see why and ATPL holder would need to take them, IFR comms was not part of the ATPL but the FRTOL exam many year I seem to rember did include IFR. Is it the case of EASA and the CAA are not thinking things through again.

Last edited by Homsap; 8th Oct 2017 at 11:09.
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Old 8th Oct 2017, 15:18
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(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.
I seem to recall this discussed before and a CAA spokesperson said it was 7 years from date of TEST, not expiry.
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Old 8th Oct 2017, 16:35
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JJ
but it doesn't specifically say that the pilot needs to resit the IR test papers
Yes it does:
FCL.625 IR — Validity, revalidation and renewal
(a) Validity. An IR shall be valid for 1 year.
(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.
IRE and IRRE
IRE as per FCL.1005.IRE IRE — Privileges
The privileges of the holder of an IRE certificate are to conduct skill tests for the issue, and proficiency checks for the revalidation or renewal of EIRs or IRs.
The IRRE can only do revalidations and renewals.
IFR comms was not part of the ATPL but the FRTOL
IFR Comms was introduced by the JAA in 1999 and relates to the ATPL and IR Exams. It has never been associated with the FRTOL which had its own TK exam pre -JAA and has used either the JAA/EASA VFR Comms exam, or the UK PPL Coms Exam since 1999.
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Old 9th Oct 2017, 16:00
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Thanks Everyone for replies.

Looks like there is no easy answer to this question and its all about interpretation of EASA verbiage that's a bit grey.

Will air on the side of caution that it is from the last IR test date.

Thanks.
Stobart.
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Old 9th Oct 2017, 18:42
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Will air on the side of caution that it is from the last IR test date.
The CAA policy is that it is 7 years from the expiry of the last IR.

I obtained this in writing from a Staff FE.

XO
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Old 9th Oct 2017, 22:20
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Anyone know if the 5 year rule is still in place? That after five years from expiry of the last IR, that the renewal has to be with a CAA examiner, not any examiner?

Thanks!
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Old 10th Oct 2017, 09:59
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Originally Posted by Whopity
That's interesting because so far, I have not come across anyone who has let the IR expire by more than 7 years and tried to renew it.
I have always wondered about that!
I would say we are seeing quite a lot these days. Mostly guys who did the CPL/IR right at the point of the market downturn and now recruitment is on the up again are having another go.
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Old 7th Nov 2017, 13:55
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Which exams make up the IR theoretical knowledge? I need to pass them to take the flying test and convert ATPL VFR to ATPL IR
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Old 7th Nov 2017, 15:57
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Does anyone have a link to where this is stated on the CAA website? I've had a look but darned if I can find it. Thanks
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Old 9th Nov 2017, 14:50
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Very unlikely to find this stuff on the CAA web site. You need to look in the aircrew regulation AMC1 FCL.625(c) IR — Validity, revalidation and renewal
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Old 9th Nov 2017, 16:13
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On top of the cited rules there is a Commission Decision benefiting third-country ICAO IR holders. See annex V in 2014/69/EU: Commission Decision of 6 February 2014, etc, EUR-Lex - 32014D0069 - EN - EUR-Lex

Para 3 in section 2.2 gives a wordy summary:

The Agency agrees with the reasoning provided by the UK. The rule [FCL.625(d)] does not take into account the possibility that the licence holder may have been flying under IFR using an IR held on a 3rd country licence during the 7-year period which has been renewed during that period and which is therefore valid. The intended derogation would concern holders of licences in accordance with Part-FCL that include the ICAO compliant IR. If such pilots after a certain time stop to fly on that licence but continue to fly on an ICAO based third country licence that includes an IR and would request then to renew their IR on the European licence they would only have to fulfil the revalidation criteria contained in FCL.625(b) based on the current and valid third country IR. This means that the rating holder must pass the proficiency check, but will not be required to undergo training or to re-take the theoretical knowledge examinations. In the case of a pilot who held a third country IR that is not any longer valid but has been revalidated or renewed within the preceding 7 years the rating holder shall comply with the renewal requirements in FCL.625(c), but will also not be required to re-take the theoretical knowledge examinations. The Agency considers that this provides a level of safety equivalent to that provided by Part-FCL.
See also Commission Decision of 1 July 2014 (2014/425/EU), etc,
EUR-Lex - 32014D0425 - EN - EUR-Lex

As far as I'm aware FCL.025(c)(2) will still apply, i.e. ATPL exam credit for the granting of an ATPL will expire 7 years after the last validity date of an IR entered in the Part-FCL licence.
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