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IMC / IR(R) embedded privileges currency

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IMC / IR(R) embedded privileges currency

Old 6th Jul 2019, 22:44
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IMC / IR(R) embedded privileges currency

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
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Old 7th Jul 2019, 07:15
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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.
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Old 7th Jul 2019, 10:04
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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.
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Old 8th Jul 2019, 10:12
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Well there's a powerful privilege, it would be foolhardy to abuse!

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Old 8th Jul 2019, 12:21
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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?
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Old 8th Jul 2019, 12:28
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To exercise the PPL privileges I need to be in currency for my biennial to keep the SEP rating current....

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Old 8th Jul 2019, 15:50
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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'.
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Old 8th Jul 2019, 15:52
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No such thing as a biennial, you could have done a prof check in the class or any other type or class.
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Old 8th Jul 2019, 15:54
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No. You are exercising the privileges 'of a PPL which includes an IMC Rating'.
That was my take on it.
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Old 8th Jul 2019, 18:09
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Originally Posted by Whopity View Post
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.

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Old 8th Jul 2019, 20:13
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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 ?
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Old 8th Jul 2019, 20:47
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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 .
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Old 8th Jul 2019, 22:25
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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
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Old 8th Jul 2019, 22:27
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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
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Old 8th Jul 2019, 22:37
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Originally Posted by custardpsc View Post
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
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Old 8th Jul 2019, 22:43
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Can I suggest that as sooner or later EASA will change it's Annex numbers again, we should just say "EASA" or "non-EASA" ?

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Old 16th Jul 2019, 09:42
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Originally Posted by Genghis the Engineer View Post
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 !
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Old 16th Jul 2019, 10:40
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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.

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Old 16th Jul 2019, 10:58
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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.
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Old 21st Jul 2019, 19:35
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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.
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