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SE IR Query

Old 8th Oct 2020, 13:05
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SE IR Query

Hi folks, I'm currently investigating the possibility of getting an EASA SE IR.

My ME IR(SPA) expired over 10 years ago but I do have a current ME IR(MPA) and also a current SEP rating.

Would the fact that I have a current ME IR(MPA) be of any benefit to shorten an SE IR course or would I be looking at completing the full 50 hour course?

Part-FCL is not very clear for my situation so maybe someone would be able to steer me in the right direction.

Many thanks
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Old 8th Oct 2020, 13:37
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I have not checked the requirements, but I seem to recall that adding another class/type to your IR privileges only involves doing an IR exam in the relevant class or type. You have already demonstrated the needed skills when you obtained your ME IR(MPA). I hope someone else can clear this one up though...

Edit: I just had a quick look. FCL.620 IR states:
Applicants who have completed a skill test for a multi-engine IR in a single-pilot multi-engine aeroplane for which a class rating is required shall also be issued with a single-engine IR for the single-engine aeroplane class or type ratings that they hold.
So if you were to do a ME IR(SPA) now, you would get the SE IR for free so to speak. In your case the ME IR is stil valid, just not for MEP or SEP classes.
I think that the bit in Appendix 8 'Cross-crediting of the IR part of a class or type rating proficiency check' may be relevant here: You are the holder of a ME IR(MPA) rating and you would be able to cross-credit the skill test for this to the IR part for a SE class rating 'Provided that within the preceding 12 months the applicants have flown at least three IFR departures and approaches exercising PBN privileges, including at least one RNP APCH approach on an SP class or type of aeroplane in SP operations'. You have not flown those three departures and approaches, but you can do that with an instructor on a relevant SEP, and then do a skills test for an IR on a SEP type to renew the rating.

The three approaches or whatever you and your instructor deem to be necessary would be considered as the training necessary before renewal. The IR skills test on a SEP would then get the SE IR part reinstated. Or, if your ME IR(MPA) is due to be renewed soon, you could perhaps use that and cross credit the SE IR part as stated in Appendix 8.

Right, this may all be wrong, but the short version is still that I don't see the need for a full 50 hour IR course.

Last edited by Jhieminga; 8th Oct 2020 at 13:59. Reason: Checked the regs...
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Old 8th Oct 2020, 16:18
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This may not be relevant to you JT8, as you don't say where you're based or why you want it, but...

If you are UK based, with a professional licence, then the UK CAA considers all UK professional licences to have embedded privileges of the IMC / IR(R) rating. So if that would deliver what you actually want - the ability to route IMC/IFR and take approaches whilst flying privately, then all you need is to pay your £40 (or whatever it is at the moment) to have a UK CPL or ATPL issued, if you haven't got one already. Not as powerful as a full IR of-course, but if it meets your needs, a very cheap fix (and probably worth doing anyhow, even if you do get a full SE-IR.

G
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Old 8th Oct 2020, 17:46
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Recommendation N ° UK/03/2013 on the notification by the United Kingdom about its intention to grant an approval derogating from certain provisions of Commission Regulation (EU) No 1178/2011 on the basis of Article 14(6) of Regulation (EC) No 216/2008. A)

BACKGROUND

1. By letter of 18 March 2013, the United Kingdom (UK) representation to the EU in Brussels notified the Commission and EASA of their intention to derogate from certain provisions of Annex I (Part-FCL) to Commission Regulation (EU) No 1178/20111 (the Aircrew Regulation), on the basis of article 14(6) of Regulation (EC) 216/20082 (the Basic Regulation).

2. In the attached letter, the UK explains that it intends to derogate from a requirement in the Annex I of the Aircrew Regulation in FCL.625(c) and (d). FCL.625(c) regulates the conditions for the renewal of an Instrument Rating (IR) and FCL.625(d) regulates that 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.

3. The UK CAA believes that the requirements of FCL.625(d) were created for the case where a licence holder ceases to fly under Instrument Flight Rules (IFR) for 7 years. The rule 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.

............................................. 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. .....

Although we are considering a multi pilot IR for credit, so not quite the same as the above: it is the case the question is regarding a pilot holding a lapsed single pilot IR. So its worth considering the following.



Aeroplanes

Credits shall be granted only when the holder is revalidating IR privileges for single-engine and single-pilot multi-engine aeroplanes, as appropriate. When a proficiency check including the IR is performed, and the holder has a valid: Credit is valid towards the IR part in a proficiency check for:

MP type rating; High performance complex aeroplane type rating

Credit is valid towards the IR part in a proficiency check for:

SE class * and SE type rating *, and SP ME class, and SP ME non-high performance complex aeroplane type rating, only credits for section 3B of the skill test for single pilot non-high performance complex aeroplane of Appendix 9 *

* Provided that within the preceding 12 months the applicant has flown at least three IFR departures and approaches exercising PBN privileges, including one RNP APCH approach on an SP class or type of aeroplane in SP operations, or, for multi-engine, other than HP complex aeroplanes, the applicant has passed section 6 of the skill test for SP, other than HP complex aeroplanes flown solely by reference to instruments in SP operations.

My thoughts are that training only as necessary (including the single pilot instrument approach) and the PBN stuff if that has not already been satisfied is all you need followed by the single pilot IR proficiency check. I would expect most IR ATOs will be up to speed on this particular issue though as this must be a common problem.
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Old 8th Oct 2020, 19:44
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Thank you all for your answers so far.

I have an Irish licence so I can't avail of any of the options above.

On my ratings page under "Remarks/Restrictions" it says "IR valid for MPA only" so maybe the real question is how do I get this removed?
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Old 8th Oct 2020, 20:57
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Originally Posted by JT8D-17 View Post
On my ratings page under "Remarks/Restrictions" it says "IR valid for MPA only" so maybe the real question is how do I get this removed?
Take an SEIR test
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Old 8th Oct 2020, 23:25
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You have an Irish Part FCL Licence, therefore; you can renew the SE IR privileges in accordance with Appendix 8
Appendix 8 – Cross-crediting of the IR part of a class or type rating proficiency check
Regulation (EU) 2019/1747

A. Aeroplanes
Credits shall be granted only if holders are revalidating or renewing IR privileges for single-pilot single-engine and single-pilot multi-engine aeroplanes, as appropriate.
If a skill test or a proficiency check including IR is performed, and holders have a valid: MPA type rating; Single-pilot high-performance complex aeroplane type rating.
Credit is valid towards the IR part in a proficiency check for:
SE class rating (*) , and SE type rating (*) , and SP ME class or type rating except for high-performance complex type ratings, only credits for Section 3B of the proficiency check in point B.5 of Appendix 9
* Provided that within the preceding 12 months the applicants have flown at least three IFR departures and approaches exercising PBN privileges, including at least one RNP APCH approach on an SP class or type of aeroplane in SP operations, or, for multi-engine, other than HP complex aeroplanes, the applicants have passed Section 6 of the skill test for SP, other than HP complex aeroplanes flown solely by reference to instruments in SP operations.
Or as Rudestuuf says you can take a SE IR Prof Check
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Old 9th Oct 2020, 13:54
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I am looking into doing something similar albeit with a UK issued EASA licence.

Whopity, is it not the case that cross crediting is valid only for the revalidation of an IR? I can see in your quoted text it does say revalidation or renewal, although any reference I find shows revalidation only.

Originally Posted by Genghis the Engineer View Post
This may not be relevant to you JT8, as you don't say where you're based or why you want it, but...

If you are UK based, with a professional licence, then the UK CAA considers all UK professional licences to have embedded privileges of the IMC / IR(R) rating. So if that would deliver what you actually want - the ability to route IMC/IFR and take approaches whilst flying privately, then all you need is to pay your £40 (or whatever it is at the moment) to have a UK CPL or ATPL issued, if you haven't got one already. Not as powerful as a full IR of-course, but if it meets your needs, a very cheap fix (and probably worth doing anyhow, even if you do get a full SE-IR.

G
Genghis, are you able to provide a reference for a professional licence having an embeded IR(R) and does this then mean it has no expiry and require no revalidation?

Many thanks chaps!
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Old 9th Oct 2020, 14:41
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Originally Posted by OhNoCB View Post
I am looking into doing something similar albeit with a UK issued EASA licence.

Whopity, is it not the case that cross crediting is valid only for the revalidation of an IR? I can see in your quoted text it does say revalidation or renewal, although any reference I find shows revalidation only.



Genghis, are you able to provide a reference for a professional licence having an embeded IR(R) and does this then mean it has no expiry and require no revalidation?

Many thanks chaps!
Genghis is not quite correct unfortunately. A UK ATPL DOES have built in unexpiring IMC rating priveliges. A UK issued EASA ATPL does not.
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Old 9th Oct 2020, 16:05
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is it not the case that cross crediting is valid only for the revalidation of an IR?


Whopity has provided a reference to the relevant amendment. Appendix 8 to Part-FCL was amended by Commission Implementing Regulation (EU) 2019/1747 in October 2019 to include renewal when cross-crediting of the IR part of a class or type rating proficiency check. This is embedded within the latest version of the Easy Access Rules to Part-FCL dated August 2020; see page 1241.

ifitaint...
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Old 9th Oct 2020, 16:06
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Originally Posted by OhNoCB View Post
I am looking into doing something similar albeit with a UK issued EASA licence.

Whopity, is it not the case that cross crediting is valid only for the revalidation of an IR? I can see in your quoted text it does say revalidation or renewal, although any reference I find shows revalidation only.



Genghis, are you able to provide a reference for a professional licence having an embeded IR(R) and does this then mean it has no expiry and require no revalidation?

Many thanks chaps!
The text of the 2020 edition of the U.K. examiners handbook states that cross crediting doesn’t apply to renewals for an SPA IR, but the forward to the handbook says that EASA regulations have primacy, and EASA state that cross crediting does apply to renewal, so it should apply for renewal in the U.K., the same as in Ireland, in accordance with the EASA rules.
In a U.K. issued EASA licence the instrument rating should just say IR, with no reference to MPA or SPA, so it doesn’t matter how long ago you last did an SPA IR renewal, you can just take the test without further training and the IRE can sign your licence (I have that from the U.K. CAA in writing as I enquired about it).
Sadly as stated above the embedded IMC rating privileges were taken away when the U.K. changed to part FCL. If you hold a U.K. CPL / ATPL it does have embedded privileges, the reference is the ANO, but you’d have to find a non-EASA aircraft that could fly under IFR in order to exercise the privileges of the licence.


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Old 9th Oct 2020, 19:38
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Excellent stuff, I missed the reference document. Thank you for clarifying.

To try and clear the last bit of it up - I have a 737 type rating which is how my IR is currently held. I have no other defined IR entry on my ratings page other a bit at the top which simply states “instrument” with nil restrictions.

If I want to cross credit to renew, what should I be expecting the examiner to enter in my licence? Extra gratitude if you can direct me towards the correct form so I can present it to my TRE and save them the hassle as I doubt they will be familiar.
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Old 11th Oct 2020, 09:59
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Originally Posted by ASRAAMTOO View Post
Genghis is not quite correct unfortunately. A UK ATPL DOES have built in unexpiring IMC rating priveliges. A UK issued EASA ATPL does not.
Which begs the question, when we are no longer members of EASA, what type of licence does a UK issued EASA ATPL morph into, and what IR(R)/IMC privileges come with it?

Edited to add:

It seems a UK issued EASA ATPL will become a UK issued Part FCL ATPL. I guess this carries exactly the same privileges as as EASA Part FCL ATPL i.e., an IR(R) rating must be added separately to an IR, and revalidated/renewed accordingly. I've been robbed!

Last edited by 36050100; 11th Oct 2020 at 10:45.
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Old 11th Oct 2020, 11:34
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Appendix 8 – Cross-crediting of the IR part of a class or type rating proficiency checkRegulation (EU) 2019/1747A. AeroplanesCredits shall be granted only if holders are revalidating or renewing IR privileges for single-pilot single-engine and single-pilot multi-engine aeroplanes, as appropriate.If a skill test or a proficiency check including IR is performed, and holders have a valid: MPA type rating; Single-pilot high-performance complex aeroplane type rating.Credit is valid towards the IR part in a proficiency check for:SE class rating (*) , and SE type rating (*) , and SP ME class or type rating except for high-performance complex type ratings, only credits for Section 3B of the proficiency check in point B.5 of Appendix 9

I have a multi pilot IR, and like many others have allowed my MEIR to lapse. I've never held an SEIR but I did have the​​​​ privileges as part of my MEIR.
The way I'm reading Annexe 8 above, I can simply apply for an SEIR (thus renewing my privileges) by presenting my last LPC pass certificate with no tests required 🤔🤔
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Old 11th Oct 2020, 11:43
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I did a JAR CPL, to which I added an IMCR, those then morphed into an EASA CPL with IR(R). I decided to pay my £42 (or whatever it was then, and is now, about that anyhow) for a separate UK CPL. When it came, it had no IR(R) listed. I queried this with the CAA.

They replied that all UK professional licences had embedded IMC privileges, therefore it wasn't separately listed. So (as I alluded to above, but wasn't explicit enough for ASRAAMTOO) yes, you do need a separately issued UK licence.

But a small fee and some paperwork gets you a UK PPL, CPL or ATPL off the back of your existing EASA licence, with substantially the same ratings - except for this.

My understanding is also that there is no need for any form of revalidation of that privilege.

So to take me, personally - I'm in the process of SOLIing my EASA CPL to Ireland. I expect that when it turns up to list my IR, but not my IR(R), but my UK CPL will continue to have embedded but unlisted IR(R) privileges, regardless of anything I do or don't do about that. I can't see that an ATPL would be any different. As G-reg aeroplanes will all now be "national" and not EASA, I'll be able to exercise IR(R) privileges on them whilst flying in the UK, irrespective of whether my IR is current or not.

So, basically, I'll need a current IR to fly in class A, or to fly IFR outside of the UK, but otherwise actually have a lot of privileges without having to continuously work for them.

The only really dangerous aspect of this is that you can have a vanilla UK CPL, with no extra ratings, and be legal to fly IFR en-route and approaches without every having been trained or assessed in them. Presumably however this has been the case since before I was born, and has never caused a problem, because everybody acts professionally enough that they never try to do so.

G
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Old 11th Oct 2020, 12:30
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OhNoCB

Your TRE does not have the privileges to do anything with single pilot IR associated with an MEP(land) or SEP(Land).
Just to make sure your aware you will need to have both an SEP(Land) and MEP(Land) on the front of your UK licence (just valid if its another EASA licence) as you cannot hold an instrument rating without the associated class rating.

To do the proficiency check your will need a CRE/IRR or IRE a list of UK CAA examiners for those categories can be found here.

https://www.caa.co.uk/General-aviati...l-or-examiner/

The last one is from experience. Be extremely careful flying single pilot IFR in serious IMC. It is nothing like multi crew airline ops. Your preflight planning, cockpit workload management and SA has to be maintained to a high level. Otherwise you will have one of "those moments" if you dont know what I'm talking about just take things slow.


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Old 11th Oct 2020, 13:05
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Originally Posted by Genghis the Engineer View Post
As G-reg aeroplanes will all now be "national" and not EASA, I'll be able to exercise IR(R) privileges on them whilst flying in the UK, irrespective of whether my IR is current or not.
Sadly not, for a while to come at any rate. The Statutory Instrument (2019/645, for those with much spare time) covering the aviation side of our withdrawal without formal agreement, as the CAA are briefing is now extremely likely, is written in such a way that it maintains parity with existing EASA methods. For example, licences currently split into EASA FCL and National will retain this split, but phrased as UK FCL and UK non-FCL (just a bit clumsy, but there it is). Aircraft currently split into EASA and non-EASA will be split into Part-21 and non-Part-21. A Part-21 aircraft will require a UK FCL licence, a non-Part-21 aircraft won't. Etc.
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Old 11th Oct 2020, 14:28
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LastStandards, don't be so quick. Currently the UK CAA is constrained by the EASA contract. If we are no longer a member of EASA then the CAA will not be constrained other than by the ICAO regulations. The UK CAA have said that those organisations who hold an EASA approval and those individuals who have commenced EASA compliant courses may: continue until their approvals expire and Individuals will have two years from 1st January 2021 to complete their training. However, the CAA will then issue ICAO compliant licences. The EASA have not yet stated, to my knowledge, that they will recognise the EASA compliant training taking place post 31st December.

Remember also that there is no such thing as an EASA aircraft. There are only aircraft that are recognised by EASA and the member NAAs by extension so subject to its rules. It will be a simple matter, should it be required, after this year, for the UK CAA to issue exemptions or whatever bit of paper that is necessary. to once again validate UK PPLs.as internationally ICAO complient- I don't mean NPPLs which are a different licence. LAPLs are pretty much identical to the NPPL but pose a different problem. The LAPL provides international privileges (within the EU) that the NPPL doesn't. For EASA not to recognise the licenses that were issued in accordance with their regulations will be appalling. The EASA should not only continue to recognise the compliant licenses designed and demanded by them but also they should provide for the maintenance for continuing compliance.

UK PPLs, CPLs and ATPLs should once again have worldwide recognition.

Last edited by Fl1ingfrog; 11th Oct 2020 at 15:02.
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Old 11th Oct 2020, 16:33
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Originally Posted by Fl1ingfrog View Post
LastStandards, don't be so quick. Currently the UK CAA is constrained by the EASA contract. If we are no longer a member of EASA then the CAA will not be constrained other than by the ICAO regulations.
(middle edited for brevity)
For EASA not to recognise the licenses that were issued in accordance with their regulations will be appalling. The EASA should not only continue to recognise the compliant licenses designed and demanded by them but also they should provide for the maintenance for continuing compliance.
Indeed - however the last few CAA liaison group meetings I've been on have made it very clear that the UK's initial policy in January will be to change very little, if anything, with the aim of being able to demonstrate an ongoing equivalent standard as and when bilateral agreement talks start, once the political side has simmered down. In particular, we must not expect any instant beneficial changes until the future consequences are fully understood - Policy's words, not mine, although they were slightly pithier. The minutes are I'm afraid confidential as part of ongoing briefings, the import of them is open to all.

EASA will, sadly, have no requirement to recognise UK licences as soon as they lose oversight of the authority. They have provided for continuing compliance by allowing transfer to an authority that will remain under EASA's oversight. Sadly, we're heading into a brave new world, with suspicions that in 5 years or so it'll look much like this world, only with more cost to maintain parallel systems without support. A look at the CAA's careers site shows work over the last few years to recruit people to build up some of the departments that lost most over the last 10-20 years.
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Old 11th Oct 2020, 16:59
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EASA will, sadly, have no requirement to recognise UK licences as soon as they lose oversight of the authority.
Surely you mean that EASA will have no requirement to recognise UK issued licences as EASA compliant. Individual EU member states are required to recognise any licence issued in accordance with ICAO Annex 1
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