Se-IR to Me-IR extension of priveleges

[Straighten Up]

Hello,

I hold EASA SE-IR (lapsed), and MEP. I want to upgrade to ME-IR. 2 questions

Where is the relevant Part-FCL section for extension of priveleges? - I can only find for helicopters. I know it's 5 hours (3 FNPTII, 2 in aircraft) but would like to read the relevant subparts.
Do I need to renew my SE-IR with appropriate training and a skills test in order to take the ME-IR skills test?

Many thanks.

[Arrow Flyer]

Part FCL Appendix 6 A.9

The holder of a single-engine IR(A) who also holds a multi-engine class or type rating wishing to obtain a multi-engine IR(A) for the first time shall complete a course at an ATO comprising at least 5 hours instruction in instrument flying in multi-engine aeroplanes, of which 3 hours may be in an FFS or FNPT II.

Holder = Rating valid so you'll need to ensure both are current in advance of the ME-IR skill test.

[portsharbourflyer]

I was going to say as the ME IR gives SE IR privileges under most NAAs then I thought it is only necessary for the SEP to be valid, not the SE IR at the time of the ME IR test.

If the SE IR is over 12 months and expired, then you would need to do training at an ATO and a test to renew it.

As an me IR test gives the SE IR privileges if the SEP is current, then does it not stand the me IR training still counts as the ATO training for the expired SE IR, therefore it stands the ME IR test does not require the SE IR to be current.

I know this will not be the case for all EASA naas.

Thoughts?

[rudestuff]

Requiring the SEIR to be current in order to take a test for an MEIR is pretty daft, considering you can also take an MEIR as your initial IR...

[portsharbourflyer]

Rudestuff, that is in a round about way that is the point I was trying to make. Just edited my original post to avoid confusion.

[Arrow Flyer]

Unfortunately I don't see any other way to interpret the regulation, though I take the point that has been made portsharbourflyer rudestuff .

[portsharbourflyer]

Arrow Flyer different NAAs will interpret that differently, so in essence you are correct but it does contradict logic from other parts of the regulation.

It does show how disjointed EASA / UK CAA regulations (mirrored of EASA as of 30/12/2020) are that one part can contradict another.

For example Malta and Potugal will not allow an EASA initial skills test to be done in a G Reg aircraft, yet the Danish will.

So I have no doubt different EASA NAAs will have a different take on this.

[Fl1ingfrog]

The holder of a single-engine IR(A) who also holds a multi-engine class or type rating wishing to obtain a multi-engine IR(A) for the first time shall complete a course at an ATO comprising at least 5 hours instruction in instrument flying in multi-engine aeroplanes, of which 3 hours may be in an FFS or FNPT II.

When a rating expires the rating is not cancelled and you remain the holder of that rating. You cannot change the meaning of a word simply to suit a point of view. If it is required that the rating must also be valid it is reasonable for that to be clearly stated.

[Jhieminga]

I agree with Fl1ingfrog that you still have the rating in question (SE-IR) and are therefore still the holder of that rating. You are currently unable to exercise its privileges, but that doesn't change the fact that you have it and have demonstrated your competency in this area. As long as it hasn't lapsed for more than seven years, you should be good to go.

I would suggest visiting an ATO and discussing the options that they offer based on the current status of your rating and your requirements. Any training needed to get back up to speed with your SE-IR will most likely be covered by the flying that you will need to do for the ME-IR. You are of course aware that the 5 hours are a minimum, you may end up flying more than that. Once you get to the skill test, make sure to confirm with the examiner that he/she will be happy to cross-credit the ME-IR results towards the SE-IR part. I am not an IRI or IRE but from a user's standpoint, have noticed that the requirements needed to revalidate both can be different. At one point we had to incorporate an extra approach to cover all the requirements, but your examiner will be able to deal with this, just follow the instructions at the time...

[BillieBob]

When a rating expires the rating is not cancelled and you remain the holder of that rating.

Then why, following expiry, are ratings transferred to the back of the licence under 'Ratings previously held by the holder'?

[Jhieminga]

Good question, but that may be due to a UK-only interpretation of the concept. Because we are talking about an EASA IR and the question was about where to find this in Part-FCL, I assumed that we could answer this based on EASA's way of dealing with this. My EASA licence doesn't have that section on the back.

[Arrow Flyer]

Originally Posted by Fl1ingfrog

You cannot change the meaning of a word simply to suit a point of view.

That's quite an accusatory statement, good thing I'm not overly sensitive about what people say on PPRuNe. I don't want to turn this into a debate on legalese or semantics, so I'd appreciate reading any Part FCL references you have so we can all learn together.

As far as I'm aware, "holder" in itself is not defined anywhere, however the privileges of a "holder" are.

Subpart H - Class and Type Ratings
FCL.705
The privileges of the holder of a class or type rating are to act as pilot on the class or type of aircraft specified in the rating.

Subpart G - Instrument Rating
FCL.605
(a) The privileges of a holder of an IR are to fly aircraft under IFR, including PBN operations, with a minimum decision height of no less than 200 feet (60 m).
(b) [...]
(c) Holders of an IR shall exercise their privileges in accordance with the conditions established in Appendix 8 to this Part.

If you're the holder of a rating, you can exercise the privileges as outlined above. If the rating has expired, you cannot exercise the privileges - I assume no debate there? If you cannot exercise the privileges of the rating, are you the "holder" of that rating?

I'll bow out of anything personal, I'm open to as much constructive discussion as you are Fl1ingfrog .

[Jhieminga]

From FCL.010 Definitions:

— "Renewal" (of, e.g. a rating or certificate) means the administrative action taken after a rating
or certificate has lapsed for the purpose of renewing the privileges of the rating or certificate
for a further specified period consequent upon the fulfilment of specified requirements.
— "Revalidation" (of, e.g. a rating or certificate) means the administrative action taken within the
period of validity of a rating or certificate which allows the holder to continue to exercise the
privileges of a rating or certificate for a further specified period consequent upon the fulfilment
of specified requirements.

This does not provide a clear solution for the debate, but what it does explain:

• After the period of validity has ended, the rating or certificate has lapsed, and it is the privileges that need to be renewed. It does not state that you need to reobtain said rating, which I assume to be the case once you are no longer the holder of a rating.
• Revalidation includes a reference to the holder, but it is the privileges that you continue to be able to exercise through this revalidation.
• These definitions do not say that you do not hold a rating anymore after it has lapsed.

Hope this helps...

[Fl1ingfrog]

This does not provide a clear solution for the debate, but what it does explain:

• After the period of validity has ended, the rating or certificate has lapsed, and it is the privileges that need to be renewed. It does not state that you need to reobtain said rating, which I assume to be the case once you are no longer the holder of a rating.
• Revalidation includes a reference to the holder, but it is the privileges that you continue to be able to exercise through this revalidation.
• These definitions do not say that you do not hold a rating anymore after it has lapsed.

Hope this helps...

It certainly does. Simple and to the point. Thank you.

That's quite an accusatory statement

It is not my place to accuse anybody of anything. I'm sorry you thought my remark was pointed at you Arrow Flyer, it wasn't.