How to move UK IR(R) onto front of licence

[glush]

Hi, I was hoping for some UK licensing advice please. I have a current UK MEP/IR and SEP class rating. My MEP/IR expires in a few months and for cost reasons, I will probably not revalidate the MEP/IR. The SEP is valid until mid 2024.

My IR(R) is on the back of my UK CPL and I was wondering how easy it would be to get the IR(R) onto the front of my licence (whilst the IR is still current), so that once my IR lapses I could use the (lesser) privileges of the IR(R) instead.

Any thoughts and advice most appreciated! Thanks…

[rudestuff]

You only have one license right? How on earth did you end up with an IR on the front and an IRR on the back? If your IR is current then your IRR should be. Just ask them to put it back on the front?

[Fl1ingfrog]

As your IMC rating (IRR) is on the back of your licence then you will need to have it reissued but you are exempt from the IMCr training syllabus. It is my view that as your IR is still current then there is no need to do an IMCr renewal test which is required every 25 months. So see a examiner to renew your IMC which is a paperwork exercise and apply to the CAA for the IMCr to be re-issued - there will be a CAA charge.

However, if the IR is costly to renew because it is on a twin and that is the issue then renew it as a single engine IR. You will continue to revalidate every 12 months instead of every 25 months for the IMCr but the aircraft element will be at SEP costs. This way you will not be throwing away all the money and effort to obtain your IR. Use the IR revalidation test to also have the IMCr renewed. Then later if the IR was to lapse, and money is tight, you will have a further 13 months before the IMCr also lapses.

[excrab]

I had a similar issue two years ago, my multi-crew IR on the front of my licence but not current, my IRR was on the back, and I had a current SEP. I could have just done a SE SPA IR renewal and had it signed by an IRE, but that would have cost the IRE fees plus hire of a full airways single which together were prohibitively expensive just to be able to teach IRR and fly under IFR outside of class A air space.

In the end I did an IRR test at a local club in a fairly basic trainer (SRA and localiser only approaches on the test because it had no glide slope receiver or RNAV), and the whole exercise cost me £340 including the CAA charge to move the IRR to the front of the licence. That gives me all the SEP IMC privileges I need, I don’t want to take off or land in less than 1500 metres in an SEP in case the engine stops, nor do I want to fly airways single crew.

The only thing to watch is to ensure that your IR is current when you send the application to the CAA, if it has lapsed by even a day they will move it to the back of your licence when they move the IRR to the front, or at least that was what they told me; as a result I had to wait until my IR was renewed before I could apply for the IRR, but that delay was due to covid so fortunately someone else eventually paid for it.

[Genghis the Engineer]

May I offer an alternative solution.

Get a UK national CPL issued as an additional licence. That is no longer limited to non-part-21 aeroplanes, and contains non-expiring IMCR privileges for anything under 2 tonnes you're flying in UK airspace.

G

[topoverhaul]

I beg to differ, a UK National CPL with an inbuilt IMC Rating is valid IFR on non Part-21 aircraft but a UK National CPL with an SEP rating is only valid to LAPL privileges on a Part 21 aircraft. The Aviation Safety (Amendment) (No. 2) Regulations 2021 4 3 c applies.

[Genghis the Engineer]

4.—(1) Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council(5) is amended as follows.

(2) In Article 3, in paragraph 2, after the words “in accordance with Subpart B or C of Annex 1 to this Regulation” insert “or of pilot licences issued in accordance with article 152 of the Air Navigation Order 2016(6) and which are deemed to comply with this Regulation in accordance with Article 3(3) of this Regulation”.

(3) In Article 3, after paragraph 2, insert–

“3. A pilot licence issued in accordance with article 152 of the Air Navigation Order 2016 is deemed to comply with this Regulation where—

(a)it remains valid in accordance with that Order;

(b)it includes one of the following ratings: SSEA, SLMG, TMG, or SEP; and

(c)it is used within the privileges of those ratings on a flight conducted in accordance with Annex VII of Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council.

4. The ratings SSEA, SLMG and TMG have the meanings given in Schedule 1 to the Air Navigation Order 2016, and the rating SEP refers to a single-engine piston aeroplane of the kind described in Annex 1, Subpart B, point FCL.105.A(a) to this Regulation.”.

(4) In Article 4, in paragraph 8, for “Until 8 September 2021, the” substitute “The”.

There is no reference there to LAPL privileges only. The referred Annex VII I've linked below and is just the enabling regulation for part NCO - Non Commercial Operations.

https://www.legislation.gov.uk/eur/2012/965/annex/VII

I looked into this a while ago, and it appeared that there were some misleading public announcements from CAA which indicated this "LAPL privileges only", but that was never actually reflected in any of the original legislation.

G

[glush]

Thanks for all the help everyone. Much appreciated!!

[topoverhaul]

The relevant text is just after your quote
4.The ratings SSEA, SLMG and TMG have the meanings given in Schedule 1 to the Air Navigation Order 2016, and the rating SEP refers to a single-engine piston aeroplane of the kind described in Annex 1, Subpart B, point FCL.105.A(a) to this Regulation.”.
If you look at FCL 105 A (a) it refers to LAPL privileges.

[selfin]

"I looked into this a while ago, and it appeared that there were some misleading public announcements from CAA which indicated this 'LAPL privileges only'"

Those weren't misleading statements. The acceptance of UK non–Part-FCL licences, ie so-called national licences, on EASA aircraft was based on a derogation in art 12 para 2a(3) of the Aircrew Regulation that lasted until 8 April 2020, before being deleted by Commission Implementing Regulation (EU) 2020/359. The derogation limited the exercise of licence privileges to that of the LAPL. The UK CAA notified its adoption of the derogation in ORS4 No. 1309 (pdf copy) published 12 Jul 2019, in addition to earlier notifications in ORS4.

[Genghis the Engineer]

ORS4 1309 is cancelled.

Regarding FCL105(A)(a)...

‘FCL.105.A LAPL(A) — Privileges and conditions
(a) Privileges The privileges of the holder of an LAPL for aeroplanes are to act as PIC on single-engine piston aeroplanes-land (SEP(land)), single-engine piston aeroplanes-sea (SEP(sea)) or TMG with a maximum certificated take-off mass of 2000 kg or less, carrying a maximum of 3 passengers, such that there are always a maximum of 4 persons on board of the aircraft.

So if that stands as you say, it basically limits us to SEP under 2 tonnes, carrying no more than 4POB, which is the vast majority of GA. Accepting that's a limitation, but not much of one and it only refers to the privileges of flying an SSEA, not any other limitation of the LAPL, so far as I can see.

Also I could get really picky and say that it's only stated to be a requirement that the rating is on the licence, not that's the rating you're exercising at the particular time. I have SEP on my national licence, I also have MEP...

Aside from anything else, I'm sure we'd all agree this was badly and clumsily done by CAA!

G