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 |
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. |
How would I, or anybody else, ever show that I am legally permitted to exercise those IR(R) privileges? ANO Schedule 8 Commercial Pilots Licence (Aeroplanes) Privileges: (1) The holder of a Commercial Pilot’s Licence (Aeroplanes) is entitled— (a) to exercise the privileges of a United Kingdom Private Pilot’s Licence (Aeroplanes) which includes an instrument meteorological conditions rating (aeroplanes) and a night rating (aeroplanes) or night qualification (aeroplane); |
Well there's a powerful privilege, it would be foolhardy to abuse!
G |
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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To exercise the PPL privileges I need to be in currency for my biennial to keep the SEP rating current....
G |
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 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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No. You are exercising the privileges 'of a PPL which includes an IMC Rating'. |
Originally Posted by Whopity
(Post 10513001)
No such thing as a biennial, you could have done a prof check in the class or any other type or class.
Anyhow, people seem to have cleared up the question, and I'm grateful for that. G |
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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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 . |
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 |
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. |
Originally Posted by custardpsc
(Post 10513228)
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 ?
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 |
Can I suggest that as sooner or later EASA will change it's Annex numbers again, we should just say "EASA" or "non-EASA" ?
G |
Originally Posted by Genghis the Engineer
(Post 10513316)
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 |
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.
G |
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 ! |
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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Genghis - I did find this sentence whilst looking at third country licence verification process - so it seems that this is still a possibility.
"Instrument Rating (Restricted) where applied for on the basis of a Third Country single pilot instrument rating " |
Current policy is still as per CAP804:
An applicant who holds an ICAO IR(A) or military green Instrument Rating (Aeroplanes) and has passed a single-pilot IR test in the 24 months preceding the date of application for the IMC Rating / IR (Restricted) will be credited with a pass in the initial IMC Rating/ IR (Restricted) Skill Test and the written examination. The applicant must apply for the issue of the IMC rating within 24 months of the last IR test passed, The IMC Rating / IR(Restricted) will be valid for 25 months after the last day of the month in which the last IR test was successfully passed. |
Beagle - thank you, I should have known it was in CAP804. Now I just need to figure out how this applies if one already held an IR(R) that was expired.. ie if my IR test/proficiency checks could be used to validate my IR(R) for my already held expired IR(R) ....
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Teaching IR(R)
Hi all,
Can someone clarify what is required for an FI (with an MEP/CPL/IR) to teach IR(R) - the old IMC rating? Many schools quote the following: Pre-Course Requirements Hold a valid IR(R) and an unrestricted FI rating; Completed at least 10 hours flight time by sole reference to instruments in an aeroplane, Full Flight simulator, Flight Training Device (FTD) 2/3 or Flight Navigation Procedure Trainer (FNPT)II. I am assuming I can teach IR(R) if I "only" have an IR and not an IR(R)? Also if I have an IR, I automatically fulfill the 10 hour requirement? Would appreciate if someone could clarify. Many thanks |
Hold a valid IR(R) and an unrestricted FI rating;] To teach for the IMC or IR a FI must have embedded IRI privileges, this is indicated in section XII of the licence under FI with a (g) for the IR and (g)(IRR) for the IMC-IRR simply holding an IR is not enough. Completed at least 10 hours flight time by sole reference to instruments in an aeroplane |
While we are on the subject. FAA CPL/IR and has a EASA PPL, SEP, IMC, FI but no CPL TK and No Easa IR. Are they able to teach for the IMC? as IN 2016-082 states (my bold):
4.3 In addition, the CAA will authorise instructors to instruct for the IMC Rating/IR(R) if they satisfy the following requirements: a) hold a Part-FCL aeroplane licence issued by the UK CAA; and b) hold a Flight Instructor (Aeroplane) (FI(A)) without supervisory restriction, qualified to instruct for the single pilot class rating for the class or type of aeroplane which the IR(R) instruction is to be conducted in; and c) hold a valid IR(R) rating or IR(A) (not En-route Instrument Rating (EIR)) on the Part- FCL licence; and d) have passed all TK examinations either for the issue of a CPL(A) or IRI(A), subject to the same time limitations stated in Part-FCL Annex I; and e) have completed at least 10 hours flight time by sole reference to instruments in an aeroplane, Full Flight Simulator (FFS), Flight Training Device (FTD) 2/3 or Flight Navigation Procedure Trainer (FNPT) II; and f) have completed the course as specified in FCL.905.FI(g) as detailed in FCL.930.IRI; and g) have passed an Assessment of Competence to instruct for the IR(R) with a Flight Instructor Examiner (FIE) as specified in FCL.905.FI(g). Note: The course specified in FCL.905.FI(g) may be completed for the purpose of qualifying to instruct for the IR(R) without having the prerequisite IFR experience for the issue of the FCL.905.FI(g) privileges. Also I have no idea what IRI(TK) is. As far as I know there is no such thing? |
Also I have no idea what IRI(TK) is. As far as I know there is no such thing? |
If you have not passed the CPL exams, your instruction is limited to LAPL level. This also includes any ratings which may be included in a LAPL if you are additionally qualified (e.g. the Aerobatic Rating). But an IR(R) cannot be included in a LAPL, so you cannot provide instruction for the IR(R) as the minimum licence level in which an IR(R) can be included is the PPL(A).
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If you have not passed the CPL exams, your instruction is limited to LAPL level. |
Thanks for your replies! So in a nutshell, if I have an EASA ME CPL IR FI, with a SOLI that is not the UK, the only way to teach IR(R) in the UK is to transfer my SOLI to UK CAA. Then do I need to go through IR(R) course to put it on my licence?
Is there a document that details all these regulations? Could not find the answer in ANO. |
A lot of this information was promulgatewed by Information Notice try IN2016-82
You would need to trasfer your SOLI to the UK and you would need to complete the IRI course if you have not already done so. |
Originally Posted by Whopity
(Post 10566251)
Which really goes to show the level of knowledge of the author of the IN! But, very easy to achieve!
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There is nothing to achieve!
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