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

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:
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.

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

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.

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?

Take an SEIR test

You have an Irish Part FCL Licence, therefore; you can renew the SE IR privileges in accordance with Appendix 8
Or as Rudestuuf says you can take a SE IR Prof Check

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.

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.

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.

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!

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 🤔🤔

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

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.

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.

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.

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.

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

The CAA will do well to retain their "pithiness" when the onslaught starts. If they intend to sit on their backsides whilst spouting excuses for their inaction I won't be surprised but they it seems most certainly they will be. The many who have survived this Covid-19 hell will not be in the mood for procrastination.

If I'm reading this correctly the UK CAA hope to come to some kind of arrangement with EASA by giving 27 foreign countries control over our own licenses and our aviation generally. It will never be the other way round. So, where would that leave UK licences, approvals and aviation? Surely it cannot be thought that UK licenses will be only national with no recognition worldwide. The only answer that I can see is that there is some mutual recognition of each others licenses and approvals but the UK being completely independent will be a block. There is too much for the EASA to give away on the world stage for that to happen.

EASA have never shown any aptitude to mutuality, in fact they resist it. They expect compliance with them in every detail. They resent ICAO but they have no choice but to accept it for the moment. For EASA the ICAO is the FAA in another name. The EASA ambition is to become the world standard and to replace ICAO. A European state such as the UK maintaining a world wide independent aviation industry will be a problem for EASA none the less. The EASA method to deal with difficulty is to push it as far into the future that it can. This has the secondary benefit of maintaining pointless employment for it's executive.

Surely...

(a) A UK CPL licence can be used to fly any G-reg aeroplane for which the pilot is suitably qualified, within the privileges of that licence. Hence a UK-FCL CPL or PPL in, say, a G-reg PA28 has IMC rating privileges in UK airspace.

(b) All UK licences remain ICAO compliant.

So, notwithstanding Fl1ingfrog's Eurosceptic stance about EASA's attitudes above (with which I substantially agree) the UK licences will be in broadly the same place as any other ICAO contracting state's, such as e.g. an FAA licence.

What will doubtless be painful is EASA's clear intention to refuse to accept mutuality of the UK's substantially identical aviation regulations. This is part of the overall bullying attitude of the EU towards all things British, as it's so important to make Brexit an abject failure, so as to dissuade all others. Sooner or later somebody will probably test this in court, which will be interesting.

G

No, they can only exercise the privileges in an Annex 1 aircraft. It has not been legal to fly an EASA aircraft on a UK National Licemce since 8th June 2018. The UK could issue an exemption after 31st December.

Yes, good point, my focus was elsewhere. I wonder whether we will end up in the odd situation that the rest of the world recognises both UK FCL and non-FCL licences as being ICAO compliant while we continue to separate the 2. There are as ever good/laudable reasons for each existing in their own right, but it's pretty clear that the whole thing is a confusing mess. It's bad enough having to interpret it within industry, my sympathies are with the genuinely good individuals at Gatwick charged with remembering/interpreting/promulgating this with little personal input into policy.

As all UK issued licences under EASA FCL become national licences on January 1st, it seems highly unlikely to me that the UK will permit itself to be in a position where the majority of the G-reg fleet can be flown only by holders of foreign licences.

G

This is where we must be very careful with the terminology of what a national licence is. From January 1st terms for UK issued licences will split into FCL and non-FCL - those that are currently EASA FCL will become UK FCL (and allow flight on Part-21 and non-Part-21 G-reg), those that are currently UK National will be referred to as non-FCL (and will only allow flight on non-Part-21 G-reg). There are no initial plans for the UK FCL licences to mirror UK National licences under the ANO, they will continue as now and mirror EASA FCL licences. It would be nice to hope for fairly instant exemptions to allow wider use of licences, but if it happens at all then it may well come with conditions analogous to LAPL privileges only or similar - we just don't know right now.

Fair point, we're heading for three standards...

Non-UK EASA.FCL - will be given honorary rights by the look of it, for at least two years.

UK.FCL - either are already issued and FCL compliant, or are about to be.created from UK issued EASA FCL licences.

Non FCL UK - so old unconverted UK PPLs, CPLs and ATPLs, plus NPPLs.

The first category are somewhat unknown, the second seem likely to be able to carry on as ever in G-reg aeroplanes (with CPLs and ATPLs having embedded IMC privileges). The Third are anybody's guess: they may potentially be limited to just permit aeroplanes, although I imagine CAA will permit PPL level privileges in CofA light aircraft pretty much indefinitely.

(Plus a fourth category - non-EU, non-UK, but ICAO compliant, e.g. FAA. The value of those is far from clear yet!)

G

Almost - but with some caveats. The 3-4 categories work. However:

Category 1: non-UK EASA FCL licences: granted automatic validation for a maximum of 2 years, but only until the first revalidation of relevant ratings. Eg an IR expiring in March makes the licence rather less useful for a UK AOC holder, even if the other ratings remain valid for the rest of the year. Slightly easier for FIs "just" doing VFR SEP instruction since they may have up to 2 unhindered years.

Category 2: UK FCL licences: yes, carry on as for now. No embedded IMC privileges though - the ANO references to these are for licences that won't fall under the new UK FCL document (technically written into existence in 2019 as a copy and paste of EASA FCL). Hence why I'm trying to steer away from describing them as national licences, although that is what they are, since they won't fall under what we've understood as national licences for the last 20 years.

One would hope that in the fullness of time there will be only one standard of UK licence (be they PPL, CPL or ATPL) that are compliant with both ICAO and EASA.

The issue of morphing LAPL and NPPL into a “UK PPL” could be dealt with by having ratings on that PPL which define the privileges that LAPL and NPPL holders currently exercise.

Oh, and I would like my lifetime IMC rating back too whilst you’re at it.

It would be nice if it could be done in just one move on the chessboard, but quite a few moves might be needed to get to the final position.

Under the old UK system it was a prerequisite to hold an IMC rating before one could start the training for the CPL. Instrument flying was also tested on the cpl skills test. Although I can't remember how much and instrument approaches were not tested.

The CAA are wrong one way or another on all UK CPL's having inbuilt IMC privilege for life. I wasn't able to upgrade my BCPL to a UK CPL until something like 2008 as I couldn't hold a class 1 medical. When I was able I was told all UK CPL''s issued after the formation of JAR would be issued without inbuilt IMC privileges. Hence I had a UK CPL issued without inbuilt IMC privileges.

It would now appear that's all been forgotten.

Not quite, it gave you an exemption that allowed you to take the 15 hour abridged CPL Course rather than the 25 hour course which included 10 hours of IF and was a cheaper option. It was mandatory for the AFI Course. Still have my old CAP54.

You are quite right Mickey. You also had to hold an IMC rating (or IR) to become a Flying instructor and thereafter maintain it. It was common practice for Flying Instructors to climb through IMC to teach in clear air on top. Here in France its rare to find a Flight Instructor who has flown in cloud, ever. The instrument flying assessment during the CPL test was pretty much as now, by the way.

For many the history of the present is a mystery so here is a short overview for those who may find it useful.

On the UK joining the newly formed JAA (1999) it was possible to hold both a UK and a JAA licence in parallel. The main stimulus for the JAA was that there would be one standard for its members. Mutually recognised licenses, ratings and type approvals between members. This was particularly valuable for the airlines. Once EASA was borne it all began to change. EASA demanded that there was to be one recognised licence held by a member state person annotated with "EASA" and to be fully recognised in the EU. For a short time a ludicrous situation existed: we had a UK international licence not recognised by the EU but recognised elsewhere throughout the world. The JAA licences* were issued for 5 years and so on renewal were easily morphed into EASA licenses without choice. Some changes that came with JAR/EASA were unpopular. The UK PPL had been issued for life and many refused to give it up. In a twist the EU had to continue to recognise the UK PPL licences for "overflight" subject to the ICAO rules. So, beyond all reason, the UK CAA resolved this embarrassing problem by demoting the UK PPL to being a national licence only although it was compliant with ICAO. The UK PPL continued with all the same privileges but only for flight within UK airspace. Job done, if you wanted to fly internationally then you had to obtain an EASA licence. A sweetener to the UK PPL was to find a way to recognise the IMC rating and to include it in the EASA licence. In a perferse move they found a way around this problem by calling the IMC rating an "IR(restricted)" but only for annotating the privilege within the EASA licence. The IMC rating is not recognised by EASA and the IR(restricted) doesn't actually exist.

* The JAR rules caused problems for many as the CAA's ability to provide discretion, particularly against medical standards, had been lost. The CAA were under pressure. The answer was the NPPL (with its artificial differences designed mainly to persuade the Dept. of Transport) and with it the "Medical Declaration" that was to be countersigned by your personal GP.

The complication of so many licences we have now is unnecessary. All of this can return to being simple: PPL, CPL, ATPL and an NPPL (sub ICAO). The BGA should be left alone because they are more than capable of running their own affairs, as they always have done.

The main problem to resolve is the LAPL it being a wholly EASA licence and issued for life. The UK for its own purposes doesn't need it. Who will oversee it?

If the UK leave EASA, then I suppose it's reasonable for EASA to say that the CAA cannot issue any more EASA licences. But for them to say that an existing EASA licence suddenly stops being an EASA licence is quite ridiculous, and should be easily challenged in court.

Which court are you taking the case to?
Who is gonna revalidate/renew existing EASA medicals?
Who is gonna revalidate/renew existing EASA ratings?

I knew someone would ask that!
​​​​1. Let's say a German had a UK EASA licence. They've taken all the exams, passed all the tests, now they're told they don't have a valid EASA licence anymore! They could go to the European court and argue their case.
2. Existing AMEs
3. Existing examiners.

​​​​

There are times when semantics are important. There are no such things as EASA licences, ratings or medicals. They are national things in accordance with EASA regulations so they are recognised by each EU member state without further ado. They are all UK things and governed by UK law. The UK courts have jurisdiction and always have.

The main problem is the LAPL: it is a sub-ICAO licence with the privilege for flight within the EU states. It is otherwise identical in most things to the UK NPPL but with the ability to add a night rating. The UK LAPL being sub-ICAO means it will not have the automatic right for overflight into Europe unless the EASA member states continue to allow it. The LAPL also has its own unique medical which has no other purpose.

Just to add to the confusion you can add a night rating to a NPPL

Nope.
Better to bring up a case before the end of December if you're British. Germans aren't leaving the EU.

*Existing AMEs in EASA land or EASA recognized in the UK - if any.
*Same as above.

JAA did exist as National law but EASA regulation is EU law overriding national regulation. UK courts do not have jurisdiction over EASA law. The exit SI takes EASA law into UK national law, but it remains separate from the ANO which regulates national aviation licences etc.

To revive an old thread and to get back to OP question, has anyone had any luck in cross crediting their MPA (IR) towards SE (IR)? Im in the same boat, I would like to see if there is a cheaper alternative to this other then taking an IR skill test?

Cheers