Military IRT validity under EASA
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Cheers jpboy, all seems logical to me. However, I think the issue is that Section F4.1 para b may not exist after 7th April 2012. I'll post here should I get a definitive answer in writing.
Outside of QSP accreditation, in current LASORs, what would a 747 pilot who TR'd 6 years ago have to do, if anything to begin a MPA TR course had he not remained 'current and valid'?
Outside of QSP accreditation, in current LASORs, what would a 747 pilot who TR'd 6 years ago have to do, if anything to begin a MPA TR course had he not remained 'current and valid'?
Last edited by Cattivo; 1st Nov 2011 at 07:15.
''Outside of QSP accreditation, in current LASORs, what would a 747 pilot who TR'd 6 years ago have to do, if anything to begin a MPA TR course had he not remained 'current and valid'? ''
Assuming his last LPC/IR was six years ago, he would have to sit another LST/IR with a CAA Examiner observing the test. This is from the latest LASORs 2010 (which was only published in April 2011!). Included in this version is a requirement to sit all the IR Nav exams if the IR has expired by more than 7 years. This is becuase JAR FCL 1-185 (issued in 2005) has it included and the CAA have only just noticed! But they have included the caveat that no experince or IR under military or a non JAA ICAO member state can be counted.
This has cuaght quite a few people out. The CAA sent letters to all UK licence holders explaining they had better renew before April 2012 and then introduced this little gem. Foregin based UK licence holders (both national and JAA licence holders) have done what the CAA instructed and got a LST/IR on their current type and were then told that the rating could not be included on their licence to renew as their IR exams had expired!
One wonders at the motive behind this. Is it a concerted action to align the UK with the JAA (which no longer exists of course) or is it a ploy to increase their revenue before a lot of it disspears in April next year?
Either way, it's a muddle - and it appears it hasn't been applied evenly. Some pilots have been issued the rating after LASORS 2010 were isssued and others who were told their UK national licences wouldn't be re-issued after 1 Apr 11 have in fact had then renewed. And other JAA authorities apply the regs differently. For example, all you have to do in Sweden to keep your rating current is to send their aviation authority a copy of your foreign rating.
And the logic is as sound as asking a doctor to retake his biology A level becuase he's been working overseas for seven years. The premise that say for example, an IR issued in Hong Kong is less valid than on issued in Turkey or the RAF is nonesence, particulary if that IR has been used to fly in European airspace.
There are enough British Pilots in the world who this affects to cause a wave. The CAA will probably be facing legal action over their interpretation of JAR FCL 1-185. Something that they won't relish right now!
I will keep you all posted on developments.
Assuming his last LPC/IR was six years ago, he would have to sit another LST/IR with a CAA Examiner observing the test. This is from the latest LASORs 2010 (which was only published in April 2011!). Included in this version is a requirement to sit all the IR Nav exams if the IR has expired by more than 7 years. This is becuase JAR FCL 1-185 (issued in 2005) has it included and the CAA have only just noticed! But they have included the caveat that no experince or IR under military or a non JAA ICAO member state can be counted.
This has cuaght quite a few people out. The CAA sent letters to all UK licence holders explaining they had better renew before April 2012 and then introduced this little gem. Foregin based UK licence holders (both national and JAA licence holders) have done what the CAA instructed and got a LST/IR on their current type and were then told that the rating could not be included on their licence to renew as their IR exams had expired!
One wonders at the motive behind this. Is it a concerted action to align the UK with the JAA (which no longer exists of course) or is it a ploy to increase their revenue before a lot of it disspears in April next year?
Either way, it's a muddle - and it appears it hasn't been applied evenly. Some pilots have been issued the rating after LASORS 2010 were isssued and others who were told their UK national licences wouldn't be re-issued after 1 Apr 11 have in fact had then renewed. And other JAA authorities apply the regs differently. For example, all you have to do in Sweden to keep your rating current is to send their aviation authority a copy of your foreign rating.
And the logic is as sound as asking a doctor to retake his biology A level becuase he's been working overseas for seven years. The premise that say for example, an IR issued in Hong Kong is less valid than on issued in Turkey or the RAF is nonesence, particulary if that IR has been used to fly in European airspace.
There are enough British Pilots in the world who this affects to cause a wave. The CAA will probably be facing legal action over their interpretation of JAR FCL 1-185. Something that they won't relish right now!
I will keep you all posted on developments.
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jpboy -Thank you for the reply. I have a JAA CPL so I'm pretty sure I have to just meet the normal prerequisites when I do a MPA ME IR(A) to upgrade to an ATPL.
As an aside I have always believed that making it easier for a QSP to get a licence does not mean everyone would than leave the service. To the contrary, when you have a licence or the ability to get one easily, there is no urgency to use it but you have it just in case. If you have to rush & work hard yourself to get and pay for the licence, you might as well use it before it lapses and you incur more expenses revalidating it. But that is for another thread.
Thanks again jpboy.
As an aside I have always believed that making it easier for a QSP to get a licence does not mean everyone would than leave the service. To the contrary, when you have a licence or the ability to get one easily, there is no urgency to use it but you have it just in case. If you have to rush & work hard yourself to get and pay for the licence, you might as well use it before it lapses and you incur more expenses revalidating it. But that is for another thread.
Thanks again jpboy.
Politically this has panned out well for the CAA (though they will never admit it). EASA have instructed member states to toe the line here - regarding military alignment with civvy ops. The crux is that the respective CAA's must do the leg work as it is not a simple paper exercise. The CAA simply don't have the staff to lead with this, so have suggested to the mil, that they do the leg work for them and they will then top and tail it for approval.
The military have already missed the boat in my opinion. This issue was aired well over a year ago and there seemed to be little or misunderstood impetus from the M0D to act in that time zone. The CAA simply don't/won't have time to push it through by next April. Game over.
The military have already missed the boat in my opinion. This issue was aired well over a year ago and there seemed to be little or misunderstood impetus from the M0D to act in that time zone. The CAA simply don't/won't have time to push it through by next April. Game over.
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Outside of QSP accreditation, in current LASORs, what would a 747 pilot who TR'd 6 years ago have to do, if anything to begin a MPA TR course had he not remained 'current and valid'?
Assuming his last LPC/IR was six years ago, he would have to sit another LST/IR with a CAA Examiner observing the test. This is from the latest LASORs 2010 (which was only published in April 2011!).
However, I believe the underlying concern in Cattivo's question is what would the 74 pilot need to do prior to beginning a further MPA TR course. Dan's answer is on the nail regarding what is required to renew the rating but there is still an argument that they can renew their IR during the TR course. Arranging a CAA Examiner to observe might be an admin issue for the course provider and so they might prefer you to start current as a bun, but that is different from what you are required to do.
In all my dealings with the CAA they have continually emphasised that Lasors is only a guide and that JAR-FCL is the provenance document and thus the law. It is also true to say that from Apr 12 EASA becomes the law and Lasors is being replaced by CAP804, a document still being complied, so there are many questions still to be answered.
It is an incredibly frustrating scenario for the individual, the employer, TRTO and dare I say it even the CAA.
In any doubt email licensing and get in writing the requirements based on your unique circumstances.
Last edited by jpboy; 1st Nov 2011 at 13:24.
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Ladies and Gentlemen,
Please see the information below. It contradicts the advice I had previously been given and posted on this thread and it's source is Policy Dept CAA.
So unless you are on a multi-engined aircraft your Green Rating cannot be used to maintain your civil IR.
As previously discussed currently all mil accreditation ceases on 07 Apr 12 so this should only affect those imminently starting a Type Rating.
Left hand v Right hand, pse don't shoot the messenger.
Please see the information below. It contradicts the advice I had previously been given and posted on this thread and it's source is Policy Dept CAA.
A ME IR is one of the pre-requisites in order to gain the first MPA Type rating. You highlighted the LASORS 2010 text of para F4.1 b) which includes the following: “A UK QSP who has held a Green IR within the preceding 5yrs is deemed to hold a ‘current and valid’ IR.” I confirmed that given the paragraph starts with ; “Hold a current and valid Multi Engine IR…….” it is reasonable to assume that all subsequent IR references would be in relation to Multi engine IRs, even though this may not be specifically stipulated. The requirement of holding a current and valid ME IR, or in the case of a QSP, a ME green IR (within the last 5yrs) has been, and is Policy.
Looking forward to next year, LASORS 2010 will be superseded by CAP 804 which will fully define EASA pilot licensing requirements. The document will be available on line, spring next year.
Finally, I will bring to your attention a paper (attached) that discusses the implications of EASA legislation and which may be viewed at ; http://www.caa.co.uk/docs/620/d-Sept2011_v2.pdf and paragraph seven discusses credit for military flying.
Looking forward to next year, LASORS 2010 will be superseded by CAP 804 which will fully define EASA pilot licensing requirements. The document will be available on line, spring next year.
Finally, I will bring to your attention a paper (attached) that discusses the implications of EASA legislation and which may be viewed at ; http://www.caa.co.uk/docs/620/d-Sept2011_v2.pdf and paragraph seven discusses credit for military flying.
As previously discussed currently all mil accreditation ceases on 07 Apr 12 so this should only affect those imminently starting a Type Rating.
Left hand v Right hand, pse don't shoot the messenger.
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Having spent the last few weeks conversing with the CAA and my potential future employer, I thought I'd share the knowledge for those interested who helped me get to the answer.
In my quest to find out whether I would need to have a current ME IR prior to starting a TR course (after EASA comes into effect and therefore discounting any QSP accreditation/"current and valid" rulings due to mil IR), the CAA stated that because the TR wouldn't be my first MPA TR (my first one was on mil MPA which opened my license) then I could renew my IR on the TR course. The only timeframe I had to meet was to renew the IR within 7 years of the expiry of my last civilian IR (otherwise face doing the 7 IR theory exams).
This news was gratefully received, however, my potential future employer stated that regardless of the CAA ruling, they wanted a current and valid civilian IR on arrival. Lesson learnt, ask everyone involved!
In my quest to find out whether I would need to have a current ME IR prior to starting a TR course (after EASA comes into effect and therefore discounting any QSP accreditation/"current and valid" rulings due to mil IR), the CAA stated that because the TR wouldn't be my first MPA TR (my first one was on mil MPA which opened my license) then I could renew my IR on the TR course. The only timeframe I had to meet was to renew the IR within 7 years of the expiry of my last civilian IR (otherwise face doing the 7 IR theory exams).
This news was gratefully received, however, my potential future employer stated that regardless of the CAA ruling, they wanted a current and valid civilian IR on arrival. Lesson learnt, ask everyone involved!
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QSP ME Green IR
jpboy,
Thanks for your very informative last thread. I'm not a big user of pprune but my situation has pushed into some deep research and I've always known pprune is a great vault of advice!
I'll quickly explain my situation and then would appreciate it if you could let me know where or who from CAA policy explained the QSP ME Green IR policy on renewals!
I'm due to leave the RAF for a major British carrier next year. I'm presently flying the Boeing C-17 on 99 Sqn and have held a frozen ATPL since my first civil IR in 2002. Last month whilst checking my licence prior to an interview I stumbled upon the change in 2010 Lasors to Sect E para 1.5 about the 7 year elapsed statement from your original civil IR and how (apparently) the QSP Green IR didn't count. Since then I've been in a bit of a flat spin trying to sort out whether I've got a valid licence or not! I've haven't touched base with the CAA yet as I wanted to get all the info together first. It was only last night I read your thread on 04 Nov 11 and the very interesting way Sect F para 4.1 b can be interpreted. If this is a direct quote from CAA policy I could have a get out (fingers crossed)
To that end are you able to tell me who in the CAA quoted this so I can at least fire my email enquiry at the right person!
Many thanks and here's to hoping all is not lost!
Mylord-Smythe
Thanks for your very informative last thread. I'm not a big user of pprune but my situation has pushed into some deep research and I've always known pprune is a great vault of advice!
I'll quickly explain my situation and then would appreciate it if you could let me know where or who from CAA policy explained the QSP ME Green IR policy on renewals!
I'm due to leave the RAF for a major British carrier next year. I'm presently flying the Boeing C-17 on 99 Sqn and have held a frozen ATPL since my first civil IR in 2002. Last month whilst checking my licence prior to an interview I stumbled upon the change in 2010 Lasors to Sect E para 1.5 about the 7 year elapsed statement from your original civil IR and how (apparently) the QSP Green IR didn't count. Since then I've been in a bit of a flat spin trying to sort out whether I've got a valid licence or not! I've haven't touched base with the CAA yet as I wanted to get all the info together first. It was only last night I read your thread on 04 Nov 11 and the very interesting way Sect F para 4.1 b can be interpreted. If this is a direct quote from CAA policy I could have a get out (fingers crossed)
To that end are you able to tell me who in the CAA quoted this so I can at least fire my email enquiry at the right person!
Many thanks and here's to hoping all is not lost!
Mylord-Smythe
Dan, is this the current version of JAR-FCL 1.185?
Quite how the CAA has managed to read into this that their former policy was incorrect, I cannot understand. It doesn't seem to have caused any difficulties in the industry to date.
JAR–FCL 1.185 Validity, revalidation and renewal
(a) An IR(A) is valid for one year. If an IR(A) for a multi-engine aeroplane is to be revalidated the holder shall complete the instrument requirements of JAR–FCL 1.245(b)(1), which may be conducted in a flight simulator or FNPT II. If an IR(A) for single-engine aeroplanes is to be revalidated the holder shall complete, as a proficiency check, the skill test set out in Appendices 1 and 2 to JAR–FCL 1.210, except for Section 6.
(b) If the IR(A) is valid for use in single-pilot operations, the revalidation shall be completed in either multi-pilot operations or single-pilot operations. If the IR(A) is restricted for use in multi-pilot operations only, the revalidation shall be completed in multi-pilot operations.
(c) An applicant who fails to achieve a pass in all sections of a proficiency check before the expiry date of an instrumement rating shall not exercise the privileges of that rating until the proficiency check has successfully been completed.
(d) If the rating is to be renewed, the holder shall meet the requirements above and any additional requirements as determined by the Authority.
(e) If the IR(A) has not been revalidated/renewed within the preceding 7 years, the holder will be required to retake the IR(A) theoretical knowledge examination.
(a) An IR(A) is valid for one year. If an IR(A) for a multi-engine aeroplane is to be revalidated the holder shall complete the instrument requirements of JAR–FCL 1.245(b)(1), which may be conducted in a flight simulator or FNPT II. If an IR(A) for single-engine aeroplanes is to be revalidated the holder shall complete, as a proficiency check, the skill test set out in Appendices 1 and 2 to JAR–FCL 1.210, except for Section 6.
(b) If the IR(A) is valid for use in single-pilot operations, the revalidation shall be completed in either multi-pilot operations or single-pilot operations. If the IR(A) is restricted for use in multi-pilot operations only, the revalidation shall be completed in multi-pilot operations.
(c) An applicant who fails to achieve a pass in all sections of a proficiency check before the expiry date of an instrumement rating shall not exercise the privileges of that rating until the proficiency check has successfully been completed.
(d) If the rating is to be renewed, the holder shall meet the requirements above and any additional requirements as determined by the Authority.
(e) If the IR(A) has not been revalidated/renewed within the preceding 7 years, the holder will be required to retake the IR(A) theoretical knowledge examination.
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Mylord S,
We have spoken but for those interested the quote regarding a Green Multi-engined Mil IR being required to maintain a Civil IR validity is indeed a direct quote from CAA Policy Department.
Tourist,
You need a valid and current Multi-engined IR at the start of your first Multi Pilot Aeroplane Type Rating Course.
Good luck.
We have spoken but for those interested the quote regarding a Green Multi-engined Mil IR being required to maintain a Civil IR validity is indeed a direct quote from CAA Policy Department.
Tourist,
You need a valid and current Multi-engined IR at the start of your first Multi Pilot Aeroplane Type Rating Course.
Good luck.
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Mylord-Smythe
I am in a very similar situation to you. However, I have just had my IR(ME) reval denied by the CAA. I have even taken it to the Head of Licencing. Their stances is that after the mil dispensation for maintaining an IR based on a mil Green IR was removed (somewhere between 2008-2010 but not advertised), the individual instantly becomes liaible to the same regulations as a civilian. In effect if your last civie IR(ME) was prior to 2004 you are out of the 7 year requal period and therefore need to conduct an approved requal cse and exams.
I am taking advice on whether the CAA is obligued to provide a period of grace and the implications that they did not advertise the dispensation removal (note the late release of LASOR 2010 and the missing LASOR 2002 because of the number of changes).
If anyone has had better luck then do please let me know. Equally, if you are in the same position then give me a PM and I will keep you in the loop.
I am in a very similar situation to you. However, I have just had my IR(ME) reval denied by the CAA. I have even taken it to the Head of Licencing. Their stances is that after the mil dispensation for maintaining an IR based on a mil Green IR was removed (somewhere between 2008-2010 but not advertised), the individual instantly becomes liaible to the same regulations as a civilian. In effect if your last civie IR(ME) was prior to 2004 you are out of the 7 year requal period and therefore need to conduct an approved requal cse and exams.
I am taking advice on whether the CAA is obligued to provide a period of grace and the implications that they did not advertise the dispensation removal (note the late release of LASOR 2010 and the missing LASOR 2002 because of the number of changes).
If anyone has had better luck then do please let me know. Equally, if you are in the same position then give me a PM and I will keep you in the loop.
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The way that LASORS F4.1(b) reads suggests that you don't even need a Civ IR to commence a TR cse, so long as you have, as a QSP(A), held a Green rating at ANY time in the last 5 years. With the clarification provided above, this means a Green rating on a ME type.
This means that Mylord-Smythe, you ought to be golden, as far as commencing a TR course is concerned. And if ReturnOfX requires his IR for the same purpose, him too (assuming his within-last-5-years Green is on an ME type). If you are talking about exercising IR privileges on your Civ licence, though, that seems to be a different matter.
In short, holding, or having held in the last 5 years, a mil ME Green IR ought to qualify you to commence a TR cse, but doesn't, in and of itself, reval your Civ ME/IR for licence privileges.
Or am I missing something?
This means that Mylord-Smythe, you ought to be golden, as far as commencing a TR course is concerned. And if ReturnOfX requires his IR for the same purpose, him too (assuming his within-last-5-years Green is on an ME type). If you are talking about exercising IR privileges on your Civ licence, though, that seems to be a different matter.
In short, holding, or having held in the last 5 years, a mil ME Green IR ought to qualify you to commence a TR cse, but doesn't, in and of itself, reval your Civ ME/IR for licence privileges.
Or am I missing something?
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I spoke to them the other day; they acknowledged that with a F166 and cat form plus logbook, I should be able to revalidate my IR and TR in my licence.
My civvie IR(A) was held on my operational type and I've held a current green ever since. Will try to get email acknowledgement of this.
My civvie IR(A) was held on my operational type and I've held a current green ever since. Will try to get email acknowledgement of this.
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Well, I'm getting different answers depending on who is on the other end of the 'phone.
It seems that there are some advisors who state that you can retaliate with a current Green, others stating an IR(A) check is required.
Anyone with the 'pink' solution?!
It seems that there are some advisors who state that you can retaliate with a current Green, others stating an IR(A) check is required.
Anyone with the 'pink' solution?!
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Well after many long emails to the CAA and the help of BALPA I'm still up s**t creek without a paddle. The CAA never backed down on the removal of the rule of a military Green IR keeping your civil IR valid indefinitely.
So the bottom line from head of training at the CAA is that if your initial civil IR has lapsed by more than 7 years you loose it !!! The only way to keep it live is to renew it every 5 years in an approved simulator or if your between 5-7 years in an aircraft and after 7 years, 6 IR theory exams (presently studying for) and the flight test!!
Further to this, if any of your process falls over the 7 April 12, then all military accreditation will be lost until the new scheme (being staffed by 22 Trg Gp) is in place. The military's paper will be complete by then, it's just how long the CAA and EASA take implementing it!!
So my advice to anyone is, unless you have to sort out licenses for a immanent career start date (my position!) then I would leave it until the dust settles post EASA. You never know, you might find yourself in a better position than before this change!! But I'd be very surprised!!!
Got to go, got some gyro theory to learn!!! Living the dream!!!
So the bottom line from head of training at the CAA is that if your initial civil IR has lapsed by more than 7 years you loose it !!! The only way to keep it live is to renew it every 5 years in an approved simulator or if your between 5-7 years in an aircraft and after 7 years, 6 IR theory exams (presently studying for) and the flight test!!
Further to this, if any of your process falls over the 7 April 12, then all military accreditation will be lost until the new scheme (being staffed by 22 Trg Gp) is in place. The military's paper will be complete by then, it's just how long the CAA and EASA take implementing it!!
So my advice to anyone is, unless you have to sort out licenses for a immanent career start date (my position!) then I would leave it until the dust settles post EASA. You never know, you might find yourself in a better position than before this change!! But I'd be very surprised!!!
Got to go, got some gyro theory to learn!!! Living the dream!!!
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M-S
Sorry to hear that. I think I'm okay at the moment; the acid test will be when I head down there with my paperwork (and no doubt plenty of cash!) in a couple of weeks.
I'll keep you posted.
Sorry to hear that. I think I'm okay at the moment; the acid test will be when I head down there with my paperwork (and no doubt plenty of cash!) in a couple of weeks.
I'll keep you posted.