IMCR - the latest update!
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IMCR - the latest update!
The CAA has released a revised statement concerning the UK IMCR, see http://www.caa.co.uk/docs/2330/srg_l...ril%202012.pdf
This is simply a clarification of the grandfathering arrangements to which EASA informally agreed in October 2010; it is in accordance with the terms of Article 4 to Regulation (EU) 1178/2011.
This new policy is not a fundamental part of ongoing FCL.008 deliberations, about which no-one should draw any conclusions. It is not the final solution for the future continuance of the IMCR, but it is a sound, pragmatic solution for the period between now and Apr 2014.
Here are some Q&As AOPA discussed with the CAA prior to this statement being released:
This is simply a clarification of the grandfathering arrangements to which EASA informally agreed in October 2010; it is in accordance with the terms of Article 4 to Regulation (EU) 1178/2011.
This new policy is not a fundamental part of ongoing FCL.008 deliberations, about which no-one should draw any conclusions. It is not the final solution for the future continuance of the IMCR, but it is a sound, pragmatic solution for the period between now and Apr 2014.
Here are some Q&As AOPA discussed with the CAA prior to this statement being released:
Q1. Will applications for UK IMC Ratings to be included in existing JAR-FCL pilot licences made between 1 July 2012 and 8 Apr 2014 result in the holder's licence being converted to a Part-FCL licence with IR(Restricted)?
A1. Yes.
Q2. In other words, that there will be no need to issue a ‘supplementary’ United Kingdom pilot licence for the inclusion of an IMC Rating?
A2. Correct.
Q3. If the CAA receives an application from a UK non-JAR-FCL / non-Part FCL licence holder for an IMC Rating after 1 July 2012, will it simply be included in the licence in the traditional manner?
A3. Yes – but the applicant might prefer instead to convert the UK licence to a Part-FCL licence with IR(R). That’ll be for the applicant to decide.
Q4. Will the UK in future adopt the term 'IR(R)' generally, rather than having 2 identical ratings with different titles?
A4. Unlikely, as this would mean change to the UK ANO, which might prove problematic. Legally we are not in fact adding the IMC rating to Part-FCL licences; what we are doing is granting the Part-FCL IR(A) to pilots who hold IMCR privileges, but with the IR(A) restricted to the privileges of the IMCR.
Q5. Of course the wording of your clause 4: 'There will continue to be provision under the Air Navigation Order to add the IMC Rating to UK (non-EASA) licences into the future, but IMC Ratings will only be valid for non-EASA (Annex II) aeroplanes from 8th April 2014 onwards. From that date forward the IR(R) must be held on a Part-FCL licence to exercise the privileges with EASA aeroplanes.' would still hold true if EASA can be persuaded to adopt the revision to FCL.600 which AOPA, CAA, IAOPA Europe, PPL/IR Europe have all proposed, so that 'new' IR(R)s could then be issued after 8 Apr 2014. The wording leaves the door open for that possibility?
A5. Yes.
Q6. In your clause 5 where you refer to 'the IMCR to IR(R) and other conversions', presumably the IMCR to IR(R) conversion is simply the administrative process as described in your Revised Statement?
A6. Yes.
Q7a. There will be pilots with JAR-FCL pilot licences, now 'deemed' Part-FCL pilot licences, who may not have intended to convert their licences physically to Part-FCL licences before the 5 year re-issue point. If those licences currently include IMCRs, will those IMCRs be 'deemed' to be IR(R)s until they too are physically converted with the licence?
A7a. No. As explained in A4, the IR(Restricted) will be an EASA rating which cannot be included on anything except a Part-FCL pilot licence.
Q7b. Or will it be a requirement for such licences to be converted physically to Part-FCL licences before 8 Apr 2014 if IMCR privileges are to be exercised on EASA aeroplanes?
A7b. Yes
Q7c. So, if you are a JAR-FCL pilot licence holder with an IMCR and you wish to exercise IMC rating privileges on both EASA and non-EASA aeroplanes after 8 Apr 2014, you must have converted your licence to a Part-FCL licence with IR(R) beforehand?
A7c. Yes.
Q7d. But If you wait until the 5 year re-issue point to convert your JAR-FCL licence with IMCR to a Part-FCL licence with IR(R), your IMC rating privileges will be restricted to non-EASA aeroplanes after 8 Apr 2014, until such time as your licence has been converted?
A7d. Yes.
Q8. Will the IR(R) be included in Part-FCL licence conversions of UK non-JAR-FCL professional pilot licences which include IMC privileges, such as the UK CPL(A)?
A8. Yes.
A1. Yes.
Q2. In other words, that there will be no need to issue a ‘supplementary’ United Kingdom pilot licence for the inclusion of an IMC Rating?
A2. Correct.
Q3. If the CAA receives an application from a UK non-JAR-FCL / non-Part FCL licence holder for an IMC Rating after 1 July 2012, will it simply be included in the licence in the traditional manner?
A3. Yes – but the applicant might prefer instead to convert the UK licence to a Part-FCL licence with IR(R). That’ll be for the applicant to decide.
Q4. Will the UK in future adopt the term 'IR(R)' generally, rather than having 2 identical ratings with different titles?
A4. Unlikely, as this would mean change to the UK ANO, which might prove problematic. Legally we are not in fact adding the IMC rating to Part-FCL licences; what we are doing is granting the Part-FCL IR(A) to pilots who hold IMCR privileges, but with the IR(A) restricted to the privileges of the IMCR.
Q5. Of course the wording of your clause 4: 'There will continue to be provision under the Air Navigation Order to add the IMC Rating to UK (non-EASA) licences into the future, but IMC Ratings will only be valid for non-EASA (Annex II) aeroplanes from 8th April 2014 onwards. From that date forward the IR(R) must be held on a Part-FCL licence to exercise the privileges with EASA aeroplanes.' would still hold true if EASA can be persuaded to adopt the revision to FCL.600 which AOPA, CAA, IAOPA Europe, PPL/IR Europe have all proposed, so that 'new' IR(R)s could then be issued after 8 Apr 2014. The wording leaves the door open for that possibility?
A5. Yes.
Q6. In your clause 5 where you refer to 'the IMCR to IR(R) and other conversions', presumably the IMCR to IR(R) conversion is simply the administrative process as described in your Revised Statement?
A6. Yes.
Q7a. There will be pilots with JAR-FCL pilot licences, now 'deemed' Part-FCL pilot licences, who may not have intended to convert their licences physically to Part-FCL licences before the 5 year re-issue point. If those licences currently include IMCRs, will those IMCRs be 'deemed' to be IR(R)s until they too are physically converted with the licence?
A7a. No. As explained in A4, the IR(Restricted) will be an EASA rating which cannot be included on anything except a Part-FCL pilot licence.
Q7b. Or will it be a requirement for such licences to be converted physically to Part-FCL licences before 8 Apr 2014 if IMCR privileges are to be exercised on EASA aeroplanes?
A7b. Yes
Q7c. So, if you are a JAR-FCL pilot licence holder with an IMCR and you wish to exercise IMC rating privileges on both EASA and non-EASA aeroplanes after 8 Apr 2014, you must have converted your licence to a Part-FCL licence with IR(R) beforehand?
A7c. Yes.
Q7d. But If you wait until the 5 year re-issue point to convert your JAR-FCL licence with IMCR to a Part-FCL licence with IR(R), your IMC rating privileges will be restricted to non-EASA aeroplanes after 8 Apr 2014, until such time as your licence has been converted?
A7d. Yes.
Q8. Will the IR(R) be included in Part-FCL licence conversions of UK non-JAR-FCL professional pilot licences which include IMC privileges, such as the UK CPL(A)?
A8. Yes.
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Great. I think.
'So, if you are a JAR-FCL pilot licence holder with an IMCR and you wish to exercise IMC rating privileges on both EASA and non-EASA aeroplanes after 8 Apr 2014, you must have converted your licence to a Part-FCL licence with IR(R) beforehand?
A7c. Yes.'
That's me. How do we apply for a Part-FCL licence with IR(R)?
'So, if you are a JAR-FCL pilot licence holder with an IMCR and you wish to exercise IMC rating privileges on both EASA and non-EASA aeroplanes after 8 Apr 2014, you must have converted your licence to a Part-FCL licence with IR(R) beforehand?
A7c. Yes.'
That's me. How do we apply for a Part-FCL licence with IR(R)?
Thread Starter
Wait until the CAA starts issuing part-FCL pilot licences in July 2012, then apply. CAP804 (due to be published shortly) should explain the precise method required.
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So what does this mean for ppl holders who haven't yet got their imc but are in the middle of training? Do we now have until 2014 to complete, or have we already missed the boat?
Thread Starter
You have until Apr 2014:
Q1. Will applications for UK IMC Ratings to be included in existing JAR-FCL pilot licences made between 1 July 2012 and 8 Apr 2014 result in the holder's licence being converted to a Part-FCL licence with IR(Restricted)?
A1. Yes.
A1. Yes.
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Thanks for the info, this is great news, not least for me as I've recently completed the IMCR 
Let's hope this is another step on the way to ensuring the continuation of the IMCR/IR(R) into the future via issue of new IR(R)'s beyond 2014
Let's hope this is another step on the way to ensuring the continuation of the IMCR/IR(R) into the future via issue of new IR(R)'s beyond 2014
How is this IR(R) revalidated? Clearly not within the privileges of a PPL FE to sign an EASA licence for an IR, so presumably must be an IRE or CRE/IRR. Once entered, what is the validity period?
Thread Starter
Whopity, have another read of Clause 2 of the CAA statement. IR(R) revalidation and renewal requirements will be identical to IMCR revalidation and renewal requirements.
Please don't cloud the issue with any more BS about the IR(R) requiring to be examined 'to EASA IR standards' - you caused a lot of unnecessary confusion last time!
The CAA are already working on IRI and examiner solutions for the IR(R); these should appear in CAP804.
Please don't cloud the issue with any more BS about the IR(R) requiring to be examined 'to EASA IR standards' - you caused a lot of unnecessary confusion last time!
The CAA are already working on IRI and examiner solutions for the IR(R); these should appear in CAP804.
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Beagle
Just to clarify, I'm still doing my PPL so will likely be getting a Part-FCL licence (and will never have had a JAR licence). Would I be able to add a new IR(r) to a Part-FCL licence before Apr 2014 (I know that after April 2014 is still under discussion)?
Same situation as someone who has to have a minor alteration to a JAR licence which will convert it to a Part-FCL licence for some other purpose. If they then try to add an IMC to their licence it would need to go straight on as an IR(r).
Or are all licences technically Part-FCL now anyway (they just look like JAR licences) so my question is silly?
Just to clarify, I'm still doing my PPL so will likely be getting a Part-FCL licence (and will never have had a JAR licence). Would I be able to add a new IR(r) to a Part-FCL licence before Apr 2014 (I know that after April 2014 is still under discussion)?
Same situation as someone who has to have a minor alteration to a JAR licence which will convert it to a Part-FCL licence for some other purpose. If they then try to add an IMC to their licence it would need to go straight on as an IR(r).
Or are all licences technically Part-FCL now anyway (they just look like JAR licences) so my question is silly?
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So if you have a JAR licence, you can train for an IMC rating up until April 2014. If you don't have to convert your licence to a Part-FCL licence before you've finished, when you add the IMC rating your your JAR licence you will get back a Part-FCL licence with an IR(r) on it.
But if you were unfortunate enough to have to hand your JAR licence into the CAA for some other reason (lets say, change your address, or re-validate another rating) before you are finished the IMC training, you will only be able to get a UK PPL with IMC privileges, as its not possible to add a new IR(r) onto a Part-FCL licence...
But if you were unfortunate enough to have to hand your JAR licence into the CAA for some other reason (lets say, change your address, or re-validate another rating) before you are finished the IMC training, you will only be able to get a UK PPL with IMC privileges, as its not possible to add a new IR(r) onto a Part-FCL licence...
Thread Starter
You will be able to include an IR(R) in a CAA-issued pilot licence after July 2012. That includes a part-FCL PPL(A) issued by the UK CAA.
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So I've got just under 2 years to get a PPL and an IR(r) then. If I don't make that - something has definitely gone wrong!
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Any thoughts please?
As per Q8, I hold a UK non-JAR-FCL CPL which includes IMC privileges. I also hold a JAR-FCL CPL now 'deemed' Part-FCL licence, valid until 2016 which includes an expired IMC Rating exemption.
From what I see on the CAA's update, if I only had the UK CPL I could convert it to an EASA licence before 8th April 2014 and thereby be granted an IR(R) on the new licence. As I effectively already have a new EASA (JAR Part-FCL licence) how do I get the IMC privileges carried over?
As per Q8, I hold a UK non-JAR-FCL CPL which includes IMC privileges. I also hold a JAR-FCL CPL now 'deemed' Part-FCL licence, valid until 2016 which includes an expired IMC Rating exemption.
From what I see on the CAA's update, if I only had the UK CPL I could convert it to an EASA licence before 8th April 2014 and thereby be granted an IR(R) on the new licence. As I effectively already have a new EASA (JAR Part-FCL licence) how do I get the IMC privileges carried over?
Thread Starter
Well perhaps you should just send your collection of licences to the CAA after July 2012 and ask them to send you a part-FCL CPL(A) with IR(R)?
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Thanks Beagle sounds like a reasonable plan. I guess it would be better to do this as close as possible to the April 2014 deadline as I can't see anything to be gained by doing it sooner. I presume I would then have an IR(R) valid for 25 months from that date? or am I missing something?
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I have read somewhere that you will need an IR in order to fly IFR after 8 June this year. Is this correct?
Does this mean that If you have a JAR licence with an IMC rating you will not be able to fly IFR after June 8th?
Does this mean that If you have a JAR licence with an IMC rating you will not be able to fly IFR after June 8th?
Thread Starter
I have read somewhere that you will need an IR in order to fly IFR after 8 June this year. Is this correct?
Does this mean that If you have a JAR licence with an IMC rating you will not be able to fly IFR after June 8th?
The effective date is, in fact, 1 July 2012 but you are correct. Under the EASA implementing rules a pilot may not fly under IFR in an EASA aeroplane unless he/she holds an instrument rating. [FCL.600 refers]
Thread Starter
Yet more of your needless obfuscation, BillieBob.
Might I suggest that you read and accept the CAA's Revised Statement, as well as the pertinent sections of CAP 804.
Might I suggest that you read and accept the CAA's Revised Statement, as well as the pertinent sections of CAP 804.