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Old 12th Nov 2012, 09:23
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riverrock83, I'm soooooooo very sorry that my free advice and licensing clarification has not been to your total satisfaction.....

Anyway, wb9999 et al., fresh from the CAA:

An IMCR first obtained prior to 8th April 2014 can be added in the form of an EASA Instrument Rating with restrictions (IR(R)) to a UK-issued Part-FCL licence at any time in the future, including after 8th April 2014. This is in accordance with Article 4 of Regulation 1178/2011

It is only IMCRs first obtained from 8th April 2014 onwards that cannot be added to Part-FCL licences as to do so would not be the preservation of a privilege obtained before the aircrew regulation became mandatory (in this particular aspect).

It is implicit in the CAP 804 text that the IR(R) can be added to a Part-FCL licence issued after 17 September as Part-FCL licences were not issued before that date.
The CAA has also agreed to amend the relevant text in the next amendment to CAP 804 to make this completely clear.

cessna24, you asked:

My IMC lapsed in June this year. How long have I got to renew it before I loose it for good?
As you will hopefully have deduced from the CAA's response and from CAP 804, if you ever held IMCR privileges before 8 Apr 2014, even if they lapsed years ago you will still be able to renew them on a Part-FCL licence issued (or upon conversion) at any time in the future. So if they lapsed 20 years ago and you waited until 2020 to renew them, you would simply follow the same renewal process as outlined in CAP 804.

However, to exercise IMCR privileges on an EASA aeroplane after 8 Apr 2014, you will need to have converted a JAR-FCL licence (or UK non-JAR-FCL licence) to a Part-FCL licence which includes the new term IR (Restricted).
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Old 12th Nov 2012, 09:46
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Sarcasm noted . I know that your time and expertise is greatly appreciated on here...

So that is a Yes - and this is based on your reading of CAP804, which doesn't say directly (it only directly talks about JAR conversions and the UK National PPL), but implicitly suggests that if you get a Part-FCL licence, then later complete the IMC course, and get the paper work to CAA before 8th April 2014, you will receive an IR(r) on your Part-FCL license (rather than the alternative national PPL with IMC Rating).

And the basis of this, is that you can't lose the privilege of being able to add an IMCR / IR(r) to your licence before April 2014 to allow you to fly EASA aircraft in IMC in the future, which trumps the other EASA regulation that says you can't add a national rating to a Part-FCL licence.

Is that a fair summary? As I've said elsewhere, it doesn't say that you can't add a new IR(r) to an already acquired Part-FCL licence. Its just quite expensive to do something based on an untested, implicit assertion (which is why I hope someone else gets a definitive, written answer from the CAA before I start!

As I've said elsewhere - I'm looking to do my PPL skills test soon, and so start to plan out what to do with my licence to learn for the next year or so, and I would like an IR(r) to feature in there, as it seems more useful than an EIR in the UK.
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Old 12th Nov 2012, 10:23
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BEagle,

Fantastic.......thank you.

That's answered it perfectly.

Kregards

c24

Last edited by cessna24; 12th Nov 2012 at 10:24.
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Old 12th Nov 2012, 10:34
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riverrock83, which part of
fresh from the CAA
do you find difficulty in understanding?

The clarification came in an e-mail received this morning in response to my request for confirmation.

Once you have your Part-FCL PPL, you will be able to include an IR(R) in it if you pass the IMC training and testing and apply before Apr 2014.
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Old 12th Nov 2012, 10:56
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Beagle
That's brilliant - thanks for your time and effort.
I should have read your post more carefully. Apologies.
RR
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Old 12th Nov 2012, 12:15
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BEags,

If I have to have converted my JAR-FCL PPL(A) with IMCR to EASA by 8 Apr 2014 in order to have an IR(R) added to it, will the CAA contact me to remind me or do I have to initiate this? (If you know!)

At the moment my JAR-FCL PPL(A) expires in 2016 so I don't want to find I've missed the deadline.

Tim
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Old 12th Nov 2012, 12:30
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The skills taught and learnt for the IMC rating is invaluable. Whether or not this rating actually exists ON A LICENSE after 2014 shouldn't matter.

If it doesn't why not issue a completion certificate, just like aerobatics?
After all the IMCR was designed for one to return home after inadvertent IMC encounter.

It wasn't designed to be a 15-hour easy-to-get IR with 20% of the training, which is what EASA fundamentally cannot accept.
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Old 12th Nov 2012, 13:36
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If I have to have converted my JAR-FCL PPL(A) with IMCR to EASA by 8 Apr 2014 in order to have an IR(R) added to it, will the CAA contact me to remind me or do I have to initiate this? (If you know!)
If you haven't converted your JAR-FCL PPL(A) + IMCR to a Part-FCL PPL(A) with IR(R) before 8 Apr 2014, you won't be able to exercise IMCR privileges on EASA aeroplanes between then and the date when you do convert. Although you will be able to exercise such privileges on suitably non-EASA Annex II aeroplanes.

So, in your case you either convert a couple of years before your JAR-FCL PPL(A) expires and keep your IMCR / IR(R) privileges on both EASA and non-EASA aeroplanes - or, if you're not bothered about IMCR privileges on EASA aeroplanes for a couple of years, then you can wait if you like. It's your choice!

soaringhigh650, the UK IMCR is a rating which has proved entirely safe for whatever purpose the holder has decided to use it. For about 40 years.

This nonsense about it being a 'get you home after inadvertant IMC encounter' is utter rubbish... For example, FIs very often use it to acheive VMC above cloud to teach early attitude flying exercises, then drop down through the cloud for recovery. You should NOT need a full IR for that sort of activity!

The privileges and limitations of the IMCR / IR(R) are commensurate with the training and theoretical knowledge requirements; unfortunately the rating was very poorly explained to EASA at the time when they were drawing up their "Ein Volk, eine Regel!" regulations....
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Old 12th Nov 2012, 15:18
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As I've said elsewhere - I'm looking to do my PPL skills test soon, and so start to plan out what to do with my licence to learn for the next year or so, and I would like an IR(r) to feature in there, as it seems more useful than an EIR in the UK.
One thing to bear in mind is that "instrument flight instruction provided by an IRI(A) or an FI(A) holding the privilege to provide training for the IR" while you're training for the IMC rating, or any PiC time on instruments after you have the IMC rating, can be counted towards the 40 hours instrument time for an IR.

To the best of my knowledge the CAA didn't include a method of lifting the restriction on the IR(R) in its conversion report. I think it missed a trick there.
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Old 12th Nov 2012, 16:10
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To the best of my knowledge the CAA didn't include a method of lifting the restriction on the IR(R) in its conversion report. I think it missed a trick there.
I doubt whether they will expend much effort on IR(R) conversions until both the EIR and C-B IR have been passed to the comitology stage - otherwise the work could well have proven to be nugatory.
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Old 12th Nov 2012, 16:37
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unfortunately the rating was very poorly explained to EASA at the time
So have they fired the lobbyist and/or their researcher(s) and replaced them with someone better?

Sounds like something went badly wrong at the upper management levels of AOPA.

Last edited by soaringhigh650; 12th Nov 2012 at 16:37.
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Old 12th Nov 2012, 17:21
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Sounds like something went badly wrong at the upper management levels of AOPA.
AOPA didn't have a member on FCL.008, soaringhigh650, despite requests to be allowed one - which was a singular bone of contention. The UK reps on FCL.088 did not represent our national position adequately, hence the current situation.

I suggest that you do a little more research before casting further erroneous aspersions....

Last edited by BEagle; 12th Nov 2012 at 17:23.
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Old 12th Nov 2012, 17:36
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AOPA didn't have a member on FCL.008, soaringhigh650, despite requests to be allowed one - which was a singular bone of contention
You don't need two AOPA members on FCL.008. The idea is that AOPA organizes itself properly so that the UK rep talks to the EU rep.

The UK reps on FCL.088 did not represent our national position adequately, hence the current situation.
So someone needs firing in AOPA UK then.
I have nothing more to say.
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Old 12th Nov 2012, 17:58
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I have nothing more to say.
Noted.

.
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Old 12th Nov 2012, 19:38
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I doubt whether they will expend much effort on IR(R) conversions until both the EIR and C-B IR have been passed to the comitology stage - otherwise the work could well have proven to be nugatory.
Certainly much more attractive to convert after the much reduced TK requirement of the EIR/CBM-IR is established. But I can't see why an upgrade route of some sort couldn't be offered. Anyway, it seems Cliff saw it your way. The CBM-IR should offer a sensible upgrade route in due course.
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