IR renewal under EASA

[Cobalt]

Under JAA, as long as the IR had not expired for 5 years or more, I just had to turn up for a proficiency check to get it renewed - which should be easy to pass if I am late for, say, a couple of days or if I have been using my FAA IR for a few years and now want to renew my JAR IR.

With the new EASA regs, "refresher training at an ATO to reach the level of proficiency needed to pass the instrument element of the skill test in accordance with Appendix 9 to this Part" is now mandatory, to be completed before the proficiency check.

Is it clear yet what this means in practice? This could mean anything from turning up at the ATO, getting the once-over by an IRI [1 extra hour flying] to a "170A mock skill test with sign off" gold-plating... [2-3 extra hours, more if the school thinks you need more training before that]

If it is anything gold plated, it might be easier and cheaper to just renew before EASA kicks in and then do the extra revalidation each year instead.

[moona]

Ballbags.....

I can see it more likely being "170A mock skill test with sign off" 2-3 hours etc....

[BillieBob]

The requirements for refresher training before renewal of a rating are contained in AMC No 1 to FCL.625(c). The AMCs were due to be published by now but, unsurprisingly, EASA have missed yet another deadline and we are now unlikely to see them before the New Year. However, it is likely that the final version will not be much changed from the that submitted to the EC as part of the EASA Opinion.

AMC No 1 to FCL.625(c)
Renewal of instrument rating – refresher training
1. Paragraph (b)(1) of FCL.740 determines that if the instrument rating has
lapsed, the applicant shall go through refresher training at an approved
training organisation, to reach the level of proficiency needed to pass the
instrument element of the skill test prescribed in Appendix 9 to Part-FCL. The
amount of refresher training needed should be determined on a case by case
basis by the approved training organisation, taking into account the following
factors:
1.1 the experience of the applicant. To determine this, the training
organisation should evaluate the pilot’s log book, and, if necessary,
conduct a test in an FSTD.
1.2 the amount of time lapsed since the expiry of the validity period of the
rating. The amount of training needed to reach the desired level of
proficiency should increase with the time lapsed. In some cases, after
evaluating the pilot, and when the time lapsed is very limited (less than 3
months), the training organisation may even determine that no further
refresher training is necessary. The following may be taken as guidance
when determining the needs of the applicant:
(a) Expiry for a period shorter than 3 months: no supplementary
requirements.
(b) Expiry for longer than 3 months but shorter than 1 year: a
minimum of 1 training session.
(c) Expiry for longer than 1 year but shorter than 7 years: a minimum
of 3 training sessions.
(d) Expiry for longer than 7 years: the applicant should undergo the full
training course for the issue of the IR.

2. Once the training organisation has determined the needs of the applicant,
it should develop an individual training programme,

which should be based
on the initial training for the issue of instrument ratings and focus on the

aspects where the applicant has shown the greatest needs.

3. After successful completion of the training, the training organisation should
give a certificate to the applicant, to be submitted to the authority when
applying for the renewal.

[EK4457]

Interesting. Is this going to be applicable straight away or will there be a 'valid from' date?

[turbine100]

I know some people that renew their IR outside of FTO's. They rent a twin and the examiner. Does this mean everyone has to go to a FTO now?

[BillieBob]

The asessment of required refresher training prior to the renewal, as opposed to a revalidation, of an instrument rating will have to be done through an ATO, as detailed in the AMC. If it is determined that refresher training is required then that too will have to be done at an ATO, which must issue a completion certificate. However, the proficiency check may still be arranged privately by the candidate with a suitably qualified FE.

The other point to note is that there is no definition of a 'training session' and it does not say that it must be a flight training session. I expect that this is yet another oversight by EASA which may or may not be corrected in the final version.

[Cobalt]

Great. So again EASA increases cost with no benefit.

• over by a day - cost +50% - +100% [sim assessment + paperwork at ATO]
• over by 3 months - ditto of you are current [e.g. FAA licence], or additional cost due to training at ATO [instead of however you choose to do it, e.g., in your own aircraft].
• 7 years - you might as well never have bothered doing it.

And of course you are at the mercy of the ATO, which has the opportunity to milk you because your NDB needlework isn't quite up to standard...

This EASA lark is great if you are an ATO, less so if you are a pilot.

[lasseb]

Under JAA, as long as the IR had not expired for 5 years or more, I just had to turn up for a proficiency check to get it renewed

Where have you been able to do this?
Under current JAR rules, if you IR is exprired (i.e. > 1 year without PFC), you need to go to an FTO and have them make up a "special" program that must be approved by the CAA.
In reality the CAA approval is no problem and most FTO's has a standard program for this; and - depending on how rusty you are - you'll get the IR renewed after 2-3 hours of flying.

[BillieBob]

The UK has never implemented the requirement for refresher training prior to renewal of the instrument rating and the situation is as Cobalt describes it. In practice, however, most candidates seeking renewal of a long expired rating will choose to undertake some refresher training to get themselves back up to speed.

[porridge]

Situation if someone holds a valid ICAO IR

Does anyone know if a person holds a valid ICAO IR, say for instance they have been working overseas, but their EASA IR has not been current if they still have to do the re-currency training?
At present if one holds a valid IR on another license, it doesn't matter if the JAA IR lapsed even for more than 5 years, one can still just do the renewal test. Will this change?

[turbine100]

I think the issue BilleBob is that this becomes binding law under EASA next year and thats the law of the land to follow. So people should be perhaps be questioning / challenging this. I dont want to be going to a FTO spending a lot of cash, doing hours of training to gain a certificate to take my renewal if flying abroad on another license and letting the IR lapse for a short period due to my work commitments or those who are instructors waiting to get the cash together or similar.

Although I may not be correct, JAA was the stop gap and perhaps things could have had a bit interpretation with member states accepting them and thats how they got around implementation..

[BillieBob]

Perhaps my initial comments stung EASA into action as the AMCs and GM have now been published here As expected, there is little change from the previous version.

Turbine-100 - My post was in direct response to Lasseb and I neither made nor make any comment on the rights or wrongs of the requirement. You are, of course, entitled to propose to the competent authority an alternative means of compliance but the basic requirement to undergo training at an ATO is in the Aircrew Regulation, which has already been adopted into EU law.

porridge - The provisions of JAR-FCL 1.245(e) in respect of the extension of the validity period of ratings have not been carried forward to the Aircrew Regulation.

[lasseb]

Billiebob -> thanks for the clarification regarding the UK exemption.
I think the JAR (and EASA to come) rule is actually implemented in most JAR countries - but no UK.

Here in the northern countries the rule actually works like a charm. And if you actually have flown a lot of IR (like on an FAA IR). The IR-refreshment course will reflect this, and in most cases you get by with just the 1.x hour PFC.

The really good think about this is that you can customize a course thereby reflection the experience (and lack of) that the student has. What you have now in the UK probably requires an examinor to fly the PFC, and if you fail, you need to do it again etc.
In other JAR contries the first part of the course can be flown with an IR instructor (=cheaper), and the examinor is saved for just the PFC itself.

[turbine100]

BillieBob - Thanks for the info, I didnt know it was already in EU law. The only point really I had was that I wouldn't want to see the FTO's playing on it and charging people for extra training when sometimes they dont need it with costs being an issue to keep current for reasons I mentioned earlier and to extend the ATPL's exams etc etc. Thanks again

[M-ONGO]

Is the 7 year rule still applicable under EASA? i.e. flying on an FAA IR, JAA one can presently lapse for 7 years without losing ATPL credits. Does that still apply?

[BigGrecian]

s the 7 year rule still applicable under EASA? i.e. flying on an FAA IR, JAA one can presently lapse for 7 years without losing ATPL credits. Does that still apply?

Show that me in a regulation.

I've never known that to be true and the CAA said they'd not heard of it when I asked them.

[BillieBob]

I assume that you are referring to JAR-FCL 1.495(b), that states:
"Provided that an IR(A) is obtained in accordance with (a) above, a pass in the ATPL(A) theoretical knowledge examination will remain valid for a period of 7 years from the last validity date of the IR(A) entered in the CPL(A) for the issuance of an ATPL(A)." If this is the case then the same provision has been carried forward to Part-FCL in FCL.625 IR(d).

I have to say that it does not surprise me that the CAA have not heard of this - their knowledge of the current requirements, let alone the forthcoming regulations, seems, at best, limited.

[M-ONGO]

That's the one BB, many thanks. BG - i had it in an email from FCL themselves about two years ago. Just don't want to loose the exams because I'm flying on a foreign ICAO licence and don't have my type on the JAA one.

[BigGrecian]

That regulation is not referring to an ICAO IR.

It specifically states that all licences/ratings referred to in JAR FCL 1 or LASORS are considered to be JAR unless stated otherwise.

JAR–FCL 1.005(a)(2) Whenever licences, ratings, authorisations, approvals or certificates are mentioned in JAR–FCL, these are meant to be licences, ratings, authorisations, approvals or certificates issued in accordance with JAR–FCL. In all other cases these documents are specified as e.g. ICAO or national licences.

Exactly the same on page 3 of LASORS: LASORS 2010 | Publications | CAA Section A

Since the reference isn't to ICAO it therefore applies to a JAR rating only.

And that's what the CAA said when asked - they don't anything about holding an ICAO IR keeping the ATPL theory credit valid - and won't recognise an ICAO IR for the purposes of keeping the ATPL theory valid.

As far as I am aware this isn't due to change.

Sorry to burst the bubble.

M-ongo - be careful your letter doesn't mean anything. I know someone who had a similar situation - he did all 14 exams again because when he applied for the ATPL they rejected it and said his letter was worthless. He ended up using Bristol for them. (This was the UK CAA - don't know about other authorities.)

[BillieBob]

Big Grecian - RTFQ

i.e. flying on an FAA IR, JAA one can presently lapse for 7 years without losing ATPL credits.

M-ONGO - You are correct, under both JAA and EASA, ATP theory credits remain valid for 7 years after expiry of the IR.