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Cross-crediting of the IR part of a class or type rating proficiency check

When I revalidated my IR ME and MEP a month back or so, the (foreign) examiner also entered a new expiry date for the IR SE into my license.

Yesterday I got an e-mail for my issuing authority saying that the entry was erroneous. If I have a IR ME, AND have performed 3 departures and approaches in the last 12 months, my IR is also valid for SE and does not require a separate entry in the license. In other words, as I understand it they claim that Appendix 8 to Part-FCL implies a rolling currency requirement as long as my IR ME is valid. So my new license now contains an IR SE that expires in May, and an IR ME that expires in 2017.

Credits shall be granted only when the holder is revalidating IR privileges for single-engine and single-pilot multi-engine aeroplanes, as appropriate.

(*) Provided that within the preceding 12 months the applicant has flown at least three IFR departures and approaches on an SP class or type of aeroplane in single pilot operations, or, for multi-engine non-high performance non-complex aeroplanes, the applicant has passed section 6 of the skill test for single-pilot non-high performance non- complex aeroplanes flown solely by reference to instruments in single-pilot operation

So as I understand it, the IR SE should be revalidated in conjunction with the IR ME proficiency check provided that at the time of revalidation I have flown at least three IFR departures and approaches in SEP.

My interpretation, and apparently my French examiner’s interpretation, is that if I at the time of revalidation of the IR ME have conducted 3 IFR departures and approaches in SEP airplane, the IR SE is revalidated and entered into the license.

What I fear is obviously that if the same regulations are interpreted in different ways, at the time of a ramp check the authority may react at the absence of IR SE in my license.

How is this interpreted, what is the practice, across Europe? Are there any additional references to regulations that clarifies this?

LFPT, LFPN

Aviathor wrote:

When I revalidated my IR ME and MEP a month back or so, the (foreign) examiner also entered a new expiry date for the IR SE into my license.

IR is not only about ME or SE engine. There is also SP and MP (Single Pilot and Multi Pilot) privileges embedded with the IR/ME.

From your post, I’m not really sure if you renewed an IR/ME SP (single pilot) or an IR/ME MP (as part of an A320 type rating for instance).

Possibility number 1
You renewed an IR/ME SP and held a valid SEP class rating at the time of your IR/ME SP renewal.

In this case, appendix 8 says :
Credits shall be granted only when the holder is revalidating IR privileges for single-engine and single-pilot multi-engine aeroplanes, as appropriate (your IR/ME SP renewal).

When a proficiency check including IR is performed (your IR/ME SP renewal), and the holder has a valid: SP SE class rating (your SEP class rating)
Credit is valid towards the IR part in a proficiency check for: SE class and type rating So, it’s an IR/SE.

There is no need of 3 IFR APP / DEP in a SEP in this case.

Your licence should looks like this :

Possibility number 2
You renewed an IR/ME MP (multi pilot) (as part of a multi pilot type rating for instance) and held a valid SEP class rating at the time of your renewal.

In this case you need to have flown 3 IFR APP / DEP in a SEP; in the last 12 months to keep your IR/SE* privilege without further examination in a SEP.

*An IR/SE implies SP (single pilot).

Last Edited by Guillaume at 19 Apr 09:09

Guillaume wrote:

Possibility number 1
You renewed an IR/ME SP and held a valid SEP class rating at the time of your IR/ME SP renewal.

In this case, appendix 8 says :
Credits shall be granted only when the holder is revalidating IR privileges for single-engine and single-pilot multi-engine aeroplanes, as appropriate (your IR/ME SP renewal).

When a proficiency check including IR is performed (your IR/ME SP renewal), and the holder has a valid: SP SE class rating (your SEP class rating)
Credit is valid towards the IR part in a proficiency check for: SE class and type rating So, it’s an IR/SE.

There is no need of 3 IFR APP / DEP in a SEP in this case.

I am in that case.

Below is the table from Appendix 8. The line highlighted in green is the one that should apply to me:

I am more and more confused as to why the NAA think that the 3 DEP/APP apply to me.

So:

  1. NAA must be wrong referring to the footnote since there is no asterisk on the line highlighted in green
  2. My IR SE should have be renewed as well as my IR SP ME.

What recourse does one have wrt interpretation of EASA regulations?

LFPT, LFPN

Indeed.

Is your licence issued by the DGAC ? If that’s the case, I suggest you go to the licencing office at CDG or Athis-Mons with that appendix and show them.

Guillaume wrote:

Is your licence issued by the DGAC ?

Nope. Foreign…

LFPT, LFPN

Here are the ratings and expiration dates entered in my license at various stages:

Before IR SP ME proficiency check

  • SEP 31.10.2017
  • MEP 31.06.2016
  • IR (A) SE 31.05.2016
  • IR (A) SP ME 31.10.2016

After entries by examiner

  • SEP 31.10.2017
  • MEP 31.03.2017
  • IR (A)SE 31.05.2017
  • IR (A) SP ME 31.03.2017

The new license received from NAA

  • SEP 31.10.2017
  • MEP 31.03.2017
  • IR (A) SE 31.05.2016
  • IR (A) SP ME 31.03.2017

Changes highlighted boldface.

LFPT, LFPN

This is really strange. As written in this thread here ( http://www.euroga.org/forums/flying/5970-sep-mep-ir-revalidation?page=1 ) a couple of days ago, I did exactly the same as you, revalidating my SEP-IR with an MEP-IR checkride (one month before you but with similar expiry dates). My examiner entered the same in your license as yours did and submitted the data to our LBA. Two months have passed since then and I have heard nothing, so I assume everything is correct.

I think you should contact your authority and point out, that your examiner did the right thing in the first place!

Last Edited by what_next at 19 Apr 16:53
EDDS - Stuttgart

I spent most of the morning today on the phone with my NAA licensing office, with their aeromedical center, with the French aeromedical center, my AME… The only person I have not talked to is my examiner.

The NAA say this is the way they do it, and I just need to have flown three IFR departures and approaches in the last 12 months to maintain IR currency on SE. I wrote another e-mail this afternoon to make my case. Well see. In the mean time I still have the license containing the examiner’s entries

Last Edited by at 19 Apr 17:42
LFPT, LFPN
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