I have this from one specialist:
Having a valid ICAO IR keeps the Part-FCL IR theory credit valid, so to say, but does not overcome the need for periodic (12 monthly) proficiency checking. The proficiency check, on the condition that the non-Part-FCL IR is valid, is then dealt with as a revalidation than as a renewal.
That is a key difference because the requirement to “renew” if the IR is expired by even 1 day, which means going to an FTO for “training as required” is never correct, so long as your FAA IR remains valid. Not even after 7 years; that time limit (from the JAA IR days) seems to have gone too.
Very few peple in the EASA IR pipeline know this… Most of them ought to know it because the concessions have been in place for some years. The amendment package for FCL, presently in comitology, incorporates the concessions directly into the implementing rules so there will be no excuse for ignorance later in the year.
Examiners ought to know that they may conduct a proficiency check on a candidate without a Course Completion Certificate provided the candidate presents a valid ICAO IR. There should be a statement to that effect in the flight examiners’ manual and it is the same situation as with the CBIR route so I’m puzzled by the needless fannying around with ATO certificates and assessments. The entire essence of conducting a renewal as though it were a revalidation is to forego the need for them.
In some cases the paperwork following the IR “renewal” had to go to the CAA was because the FE said he can sign off only stuff which is still on the pilot’s license, but the EASA IR no longer was because the paperwork had in the meantime been sent to the CAA for some other reason (e.g. PPL renewal/revalidation) and the CAA removed the lapsed IR from the bit of paper.
This marks a change from JAR-FCL licences the format of which CAA had greater freedom to specify. Examiners do however have the power to renew expired ratings in the field so long as they have not lapsed by more than 3 years except when the licence has been reprinted so as to move to the expired rating to the reverse of the page (“historic ratings”).
The above should be of interest to N-reg pilots who have occassionally allowed their EASA IR to lapse – because the constant derogations have not created a need for it.
Peter wrote:
Having a valid ICAO IR keeps the Part-FCL IR theory credit valid, so to say, but does not overcome the need for periodic (12 monthly) proficiency checking. The proficiency check, on the condition that the non-Part-FCL IR is valid, is then dealt with as a revalidation than as a renewal.
Do you have a regulatory reference for that?
Oh disregard, I can see it in the other thread.
AdamFrisch wrote:
And then we wonder why the pilot numbers decimate each year…..
We don’t wonder at all, we know exactly why! The problem is that the people making the rules don’t know/don’t care about GA, or are actively working towards its demise.
What I don’t understand is why does a SEP require validation every 2nd year, but a MEP has to be done each year? Makes no sense whatsoever. Twin engine skills don’t diminish twice as fast as flying skills in general.
I am not pleased to report that the above statement by myself
That is a key difference because the requirement to “renew” if the IR is expired by even 1 day, which means going to an FTO for “training as required” is never correct, so long as your FAA IR remains valid. Not even after 7 years; that time limit (from the JAA IR days) seems to have gone too.
is disregarded by the UK CAA. Well, your old IR exams never expire but they still require a course completion certificate. The matter has been raised up to their CEO, with no effect.
Moreover, if the CCC is based on you having a valid FAA IR (as the vast majority will be, in the European context of an “ICAO IR”) the UK CAA refuses to accept the CCC anyway. They want to see certified copies of your logbooks. In my case this happened to be addressed by them having the certified copies as a part of the SRG2140 / SRG2142 process, mentioned here.
So basically they don’t trust that the CCC (signed by an FTO head of training) is worth anything. This is somewhat funny since per EASA FCL it is not required anyway 
This week UK CAA has confirmed that candidates renewing a Part-FCL IR are not required to have a course completion certificate if they hold a valid ICAO Annex 1-compliant IR on another licence.
On 6 Feb 2014 the Commission approved this derogation from the refresher training requirement made in FCL.625(c), following notification by UK on 18 March 2013, in Commission Decision 2014/69/EU. See Annex V.
The confirmation did not discuss the possibility of a candidate failing to achieve a pass in all sections of the proficiency check in two attempts. It is a requirement of Part-FCL that candidates receive further training before making further attempts. Point (b)(1) to FCL.1030 and section A point 2 of Appendix 9 to Part-FCL. All training must be done in accordance with a developed syllabus. Art 20 of the Basic EASA Regulation and in particular point 1.8 of Annex V (Essential Requirements for Aircrew). Therefore a course completion certificate will be required, notwithstanding the above Commission Decision, if the examiner requires further training.
Also the 3 years time limit on the IR renewal is seemingly gone – for UK issued IRs at least. This and this also refer.
So when renewing your EASA IR, the remaining gotcha is that for a freelance examiner to do it, the IR still has to be printed on your license. Once it comes off the license (e.g. the license had to go to the CAA for some other reason, and they issued a fresh printout without the IR) then a freelance examiner cannot sign it. This happened to me and the CAA sat on it for 9 months, so when it arrived it had only 3 months’ validity.
My license never had / will never have to go to the CAA for any reason.
