I also have a lot of sympathy for the OP who has invested a lot of time and effort to achieve the required standard, only to find the paperwork caught him out. Pleased that this was resolved successfully.
Perhaps the regulations could have been worded slightly better, but I do think they were misread. I suspect it's just a new staff member at FCL who hasn't yet got fully up to speed with their interpretation. There has been a lot of staff turnover at the Belgrano lately.
From the extract of the FCL regulations, I would interpret the requirement to be:
a) A total of at least 40 hours IFR, which can be a mix of dual and solo
b) Up to 15 hours can be credited from an IMC training but not more. The IMC training does not need to be given by an instructor with an IR (this differs from earlier proposals)
OR
Up to 30 hours dual instruction by an IRI. This can be given outside of an ATO. An IRI would themselves have an IR, and can't be an FI with IMC rating as above.
AND
c) Any solo IFR hours conducted after gaining the IMC rating
OF WHICH
d) at least 10 hours of the 40 must be at an ATO.
It looks like Adam's problem was that he was too good, and completed the entire combination of IMC training, CB-IR training with just a few solo IFR hours in between. It looks like the CAA confused (b) and (c).
The good news is that this shows it is quite feasible to achieve a CB-IR in relatively limited time and include the IMC as a stepping stone towards it.
With the CB-IR theory content now reduced to about 50% of what it used to be, with only one classroom day required and one book to read (
can be bought for £30 online), the route to achieve an EASA IR rating with worldwide privileges is now within grasp of more pilots that it used to be. Never going to be an easy task and it's demanding for sure, but more accessible than before.
PS: Mods - should this thread be in the licensing section?
UK Flight Instructor with TB20 share at Gloucester
Post PPL flight blog