Use this forum to flag up examples of red tape and gold plate
#1726605
@Bathman,
This is an interesting area. As you know I currently instruct for the issue of the IR(R)/IMC rating but have not passed CPL TK (I suspect my licence looks like that @condor17 saw yesterday). If you take a look at UK CAA Information Notice 2016/082, specifically Clause 4.3, in the context of who the CAA will authorise it states:

(d) have passed all TK examinations either for the issue of a CPL(A) or IRI(A), subject to the same time limitations stated in Part-FCL Annex I; and …


NOTE: There is a typo in this clause insofar as there are no TK examinations for the IRI(A), they mean the IR(A).

I hold an EASA IR(A) and this was gained by passing the IR(A) TK so the CAA have authorised me to conduct IMC/IR(R) training in accordance with the IN quoted above. However a pilot who has converted from an FAA IR to an EASA IR has not completed the IR(A) TK as far as I understand. However, that said it is within the gift of the CAA to authorise and so I would suggest a call to them and ask. There is no logical reason I can see not to authorise...

Interestingly, if you look at the same IN Clause 5.5 a FI w/o CPL TK can also be granted examiner authorisation for the IR(R)/IMC.

@condor17 ,
Regarding, PPL/LAPL examining I am doing this at the moment and my authorisation will permit LAPL and IR(R)/IMC but not PPL and the reason for this is in Part-FCL Subpart K; FCL.1000 (a)(1) states:

Hold an equivalent licence, rating or certificate to the ones for which they are authorised to conduct skill tests, proficiency checks or assessments of competence and the privilege to instruct for them;
(my bold)

The FE without CPL TK does not have the privilege to instruct for the PPL thus cannot examine the PPL. The next question is can the FE w/o CPL TK conduct a revalidation by proficiency check and/or renewal of a holder of an SEP rating on a PPL licence or perhaps on an ATPL…Now the FI w/o CPL TK can hold a SEP CRI and so does hold the privilege to instruct for an SEP rating. You could argue that this SEP is added to a PPL then "no" but what about if it is attached to a ATPL? The scenario being can an FE w/o CPL TK conduct a proficiency test on an ATPL who wants to renew his SEP after a lifetime flying SLF?

:whistle: :wall: :bball: :naughty: :pray: :shifty: :snooty: :think:
#1726691
IE ,
' Very interesting Mr Bond ' ! Will have to read at leisure as got to dash .
Quick and dirty 'tho . Makes sense that having passed the IR inc. IRTK , and IRI rating ; you can instruct IMC/IRR.
That's probably a rare combo of FEing for LAPL and IMC/IRR .
The last paragraph probably comes under the '' Oh 'wot a tangled web we [ CAA ] weave '' scenario .

Thanks for excellent explanation of a rare and complex area .

rgds condor .
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