Use this forum to flag up examples of red tape and gold plate
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By Irv Lee
It could have been voice in my head....
(I will see if it was an email rather than a voice, stand by....)

Ok, I'm back in the room....
the point is, (and you can check with Fclweb): the RF can act as an ATO in respect of the type of training it was doing before EASA came in fully (until 2018) so the new regs would have to preclude an RF. They don't. So if the pilot has a licence already, training by an ATO or an rf acting as an ATO under whatever the reg is that allows it to, (article 10a?), allows the examiner to use temp certificates.
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By nickwilcock
The policy of IN 2016/027 is only applicable
to an applicant that has completed the applicable EASA approved training course(s) at an ATO that is fully approved for such training in accordance with Commission Regulation (EU) No. 1178/2011 (as amended) – Annex VI – Part-ORA

So I don't see your point, Irv, about 'RFs being OK'.

The new policy may not be used for any initial licence issue, so about the only 'RF' case which might spring to mind is the addition of something which can be taught at an RF and included in an existing Part-FCL or JAR-FCL licence. Such as, perhaps, adding a TMG Class Rating to a Part-FCL PPL(A)?
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By Irv Lee
Yes, I know it isn't initial licences. Whilst there are minor numbers of sep->tmg, tmg->sep, and even retiring commercial pilots without SEP on their licences, I saw the new allowance as being mainly used at Single Engine level by pilots with SEP on the back of their EASA licence and wanting CAA action to put it on the front. The previous CAA action to allow examiners to sign SEP as long as it was already in Section XII (however long the expiry) was a big 'gain' but still unfortunate for those who had converted (or reprinted) and SEP had slipped onto the back of the licence