EASA AND THE IMCR - NEWS [Archive]

Genghis the Engineer

21st Sep 2011, 15:08

So EIR(SE): not below 1000ft above highest point within 1000nm, annual revalidation, minimum 100hrs ground training, 15+hrs training of which 10+ airborne, limited to day use only.

Obvious flaws: restriction to day use (what's wrong with night IFR/IMC if the holder also has an NQ?), lack of approaches - I see no argument in favour of permitting anybody to fly above 8/8 cloud if they can't fly an approach. Lots of the theoretical knowledge is in the CPL, and to some extent the PPL - why all the repetition, and why no consessions (as there is in UK for the IMCR) for CPL holders against TK? SIDS are in the TK but not the flying syllabus. Circling approach not in skill test.

Obvious advantages: Modular route to full IR, no restriction against flying in airways.

Obvious questions: Why can a TRI with IR teach for EIR but not a CRI with IR? What the heck is an "emergency IFR approach" - either it's an instrument approach, or it isn't. Why is the bridge from UK IMCR so hard to state explicitly.

Interesting quote:
Some of the group experts were in favour of developing a similar rating like the UK national IMC rating which allows the pilot only to fly in IMC in classes D, E, F and G airspace. But the groups could not agree on this issue of an additional rating to fly in IMC with lesser requirements than the current requirements for the Instrument Rating. Due to the time constraints for the development of the Implementing Rules for licensing, it was agreed to start a separate rulemaking task.

estimates are very rough and do not give a representative picture for the whole of Europe. However, they do give an indication that stakeholders’ concerns are well justified and explain the attractiveness of FAA licences in Europe. Making instrument ratings more accessible could thus significantly increase the number of Europeans with such a rating

Personal observations: (1) More on approaches is essential, even for an En-Route IFR qualification, (2) The massive history of the UK IMCR is apparently regarded as irrelevant, that is quite surreal, being able to go into airways with the EIR will be a benefit, a considerable benefit to a few individuals (3) The restricted IR for IMCR holders might be quite nice if it really happens.

G

bookworm

21st Sep 2011, 16:28

(2) The massive history of the UK IMCR is apparently regarded as irrelevant,

Far from it. I think without the "massive history of the UK IMCR" FCL.008 would never have got off the ground. The relatively safe operation of UK pilots under the IMCR regime is the safety justification by which the competence-based IR is justified.

What the heck is an "emergency IFR approach" - either it's an instrument approach, or it isn't.

In the same way that you would expect a PPL to get a few hours of instrument flying and to perform an "emergency 180 degree turn on instruments", without giving them privileges to fly intentionally in cloud, it doesn't seem unreasonable to give EIR holders some "emergency" instrument approach practice without giving them privileges to fly instrument approaches intentionally.

being able to go into airways with the EIR will be a benefit, a considerable benefit to a few individuals

That's a very UK-centric view of airspace. Only the UK has this peculiar reverence for "airways", in which the easiest instrument flying takes place (hold a level, fly a heading). Everywhere else, you just use the airspace that's there. The hard part of instrument flying is the approach, which is why the EIR holder has to go to some lengths to ensure that they don't end up flying an approach in IMC.

I've never really understood the concern expressed here. If I have an IR, I need my destination to be above minima, otherwise I divert to my alternate. If my alternate is also below minima, I'm left in some difficulty, and may have to use my "emergency skills" to get down safely. If I have a PPL, I need my destination to be VMC, otherwise I divert to my alternate. If my alternate is also below VMC, I'm left in some difficulty, and may have to use my "emergency skills" to get down safely. If I have an EIR, I need my destination to be VMC, otherwise I divert to my alternate. If my alternate is also below VMC, I'm left in some difficulty, and may have to use my "emergency skills" to get down safely. What's the difference?

421C

21st Sep 2011, 16:41

I see no argument in favour of permitting anybody to fly above 8/8 cloud if they can't fly an approach

Well then you are missing the fact that almost all the world's plain vanilla PPLs are permitted to do exactly that. The UK is an outlier in having its "in sight of the surface" restriction.

So what is your counter-argument that opposes the successful experience of practically all the world's PPLs?

brgds
421C

Cough

21st Sep 2011, 16:45

not below 1000ft above highest point within 1000nm

Yer what? The UK is within 1000nm of the alps, so the lowest usable level is about FL170...

Please tell me they meant not below 1000ft above the highest point within 1000m?

Genghis the Engineer

21st Sep 2011, 17:14

Yer what? The UK is within 1000nm of the alps, so the lowest usable level is about FL170...

Please tell me they meant not below 1000ft above the highest point within 1000m?

My typing error, actually it's 1000ft above the highest point within 5nm.

421c is there actually evidence that (a) most PPLs can/do fly VFR on top, and (b) they don't have accidents whilst doing so. Apart from anything else, my experience as a researcher is that outside of the UK, US, Germany and Australia, most countries safety statistics are so poorly compiled that you can prove just about anything, or nothing. And again, I'm aware that ICAO standard permits VFR on top, but how many countries actually permit that?

Regading class A - my reference was actually to the PPL/CPL(VFR)/IMCR not permitting flight in class A. An embuggerance on occasion and if the EIR gets rid of that, it will have benefits along the way. Part of that is the ability to fly along airways, but also just to ask permission to cross them or free-fly where there is class A airspace. But equally, some people will want to file IFR along airways, and no reason they shouldn't really.

G

421C

21st Sep 2011, 17:42

is there actually evidence that (a) most PPLs can/do fly VFR on top, and (b) they don't have accidents whilst doing so. Apart from anything else, my experience as a researcher is that outside of the UK, US, Germany and Australia, most countries safety statistics are so poorly compiled that you can prove just about anything, or nothing. And again, I'm aware that ICAO standard permits VFR on top, but how many countries actually permit that?

All US PPLs can fly VFR on top, and it's perfectly normal practice in the US. I may be wrong, but as I understand it, the JAR-FCL PPL allows VFR on top, it's a UK restriction. I am not sure if any other JAA countries also implemented this restriction, I don't think many did, if any. I imagine plenty of French PPLs fly VFR on top on their long Class E airways.

Hence my point about the majority of the world's PPLs. You're the one who made the point that "I see no argument in favour of permitting" something that is a normal part of the PPL privileges outside the UK, so you show me the evidence supporting what I find an extraordinary claim. The FAA have hundreds of thousands of PPLs without IRs. They publish papers and educational material on all sorts of flight training and risk management topics. Show me one advising against VFR on top, or highlighting the risks thereof. The NTSB accident database is searchable and has a vast volume of data. Do your research thing and show me any evidence suggesting VFR on top is dangerous.

brgds
421C

IO540

21st Sep 2011, 18:39

I doubt there is any evidence that VMC above an overcast is risky in any particular way.

These days, everybody who flies for real uses a GPS 100% of the time. I know this will upset some of the usual pilot forum residents but that is the present day reality. WW1 is over, WW2 is over, the Germans were beaten, even a 747 no longer carries a navigator, it's time to move on, and navigation is not a relevant issue.

And if navigation is not an issue, why object to VMC on top?

It is permitted under ICAO VFR. Just a few countries in the world impose a "sight of surface" requirement for VFR. VMC on top is not a "permission" as such - it is the default international position.

AFAICT the reason the UK CAA objects to VMC on top is because they pretend that GPS doesn't exist, which is a completely proper position given that it is not in the PPL syllabus.

But the proper way to deal with that is to update the syllabus :)

It is probably true that the EIR will benefit only a small % of pilots, because only a few people have long distance capable aircraft, fly abroad, but do not have an IR. I am pretty familiar with this position because that is what I was 2002-2006. But to object to the EIR on that basis is a retrograde step. We should be thinking of how to improve GA capability, because the whole scene is gradually collapsing into a black hole. The EIR will improve it.

I don't have time to read the 230 page EASA proposal now in detail (flying back to the UK from Greece) but it looks like a move in the right direction. FAA IRs accepted without flight training but one has to sit ~ 5 exams (perhaps a 30% reduction off the present "90% garbage" JAA IR TK), plus the flight test with an IR examiner (which will itself mean something like 10-15hrs flying for most experienced IFR pilots, to suss out the expected flight exam procedures), plus the JAA Class 1 audiogram or a JAA Class 1 medical (no improvement on the medical front; a huge missed opportunity, sadly).

Bear in mind though that it is still only a proposal worked out by a committee behind closed doors, with just the basics leaking out over the past year or two, so nothing actually changes right now in terms of what insurance policy an FAA licensed pilot may want to secure in time for 2014, or whatever. And FCL008 does nothing for commercial pilots.

Genghis the Engineer

21st Sep 2011, 19:08

Okay, thanks to a little prodding from C421 I've done a little more homework.

"VFR on top" in FAAspeak, and I think most other countries, is an IFR clearance.

"VFR over the top", in FAA and Transport Canada speak is a VFR condition. FAR-135 permits VFR over the top in the following way:

Sec. 135.181

Performance requirements: Aircraft operated over-the-top or in IFR conditions.

(a) Except as provided in paragraphs (b) and (c) of this section, no person may--

(1) Operate a single-engine aircraft carrying passengers over-the-top; or

(2) Operate a multiengine aircraft carrying passengers over-the-top or in IFR conditions at a weight that will not allow it to climb, with the critical engine inoperative, at least 50 feet a minute when operating at the MEAs of the route to be flown or 5,000 feet MSL, whichever is higher.

(b) Notwithstanding the restrictions in paragraph (a)(2) of this section, multiengine helicopters carrying passengers offshore may conduct such operations in over-the-top or in IFR conditions at a weight that will allow the helicopter to climb at least 50 feet per minute with the critical engine inoperative when operating at the MEA of the route to be flown or 1,500 feet MSL, whichever is higher.

(c) Without regard to paragraph (a) of this section, if the latest weather reports or forecasts, or any combination of them, indicate that the weather along the planned route (including takeoff and landing) allows flight under VFR under the ceiling (if a ceiling exists) and that the weather is forecast to remain so until at least 1 hour after the estimated time of arrival at the destination, a person may operate an aircraft over-the-top.

(d) Without regard to paragraph (a) of this section, a person may operate an aircraft over-the-top under conditions allowing--

(1) For multiengine aircraft, descent or continuance of the flight under VFR if its critical engine fails; or

(2) For single-engine aircraft, descent under VFR if its engine fails.

Sec. 135.211

VFR: Over-the-top carrying passengers: Operating limitations.

Subject to any additional limitations in Sec. 135.181, no person may operate an aircraft under VFR over-the-top carrying passengers, unless--

(a) Weather reports or forecasts, or any combination of them, indicate that the weather at the intended point of termination of over-the-top flight--
-(1) Allows descent to beneath the ceiling under VFR and is forecast to remain so until at least 1 hour after the estimated time of arrival at that point; or
-(2) Allows an IFR approach and landing with flight clear of the clouds until reaching the prescribed initial approach altitude over the final approach facility, unless the approach is made with the use of radar under Sec. 91.175(f) of this chapter; or

(b) It is operated under conditions allowing--
-(1) For multiengine aircraft, descent or continuation of the flight under VFR if its critical engine fails; or
-(2) For single-engine aircraft, descent under VFR if its engine fails.

G

AN2 Driver

21st Sep 2011, 19:19

Class 1 medical for IR, even if attached to a PPL?

That would kill it for a lot of people. So far to my knowledge you needed an audiogram and some additional requirements for the Class 2, but to get a class 1 medical would be the show stopper and also again make the IR impossible to achieve for a lot of folks.

Otherwise, I have to say I like what I am seeing. A lot actually. The EIR as a first step, fully acknowledged for the "full" IR if taken later, the IR theoretical stuff reduced to some new level e.t.c. sounds almost too good to be true.

VMC-on-top

21st Sep 2011, 19:29

Otherwise, I have to say I like what I am seeing. A lot actually. The EIR as a first step, fully acknowledged for the "full" IR if taken later, the IR theoretical stuff reduced to some new level e.t.c. sounds almost too good to be true.

As an IMCR holder myself, I'd tend to agree. I've held off for the last year doing an IR (no desperate need to do it at the moment), I thought i'd hold off going down the FAA route and see what happens in EASA land - and I also like the idea of the modular route.

Not read the whole report yet but assume that currency / retesting of the EASA IR will be similar to JAR, rather than the (effective) self-renewing FAA route?

Edit : although I do agree that concept of the EIR is quite ridiculous - it effectively gives the EIR holder the same privileges as the PPL holder throughout most of the world! - I would imagine most EIR holders (assume former IMCR holders) will simply descend through IMC to do a VFR approach? Surely the muppets at EASA realise that!?

bookworm

21st Sep 2011, 19:45

FAR-135 permits VFR over the top in the following way:

Part 135 is only for "commuter or on-demand [air taxi] operations".

bookworm

21st Sep 2011, 19:59

although I do agree that concept of the EIR is quite ridiculous - it effectively gives the EIR holder the same privileges as the PPL holder throughout most of the world! - I would imagine most EIR holders (assume former IMCR holders) will simply descend through IMC to do a VFR approach? Surely the muppets at EASA realise that!?

The proposed EIR allows flight under IFR in IMC enroute (including the climb and descent above MSA). That's vastly more useful than the ability to fly VFR in VMC on top of a cloud layer, which is the privilege most PPLs have. The whole idea of the EIR is that the holder "will simply descend through IMC to do a VFR approach". So yes, the "muppets at EASA" do realise that!

As for "assume former IMCR holders", I would think an IMCR -> EIR conversion would be almost pointless. The IMCR holder is likely, according to the Introduction, is likely to get an IR limited to reflect the privileges of the current IMC rating (which include approaches). A sensible conversion route for such a pilot would likely be to the full (competence-based) IR, which would for many IMC rating holders require 10 hours of training in an ATO, plus the ground exams, assuming there is no simpler route proposed.

bookworm

21st Sep 2011, 20:05

Class 1 medical for IR, even if attached to a PPL?

That would kill it for a lot of people. So far to my knowledge you needed an audiogram and some additional requirements for the Class 2, but to get a class 1 medical would be the show stopper and also again make the IR impossible to achieve for a lot of folks.

There's no requirement for a Class 1 being proposed. IO-540 is simply pointing out that the existing audiogram requirement for an IR is not being relaxed.

dublinpilot

21st Sep 2011, 20:18

Edit : although I do agree that concept of the EIR is quite ridiculous - it effectively gives the EIR holder the same privileges as the PPL holder throughout most of the world! - I would imagine most EIR holders (assume former IMCR holders) will simply descend through IMC to do a VFR approach? Surely the muppets at EASA realise that!?

I'm not a supporter of the EIR, as I think it's dangerous. However in fairness to it, it does offer far greater privileges than a non-UK PPL holder; it allows flight in IMC under IFR above a certain MSA. No basic PPL holder has those privileges.

What's the cost/hassle factor in renewing a JAA IR annually?
It it required to be renewed annually under ICAO, or is that a Euro invention?

englishal

21st Sep 2011, 20:56

Genghis the Engineer

21st Sep 2011, 21:20

I think an EIR would be pretty useful..... UK airspace would "disappear" and so one could file from sunny Edinburgh to sunny L2k for lunch, and the flight wouldn't have to dogleg around airspace, or risk busting airspace. If it is cloudy en route, no problem, you are not banned from Class A airspace, you just keep going.

So you won't be able to fly the ILS at L2k...well, you can fly it down to 1000' cloud base I would imagine or find a hole, so it'd have to be pretty miserable and would suit most PPL's very well. It is a shame it doesn't include a precision approach capability though as I am sure many holes will be appearing in clouds which previously didn't have a hole ;)

1000ft above the nearest obstacle within 5nm, a lot of places, will be about 1200-1400 DH and sometimes 2000ft+ aal, compared to 600ft DH for an NPA with an IMC or 500ft on a PA, so it is rather more restrictive. Yet another argument to make sure you have an IMCR by Easter !

But apart from class A of-course, you can do that flight pretty much in a straight line if you don't mind doing a lot of radio calls to get through controlled airspace. I did Lydd to Prague pretty much in a straight line a week or so ago, with the only significant dogleg (out of Enstone) being around London. That was all through airspace, VFR with an IMCR (so VFR OTT), and that wouldn't be a lot different with an EIR - you still need to talk your way through everything. Okay, yes, in airways it will be easier because once in airways with an accepted flight plan you have no ongoing need to ask for permission - but it won't affect the route much.

To be honest, broadly I do favour the proposed EIR, but I'd still like to see approaches covered and permitted without having to declare an emergency - albeit certainly with a conservative DH like the IMCR. 600ft DH has worked for the IMCR with that level of training and is a lot less restrictive than MSA, which is what the EIR effectively proposes. And include a SID in the skill test, since it's clearly in the theory. That and can we use it at night please?, subject of-course to an NQ: I can't help suspect that the wording there is just unfortunate rather than deliberate.

Perhaps conservatism and privilege would be settled by allowing a 1000ft DH with the EIR - more conservative than the IMCR, but useable nonetheless.

G

Genghis the Engineer

21st Sep 2011, 21:23

Part 135 is only for "commuter or on-demand [air taxi] operations".

For private flying, is there an equivalent document that I didn't find?

G

Fuji Abound

21st Sep 2011, 22:02

It would appear to be a very good result.

I do hope that certain well known commentators will hold their peace, not, mind you that i can imagine easa will be readly diverted from the course now set.

Having worked with a few on here to support the imcr let it also be said the effort appears to have been very worth while.

Inevitably the devil may yet be in the detail.

mm_flynn

21st Sep 2011, 22:13

For private flying, is there an equivalent document that I didn't find?

G

Part 91 is for non-commercial ops.

Part 135 and 121 are the rules for what you would call AOC operators.

I don't believe Europe offers an IFR clearance comparable to the FAA 'VFR-On Top' clearance. The description of this clearance sometimes confuses people. For the avoidance of doubt, the FAA allows PPLs to fly VFR over an undercast with no more formality than flying on a clear day.

flybymike

22nd Sep 2011, 00:12

compared to 600ft DH for an NPA with an IMC or 500ft on a PA,
AIUI these are recommended minima. Full IR minima may be used with an IMCR if wished, subject to 1800m vis for take off and landing.

IO540

22nd Sep 2011, 05:09

although I do agree that concept of the EIR is quite ridiculous - it effectively gives the EIR holder the same privileges as the PPL holder throughout most of the world! -

You get mega new privileges: access to all airspace, and ability to fly in IMC.

I used to do long VFR trips across Europe, on a PPL/IMC, but one has to ask for each CAS transit. On the EIR, you just file a Z flight plan (VFR-IFR-VFR) and during the IFR portion you are treated as an IFR enroute flight, and you just go, with CAS being irrelevant.

What's the cost/hassle factor in renewing a JAA IR annually?

That's a very good question. My totally informal research around where I fly from is about £150. This is "not a lot" but is another £150 of pointless cost inflation. It is possible for a "mate" who can do it to do it for nothing, of course. N-reg owners will need the DfT permission for the test in their plane if they are paying the instructor and they are doing it in UK airspace; this permission is currently free.

(I cannot get the pprune quotation feature to work unless I access the internet via a VPN terminating in the UK - quite odd :) ).

Genghis the Engineer

22nd Sep 2011, 06:27

Flybymike - negative, those are hard limits shown in the ANO, as is the 1800m viz. But yes, most of the other stuff in the IMC syllabus about higher limits is only advisory.

G

huv

22nd Sep 2011, 08:18

VFR on top is permitted according to national Danish legislation on the following condititions:

VMC forecasted on the planned route/altitude; destination forecast with min vis 5 km and no cloud layer denser than 4/8 (ETA +/÷ 1 hr). Fuel reserve requirements similar to IFR: alternate + 45 min.
This minimises the risk of ending up flying in IMC.

The pilot is required to have logged at least 150 hrs, and the aircraft has to be IFR equipped.
This ensures some probability of succes should IMC be encountered accidentally. But there is no specific training or skill requirements for the pilot to exercise the right to fly VFR on top.

bookworm

22nd Sep 2011, 08:51

Flybymike - negative, those are hard limits shown in the ANO, as is the 1800m viz. But yes, most of the other stuff in the IMC syllabus about higher limits is only advisory.

The 1800 m vis is a "hard limit" in the ANO. The 600 ft MDH and 500 ft DH are recommended by the AIP.

bookworm

22nd Sep 2011, 09:00

For private flying, is there an equivalent document that I didn't find?

There are no corresponding restrictions in Part 91 about flying VFR over the top, if that's what you mean. For Part 91, VFR is VFR I think.

Genghis the Engineer

22nd Sep 2011, 09:24

There are no corresponding restrictions in Part 91 about flying VFR over the top, if that's what you mean. For Part 91, VFR is VFR I think.
Thanks, consider us educated!

For anybody who wants to double check, Electronic Code of Federal Regulations: (http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=3efaad1b0a259d4e48f1150a34d1aa77&rgn=div5&view=text&node=14:2.0.1.3.10&idno=14#14:2.0.1.3.10.2.5.35) but Bookwork seems to be correct.

G

BillieBob

22nd Sep 2011, 10:41

So you won't be able to fly the ILS at L2k...well, you can fly it down to 1000' cloud base I would imagineHow will you be able to do that when you may not accept an IFR clearance to fly an arrival or approach procedure?

IO540

22nd Sep 2011, 11:37

The exact way the EIR would work in these situations remains unclear at the moment.

In the simplest scenario, the pilot will be unable to fly an IAP even under total VMC.

But one can also look at it from the Z flight plan POV where the VFR to IFR to VFR transitions are specified (as waypoints) in the flight plan, and during the VFR sections the behaviour expected of the pilot is very clear - VFR. I suspect this is the intended way of working it.

Justiciar

22nd Sep 2011, 14:27

This seems like the curate's egg: good in parts.

I am not clear why they have so explicity excluded instrument approaches from the EIR. They recognise that there will be situations when such an approach is necessary, hence the emergency training requirement. Why not go the rest of the way and allow add on training to permit legal instrument approaches?

Arguably though this is not as significant as it appears as many wanting to use the EIR will not being going into an airfield which has an instrument approach, so the end phase of the flight becomes all the more critical in the planning, from a Wx perspective.

These proposals seem to indicate no grandfathering of IMCR privileges to the EIR but strangely up to 30 hous instrument time (from the IMCR training or otherwise) will count towards the Competency based IR! Interesting that classroom time may be combined with the practical flight training. I am not clear what that means. Does a briefing count?

Contacttower

22nd Sep 2011, 14:36

I haven't had a chance to read the entire thing in detail but from the brief skim read of it I can't see anywhere an explanation how many written exams there will be and how exactly they are administered? I got the bit about 100hrs of theoretical study though and some more 'high performance' stuff being deleted from the written syllabus.

There is nothing to indicate how EASA will deliver on the promises made by the EC to the European Parliament regarding taking the UK IMCR into European legislation.

I guess someone must know at what point this will be addressed...?

I think overall the sentiment expressed in this NPA is broadly in the right direction.

bookworm

22nd Sep 2011, 14:46

I am not clear why they have so explicitly excluded instrument approaches from the EIR. They recognise that there will be situations when such an approach is necessary, hence the emergency training requirement. Why not go the rest of the way and allow add on training to permit legal instrument approaches?

As I mentioned earlier in the thread, I think there's a clear analogy with the instrument training given to PPLs. We make them do a few hours under the hood, even though there is no intention to permit instrument flight as a privilege of the basic PPL. It's for emergencies, not for regular use.

Pace

22nd Sep 2011, 15:05

Arguably though this is not as significant as it appears as many wanting to use the EIR will not being going into an airfield which has an instrument approach, so the end phase of the flight becomes all the more critical in the planning, from a Wx perspective

That is the danger that being precluded from making safe instrument approaches pilots will be making home made cloud breaks into hilly or mountainous regions to try and go VFR below.
Not a clever or safe scenario. People are People and the accident stats will go up with what EASA are suggesting which is contrary to what the safety aspect of the IMCR was all about.

Pace

Justiciar

22nd Sep 2011, 15:21

I think there's a clear analogy with the instrument training given to PPLs

Maybe they are making an analogy, but there is still no rational argument as to why. I have only skimmed the EASA document, but they have advanced no rational explanation for this and I can only assume that it is to placate the airline mob who do not want anyone flying full IFR without the full IR.

It seems to make no sense to me to allow a pilot to legally fly IFR for hundreds of miles and then for him to have to rely on limited emergency training to get down when he finds unexpected IMC at his destination. This seems a bit like training a pilot to fly but not to land!

Of course if you add approaches to the EIR you have a full IR. I suspect that EASA could not bring themselves to accept the IMCR and have ended up with something which though undoubtedly useful to many is also possibly fatally deficient in the key area of approaches.

bookworm

22nd Sep 2011, 15:39

Maybe they are making an analogy, but there is still no rational argument as to why.

Why? What's the hardest aspect of flying IFR? Is it sitting on an airway staying within 5 miles of the centreline for hours at a fixed altitude? Surely not. Rather, it's flying the approaches. So if you're going to permit pilots to have privileges before they've done the full training to fly IFR in the form of the IR, doesn't it make sense to allow them to do the easy part (enroute) but not the hard part (approaches)?

Once again, I just don't understand why you'd pick on the EIR as "possibly fatally deficient". A PPL without any instrument qualification can find "unexpected IMC" at the destination, and an instrument rated pilot can find conditions below Cat I minima. They survive by going to their alternate where conditions are better.

Pace

22nd Sep 2011, 15:39

Of course if you add approaches to the EIR you have a full IR. I suspect that EASA could not bring themselves to accept the IMCR and have ended up with something which though undoubtedly useful to many is also possibly fatally deficient in the key area of approaches.

Justiclar

You have hit it right on the nail. EASA are not motivated by their mandate as a safety organisation but have their own mandate of regulating, protectionism and control.
They will only budge from that if up against a brick wall.
What they are offering is fatally flawed and I dont use the word lightly!

Pace

bookworm

22nd Sep 2011, 15:44

You have hit it right on the nail. EASA are not motivated by their mandate as a safety organisation but have their own mandate of regulating, protectionism and control.

Right sentiment, wrong target. EASA has been told by the European Commission that they have to do things the ICAO way. The ICAO way is to require 40 hours of instrument time before you get an IR. So do the FAA for that matter.

Pace

22nd Sep 2011, 16:10

Bookworm

But allowing a pilot to fly on top is instrument flying. The tops can an do rise I can well remember getting into such a situation many moons back in a single Saratoga. The clouds rose and before I knew it I was not just IMC but icing up.
It was a front moving west to east and I was flying north to south.
I ended up just on top at 12K with the cloud in the hills below.
This on top thing is fine if the pilots are ENCOURAGED to declare and take an assisted instrument approach if their is any doubt about their descent at the other end.
The IMCR is a safety rating as proved in the stats! Some use it with anger others use it as a just incase but pilots do get into a mess of their own making and thou shall not do this is not enough.
I dont agree on EASAs safety priority in their rule making
I am one who doesnt agree with holding onto the IMCR. I have always pushed for the easely achievable PPL IR based on the FAA system.
Statistically as safe as the JAA IR and equally as good but achievable by all and a proper instrument rating.
If EASA are so safety mandated why dont they offer the same albeit with European study material instead of USA.

Pace

KeyPilot

22nd Sep 2011, 16:23

Oh dear. I had hoped to come on here and get the lowdown on the NPA without having to read the whole thing. Sadly despite reading many posts I don't know if it's a good or bad thing!

Time to stop being so lazy. Will read tonight.

One thing does strike me, though. 239 pages seems an awful lot to cover "Qualifications for flying in IMC", and especially so since the NPA does not specify in any meaningful detail the transition route from one such existing European qualification (namely the UK IMCR) to the proposed new regime!

Only in Europe?!

Justiciar

22nd Sep 2011, 16:28

do things the ICAO way

This is a bit like "Health & Safety" and "Data protection" which is wheeled out by jobsworths and bureaucrats whenever they want to justify some crass rule or rules, without actually understanding what they are talking about. EASA have not worried too much about ICAO in their plan to require EASA paperwork to fly "N" reg in the EU, which is not provided for in the Convention in that form, i.e basing it on place of establishment as opposed to nationality.

Why? What's the hardest aspect of flying IFR? Is it sitting on an airway staying within 5 miles of the centreline for hours at a fixed altitude? Surely not. Rather, it's flying the approaches. So if you're going to permit pilots to have privileges before they've done the full training to fly IFR in the form of the IR, doesn't it make sense to allow them to do the easy part (enroute) but not the hard part (approaches)?

I am sure you are right, which makes the proposal even more difficult to understand. Allowing a pilot to fly when he is trained just for the easy bits seems to me to be a recipe for disaster. To my mind a rating should be focussing on that most difficult aspect, ie getting down safely in IMC using an instrument approach. The holder of an EIR will not be able to practice his skills by doing instrument approaches (other than with a safety pilot under VFR); he will only be able to do one in a real emergency, when his currency will be almost non existent. That seems to me to be the height of stupidity.

You may say, if you want that do the IR, but that brings us back full circle to the arguments and issues why so few pilots in Europe have an IR.

The IMCR has the right balance in my view, with extensive privileges outside class A and the option of letting down safely and of practising those skill regularly. That suits the flying pattern of many pilots in the UK. With the EIR the safety of any flight will now be determined by the accuracy of the met forecast at the other end!

soaringhigh650

22nd Sep 2011, 16:41

With the EIR the safety of any flight will now be determined by the accuracy of the met forecast at the other end!

Just like any other PPL.

But the IMCR and EIR both achieve different objectives.

and the option of letting down safely and of practising those skill regularly

With the IMCR, I hear you don't have to fly any instrument approach or be checked by anyone for almost two years. Then you can legally take off, hack through cloud, and fly an approach to a 300ft cloud base?

Sounds like a death rating to me.

thing

22nd Sep 2011, 16:43

With the IMCR, I hear you don't have to fly an instrument approach for two years. Then you can legally take off, hack through cloud, and fly an approach to a 300ft cloud base.

Sounds like a death rating to me. Well if you're dumb enough to actually do that then I suppose it is. As with all 'legally defined' aspects of flying you have to exercise your wisdom. I'm a new PPL, my legal limit for vis is 5k. There's no way I'd even drive to the airfield if it was only 5k, likewise unless you want to appear in the Darwin awards you wouldn't shoot an ILS to 300 ft if you hadn't done one for two years, legal or not.

KeyPilot

22nd Sep 2011, 16:50

Reading now.

I agree with others that say the idea of allowing en route IMC flight but not intended approaches is wrong. Indeed in my view it is utterly preposterous.

The preamble to the report states that the EIR will allow PPLs "to cope with unforeseen deteriorating weather conditions". This is exactly what it will not do. The principle area of risk is for weather at destination to be below expectation; and this rating does not help with that in prohibiting IMC approaches (unlike the UK IMCR). The idea of allowing "emergency" approaches is a nonsense - in an emergency, a Commander may take any decision he sees fit in the safety of himself, his aircraft and those on board. For a rating to be useful, it must contain priviledges which may be regularly exercised and practised - otherwise (especially with IF) they will be rusty and dangerous.

I am shocked at this glaring shortcoming in a proposal from EASA. Or maybe I shoudln't be. The EIR is retrograde step, and we should ensure that EASA gets as many responses from the UK GA communty as possible pointing this out.

Back to reading.

soaringhigh650

22nd Sep 2011, 16:57

Well if you're dumb enough to actually do that then I suppose it is.

Same idea with the EIR then. Are you dumb enough to arrive at an airport when the conditions ain't VFR?

Many have complained about over-regulation from the regulators over the years.
Are some guys complaining about under-regulation this time?

flybymike

22nd Sep 2011, 17:35

I'm a new PPL, my legal limit for vis is 5k.
Only inside controlled airspace.
Otherwise 3k

thing

22nd Sep 2011, 17:44

Slip of the finger there. 3K, but I mean, what low hour PPL would take off in 3k vis?

oldspool

22nd Sep 2011, 17:49

I think the proposals are a hugely positive step and I hope that the NPA receives strong support.

Existing IR = 55 hours + a load of theory.

New Modular IR = 40 hours + reduced, targeted theory. Plus credit for previous experience (competence based). In addition, signs that IMCr privileges transfered and credited towards both E-IR and full IR.

Lots of whinging about no instrument approaches for the E-IR. If you want those privileges, do the full modular IR - its now a realistic prospect.

You do 15 hours instruction for the E-IR, excercise the privileges of the E-IR for 15 hours PIC (IFR), then you only need [potentially] 10 hours instruction at an ATO for the full IR. That's 25 hours instruction total (which is where the cost is)!!!

Even better, do your IMC now and theres a good chance that initial 15 hours for the E-IR will be reduced.

It's certainly a lot better for those who want a full IR.

Justiciar

22nd Sep 2011, 18:21

Just like any other PPL.

No. With a PPL you are not able to fly IFR in IMC with the presumption (hope?) that you destination will be VMC, but without the skill to get yourself down if it is not. Yes a PPL can get caught out but the chance must be greater with an EIR where you can legally take the decision to fly a substantial part of the route IMC.

With the IMCR, I hear you don't have to fly any instrument approach or be checked by anyone for almost two years. Then you can legally take off, hack through cloud, and fly an approach to a 300ft cloud base?

... and you can legally get into an aircraft once a year with no checkride. But most don't and most serios IMCR pilots practice their skills. They can shoot as many ILS or non precision approaches as they wish in IMC. The EIR pilot cannot do this other than in VMC/VFR, so he is unable to practice an essential skill which sits with enroute IFR flying. His chance of practising his "emergency" approach procedure will be limited to his annual revalidation.

dublinpilot

22nd Sep 2011, 18:22

Same idea with the EIR then. Are you dumb enough to arrive at an airport when the conditions ain't VFR?

How would you know? You will have sat above the cloud, or in it practicing your IMC skills, for the past three hours, fat dumb and happy, knowing that the forecast for your destination was good VFR, and blissfully unaware that the airport is now covered in fog or low cloud.

If you were flying VFR you would have seen the changes happen, but because with your EIR you were on top or in the cloud, you wouldn't have seen what was happening below.

I think there is a lot of good in these proposals. I can understand why they wouldn't want full approach priviliges in the EIR (to distinguish it from the full IR) but I agree with justiciar that the lack of any approach priviliges will feature in the statistics in the future.

In terms of drawing a distinction from the full IR they could easily have left out all IFR departure proceedures, and all IFR arrivals apart from one type. The one type that needs to be tought could be specified in the leglisation or left up to the canidate to choose. Having to learn only one type of approach shouldn't increase the time requirement too much. Once they needed more than one approach type they'd need to full IR.

This would ensure that the EIR holder always would have one way out if the forecast turned out to be wrong.

dublinpilot

22nd Sep 2011, 18:29

As I understand it the purpose of the EIR is to allow those wishing to do an IR to cut down the dual training. They can do the EIR course, and then do much IFR time by themselves as PIC and then only a few hours more for the IR course.

Is this dual time which will be replaced by PIC time really going to work like that? As I understand it the EIR will only be allowed to fly enroute IFR, and all the IR pilots here seem to be saying that that's the easy part.

So will the reduction in dual time requirement really result in a reduction in actual dual time required to pass or will it simply mean that compulsory dual time will be replaced by voluntary dual time?

bookworm

22nd Sep 2011, 19:00

Allowing a pilot to fly when he is trained just for the easy bits seems to me to be a recipe for disaster. To my mind a rating should be focussing on that most difficult aspect,

By that argument, why would any pilot ever be allowed to fly without a full instrument rating? Isn't what the IR trains you for more difficult than bimbling around VFR? But what we do, is give pilots privileges to match the activities they have been trained for.

bookworm

22nd Sep 2011, 19:12

Is this dual time which will be replaced by PIC time really going to work like that? As I understand it the EIR will only be allowed to fly enroute IFR, and all the IR pilots here seem to be saying that that's the easy part.

Well the IMC-rated pilots here seem to be saying that you can train pilots to fly both enroute and approaches in 15 hours for the IMC rating. If that's the case, why not do so, and allow the remaining hours to be a form of hour-building towards the ICAO minimum of 40 hours IF for the IR? Just as you have to build 70 hours PiC for a CPL and 1500 hours for an ATPL.

I don't have a problem with the concept of issuing a pilot with 15 hours of IF training with an IR if they can pass the skill test. But unfortunately, arguing that we should simply ignore the ICAO requirement for 40 hours is not going to fly in Cologne.

bookworm

22nd Sep 2011, 19:21

For a rating to be useful, it must contain priviledges which may be regularly exercised and practised - otherwise (especially with IF) they will be rusty and dangerous.

By the same token, would you advocate giving PPLs with no instrument qualification the privilege of flying solo into IMC so they can practise an inadvertent encounter with cloud? We do, after all, spend a few hours training them to keep it the right way up in cloud in the basic PPL syllabus.

bookworm

22nd Sep 2011, 19:32

AN2 Driver

22nd Sep 2011, 19:35

Folks,

there is plenty to gain from an EIR. Plenty. I am appalled at the shortsightedness expressed in some commentaries here, please take a moment to check what this means and try to see it also outside the UK focus only. Airspace in other countries are very different. While I myself would rather go for the full IR once it becomes this accessible (and it remains to be seen if it will), I'd take an EIR anytime and with enthusiasm as it will allow me to do most of th enroute portion of the flight legally in IFR.

THAT means a couple of things and only few of them are related to real IMC.

Any of you ever flown VFR in Italy? Bloody pain in the neck with several A airspaces all over the place, Milano, Rome. Coming from the alps one needs to descend to 2000 ft AGL in the turbulence of the heat of the area there, in the murk and dust with maybe 5 km vis whereas in FL90 there is bright sunshine. Or Rome, where you need to fly 1500 ft above WATER. Hell, I'll take the privilege to fly these things legally with an EIR ANYTIME to finally be able to route along airways and forget about all the special use airspace which make flying VFR often enough a question of a great circle index in the 150ties. Not only Italy, there are other places like this where controlled airspace is all over the place but with nice straight airways going right through them. I'd love to use those rather than constantly having to circumnavigate huge areas.

Think. This is a huge chance, especcially with the proposed modular system where you can get the EIR first, get comfortable with it and then progress to a full IR, which in any event is superior to both the IMCR and the EIR.

I think if the JAR and before the national IR had ever been this accessible to the PPL pilots, there would not really have been a need for an IMCR in the first place. For us outside the UK, there never was an IMCR. So this proposal would be a mighty breath of fresh air.

Folks, let's not spoil this by hanging onto things which will not be there anymore in any case. Rather let's use the chance to expand our privileges and, for those who can live with the EIR do this and for the others go for the full IR. I fully intend to.

I used to have a national IR but it's expired (more than 7 years) so I need to do the theoretical part this way or the other. But I will wait now until we see what happens with this proposal, which I believe is a lot easier to fulfill than the JAR doctorate IR.

Best regards
AN2 driver.

mm_flynn

22nd Sep 2011, 20:16

Pace

22nd Sep 2011, 21:40

How would you know? You will have sat above the cloud, or in it practicing your IMC skills, for the past three hours, fat dumb and happy, knowing that the forecast for your destination was good VFR, and blissfully unaware that the airport is now covered in fog or low cloud.

And with an IR you can have sat above the cloud, or in it practicing your IMC skills, for the past three hours, fat dumb and happy, knowing that the forecast for your destination was above aerodrome operating minima, blissfully unaware that the airport is now covered in fog or low cloud that takes it below Cat 1 minima. If that is such a likely occurrence, where are all the bodies?

Bookworm

And here lies the problem. The guy flying along on top will NOT be able to get accurate weather for his cloudbreak as getting actuals for his destination will not give him the cloud cover or vis for his descent 20 or 30 miles out.
Infact getting weather for his destination where they give overcast at 3000 feet and 10k plus vis could be 1000 overcast and 3000 metres in rain 30 miles out where he is descending so I ask with the EIR whats the point of getting destination weather when you cannot use that airspace in anger?
Destination weather is meaningless for your cloudbreak point!

What is the point of getting Barcelona actuals if your home made instrument approach/cloudbreak isnt at Barcelona but 30 miles away over hefty mountains?

Infact it makes a legal mockery of stating that you can only fly on top if your detination is forecast as good because your destination is not your destination as far as weather goes if you get my jist?

The only safe way is to descend on a procedure or with radar into an area with accurate weather reports and preferably down an ILS not with some half baked home made cloudbreak into an area you have no clue on what lies below weather or otherwise?

The other blatant problem is the PPL who gets his weather at destination happily climbs on top smelling the roses knowing Barcelona is Cavok when half way enroute over france his engine coughs or he has some other mechanical, electrical, or fuel problem? Oh dear the area he is over and all the airfields below are all giving 300 to 500 foot overcast with 700 to 1500 metre vis? what does the said EIR do then?

Pace

mrmum

22nd Sep 2011, 21:43

With the IMCR, I hear you don't have to fly any instrument approach or be checked by anyone for almost two years. Then you can legally take off, hack through cloud, and fly an approach to a 300ft cloud base?

Sounds like a death rating to me.
Perhaps, if you choose to act stupidly. It's actually just over two years, up to 25 months to be exact. However, that's not much different to a JAA-PPL with SEP(L) class rating, you could choose not to fly for a year and 51 weeks, then jump into your sole-owned aircraft in 3km vis. All perfectly legal, but not sensible or safe.

flybymike

22nd Sep 2011, 22:56

The other blatant problem is the PPL who gets his weather at destination happily climbs on top smelling the roses knowing Barcelona is Cavok when half way enroute over france his engine coughs or he has some other mechanical, electrical, or fuel problem? Oh dear the area he is over and all the airfields below are all giving 300 to 500 foot overcast with 700 to 1500 metre vis? what does the said EIR do then?

What would a vanilla PPL flying perfectly legally VFR on top (outside the UK) do?

Pace

23rd Sep 2011, 06:31

What would a vanilla PPL flying perfectly legally VFR on top (outside the UK) do?

DIE ??? :{

Pace

thore

23rd Sep 2011, 07:04

>>What would a vanilla PPL flying perfectly legally VFR on top (outside the UK) do?

The same others do when riding on a 'normal' IFR flight plan? Or at night or over open water?

If he has a chut, it' a perfect moment for pulling. If he doesn't, minimum airspeed, control the airplane, after coming clear look for options.

My instructor in the US told me once: in case of an emergency at night, turn on your landing lights. And if you don't like what you see, turn them off again.

Fuji Abound

23rd Sep 2011, 08:35

There would seem to be a suggestion that with an EIR the pilot can fly the IAP down to the EIR minimium so establishing VMC (hopefully).

That would make better sense.

Pace

23rd Sep 2011, 09:08

Fuji

Where is your source for that? So you are saying that a PPL with the EIR will be allowed to fly the STAR onto an instrument approach and descend to SSA on that approach?
What happens then? He breaks off and causes chaos to all the inbound RyanAirs and EasyJets flying into Alicanted, Bilbao, Malaga etc.

Say said pilot is flying the procedure into Bilbao where there is a step down approach over very high ground he descends to SSA and nothing or even worse gets partially visual with scattered broken cloud below.
Doesnt sound very safe or practical to me.

There are 67000 FAA pilots in Europe! a lot with full FAA IRs flying perfectly safely in a safe invironment from take off to touchdown.

They are using a rating which is statistically equal to the JAA IR.
EASA the so called safety body could quite easely copy the FAA IR as are the french but they wont!!! Why? matters of safety?

To expect a PPL to be good enough to climb up through cloud navigate on Top and then to be abandoned to his own devices on a home made cloudbreak with NO possibility of getting accurate weather for that cloudbreak is lunacy.

IMO this is all a complete and ridiculous NON SENSE.

Pace

Fuji Abound

23rd Sep 2011, 11:25

Pace

Having now read the document for myself it says the EIR holder should plan to be VMC by the initial approach fix. I take this to mean that there would be no reason why the pilot could not ask for radar vectors to the IAF with a descent in IMC until cloud break as long as the cloud break comes before the IAF. That would mean a controlled descent probably, but not necessarily, in a terminal control area with other traffic and with "known" weather conditions based on the TAF and METAR.

It will be interesting to consider how this might work. Take Southampton for example the IAF is overhead SAM which in turn is almost overhead the airport. Accordingly the METAR for Sothampton should be reliable in "predicting" whether a cloud break will be achieved as should the TAF in terms of forecasting an achievable cloud break.

If the pilot were flying the procedure he would be positioned on the IAF at 3,000 feet, descending to 1,800 to turn inbound on the ILS, but the plate says the procedure can be started from the hold down to 2,000 feet. Presumably the EIR holder could request vectors to the IAF with descent to 2,000 feet followed by a visual approach to RWY 20. I dont see that this would be necessarily disruptive to CAT although if the pilot did not become visual it would be interesting to conject how ATC will deal with the aircraft which is presumably not entitled to continue with the procedure at 2,000 feet and fly the missed but would be required to receive vectors and a climb away from Southampton towards the planned diversion or would require to be repositioned for another descent to the IAF.

In the case of Southampton it seems to me that really the only additional burden for ATC over and beyond handling the lower speeds of any light aircraft would be pilots pitching up requesting vectors to the IAF at the minimium altitude from which the procedure could be commenced and dealing with that traffic going "missed" when they are not VMC by the IAF or the traffic having established VMC breaking off and potentially flying their own made up visual approach - on which point it seems to be far more sensible that the EIR holder should be expected to continue with the published procedure, but to maintain VMC.

I am guessing that at the largest airports with a stream of inbound CAT on a day when conditions are on the EIR holders minimium this could cause a certain amount of quick thinking by both pilot and more especially the controller but on the whole airports of this sort are not the home of GA. I am not convinved any where else would it cause the controller or anyone else for that matter too many issues.

FWIW personally I think it would have been far more sensible that the EIR holder should be visual by the top of the G/S. This would ensure all the traffic is following the same routine, with the only difference being some traffic might break off the approach at the top of the G/S and go missed either to be put back in the hold, be vectored to the IAF for another go, or to b***er off some where else. By going missed at the top of the G/S it seems to me everyone would be following the same procedure the only difference being that while the IR holder might break off at 250 feet the EIR holder would be breaking off at 1,800 feet. In so doing the EIR holder would be provided with the same protection that much higher minimium would give and yet would fit with the needs of all the other traffic.

I think expecting pilots to make up their own descent some way away from the IAF is nuts and is really unlikely to helpful to either controller or the pilot, but we shall see what the true intention is.

I do think however that in terms of the EIR holder these are pretty substantial approach tolerances and something has gone very wrong at the planning stage if the pilot cannot establish visual beneath an undercast.

As a final thought mind you I do find hard minimium at these heights a more interesting real world concept. In my experience at least, except in the case of fog, when ever conditions are on the deck in the vast majority of cases the pilot is "really" visual by the DH (or not). By that I mean the DH is "so low" that it is rare to have anything other than visual condtions until wheels touch. However with the much higher minimium proposed with the EIR I can think of numerous approaches where the pilot is visual at say 2,000 feet but with all sorts of broken, scattered and other "cr**" below, however you want to define it. In the real world the EIR holder is now presented with an interesting scenario. He knows he is required to maintain VMC bit does he ignore the odd bit of scattered and go on through, or does he weave and dodge. From a practical point of view in poor visibility, and with gusty wind as we all know the key to a good approach is a well establsihed and controlled descent from the FAF with the aircraft correctly configured and on the speeds. The last thing the pilots wants to be doing is dodging around the various bits of scattered.

I raise the last point in particular because I do find myself wondering when reading some of the commentary whether the posts are from those who actually fly in the variety of weather conditions we see because it sometimes comes across that they believe the weather follows the rule book with a 2,000 or whatever foot base, sharply defined, and with only woderful VMC below. We can only wish.

Ah well as we all know the weather has a nastly habit of certainly not following the wishes of the bureacrats in Brussels whether it be the with respect to the financial, political or any other climate you may like to pick :)

Timothy

23rd Sep 2011, 11:34

There seems to be a point which Bookworm has made, perhaps too quietly, and has not been heard.

An EIR is an IR with higher minima.

All the same decisions have to be made by an EIR holder as an IR holder, except that he has to consider minima around, say, 1400' rather than 200'. He can follow procedures (STARs and the Initial Descent) but must be VMC at IAF. That happens nearly all the time anyway...how often do we really fly to minima?

(Why it is necessary to descend below MSA at 30nm is lost on me.)

I was originally taught the IR by the great Dai Heather Hayes. He made me do a completely blind ILS, right down to tracking the localiser on the runway after landing. That was way more than the syllabus required, but, he told me, one day I would thank him. Well, 25 years later, I wrote him that thank you letter because I had had to land completely blind at Resolute Bay in the deep Canadian Arctic, when the weather went to complete sh1t and the windscreen was covered in the very ice that all the books say cannot form at -25C.

Having the knowledge from Dai that I could land way, way below minima was what saved me and my aircraft that day.

Well, I would expect any sensible EIR and any sensible EIR instructor to do the same as Dai did for me. Just check that even if things go completely to sh1t you can still make an arrival.

But for 25 years I never needed that skill, even at hundreds of hours a year. It took the wilds of the far North of Canada, where alternates are 600nm apart, to force me into a position where I had to accept completely unexpected conditions.

It will be very rare for EIR holders, and when it happens they will survive.

The "Death Rating" wallahs are doing no good to GA at all. They should be ashamed that they trying to kill off the best thing to happen to GA for a generation.

Pace

23rd Sep 2011, 11:45

Fuji

There was another major collapse on the stock markets yesterday main concerns being the USA and the imminent demise of Europe.
Why is Europe and the Euro in such a bad state because for a successful Europe the only way it would have worked is as a copycat of the USA! Ie a united states with one currency, a central government and tax raising abilities.
Anything half baked aint going to work.
The same with this fangled EIR.
The only safe way is for the aircraft to fly IFR takeoff to touchdown. real world I agree with you the weather doesnt follow EASA DIRECTIVES.
I would advice anyone in such a predicament to use their Captaincy legal overide on grounds of safety, inform ATC that you will stick with the ILS thank you and let our Safety body (EASA) fight you in the courts.
A complete and utter NON SENSE and I split the word on purpose.

Pace

JOE-FBS

23rd Sep 2011, 12:04

Early in this thread someone said, and I cannot see it corrected, that a UK IMCR holder can leagally fly an ILS down to 300'. Surely (and I only had to learn this a few months ago) the height minima for a UK IMCR pilot are 500' for precision approach and 600' for non-precision. Usually when I do the MDH or DH calculations for me as an IMCR pilot, the result is rather higher than that anyway.

I love having an IMCR and use its privilieges on most flights but it's probably best not to frighten foreigners and regulators by exagerating what it allows.

flybymike

23rd Sep 2011, 12:28

It was me who said that the 600 feet and 500 feet minima are recommendations only. The 1800 metres vis is statutory, otherwise IR minima apply. Bookworm did in fact confirm this later in the thread.

mm_flynn

23rd Sep 2011, 12:32

Pace (and others),

I think you are making an unproductive issue of the EIR. The EIR is clearly not relevant to IMCr holders or to third country IR holders. It has the same amount of flight training as the IMCr and more knowledge requirement - so characterising it as a 'death rating' just feeds ammunition to the people opposed to the IMCr concept (I know the detail is in the level of approach training - but even the pro IMCr argument is mixed between the 'get out of jail' and 'plan to fly IMC within slightly higher limits' camps).

The EIR includes training in approaches for emergencies, so it is not like having a VFR PPL on top of a layer with no way back through it. It is an incremental step to address the perception that a full IR is too hard. I suspect with the competency based approach to the IR, most people who get an EIR will then go on to get a full IR within a year or so. Allowing people to incrementally move through the IR process is a fantastic thing.

The complaints about the EIR are highlighting the downside of some low probability events while ignoring the upside for the vast majority of circumstances.

I don't fly as much as others, but I can't think of a case EVER where I set out expecting a 2000+ cloud base and then was faced with sub 1400 feet over such a wide geographic and temporal area that I could not have held or diverted to any number of VFR destinations.

widespread low clouds/fog (as compared to local weather) is virtually always well forecast.

BillieBob

23rd Sep 2011, 12:46

There would seem to be a suggestion that with an EIR the pilot can fly the IAP down to the EIR minimium so establishing VMC (hopefully).He can follow procedures (STARs and the Initial Descent) but must be VMC at IAF.This is not the case. The holder of an EIR will not be able to accept an IFR clearance to fly any departure, arrival or approach procedure (see GM1 FCL-825).

dublinpilot

23rd Sep 2011, 13:07

They should be ashamed that they trying to kill off the best thing to happen to GA for a generation.

Timothy,

I don't think anyone is arguing to kill it. Our concerns seem to be that about the lack of approches included in the EIR. Most seem to be concerned for the safety of someone who is given the tools to get themselves into a dangerous situation, but no tool to help them get back out legally and safely.

My comments will be that an EIR should include one type of approach privlidges. I won't be arguing against the rating itself. I might even do it in the future. It would be tempting.

neilr

23rd Sep 2011, 13:08

I am confused .... how does a E-IR pilot safely descend to VMC perhaps outside of controlled airspace, or even in controlled airpsace for that matter and quite probably without the aid of radar vectoring

VMC could well be below MSA

It is never advisable to descend below MSA unless on an approach or in the hold ... in other words in a protected zone

He could fly to the IAF, and descend in the hold - however this requires a resonable level of skill that many IR pilots in their 50 odd hours training struggle with

421C

23rd Sep 2011, 13:10

The same with this fangled EIR.
The only safe way is for the aircraft to fly IFR takeoff to touchdown. real world I agree with you the weather doesnt follow EASA DIRECTIVES.
........A complete and utter NON SENSE and I split the word on purpose.

Pace,
You are not exactly plagued by self-doubt in your opinions!
So tell me, what do you think people should do who are IFR-capable but based at VFR airports? This is very prevalent in the GA community, eg. around London and airports such as Blackbushe, Denham, White Waltham - frankly over much of the UK where the costs of IFR airports are high? Is there death and destruction as a result of people using, in effect, EIR privileges? Are their vast numbers of diversions to Farnborough or Northolt or even Heathrow? Should they be rebasing themselves at Farnborough at vast cost to avoid a VFR arrival phase on an IFR flight? Of course not, it would be NON SENSE, to use your terminology. So where exactly is the problem?

If the real world weather doesn't follow EASA directives, what is anyone with a plain PPL meant to do - since they can never guarantee VMC? Or with an IR but only Cat 1 capability?

The problem here I think is that people are arguing from "personal conviction on first principles" and ignoring the practical experience of pilots, uncertain weather and sensible decision-making. Let me give you an example. Imagine a universe in which there was no GA IFR but only GA VFR and airliners with zero-zero Cat IIIC capability. Someone invents a GA airplane like the ones we have today. What would you be writing:
"the IR is a DEATH rating because of the 200' limit. No-one can predict the weather. Fog can easily cover a region unexpectedly, putting all the regional airports below minima. It is a recipe for death and disaster blah blah blah".....I hope the analogy is clear.

I would advice anyone in such a predicament to use their Captaincy legal overide on grounds of safety, inform ATC that you will stick with the ILS thank you and let our Safety body (EASA) fight you in the courts.

Of course that is what anyone should do. I imagine that if an EIR holder flies to a destination forcasting suitable VMC but is surprised by unexpected IMC and no reasonable alternative is available, a successful instrument approach would be an outcome warmly commended by EASA. Where on earth did you get the NON SENSE view that EASA would rather someone crash and burn than fly an IAP in a genuine emergency of unforecast weather?

421C

23rd Sep 2011, 13:24

I am confused .... how does a E-IR pilot safely descend to VMC perhaps outside of controlled airspace, or even in controlled airpsace for that matter and quite probably without the aid of radar vectoring

Neil
He does it in exactly the same way an existing IR or IMCr holder arrives today at a VFR-only airport. For that matter, during the first 20 years or so of the IMCR, before the UK started using the ICAO airspace classification system in the 90s, there were many of the present IFR Class D airports "notified under Schedule 8" in which IMCr holders could not fly IFR. In effect, the IMCr was an EIR in those days, in many circumstances where a diversion would have been an incredible hassle.

Let's be clear on one thing. There is no "mystery" as to how a flight which is IFR in IMC enroute (in airways or non-) establishes VFR for the approach and landing. It happens all day every day at VFR airports with IFR-capable GA traffic.

brgds
421C

neilr

23rd Sep 2011, 13:37

Doh !! .... thanks 421C - a fair point

Pace

23rd Sep 2011, 13:50

421C

Firstly If it is the case that the EIR will allow an aircraft to fly a STAR and part of the approach in CAS to safely become visual then I dont have a problem with that.
I have thousands of hours hard IFR in piston twins all over Europe. One was going into a VFR airfield very near Barcelona. Barcelona were giving CAVOK with sunloungers on the apron.
Inland from the coast I was on top of solid cloud and attempted to descend to get visual for the little VFR airfield with high ground all around.
Not breaking out and half scaring myself I climbed and asked for IFR to land at Barcelona.
Getting your weather at destination can be meaningless unless you are landing at that airport. 300 overcast and the correct RVR and you are pretty sure thats what you will get. If not you miss and fly a missed app procedure for another go or divert.
If it is true that the EIR pilot can follow a set arrival like a STAR and fly an instrument approach in IMC albeit to much higher minima then I am not complaining but that is not how I interpreted what was to be allowed.
Maybe someone can clarify?
If it is the case that the pilot will have to cloud break without accurate weather 20 plus miles out then that is dangerous. Not so much in the low lying south UK But dangerous in many parts of Europe.
Yes more experienced pilots like yourself do fly cloudbreaks into places like Fairoaks, Elstree etc. Sometimes to cloudbases we would not admit.
But that is a bit different to doing the same at somewhere like Bilbao without a lot of experience.
But the EIR doesnt apply to you or I with bags of experience but pilots with far less experience.
I strongly hold that the safest way is in CAS takeoff to touchdown if this allows that to nearly touchdown where an aircraft could continue on the ILS if all was not as expected then I have no problems with it.
The other point is that this is a European rating. Flying around the south of England means your unlikely to hit anything nasty. That is not the case in many parts of Europe where the mounatins often reach several thousand feet or more.
Finally WHY WHY WHY not take the french FAA copycat proper IR based on European regs? There is no safety difference between the FAA IR and JAA IR only one is a lot more accessable to the working man PPL?

421C i can be provocative in my writing on certain subjects but that more to generate passion and discussion both ways than to dictate my view ;)
Maybe someone would kindly clarify what will or will not be allowed with the EIR?

Pace

mm_flynn

23rd Sep 2011, 14:03

Pace,

The French copy cat IR and the competency based IR as proposed seem very very similar. There are a number of issues I have with the NPA modular IR in detail (like why 3 and 1/2 hours of testing, why Europe seems unable to implement efficient, economical, readily accessible computer based testing, etc. ) but these are all petty irritations and IMHO just a fact of life in many aspects of life in Europe. We should be focusing on all of the upsides on the NPA not providing ammunition for the axe grinders.

I think there are a number of comments one can make productively such as

The EIR syllabus should include the use of an ILS or SRA as an emergency procedure, execution of which in the flight test
The EIR holder should be allowed to be descended to minimum RVA and hence a visual approach (as in a typical arrival to Fairoaks etc)
Others?

With regard to your example in Spain, I don't see where the problem is, the EIR descends to MSA/MVA is not visual, climbs back up and goes to the sun on the coast. The example just makes the point that unexpected bad weather tends to be localised and the EIR holder proceeds IFR enroute (as trained and practiced) to his alternate.

The cloud breaks we fly into Fairoaks, Denham etc are flown by people with the same number of hours of training as proposed for the EIR (I.e. and IMCr) and substantially less required knowledge, so I am struggling to see why the EIR pilot is going to be so much less competent in this particular activity (which after all is decision making and flying an IMC descent to an altitude - a task which I recall doing once or twice in the enroute phase of an IFR flight)

Fuji Abound

23rd Sep 2011, 14:06

Pace

I think it is clear that the EIR holder will be able to fly to the IAF by whatever means and that at the IAF he must be in VMC. in order to proceed with a visual approach.

Will the pilot continue with the procedure (flown visually) or will he self position for a visual approach I dont know (see my earleir post).

In other words presumably the higher of his rating privilige and the minimium descent altitude at the IAF is his DH as to whether or not he can continue with a visual approach.

That seems to me reasonably clear.

The whole point seems to me the pilot is trained to fly to a much DH and if not visual does the safest thing (for that pilot given his level of training) which is to go else where or to declare an emergency so that ATC can keep a very close eye on what he is up to. In your example it seems to me the EIR would do a very good job of protecting the pilot from a further descent that might even test the skills of an experienced IR holder. ;)

bookworm

23rd Sep 2011, 14:26

Maybe someone would kindly clarify what will or will not be allowed with the EIR?

I think one has to remember that the NPA is just a proposal. IMO, one area that will require work before the regulation is set in stone is the detail of the mechanism for transition between visual and instrument flight. The contributions on this thread are valuable in exploring the options and the potential advantages/disadvantages of each. While I understand the nature of the fairly polar reaction to the concept of the EIR, most of you seem to suggest that there are refinements that would make it acceptable:

Firstly If it is the case that the EIR will allow an aircraft to fly a STAR and part of the approach in CAS to safely become visual then I dont have a problem with that.

My comments will be that an EIR should include one type of approach privilege. I won't be arguing against the rating itself.

So I'd encourage you to suggest what would need to be case to make it work.

421C

23rd Sep 2011, 15:24

Pace

I have thousands of hours hard IFR in piston twins all over Europe.
I take your Barcelona example as a good one. But with your experience you are going to plan a VFR arrival (was it Sabadell I guess?) less cautiously than an EIR holder should. Not breaking out and half scaring myself I climbed and asked for IFR to land at Barcelona.
But Barcelona was VMC you said, so in an emergency an EIR holder would have had no trouble getting a VMC arrival.

Yes more experienced pilots like yourself do fly cloudbreaks into places like Fairoaks, Elstree etc. Sometimes to cloudbases we would not admit.
But that is a bit different to doing the same at somewhere like Bilbao without a lot of experience.
But the EIR doesnt apply to you or I with bags of experience but pilots with far less experience.
I disagree that enroute descent from IMC to VMC is for the experienced only. I think the majority of IFR-capable users at the VFR airports in the UK are likely to be relatively inexperienced IMCr holders, not guys with your kind of experience (or my more modest experience). It's a simple fact that these kind of pilots have safely operated IFR enroute and VFR arrival for decades.

I take your point that in the parts of Europe with terrain, it does become a more serious issue. I've flown to Bilbao and Barcelona and I know what you mean. But the people the EIR is aimed at today will be VFR only pilots - what about the risks they take in marginal weather scud-running into Bilbao? I think it would be better that they fly enroute IFR with the right training (remember the 15hr EIR training minima is the same as the entire full-blown FAA IR training minima!) and then establish VMC in descent. If they can't, they go out to sea and try there, or they declare an emergency and fly the approach - remember that the "weather worse than forecast" can be a lot worse than that required for a 1000'/5nm enroute descent but still make it a pretty benign emergency approach.

Finally WHY WHY WHY not take the french FAA copycat proper IR based on European regs? There is no safety difference between the FAA IR and JAA IR only one is a lot more accessable to the working man PPL?
Err, because, as I read it, the new full IR proposed in FCL008 is a long way towards the FAA model (compared to the present) and goes further than the French model.

brgds
421C

BillieBob

23rd Sep 2011, 16:46

Maybe someone would kindly clarify what will or will not be allowed with the EIR?Simply put, you will be able to fly under the instrument flight rules above MSA (as defined in SERA A) but you will not be able to accept an IFR clearance to fly any departure, arrival or approach procedure. A VFR/IFR transition point on departure and an IFR/VFR transition point on arrival should be included in the flight plan, the latter point should be passed prior to reaching the IAF. Consequently, you should not commence or continue a flight unless the forecast conditions at the destination or alternate aerodrome will, for one hour before and and one hour after your ETA, allow flight at and below MSA in VMC (as defined in SERA A) on or before reaching the declared IFR/VFR transition point.

JOE-FBS

23rd Sep 2011, 17:53

Well, you live and learn. Thank you to FBM for putting me right, I was wrong about the minima for IMCR holders. Thanks to another PPrune thread, I have found the reference:

UK AIP AD 1-1-7 section 8

Fuji Abound

23rd Sep 2011, 19:45

All in all I am very happy with the proposals.

I would like to see:

1. The EIR holder being entitled to fly a vectored approach to the top of the G/S,
2. The theory to be further reduced and more specific to the EIR,
3. Instructos and Examiners currently entitled to teach the IMCr to be grandfathered into the EIR training camp,
4. The EIR holder to be entitled to depart with a lower cloudbase where not required to fly a SID.

FlyingStone

23rd Sep 2011, 21:37

With the IMCR, I hear you don't have to fly any instrument approach or be checked by anyone for almost two years. Then you can legally take off, hack through cloud, and fly an approach to a 300ft cloud base?

Sounds like a death rating to me.

Well, a full IR/ME allows your (for private ops, depends on the country regulations) to fly a Seneca I 364 days after your proficiency check to takeoff in 150m visibility, and let's say you have an engine failure upon rotation and the runway remaining (if you even see any of it at all) isn't enough to abort the takeoff. So you then do a one-engined approach down to 200ft DH with RVR 550m, probably on some airport 50NM away. You can use the same scenario (obviously without an engine failiure) for an owner-pilot, which flies his/her own Jetprop/TBM 364 days after his/her proficiency check down to the same minima as stated before. Not the safest place to be.

Rules are for the obiendce of fools and the guidance of wise men. - Douglas Bader

Every licence is a death-attracting one, if you take all the regulations blindly serious. Sadly, the aviation is going British/France way, overdoing everything, writing rules/guidance/schedule/orders/whatever you call it for everything. Soon you will require an STC'd pens, mobile phones, paper, etc. for use in cockpit. I bet that with the current rate of law development, there will become a day when you'll have to check that the air in the engine intake complies with the standards and will have to be checked by a trained professional. Everybody who's ever flown IFR in piston single knows that there is great difference between what is legal to do and what is actually smart/safe to do in certain situations.

Back on topic. Any IR rating as such, being EIR, IMCr is useless without approach capability. I agree with IO540, IR and ability to file and fly on IFR flightplan has its advantages in routing (e.g. you don't need to request transit through every little piece of CAS), but in reality I don't think one actually needs the right to fly in IMC in en-route phase. Many times, if weather is getting worse (from VMC into IMC, probably with raising tops, developing Cu and TCu), one can safely expect the weather won't be that good at destination (unless you do really long trips, passing through different weather systems), so there is no point in being able to fly en-route IMC, if you then can't shoot an approach to a certain safe DA/MDA at destination. But still, there need to be some limits in approach capability, since EIR/IMCr/whatever you call it will/is mostly used by pilots who don't fly that much and use it only as an exit strategy. I think it would be smart to include the type of approach and number of attempted approach in regulation. For example, you arrive at the airfield and you elect to do a VOR/DME approach, which you either don't fly good enough or you have no visual references at minima. I believe this (and all other less-precise approaches) should be forbidden for you from then, so if you choose to make another approach, you would be left with ILS or LOC approach. So basically, each consecutive approach you make at the same airfield should be the one with greater precision - I believe it would increase the safety quite significantly.

I don't agree with a MDA/DA recommendation that is currently the case with IMCr. An ILS approach, probably to a field with supports Cat II/III operations with radar vectors even with half-scale deflection throughout to DH of 200ft is MUCH safer than a dodgy plain non-DME NDB approach with the beacon at the airfield and no (or procedural-only) ATC to let's say recommended MDH of 600ft, especially if regular MDH is close to 600ft. However I do agree that visibility should be required for an approach, but the same minimums as for circling minima currently in EU OPS should do just fine (1500m for Cat A, 1600m for Cat B).

But that's just my opinion.

gasdynamic

23rd Sep 2011, 23:51

Does anybody know when this could come in to force?

Pace

24th Sep 2011, 07:11

Consequently, you should not commence or continue a flight unless the forecast conditions at the destination or alternate aerodrome will, for one hour before and and one hour after your ETA, allow flight at and below MSA in VMC (as defined in SERA A) on or before reaching the declared IFR/VFR transition point.

So this means you cannot fly any of the approach but have to leave CAS by decent into VFR.
That brings back the concern that what relevance does weather at your destination/alternative have to the transition point and the cloudbase for your VFR descent? both could be wildly different.
9/10 such a descent will be fine but there has to be a plan B option which includes an option for some sort of approach and maybe a restriction on some airports for the EIR???

Pace

Timothy

24th Sep 2011, 07:24

There are already airports which don't accept VFR (ironically, Barcelona being one such) so I would not be surprised if some will not accept EIR pilots, as they will be VFR at the point of arrival.

But my feeling is that the airports which won't accept EIRs will be the very ones that EIRs won't want to go to.

I also think that the 9/10 ratio is wildly pessimistic, probably by more than two orders of magnitude. We are talking only about people who have been caught out by seriously misforecast weather.

That will happen, just as it happens to VFR, IMCR and IR pilots today. When it happens we mostly find a way of sorting them out but, very occasionally, one comes to grief.

But just as VFR, IMCR and IR pilots come to grief from time to time now, VFR, IMCR, EIR and IR will all occasionally come to grief in the future. You cannot, and should not, legislate that possibility away.

If you try to, you will kill all aviation.

Fuji Abound

24th Sep 2011, 07:46

That will happen, just as it happens to VFR, IMCR and IR pilots today. When it happens we mostly find a way of sorting them out but, very occasionally, one comes to grief.

Timothy

Doubtless it will, but I think you give the wrong impression.

I would hope that every EIR holder that uses the rating in earnest will keep their approach skills alive with an instructor or by flying approaches in VMC.

If the weather really misbehaves and no alternative is available I see no reason why an EIR holder should not be capable of flying an approach down to 500 feet, which would mean the weather would be seriously in the naughty corner.

After all even if he doesnt fancy the ILS a talkdown is hardly the most challenging approach to fly.

Timothy

24th Sep 2011, 07:58

FA,

I completely agree that any sensible EIR will take out his own insurance by doing some practice.

Having said that, I have flown with some IMCRs who would, IMO, probably kill themselves and their pax if they tried to fly an ILS to minima for real, because they have not been sensible enough to develop and retain the skills, and I guess that there is an analogy with some EIRs.

But I think that the reality of all this is that most EIR pilots will be very conservative and only fly on days when they would have gone VFR, but now have the ability to fly, in VMC, on airways, under the protection of IFR, without having to scrabble around for Class D crossing clearances and worrying about parachute drops.

That will be the real premium.

Timothy

24th Sep 2011, 08:07

It has just occurred to me that there is an analogy here.

For years we have managed with an IMCR, which is great, but has faults. One such fault is that the weather can fall below the minima an IMCR holder can cope with. But it hasn't been a real problem, life has gone on and we have coped.

Now the EIR is coming along and some people are upset that an unforecast change in the weather could engender embarrassment, difficulty or even danger for the holder, forgetting the similar shortcomings of the IMCR.

Is this not just the same as the GPS replacing the NDB/ADF for approaches?

For decades we have been using unreliable and error prone technology to get us down to 400' on the approach, with the needle bobbing around, pointing at thunderstorms, being bent at night or near coasts, but we have managed.

Then along comes the GPS and the CAA gets all worked up about possible obscure failure modes, not giving a thought to the fact that it is a million % better than what came before.

Is that a useful analogy, I wonder?

mm_flynn

24th Sep 2011, 08:13

So this means you cannot fly any of the approach but have to leave CAS by decent into VFR.
That brings back the concern that what relevance does weather at your destination/alternative have to the transition point and the cloudbase for your VFR descent? both could be wildly different.
???
While it is true weather varies around the piece, it is going to be an exceptionally unlucky pilot who has CAVOK at both the reporting stations he is using for his alternate and destination weather and has no point in the IFR system within his fuel range that he can make a descent to VMC at the MSA ... AND who then chooses to descend below MSA in the clag and hit something, rather than declare an emergency and proceed along a STAR to a VFR arrival (not something that is going to be a real challenge).

There EIR is not going to guarantee you make it into your destination, but I just don't see the purported risk being of any significance.

Pace

24th Sep 2011, 09:30

mm_flynn

24th Sep 2011, 13:19

Mm

That's not my experience the weather can be very different in the course of 20 mi!es my Barcelona example as one.
Not a problem if your flying into a sleepy IFR airport where a request to fly to the overhead at MSA would get an approval so you can get a descent in VMC but a bigger problem into a busy airport.

That IS my point. Having only EIR capability might be a PITA on occasion, but not a safety issue. In your example you destination was not accessible, however there were plenty of CAVU destinations near by - hence no safety issue.

With regard to long distances on top, this is no worse and probably better than a VFR only pilot undertaking the same flight (as he is currently allowed).

Personally I would get an IR rather than an EIR (but I made that choice a long time ago)!

I think this, combined with the grandfathering of IMCr holders, the modular IR, reduced TK and sensible Foreign conversion as a package is fantastic. I don't see any reduction in safety or utility from what we have today AND a sensible path for a big fraction of European GA pilots to take a range of positive steps to increase utility and safety. Some may only go for the EIR, some all the way to a full IR (sadly I don't think Europe is any where near authorising single pilot piston Cat II approaches as can be done in FAA land ;) - so we will just have to live with that 'risk').

Probably the one missing item is a CAA decision to contnue issuing the restricted IR AKA IMCr after 2014. But we can hardly expect or lobby that decision until this one is landed.

Am all for probing and discussing , but believe it is good policy and imperative that GA stands up and endorsed the key thrusts of this NPA while not feeding ammunition to those who would water down the proposals.

M

Pace

24th Sep 2011, 14:57

MM

Ok I will shut up now :E

Pace

dublinpilot

24th Sep 2011, 17:08

With regard to long distances on top, this is no worse and probably better than a VFR only pilot undertaking the same flight (as he is currently allowed).

A VFR only pilot might be allowed to do it, but in my experience none actually do it, unless they have an IMCR or lappsed IR.

dp

BEagle

24th Sep 2011, 19:07

How many of those considering the EIR actually have access to aircraft which actually meet the legal requirements for flight in CAS, I wonder? 'Airways equipped' being the historical term.

What I find interesting is that the FCL people in that Tower of €urobabble are working to a different timetable than the SERA / SES people. So that the FCL people are trying to sort out the rules for a game, the shape of whose playing field is as yet uncertain.

Far better for the FCL people to sit on their hands and let JAR-FCL 1.175(b) continue until such time as the airspace requirements for which they're trying to invent their ponderous licensing rules is actually known.

Last week was the 40th anniversary of the first instrument qualification I ever held - a PIFG on the Chipmunk. That required 11:05 of IF time - and of course it included IF approaches as did every single other instrument qualification, miltary or civil, which I held since. On my test from RAF White Waltham I had to fly an ACR7 approach into RAF Andover; the whole test taking 1:15 of which all bar 5 minutes was on instruments. The emphasis was on safe flight in IMC, not playing airliners in spam cans.

Never in the past 40 years have things been so ridiculously confused as they are today - or rather as they will be when those lunatic €urocrats start meddling when, as they have been told on countless occasions by the Commission, there isn't actually any need for them to do so.

bookworm

24th Sep 2011, 19:18

How many of those considering the EIR actually have access to aircraft which actually meet the legal requirements for flight in CAS, I wonder? 'Airways equipped' being the historical term.

I'm afraid "airways equipped" is a thing of the past, BEagle. EASA NCO OPS only differentiates equipment for IFR flight from equipment for VFR flight. It makes no distinction based on the flavour of air you happen to be passing through.

Timothy

24th Sep 2011, 22:35

lunatic €urocrats start meddling
....and you are representing AOPA's position to EASA? Not a great start.

S-Works

25th Sep 2011, 06:56

ridiculously confused as they are today - or rather as they will be when those lunatic €urocrats start meddling when, as they have been told on countless occasions by the Commission, there isn't actually any need for them to do so.

Change is inevitable. Do you wonder if perhaps you may be getting so long in the tooth you are loosing objectivity?

40 years ago a Chipmunk may have been fine for IFR, these days it's a summers evening plaything. The aviation world has moved on albeit slowly but we should approach it with an open mind......

Pace

25th Sep 2011, 07:45

Bose

I know your response above was to BEagle BUT!

Change is good if its positive and for good reason not just for the sake of change.

Aviation knows no boundaries. Thousands of FAA reg aircraft trundle from the USA to Europe and Beyond every day and visa versa with European based aircraft heading to FAA land and worldwide.

The world is a very different place to what it used to be. We have far better communications we are all linked financially and dependant on each other.

Change has to be a common acceptance of licences and getting rid of old hat terratorialism, protectionism and all the other rubbish that motivates in a negative change way.

I very much hope EASA is now going forward with POSITIVE change! realises there are a lot of FAA licence holders based in Europe and appreciate why so many are based here and make positive change to put something in place which is equally as attractive as the FAA PPL IR.

I hope they realise that the IMCR is a safety addon to the PPL proved by statistics.

EASA sre supposed to be a SAFETY based organistation. That SHOULD be their one and only mandate.

What they are doing with this above cloud rating is a step in the right direction but IMO they should look at some sort of approach at SOME airports should the need be.

Above all especially with N reg pilots I hope they realise that they are dealing with real people some who will be severely financially damaged by changes they make through no fault of N reg pilots in Europe.
That is not even talking about older FAA ATPs working and based in Europe who will loose their work and livelyhood.
For them converting would not be time or financially viable with only a few years flying left to run.
I hope they look at annual excemptions for special case FAA ATPs in Europe?

FAA Licenced pilots have been legitimely flying in Europe for far longer than the EEC has been around so should have legal status based on established practice or at least a moral obligation to these people which there most certainly is.

A lot with EASA has been a NON SENSE so lets hope they are finally adding some sense to all this?

Pace

BillieBob

25th Sep 2011, 08:04

Originally Posted by BEagle
lunatic €urocrats start meddling
....and you are representing AOPA's position to EASA? Not a great start.On the contrary, I think it is an excellent start. It is up to the the likes of AOPA to try to bring these self-seeking, devious liars in Cologne under control - there is clearly nobody else prepared to do it. Even the bulk of the EP Transport and Tourism Committee seems to have been successfully bought off, despite one of its members once famously saying, "Every time I come to this committee we seem to have to deal with the fallout from some decision by this wretched EASA organisation".

bookworm

25th Sep 2011, 08:21

What I find interesting is that the FCL people in that Tower of €urobabble are working to a different timetable than the SERA / SES people. So that the FCL people are trying to sort out the rules for a game, the shape of whose playing field is as yet uncertain.

What do you think are the uncertainties in SERA that cause issues for FCL?

BEagle

25th Sep 2011, 09:12

bookworm

25th Sep 2011, 09:31

bookworm, the statement made by the European Commission's Director for Air Transport, concerning Member States' need for flexibility to take account of local conditions such as geography and typical weather, is good enough for me.

In my experience of the SERA rulemaking process, I think you'll find that there's about as much flexibility as you can shove between the I and the C of ICAO. If you think EASA is behaving like a steamroller, you should see what Eurocontrol is up to.

However, my question stands. What do you think is unknown about it in a way that will impact the FCL.008 issues? It's a genuine question.

Timothy

25th Sep 2011, 09:42

On the contrary, I think it is an excellent start. It is up to the the likes of AOPA to try to bring these self-seeking, devious liars in Cologne under control - there is clearly nobody else prepared to do it. Even the bulk of the EP Transport and Tourism Committee seems to have been successfully bought off, despite one of its members once famously saying, "Every time I come to this committee we seem to have to deal with the fallout from some decision by this wretched EASA organisation".
EASA come out with the best proposal for GA in a generation and you think that AOPA's best response is to attack them as self-seeking devious liars?

I would have thought that "yes please" and "thank you" would be a good approach.

I do hope that Nick, through AOPA, doesn't blow this for everyone else.

If anyone is concerned about Nick's approach, I would recommend lobbying Martin Robinson, whose approach is much more embracing and wise than Nick's, and who should be giving Nick his direction in the discussion. This needs to be done soon before Nick goes to meet EASA next week.

BillieBob

25th Sep 2011, 10:02

you think that AOPA's best response is to attack them as self-seeking devious liars?I know that it suits your prejudice but that is not what I said - the word 'attack' is wholly yours. What I said was that it has been left to the likes of AOPA to try to keep the 'wretched' EASA eurocrats under control and to mitigate their worst excesses since the EC and EP seem to have walked away from their responsibilities in this respect. That a good proportion of the movers and shakers at Cologne are self seeking, devious and have lied is a simple statement of fact.

As for "the best proposal for GA in a generation", words, for once, fail me.

stuartforrest

25th Sep 2011, 10:37

I am confused. This looks like a pretty positive proposal to me. Are we sure we are not just looking for the worst here. It seems very good for an IMCr pilot like me who would like to fly to France in airways rather than as recently happened where I had to descend to 3000 ft to cross the channel because of a danger area notam for one day while going up would have busted an airway!

I would be happy to have the EIR while I train for the IR.

I hope this becomes law and the sooner the better, unless I am missing something. It sounds like the law makers have been listening and have come up with proposals that offer more than we currently have while still fitting in with ICAO.

It must be pretty demoralising to read this message board ( if they did) when they have tried to put together a proposal to move forward considerably from where we are right now.

Sorry i don't mean to upset anyone but it does seem there is a lot of negative comments so I thought I would add my positive ones!

BEagle

25th Sep 2011, 10:43

BillieBob, AOPA (UK) has already stated its position regarding the assessment which against which it will judge the NPA.

Whilst the IR looks reasonable, we still do not know how EASA intends to support the promises which have been made regarding the future of the UK IMCR. It is obvious that this will be of considerable concern to AOPA(UK) members, whereas other national AOPAs might have more interest in other aspects.

One aspect of the IR which needs clarification is how it would be credited towards a future CPL/IR. I haven't yet had sufficient time to establish that.

Martin and I have spoken at length on the topic of this NPA over recent days and have agreed a suitable strategy for the meeting.

Pace

25th Sep 2011, 11:21

who would like to fly to France in airways

Stuart

It had long been the case that you could fly French airways VFR at quadrantle levels.
As was the case with S Ireland

Pace

Timothy

25th Sep 2011, 11:32

It had long been the case that you could fly French airways VFR at quadrantle levels.
Pace,

I don't want to start another fruitless argument, but that is not right in a number of ways.

Firstly the quadrantal rule does not apply in France. What you mean is VFR levels, which is the appropriate IFR level plus 500'. If you flew NE at at Odd level, as you would under quadrantal, you would be in big trouble.

But much, much more important is that you do not fly the airways at VFR levels. Airways do not exist at VFR levels. You are flying the route of airways in Class E airspace, in the hope that they will keep you out of restricted airspace.

This hope is entirely misplaced. I cannot put that strongly enough.

It is not uncommon for the French IFR controller to reroute you off an airway because of military exercises. Flying VFR you do not get that service (unless you are lucky enough for FIS to tell you, but that is not obligatory on either part.)

Furthermore, airways at low levels can pass through Class A, C or D airspace, for which you need a clearance.

Flying IFR on airways you are cosseted and protected by ATC.

Flying an airways route through Class E under VFR you are not, and, frankly, and speaking as someone who does this all the time, you are much better off flying in a straight line through Class E and D, partly because it's quicker, and partly because it makes quite clear to you your obligation to make your own arrangements to stay away from restricted airspace.

You get the same (now excellent) radar assisted FIS service as you would get on an airways route.

Pace

25th Sep 2011, 11:40

Firstly the quadrantal rule does not apply in France. What you mean is VFR levels, which is the appropriate IFR level plus 500'. If you flew NE at at Odd level, as you would under quadrantal, you would be in big trouble.

Timothy my loose use of terms! IFR level plus 500

Pace

stuartforrest

25th Sep 2011, 11:48

It had long been the case that you could fly French airways VFR at quadrantle levels.
As was the case with S Ireland

Thanks for the reply but why would I want to fly vfr in French airways when this proposal allows me to fly IFR. Unless you have never been on an IFR flight, we all know is easier and safer than airspace dodging etc.

Surely being able to do something similar is not a reason to object to this proposal?

Timothy

25th Sep 2011, 12:00

...and my point is that it isn't really similar. That is a dangerous illusion.

Pace

25th Sep 2011, 12:03

Unless you have never been on an IFR flight, we all know is easier and safer than airspace dodging etc.

Stuart

First I have been on tons of IFR flights and as to easier the answer is yes and no!

Yes in the sense that you fly waypoint to way point and dont worry about other blocks of airspace no in the sense that you have to be more precise and fly to IR tolerances (broken autopilot)
No in the sense that you dont have the freedom of movement up down left or right that you do VFR.
Then with this system you need to be sure that you can get down not just at your destination but anywhere enroute in the event of a problem.
It will make things easier for long distance pilots who want to get high and stay there till their destination without doubt but with a caveat that long distance weather rarely stays as you want it above and below so to the single piston PPL more reason to only go when the weather is right because your sitting on top in the blue often isnt the case.

Pace

Fuji Abound

25th Sep 2011, 12:55

Pace

I dont think that is entirely correct.

Level and heading changes for weather are not usually a problem and if it suites dropping out of the airway is another option so even the SEP pilot has similiar options to being outside the airway albeit it does require some fore thought.

It really is up to you whether you plough on through a front with tops higher than forecast that you could see from 30k away.

Bose

It would seem things have turned out much better than you forecast which makes a change given all the talk about much worse than forecast weather.

PS Why is it the weather is always worse than forecast and never better. ;)

Timothy

25th Sep 2011, 13:53

PS Why is it the weather is always worse than forecast and never better.
I note the smiley, but my experience is that weather is almost always less bad than forecast.

Pace

25th Sep 2011, 13:58

Level and heading changes for weather are not usually a problem

Agreed but level changes will usually be in 2K increments which might not be where you want to be and are not always given without due cause.
A 2K climb can put you straight into icing.
Heading changes are usually given for weather ie "request left or right 15 degrees for weather"! But often you are given radar headings to hold.
All I am making clear hear is a miconception that you can climb to 10K and merrily sit on top in the blue sunshine till you drop down the other end.
Of course that can be the case but you have to look at the worst scenario especially with New pilots or rated pilots.

It is different with experienced pilots in capable aircraft. Many IMCR pilots do fly all weather around the UK on home made cloud breaks to very low heights and have been doing so for years and I am sure they would be constructive enough leaving an intersection on a long IFR flight to get themselves VMC to land. Is that as safe as getting radar vectors onto an ILS? NO

I note the smiley, but my experience is that weather is almost always less bad than forecast.

Tim you obviously dont fly when I do:E

Pace

IO540

25th Sep 2011, 16:07

I am confused about this "airways" business.

"Airways" are just lines on the map.

What matters to whether a pilot with particular papers can fly somewhere is the airspace classification e.g. Class A,D,G etc.

France has a lot of Class E between FL065 (generally) and FL115. FL120-FL195 is Class D, in which enroute VFR is banned (a breach of ICAO but hey they are French) and FL200+ is Class A, generally.

It so happens that that airspace has routes drawn in it, which UK PPLs call "airways", but really they are just suggested routes. These routes are common to the Class E (say FL065-115) and to the Class D above that (say FL120-195).

So a plain PPL can fly there VFR FL065-115, and an IR holder can fly the same routes FL065-FL195.

The IR holder has had to file a Eurocontrol IFR flight plan, and his routing makes use of those routes.

Class E is uncontrolled airspace for VFR, and this is how a plain PPL can fly VFR in that airspace. UK PPLs call this "flying in French airways" but that is meaningless. It is just a VFR pilot flying in uncontrolled airspace.

Those suggested routes generally avoid the extensive French military airspace, which makes them extra handy. In fact I have never seen any military activity impinge upon them. The French military have all the rest of France to themselves :)

As regards EASA officials being dishonest and disingenuous, that is a fact. Just watch Goudot's "little test" TV performance. Quite what can be done about it is another matter. I think we are stuck with it.

since EIR/IMCr/whatever you call it will/is mostly used by pilots who don't fly that much and use it only as an exit strategy

That is simply not true, but there is a limit on the time one can spend writing here.

oldspool

25th Sep 2011, 16:40

BEagle, you said...

''One aspect of the IR which needs clarification is how it would be credited towards a future CPL/IR. I haven't yet had sufficient time to establish that.''

I may well have mis-understood the proposals, and forgive me for stating the obvious but, the CPL is a licence and the IR is a rating. I thought this NPA was describing the future rating(s) associated with flight in Instrument Meteorological Conditions, in which case the rating is the rating regardless of what licence it is attached to?

Therefore, I would have thought the proposals for the IR would be the same whether someone holds a PPL or a CPL.

The only difference between a CPL holder a PPL holder doing the IR is that the CPL holder would most likely complete the High Performance Aeroplanes (HPA) section of the theoretical knowledge exam(s).

Isn't that correct? I'm sure one of the introductory paragraphs said words to the effect that whilst the motivation for this work was to make the IR more accessible to private pilots that commercial pilots would also benefit.

Slopey

25th Sep 2011, 17:14

As someone doing the IMCr at the moment before the Euro idiots dispense with it, from all the talk on this thread, and as someone who lives in the North of Scotland and doesn't fly to France/Europe every weekend - can someone explain to me how an En-route IR which doesn't enable the pilot to accept an IFR approach, is a benefit over the IMCr which does albeit only within the UK.

With the weather such as it is up these parts, I'm certainly intending to use the IMCr in anger, and I'm in a very active syndicate where several of the members already do, and spend large amounts of time keeping very current on it so they can.

An EIR will be pointless - aside from being able to simplify the flying from A to B by going IFR rather than VFR, and that's only going to make sense on longer journeys anyway, if the weather has to be guaranteed VMC at the other end that's going to limit the utility of the rating. And even worse, if it is VMC when I set off, but deteriorates en-route, I could be possibly left with having to try to get VMC without an IFR approach at the other end.

So, how is this a *good thing* if you're not constantly popping over to the continent or somewhere with better weather?

oldspool

25th Sep 2011, 17:31

Slopey,

Despite 90-95% of the thread taking the form of 'IMCr versus E-IR', the E-IR is not a replacement for the IMCr.

The proposals are for a more accessible 'full' IR, and the E-IR needs to be seen as a module of the 'full' IR. The fact that you exercise the privileges of this [E-IR] module is a good thing because...

1) it may well suit some people and the sort of flying they do. If it doesn't suit you and you want full IR privileges then;
2) you can use it to build 15 hours PIC (IMC) and considerably reduce the training for the 'full' IR (to 10 hours).

Slopey

25th Sep 2011, 17:54

Ahhh - apologies, I'd mis-read along the discussion that the plan was to morph the IMCr into the EIR, which for me anyway would be a significant loss.

I take it the (as far as we know) plan then is to grandfather the IMCr privileges, but to count it towards an EIR which in turn could be counted towards the IR requirement?

Timothy

25th Sep 2011, 18:09

For two years a small number of reactionaries have tried to make that the conversation, but it is not. They are utterly different.

You will be able to grandfather the IMCR and you will be able to count it towards the EIR or IR.

oldspool

25th Sep 2011, 18:22

''I take it the (as far as we know) plan then is to grandfather the IMCr privileges, but to count it towards an EIR which in turn could be counted towards the IR requirement?''

The NPA doesn't detail how this might be done but the suggestion appears to be that those with an IMCr will continue to be able to exercise those privileges, and that the IMCr will, in some way, count as credit in the new modular system.

So, in your case, you'll be able to do what the IMCr currently allows you to do, and you'll have a much more accessible route to a 'full' IR if you want/need the additional privileges.

BEagle

25th Sep 2011, 20:03

Therefore, I would have thought the proposals for the IR would be the same whether someone holds a PPL or a CPL.

oldspool, that's what I need to confirm. You see the FCL.008 group's TORs included the following objectives:

Review the existing JAR-FCL requirements for the Instrument Rating with a view to evaluate the possibility of reducing these requirements for private pilots flying under Instrument Flight Rules. This evaluation shall take into account the ICAO Annex 1 SARPs for the issue of an IR.

Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges.

BillieBob

26th Sep 2011, 10:15

NPA 2001-16A, para 1.1

Although the initial starting point for this task was to develop a more accessible instrument rating for PPL holders, the Agency agrees with the proposal of the rulemaking group not to limit the new ratings to PPL only. As the Agency expects that these ratings will also lead to an increase of VFR rated CPL holders taking up the training for one of the two new instrument ratings, it is proposed to widen the scope and to allow CPL holders to also receive training for these ratings.

Pace

26th Sep 2011, 11:08

Billy

just a few hints :E EASA have come up with a legal stumbling block regarding existing employed FAA licenced pilots in Europe so all this stuff having to hold dual licences can only apply to new commercial pilots not pilots who are already employed. EASA have accpeted that!

Second the whole impetus is now towards a Bi Lateral agreement.

Third 2014 will be changed to a later date

My source is very accurate

Pace

flybymike

26th Sep 2011, 11:33

Pace can you outline "the legal stumbling block"?

Pace

26th Sep 2011, 12:52

Basically employment on N Reg aircraft in Europe by it's citizens is legal established practice. You cannot legislate against EU law which protects your rights to that employment without recourse.
There are also legal problems for older working pilots in the present structure regarding age discrimination laws.
My source is very reliable. 2014 is out of the window with the earliest date as 2015 but more likely 2016 and there is a genuine Bi Lateral agreement behind all this
I could add a lot more but won't :E

Pace

IO540

26th Sep 2011, 14:20

I recall speaking to at least two barristers who think there are various legal avenues possible, in the CPL/IR / ATPL paid pilot arena and possibly others, and it doesn't suprise me, but nobody should be going public with where these might lie :)

Years ago, a sovereign country could do as it wished and Crown Immunity (or the locally named version of it) prevented its Govt being sued for any economic loss, but things are not quite the same in the EU today.

Pace

26th Sep 2011, 14:26

10540

I think EASA are fully aware of their problems I will PM you

Pace

jez d

26th Sep 2011, 14:34

Genghis the Engineer

26th Sep 2011, 15:25

A question concerning the IMCR.

It appears that the proposal is to grant an IMCR holder a restricted IR. Will this IR Lite, or whatever it is to be termed, allow access to Class A airspace ?

Many thanks, jez

Nobody's said anything, but my guess would be no since the IMCR syllabus does not include flight in airways. I'm guessing that the future pilot with IMCR grandfather rights would need to separately do the EIR to get that privilege, although one hopes that might be pretty painless.

What would be much more interesting to me is whether the EASA grandfathered IMCR would be useable outside of the UK?

G

IO540

26th Sep 2011, 15:31

since the IMCR syllabus does not include flight in airwaysThat is not really correct.

The IMCR offers IFR privileges for UK airspace classes D,E,F,G.

"Airways" is a nonexistent concept as far as pilot privileges are concerned. If you can find a piece of enroute airspace which is Class D (I believe there is some in Scotland) then you can fly in it on the IMCR, under IFR.

It is true that the IMCR syllabus does not include SIDs and STARs but they are nothing to do with the airspace class. Bournemouth has both and is wholly in Class D so an IMCR holder could fly a SID or STAR there legally. (The fact that these procedures lead in or out of Class A eventually is another matter).

It appears that the proposal is to grant an IMCR holder a restricted IR. Will this IR Lite, or whatever it is to be termed, allow access to Class A airspace ?The short answer is that nobody knows, as the ways forward for IMCR holders are not yet worked out.

The current proposals, just out, are the FCL008 ones: the EIR and the IR.

Both will allow flight in all airspace classes.

The EIR will have no instrument approach privileges so it is for enroute IFR only.

The grandfathering path from an IMCR to the EIR or to the IR is AFAIK not yet known.

Slopey

26th Sep 2011, 15:31

What would be much more interesting to me is whether the EASA grandfathered IMCR would be useable outside of the UK?

But if a grandfathered IMCr was usable outside the UK, that would effectively make the EIR pointless (aside from non-SVFR Class A airspace access), and it would be easier for EASA to adopt the IMCr euro-wide rather than invent an EIR?

As much as it might be a boon for everyone else, I doubt they'd do that!

IO540

26th Sep 2011, 15:45

This debate runs and runs both here and on Flyer :) I've almost given up following it.

I think the short answer is that if you try to do too much you end up with a qualification which is an IR in all but name, which is not politically acceptable.

Frankly (and I have had an IR since 2006 and have used it extensively around Europe) a properly trained IMCR is 99% of the way to what you need to know. The SIDs/STARs are just a tiny piece of trivia which take 5 minutes to explain. The rest is all operational knowledge, which nobody is formally teaching anyway...

The full IR and the historically inflated training package, especially the grotesquely inflated European version, is very much a matter of an emperor being start naked, but nobody can say that.

I think the EIR is a valuable proposition because of the reduced training requirements relative to the full "FCL008 IR". In that respect it is wholly an additional privilege which does not detract from any other.

Whether it is valuable enough relative to the training effort difference to the full IR is a personal matter. It's a bit like whether a £100k plane does "enough more" for you than a £70k plane.

I would never go back from the full IR (just see how much easier (http://www.peter2000.co.uk/aviation/index.html) flying with the full IR is, comparing VFR and IFR trips) short of losing my medical, but taking myself back to my VFR-only days (albeit with the IMCR), the EIR would give me a very valuable capability increment for long trips.

There is an argument that the EIR won't benefit many people, in that its chief selling point is the ability to fly VMC on top enroute, which is not practically possible in CAS (due to Eurocontrol / ATC issues) below say FL070-090) so some reasonable level of aircraft capability is required for that. But it will be no worse than the IMCR which allows you to fly around the UK, in IMC, OCAS.

jez d

26th Sep 2011, 16:25

Thanks for the replies. So, it appears that IMCR grandfathering has yet to be resolved, but the consensus is that holders will be granted some form of instrument flying privileges, for the whole of Europe, roughly equivalent to existing IMCR privileges.

With reference to your comment, Slopey, "But if a grandfathered IMCr was usable outside the UK, that would effectively make the EIR pointless", as I understand it the IMCR will no longer exist as of April 2012, so the EIR will become the only sub-IR entry route for instrument flying.

As the IR 'Lite' will be for IMCR holders only and should afford the same privileges as currently granted to IMCR holders (but across the whole of Europe), it seems to me that getting an IMCR before the April 2012 cut-off date would be a wise move.

Regards, jez

jez d

26th Sep 2011, 16:31

Another thought.

If, as it currently appears, the EIR isn't available until 2014/2015 (and presumably the IR Lite for IMCR holders), wouldn't it be wise for the-powers-that-be to allow IMCR training to continue until such time as the EIR and IR Lite comes into being ?

IO540

26th Sep 2011, 16:40

Yes, that is self evidently correct.

I gather that EASA will allow (gosh we need to be grateful for small mercies from these characters) an individual country (e.g. the UK in this case) to adopt national differences to an IR, and this is how the IMCR would continue in the UK only, as it is now.

BEagle

26th Sep 2011, 17:25

jez d - the proposed IR(Restricted UK) would simply be the existing IMCR by another name. It would not be useable outside UK airspace, neither would it include any additional privileges.

I gather that EASA will allow (gosh we need to be grateful for small mercies from these characters) an individual country (e.g. the UK in this case) to adopt national differences to an IR, and this is how the IMCR would continue in the UK only, as it is now.

IO540 - if only that was true! It's the current situation under JAR-FCL 1.175(b), but has not been carried into EASA proposals. If it can be, it will solve all the IMCR problems at one stroke......:hmm:

421C

26th Sep 2011, 18:07

It's the current situation under JAR-FCL 1.175(b), but has not been carried into EASA proposals. If it can be, it will solve all the IMCR problems at one stroke
That's true, but pretty tautological. JAR-FCL 1.175(b) is a paragraph that permits national IFR qualifications. EASA FCL doesn't permit national qualifications. So yes, if EASA said we could have the IMCr, then there wouldn't be an IMCr problem. There appears to be zero chance of that position changing, so we should get on with maximising the value of the grandfathering solution and getting FCL008 through in full.

Pace

26th Sep 2011, 18:36

BEagle

Surely that would be a better situation in UK airspace. The EIR woulld give you the ability to fly airways enroute, the grandfather righted IMCR the right to take approaches at the other end? almost all the benefits of a full IR in UK airspace ;)

Pace

awqward

26th Sep 2011, 20:26

I must admit my brief read through NPA 2011-16 this afternoon gave me great hope in the future - the IMCr will be effectively grandfathered in terms of a IR (UK restricted) for a UK IMC rated pilot -except that getting the EIR would mean having access to Class A airspace.

Even getting the EIR if you already have the IMCr looked to be realtively easy provided the 10hrs ATO training could be credited from the previous IMC training...so to me the NPA is great news for UK IMCr pilots....what have I missed?

mm_flynn

26th Sep 2011, 20:37

Even getting the EIR if you already have the IMCr looked to be realtively easy provided the 10hrs ATO training could be credited from the previous IMC training...so to me the NPA is great news for UK IMCr pilots....what have I missed?
The only thing you missed is for a couple of extra hours (beyond the EIR) a reasonably experienced IMCr holder would be able to get a full ICAO IR. Useable down to system minimums anywhere in the world. I would expect the number of IMCr holder who do just the EIR to be small given the marginal extra work. The EIR will benefit much more all of those people who have never had an opportunity to get an IMCr (i.e. the rest of Europe).

Genghis the Engineer

26th Sep 2011, 22:00

I think we should just point out a few things we don't know from the very long and detailed NPA:

(1) If, or when, it'll happen.

(2) What changes may yet happen to this "Notice of Proposed Amendment" before it eventually becomes regulation.

(3) Whether or not the UK IMCR will get grandfathered outside of UK airspace.

(4) What the extra training requirements will be for an IMCR holder to get the EIR or full IR, particularly given that at present an IMCR holder pretty much has to start again from scratch to get the IR. We don't know if that current, arguably rather unsporting, position will change.

G

Whopity

27th Sep 2011, 07:15

(2) What changes may yet happen to this "Notice of Proposed Amendment" before it eventually becomes regulation. By and large nothing, because EASA do not like the NPA process and don't understand technical or safety based responses.
What the extra training requirements will be for an IMCR holder to get the EIR or full IRMore than most imagine because the NPA makes it clear all testing will be carried out by a IRE to the same standards as required for an IR. That will make it very difficult for most IMCR holders, and the cost of testing alone will be x 4 as an IRE charges roughly twice what a PPL FE charges, and it will be twice as often (12 months versus 25).

Pace

27th Sep 2011, 10:04

My guess is that the IMCR will go in total.
In EASA eyes by the time we get there they will have offered their own IMCR in the form of the IRE ( albeit I think they will have to add some sort of instrument approach capability in event of weather not working to plan which doesn't involve declaring an emergency a plan B)
The route to a full IR being much closer to the FAA system.
My tongue in cheek response to an IMCR plus a IRE equalling an instrument rating in the Uk is not far from
The truth.
Hence my guess the IMCR and grandfathering rights will never materialise.
I really hope I am not right for all those who have fought so hard to retain the IMCR.

Pace

Fuji Abound

27th Sep 2011, 10:27

Pace

I think you are wrong.

Here is why.

While many don’t trust EASA or the CAA I think some commitments have been given with regards the IMCr. I also think that there are a sufficient number of holders who have spent a sufficient amount of money on the rating that will not so readily "roll over" unless they are offered appeasement. We must remember that unlike the N reg issue we are talking about a rating that is/was issued by a European government for receipt of valuable consideration effectively creating a contract between the two parties. I think reneging on a contract of this sort is politically unattractive.

Of course the IMCr may be traded for rights into something else hence my earlier reference to appeasement, but that might be as acceptable.

Whether an EIR combined with an IMCr creates a mini IR is debatable but to that extent the suggestion that IMCr holders will be grandfather into a restricted IR would seem to make sense and doubtless would be acceptable to most people.

Whopity

27th Sep 2011, 11:17

I think reneging on a contract of this sort is politically unattractive.I admire you confidence in this bunch of Shysters. Sadly, I think Pace is nearer the mark. What is quite sad about all of this is that nothing was broken, so why the need to fix it? ICAO defined a perfectly good IR many years ago, the UK used to work to it and guess what, when the longer JAA IR replaced it, there were fewer first time passes. The TK bears little relevance to the flying and could well be overhauled, but yet again, no sign of a Training Analysis, just a bunch of TOs assembled by a clerk and based on all the old irrelevant crap.

I Love Flying

27th Sep 2011, 11:23

I certainly hope Pace is wrong. I am currently 3/4s of the way through my IMC course, which I decided to do now rather than put it off due to all the uncertainty over the IMCr. The grandfather rights discussed had a significant impact on my decision.

Of course, all the skills taught will remain mine and cannot be taken away from me, but surely common sense dictates that it is only fair that pilots get recognition (i.e. in the form of a rating) for the not insignificant amount of time, effort and money spent doing the course and completing the exam.

421C

27th Sep 2011, 12:09

I certainly hope Pace is wrong.
I think he is. Whilst we can take nothing for granted, I think para 7 on page 5 of the NPA is pretty encouraging

"a conversion of existing IMC ratings is already covered by the draft Commission Regulation laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council. This draft Regulation clearly defines that Member States should convert existing licences and ratings into Part-FCL licences and ratings. It is highlighted in this Regulation that Member States should aim at allowing pilots to, as far as possible, maintain their current scope of activities and privileges. The Agency already discussed this issue with the CAA UK and industry experts in order to identify possible options for UK IMC holders. The most favourable solution seems to be that a Part-FCL licence and an IR will be issued with certain conditions on the basis of a specific conversion report in order to reflect the current privileges held. This would allow the existing UK IMC holders to continue to exercise their IMC privileges."

This provides a pretty clear legal/regulatory context for how the IMC can be grandfathered, and, whilst I am sure there are important details to be resolved, I would have thought there is a very good prospect that a solution along these lines will be executed.

In EASA eyes by the time we get there they will have offered their own IMCR in the form of the EIR
Even if this was the secret intention of EASA, and I am aware of no grounds for thinking so, the timing wouldn't work. The IMCr grandfathering needs to happen by summer 2012, and there is little chance of the FCL008 NPA coming into effect until later. Quite reasonably, UK stakeholders will want a better degree of clarity and certainty well before then, so I am sure AOPA and the UK CAA will be working to get execution of the IMC solution quoted above in place asap. It doesn't seem particularly onerous? New EU law (like FCL or the FCL008 amendment) takes forever to go through processes like CRD and Comitology. Implementing stuff which is within the existing scope of EU laws (as the grandfathering appears to be) is pretty straightforward if the lawyers all agree. EASA has some very capable legal people and I don't think para 7 would have been published without a good degree of confidence that it can happen.

brgds
421C

Fuji Abound

27th Sep 2011, 12:53

In fact why even have para 7 unless this is the intention?

It would seem odd to specifically address the issue of the IMCr unless you intend to find a solution and more to the point a solution along the lines set out.

What is quite sad about all of this is that nothing was broken

To be fair I dont think anyone said it was (broken). What they did say was that it makes sense to have a common set of regulations that cover the EU as after all they are our immediate neighbours, and trading partners. In the same way in some respects how much more logical are the arrangements under Schengen - which we have so far chosen not to be a part.

Now you may well be a Eurosceptic, but that is another story. The fact is we are part of Europe and if Europe has any chances of working, then it will only do so as a Union, if not, better break the thing up and start over.

Timothy

27th Sep 2011, 12:54

I don't see how EASA could be more transparent. They are saying that people with IMCRs will retain their privileges and that the EIR is a different matter.

We are not discussing stupid things that EASA people have said at meetings, but their proposals for rule making in black and white.

The EIR is not a substitute for the IMCR, except that in the rest of Europe it will provide people with a stepping stone in a way not dissimilar to the IMCR.

It is a different rating, giving very different privileges, some greater than the IMCR, some less.

I am delighted that AOPA continue to advocate the retention of the IMCR, and all power to their elbow and I will help in every way I can.

But no-one in AOPA should think that the EIR will make any difference to that process, so they do not need to resist it on those grounds.

Pace

27th Sep 2011, 12:58

421C
I very much hope I am wrong too. If anything it shows how
Hacked together and incomplete all this is from EASA.
If the Imcr was grandfathered over to the uk the following could be a reality!
A fairly recent PPL imcr could get substantial allowances to the EIR and effectively would have a full IR in uk airspace.
He would be able to fly airways and take approaches!
The only limiting factor would be RVR on those approaches as cloud base is not proveable.
But let's wait and see as I am sure the shape in
2016 won't resemble what we have on the plate now.

Pace

mm_flynn

27th Sep 2011, 13:50

.
If the Imcr was grandfathered over to the uk the following could be a reality!
A fairly recent PPL imcr could get substantial allowances to the EIR and effectively would have a full IR in uk airspace.
He would be able to fly airways and take approaches!

which seems exactly the intent!

The NPA makes it clear that EASA believe (and I agree) there is a positive safety case for allowing people to fly enroute IFR with 15 hours of training, the revised TK and a flight test. So yes, one would expect 'a fairly recent PPL having passed the EIR tests' to be able to do this.

In addition, nobody on this forum believes the UK approach privileges of an IMCr holder are a material safety risk. So, yes, one would expect an IMCr holder to be able to exercise his privileges as he does today.

Fuji Abound

27th Sep 2011, 14:07

Pace

I am not sure whether on your part there is a certain "concern" that the combination of an EIR and IMCR would provide a back door route to essentially a Euro land IR?

If it does as you know it wouldnt confer any commercial advanatges to aspirant private come commercial pilots who would still need an IR. Moreover is the concept that different from Australia where an enroute IR (Euro EIR style) already exists with the opportunity for holders to add approach priviliges - well consider it, an IMCr holder is simply a pilot who has the proven capability to add on approach priviliges to his EIR.

GA desperately needs to provide a mechanism for private pilots to "enjoy" instrument priviliges. The EASA IR does not cut the mustard for most with a theoretical burden that may still prove too much, but Europe was never going to follow the FAA model - whether we like it or not.

So what we appear to have got is I suspect as good as we could have hope for and will be a long awaited breath of fresh air for the average GA pilot in Europe who wants to extend their flying capability.

Pull what

27th Sep 2011, 14:11

....and you are representing AOPA's position to EASA? Not a great start.
Yes sadly arrogance only works in the armed forces.

Pace

27th Sep 2011, 16:01

Fuji
I used an IMCR in the uk in anger for many years and appreciate that some IMCR pilots are very experienced and competent IR fliers.
I was always in all this EASA stuff more inclined to putting all our efforts to an FAA style European IR as I am convinced the FAA IR is as good as any JAA IR but one heck of a lot easier to get in time and money.
So my preference would have been FAA style.
I foresee safety problem in the EIR without an ability to take instrument approaches.
As far as the grandfathering of rights to the IMCR with what EASA would see as their own IMCR in place I am more skeptical and untrusting of EASA and their real intent than you are

Pace

Timothy

27th Sep 2011, 20:05

Pace,

Could you explain, so we all understand, why you consider that EASA look on the EIR as their own IMCR?

The question is asked particularly in the context of the number of states represented in EASA, and the number of Brits in the decision making process (who would even care about the legacy of the IMCR.)

Why is it not more likely that the EIR has been created without any particular reference to the IMCR?

Pace

27th Sep 2011, 20:35

Timothy

Yes quite happily! The IMCR was pushed at EASA as a safety addon for the VFR pilot! The safety angle was shown to be the case especially regarding the attrocious French VFR accident rates compared to UK VFR accident rates.

As such they were forced to do something as an addon for VFR pilots which added some instrument capability and privalages without being a mini IR.

EASA would not put anything in place which would fight with their own beloved IR so put in the EIR which would be an enroute to the IR ie a modular part of the IR.

Basically they have added their own acceptable IMCR and acceptable means without approaches.

Pace

funfly

27th Sep 2011, 21:49

Pace is getting to a valid point - the IMC rating is not wholly about flying under instrument conditions, it is about offering an ADDITIONAL level of pilot training that can take a pilot to an enhanced level of flying skills and can add to the safety of his/her flying by the ability to use instrumentation. I see no reason why the training and the qualification should not continue for this sake alone even if there was no official 'out of sight' privileges gained. In my case I never flew in instrument conditions but the IMC training, post PPL, made my flying better, more precise and more enjoyable.

IO540

27th Sep 2011, 22:00

I don't disagree with you but you could make the same point about the full IR.

Both of them enhance the ability to fly under VFR :)

The only difference between the IMCR and the IR is the big increment in the hassle, cost, hassle, cost, ongoing hassle, ongoing cost, in getting the IR and keeping it :)

In fact I would argue that you need an "instrument capability" to fly VFR to anywhere near the license privileges e.g.

- at night
- in haze
- in difficult lighting conditions
- in a lack of a horizon
- when there are no visual nav references
- anytime you don't want to bust airspace ;)

Timothy

28th Sep 2011, 07:03

Ironically, I have long argued that it is somewhat irresponsible (both of the authorities and individual pilots) to allow people who are not capable of instrument flight to command an aircraft.

Can you imagine a "good weather" driving licence, where the driver is disqualified from entering rain, and is likely to crash if he does?

The tiny amount of instrument flying in the PPL is clearly inadequate.

So, if I were King, I'd probably make the EIR a compulsory part of the PPL. Don't worry, though. Neither of my parents is a Queen :p

Whopity

28th Sep 2011, 07:51

The tiny amount of instrument flying in the PPL is clearly inadequate.We used to have 4 hours of it, but it created a level of overconfidence in some pilots who would press on in conditions that they should not have been flying in. It was taken away from aeroplanes under the JAA umbrella, but given to the helicopter pilots who are allowed to fly VFR in lower visibility. The same overconfidence has appeared in some areas.

This alone indicates a little knowledge can be a dangerous thing, if you half train people to do any job, some will think they can do the whole job. And what is to stop them?

Genghis the Engineer

28th Sep 2011, 09:19

We used to have 4 hours of it, but it created a level of overconfidence in some pilots who would press on in conditions that they should not have been flying in. It was taken away from aeroplanes under the JAA umbrella, but given to the helicopter pilots who are allowed to fly VFR in lower visibility. The same overconfidence has appeared in some areas.

This alone indicates a little knowledge can be a dangerous thing, if you half train people to do any job, some will think they can do the whole job. And what is to stop them?

Interesting that this is very similar to the arguments that led to removal of spinning from the PPL syllabus (and it's not even in the CPL now, or was it ever?)

By extension of course, don't teach people to fly at-all, then they won't feel tempted to try, and thus safety is substantially enhanced!

G

Fuji Abound

28th Sep 2011, 10:14

Interesting that this is very similar to the arguments that led to removal of spinning from the PPL syllabus

Genghis

While I have some symphathy with your argument (and in jest it was probably partly meant) I think there is an important distinction.

While I personally think spin training is a good idea I am not sure how many people's lives it actually saved. The reality is the only time inexperienced pilots manage to spin the aircraft is close to the ground in the circuit at which point the spin training will probably be of little help. In fact it seems to me most pilots are so scared of the stall they back off well before.

On the other hand the biggest killer remains flying into IMC or some variation thereof - CFIT which more often than not arises from flying into IMC.

So if the evidence was piltos were killing themselves in self induced spin accidents it should be taught: whereas the evidence is people are killing themselves in IMC so I suspect it is really important that is taught as well as possible at the PPL stage without of course turning a PPL into a mini IR.

Genghis the Engineer

28th Sep 2011, 11:42

It was partly in jest. However...

- The biggest killer if you plough through the GA safety stats is LoC at low level, usually in VMC. So the current concentration on stall avoidance is pretty sensible.

- CFIT is a relatively small killer, but still significant, and so I don't actually support the view that we should eliminate instrument training for PPLs - I think it does have value.

- There was, historically, a big dip in spin-related fatal accidents when it was eliminated from the UK PPL syllabus, for whatever reason.

G

IO540

28th Sep 2011, 11:45

The biggest killer if you plough through the GA safety stats is LoC at low level, usually in VMC. So the current concentration on stall avoidance is pretty sensible.

Would it not be better to train people to avoid low and slow flight?

I think too many pilots fly too slowly; maybe 10kt above Vs, wallowing around the circuit, because they were trained like that.

Fuji Abound

28th Sep 2011, 11:57

- The biggest killer if you plough through the GA safety stats is LoC at low level, usually in VMC. So the current concentration on stall avoidance is pretty sensible.

Is that right?

Timothy

28th Sep 2011, 12:09

We also have to confess that CFIT is far from limited to VFR pilots.

Indeed the last four high profile cases have been with rated (variously IMCR and IR) pilots screwing up badly in one way or another.

Genghis the Engineer

28th Sep 2011, 13:05

Is that right?

Yup, see the recent GASCo 29 year UK fatal accident statistics review....

25% LoC VFR
16% Low flying / aeros
12% CFIT
12% Forced Landing
8% Loc IMC
6% mid-air
5% ground collision
4% airframe failure
4% low approach
3% medical or suicide
5% undetermined

(I've only got a draft to hand, so if you have a final version, the numbers may be very slightly different, but not much.)

So 33% definitely attributable to LoC, and when you analyse them the vast majority were low level. Odds are that a proportion of the 16% low flying and aeros involve some form of low level LoC also.

From that, I'd say that LoC - usually low level, is probably 3-4 times as regular a killer as CFIT.

G

Genghis the Engineer

28th Sep 2011, 13:12

Would it not be better to train people to avoid low and slow flight?

I think too many pilots fly too slowly; maybe 10kt above Vs, wallowing around the circuit, because they were trained like that.

Interesting perception - why do you think that?

My experience is that PPLs are more likely to fly too fast and get badly behind the aeroplane, rather than fly too slow and nibble the stall. The stall related LoC accidents tend to be finals, go-around or climbout, when you have to be fairly near the stall anyhow.

G

Pace

28th Sep 2011, 13:32

I do think there is an element of truth to what 10540 says.
I have flown with many pilots who get
Slow and you have to prompt them.
There are equally some who seem oblivious to wind and shear conditions and peg the same old speed.
Looking at the LOC VFR how many are minimal VFR or almost IMC ?

Pace

Genghis the Engineer

28th Sep 2011, 14:06

Would you also outlaw aircraft that cannot be controlled in the clouds? Just curious - it would outlaw much of the GA fleet, or at least 1/2 of my fleet! It does sound like a logical extension of current Euro regulation.

Given the amount of time we all spent doing partial panel training, I suspect that your statement isn't true.

It may be unwise, but it is possible to fly just about anything in cloud, and control it. The only exception that I can think of are weightshift microlights, where there is significant evidence this'll probably end in tears - but pretty much any fixed wing aeroplane with an ASI, altimeter and compass (which is all of them) can be flown and controlled in cloud, although doubtless T&S, DI/HSI and AI make life far safer and easier.

G

Contacttower

28th Sep 2011, 14:19

Coming back to the NPA....

Having now read the thing in it's entirety it seems to be a fairly reasonable document.

I would highlight several issues however that I think need expansion on or modification:

1. This has already been raised several times but in terms of the EIR the VFR to IFR transition needs to be thought through quite carefully. At the moment the proposal is to allow departures in VFR only and not be allowed to enter IMC below 1000ft above the highest obstacle with 5nm. Now as far as I can see from the NPA there is no explanation as such of how this will be achieved; the proposed flight test syllabus does not include SIDs but at the same time nowhere in the NPA does it say that they are prohibited. To make things simple (especially from an ATC point of view) it would seem sensible to allow them to fly the SID but state that it must be visual for the first 1000ft after departure. If there is no SID then simply revert to the 1000ft within 5NM of highest obstacle rule.

With arrivals a similar clarification is needed. Although some posters have make reference to needing to be visual by the IAF I don't see this specific statement in the NPA. Only that the arrival and landing must be VFR. As with departures it seems sensible to allow them to fly the start of the STAR at least since otherwise it will be a pain for ATC.

I suspect the reason SIDs/STARs are not included is because once you teach people to fly them you have taken up more hours and the advantage of just doing the EIR as opposed to doing the IR in one go decreases. If they can be included though in the proposed minimum instructional hours for the rating it would seem to make sense to do so.

2. The proposed 100hrs of theoretical study seems excessive, especially since the EIR and IR written exam are proposed to be the same. I know in reality people will use distance courses a lot but overall the process of taking the writtens sounds like it could still be rather laborious; distance courses as I have found myself with the JAA IR are a bit of rip off and complicate the process when actually the FAA way of just learning the stuff and then getting an instructor to check your knowledge and sign you off is perfectly adequate. However I commend the suggestion in the NPA that the written exam could be done all in one sitting. They have scratched off a lot of garbage from the written exams but as IO540 pointed out on another thread there is still the fear that the actual quality of the remaining questions will still be poor.

3. The proposal for the conversion of foreign IRs seem reasonable, ie no required dual time, just a flight test. However I would like to know what they mean by 'demonstrate' knowledge of Air Law, HPL etc? A chat with the examiner? Just take the written exams?

I would encourage people to comment on the NPA with their thoughts. EASA may or may not listen but reading this NPA it would seem they have at least attempted to deal with the PPL/IR issue so its probably worth contributing.

IO540

28th Sep 2011, 14:23

Indeed the last four high profile cases have been with rated (variously IMCR and IR) pilots screwing up badly in one way or another.I am not completely sure which four you refer to, though one of them must be the recent one near Nice.

When I read some accident report (and I have read many many) I try to take something home from it.

The problem I have with the "IR holder CFITs", and these are usually discussed here on pprune fairly thoroughly and much more so than on any other forum, is that they are just plain weird, bizzare, nonsensical.

N2195B (which lived in "my" hangar) was an IR holder who was > 2T but his Seneca did not have the 1999kg STC, and this was possibly a factor in why he flew mostly VFR on his long foreign trips. I happen to know (can't say how) that he used to file around 10 Eurocontrol flight plans per year, so he did know about "IFR". His final flight was "VFR", mostly in IMC (the BEA report doesn't say that but they barely bother in their GA reports), and into conditions which made it clear he never even checked the BBC weather, let alone looked at tafs, metars, mslp, radar, IR, whatever, as well as having no clue that there is "terrain" in the lower bit of France. A very good friend of mine was the last to see his family alive, and when he pointed at the OVC006 RA conditions (what a scream, filing "VFR", hey?) he was told by the highly intelligent PhD economist pilot that he "always flies". With no oxygen, he cut off his wx escape routes, apart from a 180 which he was unlikely to consider anyway. What is one supposed to make of that?

N403HP crashed after cancelling IFR, which he did about 50-100nm before his destination. Not clear why he cancelled IFR so far back. He then flew what looks to me like a pretend visual circuit, for the benefit of Vienna radar, in absolutely solid IMC, and crashed while doing that. He could have popped into LOWW which was 5 mins' flying time away and auto-landed his Jetprop on their ILS. A highly intelligent businessman with a CPL/IR and CFII. What is one supposed to make of that?

Regarding the last one, little is known and those who were flying in the group are not talking, but the appearance is that he crashed while pottering about, presumably in IMC (who actually does a CFIT in VMC, short of flying in a canyon?), before he managed to collect an IFR clearance. I hate to speculate on this one because so little is known but I won't be shocked to learn he had no oxygen and was thus trying to fly low in that area, where airway routes are unavailable below FL150 or whatever.

So it looks like most if not all CFITs of IR holders happen when they are not using their IR.

I am not aware of a CFIT in the UK, or connected with the UK, where one could say "damn I could have fallen for that one". I had a very sticky one on Greece last year, pottering around among hills in ~ 1k viz while trying to collect an IFR clearance from a couple of units which were both snoozing, but I had a GPS running a real topo map.

There have been CFITs in the USA where subtle avionics issues were possibly implicated. For example a pilot I know researched a number of CFITs of aircraft carrying a KMD550 MFD, whose colour terrain/elevation depiction contains absolutely life-threatening defects (basically, missing mountains, due to Jepp having downsampled the elevation data by averaging adjacent heights, rather than by taking the highest value) and these pilots hit isolated peaks. OK, they were dumb to rely on the kit to fly an off-airway DCT because the MEA concept is then void, but...

Interesting perception - why do you think that?I repeatedly see people fly very slowly in the circuit. Really slowly, and I am talking about a C152 doing ~60kt.

They also have a very common habit of drifting downwards. Where I am, the cct is at 1100ft, with terrain around the dw/base turn area of 840ft (especially if you fly a wide cct). But I often see people flying the final leg somewhere down on the ground, flying much of it maybe 300ft AGL, very hard to spot, and then they suddenly pop up on very short final. Very few are flying a "glideslope" or a stabilised approach trajectory.

My experience is that PPLs are more likely to fly too fast and get badly behind the aeroplane, rather than fly too slow and nibble the stall. I don't see that in the circuit. I am sure it does happen, but normally it would result in a go-around. Also, traffic separation issues excepted, there is nothing wrong with flying the circuit too fast. It is only on short final that you have to get it right :)

The stall related LoC accidents tend to be finals, go-around or climbout, when you have to be fairly near the stall anyhow.There is no reason to be lower than 1.3 x Vs anywhere before very short final, and being at 1.3 Vs at the base-final turn is IMHO needlessly slow.

3. The proposal for the conversion of foreign IRs seem reasonable, ie no required dual time, just a flight test. However I would like to know what they mean by 'demonstrate' knowledge of Air Law, HPL etc? A chat with the examiner? Just take the written exams?I agree with your thinking ;) but it has always meant sitting the written exams.

IMHO, introducing an FAA-style oral exam into the European pilot training machine would scare the living daylights out of most ab initio people especially at the IR/ATPL level, not least because nearly all of them a) sat the exams months or years before they do the flight test and b) did most of the study using a QB.

IO540

28th Sep 2011, 14:39

You can fly with just a compass, in smooth conditions, to keep the wings level.

But if you get into anything remotely resembling a "bank angle" then you will not recover.

Also, for some reason, most planes are more roll-stable in a descent, so getting down is less work.

It is somewhat easier to do this stunt with a gyro compass (a DI) because it doesn't wobble about so much.

BillieBob

28th Sep 2011, 15:08

Contacttower wrote:
nowhere in the NPA does it say that they [SIDs] are prohibited.GM1 FCL.825 states:

Since the privileges of the EIR are only to be exercised in the en-route phase of flight, the holder of an EIR should:

1. at no time accept an IFR clearance to fly a departure, arrival or approach procedure;

There is nothing to prevent procedures from being flown VFR but I don't think that's what you had in mind.
Although some posters have make reference to needing to be visual by the IAF I don't see this specific statement in the NPA.
AMC1 FCL.825 states:

A VFR transition point should be used in order to enable the pilot to conclude the flight under VFR to the intended destination. For this purpose, when filing a flight plan in accordance with operational rules, the holder of an EIR should include IFR/VFR transition points. If an IFR approach procedure is established at the destination airfield, this IFR/VFR transition point should be passed before reaching the Initial Approach Fix (IAF).

Remember that, under EU legislation, where there is only one published Acceptable Means of Compliance it is to be considered mandatory. Anyone is at liberty to propose alternative AMCs to the competent authority.

BEagle

28th Sep 2011, 15:54

AMC1 FCL.825 states:

A VFR transition point should be used in order to enable the pilot to conclude the flight under VFR to the intended destination. For this purpose, when filing a flight plan in accordance with operational rules, the holder of an EIR should include IFR/VFR transition points. If an IFR approach procedure is established at the destination airfield, this IFR/VFR transition point should be passed before reaching the Initial Approach Fix (IAF).

'Should' in EASA-speak is a recommendation, not a mandatory requirement. The circumstances described above need to be changed to become mandatory as they will then have legal strength. This could be achieved by the use of 'shall' instead of 'should'.

That is one example of the type of comment I will be making at the forthcoming workshop. It will be neither the time nor place to argue the relative merits of the IR, its theoretical knowledge requirements, nor whether they are proportionate for the proposed EIR, nor the EIR itself. To me the EIR theoretical knowledge requirements seem disproportionate for the privileges conferred - so the option to do an 'EIR' exam first, followed by a delta for the 'IR', would seem a reasonable alternative.

The workshop will really only be an information gathering session and will not be suitable venue for indicating the direction the NPA response of an individual or organisation will take. However, it may be necessary to advise EASA that, given the very short period of time which has been available to study the NPA, it does not at present seem to meet the UK's position as regards the IMCR. Rather than press the point on Friday, I hope that my fellow UK representatives and I will restrict ourselves to a few basic questions concerning the IR, EIR and 'sailplane cloud rating' within the scope of the NPA, but will be taking up the matter of the UK IMCR in UK airspace with the UK CAA and 'others' over the coming weeks.

It's possible that the EIR might be considered a 'student' rating, allowing IR students to gain the relevant experience towards the IR, rather than an indefinite V/IFR rating. Why? Because that could be a strategem to reduce opposition from ATS providers who are known to be concerned at the impact of additional IFR activity in busy sectors.

Typical questions I am already considering:

1. Define 'busy IFR airspace' for EIR training.
2. Define 'emergency IFR approach' for EIR training.
3. Were ATS providers consulted during FCL.008?
4. What is the minimum cloudbase permitted for a sailplane / powered sailplane pilot to fly in cloud with the sailplane cloud rating?

I'm aware that the level of 'bull$hit' in the IR theory requirements has already illuminated the 'BS' caption - it will take people quite a while to wade through it all, but please do so!

It will hopefully be a productive information-gathering session in Friday - and I'm looking forward to a Schnitzel und Weißbier tomorrow night at the usual place!

mm_flynn

28th Sep 2011, 15:58

IO,

The fourth was an IMCr rated instructor in a non-fatal (exceptionally lucky!) CFIT at night, broadly due believing they were in a different location than the actually were.

Contacttower

28th Sep 2011, 16:18

1. at no time accept an IFR clearance to fly a departure, arrival or approach procedure;

I obviously missed that bit...

AMC1 FCL.825 makes it clearer but I just think it might be a bit clumsy from an ATC point of view.

IO540

28th Sep 2011, 16:21

Oh yes OK I do remember that one.

But he was not using his IR at the time; well not in anything remotely resembling IFR as practiced in the 21st century.

IIRC, he was doing something like this (http://en.wikipedia.org/wiki/Star_Dust_%28aircraft%29). Dead reckoning in IMC does involve making various assumptions, none of which need to be made by anybody flying for real today.

Timothy

28th Sep 2011, 20:16

But he was not using his IR at the time; well not in anything remotely resembling IFR as practiced in the 21st century.
The same could be said of all of them. I agree broadly with your analysis, but note carefully my original point.

The IMCR/IR/EIR can be sold as ways of helping VFR pilots avoid CFIT, but the sad, desperately sad, truth is that a good proportion of CFIT incidents involve instrument qualified pilots.

mm_flynn

28th Sep 2011, 20:51

The same could be said of all of them. I agree broadly with your analysis, but note carefully my original point.

The IMCR/IR/EIR can be sold as ways of helping VFR pilots avoid CFIT, but the sad, desperately sad, truth is that a good proportion of CFIT incidents involve instrument qualified pilots.
It may be worth noting that many more VFR only pilots suffer from CFIT. Also, most UK based VFR pilots that come to grief do so in the UK (and often in their local area), where as most IR rated UK based pilots come to grief outside the UK. One would reasonably expect, on average, IR holders to operate over much greater distances than VFR only pilots. However, I suspect the UK IFR CFIT statistics also benefit from the very flat country (relative to the Alps).

IO540

28th Sep 2011, 21:42

I am sure that is true, plus also the desire to fly "VFR" to avoid eurocontrol route charges, since a much higher % of IR holders fly twins, and most twins are over 1999kg.

a good proportion of CFIT incidents involve instrument qualified pilots.

while flying VFR, however, and failing to maintain VMC. Same as the average PPL CFIT really.

Timothy

28th Sep 2011, 22:43

But you are still missing my point. These are people who are instrument qualified, which means that an instrument qualification is not a total panacea.

Fuji Abound

28th Sep 2011, 22:46

[QUOTE][QUOTE] The biggest killer if you plough through the GA safety stats is LoC at low level, usually in VMC.

And

Is that right?
Yup, see the recent GASCo 29 year UK fatal accident statistics review....

25% LoC VFR
16% Low flying / aeros
12% CFIT
12% Forced Landing
8% Loc IMC
6% mid-air
5% ground collision
4% airframe failure
4% low approach
3% medical or suicide
5% undetermined

(I've only got a draft to hand, so if you have a final version, the numbers may be very slightly different, but not much.)

So 33% definitely attributable to LoC, and when you analyse them the vast majority were low level. Odds are that a proportion of the 16% low flying and
aeros involve some form of low level LoC also.

Genghis

Without wishing to be to pendatic it was your low level comment to which i was referring.

As always you can cut the stats in different ways but cfit and loc in imc (both originating or possibly originating from instrument flying ability) are right up there as maybe some of the loc in poor vmc.

Genghis the Engineer

28th Sep 2011, 22:49

Without wishing to be to pendatic it was your low level comment to which i was referring.

Pretty much all of those accidents, if you analyse them - the detail is all in the GASCo report - were LoC at low level.

Which, logically, makes sense. LoC at altitude gives time and height to sort things out.

G

IO540

29th Sep 2011, 06:56

These are people who are instrument qualified, which means that an instrument qualification is not a total panacea.It is of little use if you choose to not use it, however.

Whether an IR is somehow relevant or not if somebody chose to not use it, is a debate for philosophers only.

Pretty much all of those accidents, if you analyse them - the detail is all in the GASCo report - were LoC at low level.

Which, logically, makes sense. LoC at altitude gives time and height to sort things out.

However, the basic issue is probably not loss of control but flying too slowly. In VMC, one should not easily lose control. But one can screw things up pretty well in VMC by flying slowly and then pulling some Gs.

This needs to be addressed by training.

421C

29th Sep 2011, 06:57

(deleted. the answer to my q was a few posts up in the thread)

Genghis the Engineer

29th Sep 2011, 14:52

It is of little use if you choose to not use it, however.

Whether an IR is somehow relevant or not if somebody chose to not use it, is a debate for philosophers only.

However, the basic issue is probably not loss of control but flying too slowly. In VMC, one should not easily lose control. But one can screw things up pretty well in VMC by flying slowly and then pulling some Gs.

This needs to be addressed by training.

The basic issue is that the pilot:aeroplane combination is insufficiently good at avoiding pitching nose-up beyond alpha-crit.

A lot of that is indeed down to training, but also aircraft design/flying qualities, and type checkout practices are identified as being significant.

Pilot training, currency and atttitude are always the issues when the aeroplanes are perfect and the weather completely predictable!

G

awqward

29th Sep 2011, 15:26

Timothy

29th Sep 2011, 15:31

...those of us who occupy airways at 80-120 know that they are almost completely empty, and very often controlled by airport based rather than area based controllers.

If this initiative doubled, trebled or quadrupled usage at those levels they would still be almost completely empty.

TMA occupation is more likely to be an issue, especially as we go around at 100-180 kts and CAT is at 220-250 kts (or more if not speed controlled).

IO540

29th Sep 2011, 17:05

If there a surge in the number of PPLs with either the EIR or the full IR, there will be a large number of small aircraft on the Class A airways - albeit mostly below 10,000ft. Presumably this will have an impact on commercial / jet operations....my guess is that the current exemption from airways charges for small aircraft will be removed....again pushing (some)PPLs (in the UK at least) into IFR OCAS..

I have just flown to Greece and back and the only plane I saw, at around my level, on the entire trip, was this (http://www.peter2000.co.uk/aviation/kithira/lszr-egka-2-big.jpg) one.

One could do the same from say Bournemouth to say Aberdeen, FL150.

The "crowded airspace" is a myth, FL100-200.

The Eurocontrol routings take enroute low airway traffic away from terminal areas, as in this (http://www.peter2000.co.uk/aviation/kithira/lszr-egka-big.jpg) example around Paris (VATRI to XORBI) which diverts all traffic below FL200. Others e.g. Frankfurt have minimum crossing levels e.g. FL120/130.

Finally, the benefit of an IR if flying wholly within the UK is fairly small - due to the extensive Class G airspace.

If this was ever going to be an issue, it would have been an issue many years ago.

Pace

29th Sep 2011, 17:56

10540

I wonder how long with the EIR it will be before aircraft below 2 metric tons get charged for the IFR service they get?

Pace

IO540

29th Sep 2011, 19:07

Nobody can possibly answer that, but the 2T charging threshold was reviewed a year or two ago and they decided to leave it as it is.

Looking at the pilot community I know, I don't think the EIR or the FCL008 IR will make a massive difference to the number of people flying in IFR enroute airspace.

Most pilots are limited by time/money (as indeed is the acquisition of the IR itself) and are limited by hardware. I know you can fly a PA28 at 10k-11k (I did so in Arizona, in ISA+5/10) but the whole UK culture just doesn't fit into that kind of mould.

Also if you take a typical high-hour GA pilot, 150hrs/year at most, of which only 30-50 is enroute IFR. Take the whole European IR community and assume they do those hours (which they mostly don't). It translates to lower airway occupation going up from virtually nothing to slightly less than virtually nothing.

Currently you can fly from UK to say Prague and probably hearing only 1 other GA aircraft on the frequency, along the whole 700nm leg.

It reminds me of the old VLJ debate, with various groups including Eurocontrol being scared of "thousands" of VLJs clogging up European airspace. I've been to numerous ATC-type presentations where this was trotted out. But in reality those who might buy a $2M light jet are just those who already fly a turboprop, and you can count them at the usual hangouts like Cranfield, Biggin, etc.

Genghis the Engineer

29th Sep 2011, 19:59

Currently you can fly from UK to say Prague and probably hearing only 1 other GA aircraft on the frequency, along the whole 700nm leg.

Doing just that trip last month with Anton_K, I'm not sure I recall hearing any other GA aircraft at-all between Lydd and Prague; did most of the trip about 5,000ft.

G

blagger

29th Sep 2011, 20:02

IO - think that is one of the crucial points; the modular IR is great but I can't see many more private flyers going for it than currently do the IMCR. The prospect of renewing it every year with an IRE (EIR is the same I think) will put many off - you're looking at a spend of about £500+suitable ac hire annually before you've done anything. That is if you can get access to anything remotely properly equipped. I think a lot of people will just chin off instrument flying and stick to Day VFR, two micro schools I know running EV97s and C42s can't buy new aircraft quick enough to satsify demand at the minute, and I think there will be a real move towards that end of GA.

IO540

29th Sep 2011, 20:19

Most people will pay about £150 to a freelance instructor for the IR renewal, plus the cost of the flight itself.

Compared to the 6/6 FAA IR rolling currency, this is something I don't like, but this is how Europe works.

This is one of a number of reasons why the IMCR must be preserved.

Timothy

29th Sep 2011, 20:25

Blagger,

There are a couple of countries in EASA without access to the IMCR, I believe.

blagger

29th Sep 2011, 20:28

Timothy - sorry, I don't understand what you are getting at??

Timothy

29th Sep 2011, 21:04

I can't see many more private flyers going for it than currently do the IMCR.
What about all the PPLs of France, Germany, Italy, Spain and all the rest who cannot get an IMCR and now, suddenly, have a real prospect of IFR/IMC flight?

Pace

29th Sep 2011, 21:12

Timothy

too true :E I fly into Bezier on the south coast of france and met a French PPL who flies from Paris to his villa VFR
Such a rating would I am sure appeal to someone like him

Pace

blagger

29th Sep 2011, 21:12

I'm still making the same point - I think the IMCR is accessible and achieveable, but uptake is still relatively low. As written the new EIR and IR, still with a reasonable TK requirement and annual renewals with an IRE to IR standards, I can't see a great percentage of private pilots taking it up anywhere (regardless of whether they have IMCR now or not).

Timothy

29th Sep 2011, 21:22

An alternative theory is that IFR will no longer be seen as unattainable and elite and become much more part of the mainstream, as it is in the US.

IO540

29th Sep 2011, 21:42

I think that has a chance of becoming true outside the UK, where they never had anything lesser than the full JAA IR.

But there are other factors at work there too... why touring is so obviously rarely done by certain European nationalities. I think the reason is obvious: they can't speak English; the totally universal language of European IFR. That is one reason why an IR uptake in Europe as a whole will never reach the US levels. They have no Customs, a common language, no PPR, etc.

No matter where I go, where I meet pilots who have come from a long way away, they are mostly from countries where English is spoken well.

Also the IMCR exists in the UK and no matter how one wraps it up, the IMCR is a helluva lot less work in getting and keeping than any IR proposal now on the table.

Much will depend on the detail i.e. the IMCR -> FCL008 IR upgrade route.

Pace

29th Sep 2011, 22:15

Blagger

to IR standards, I can't see a great percentage of private pilots taking it up anywhere (regardless of whether they have IMCR now or not).

Do you think anyone should be flying IFR airways if they cannot fly to IR standards? I dont!!!!

I have never had a problem with any flight test( If you cannot fly the tolerances and deal with all the rest maybe you should not be there) only in ATP terms 14 exams, 6 months full time study or 2 years distance learning and a big portion of that learning totally irrelevant!!!

Pace

soaringhigh650

29th Sep 2011, 22:35

they can't speak English

I think you'll find a significant proportion of people in Europe do speak English better than the average English speaker speaking any other language in Europe!

TMA occupation is more likely to be an issue, especially as we go around at 100-180 kts and CAT is at 220-250 kts (or more if not speed controlled).

That's why there are different procedures for the different categories of aircraft. You bunch the ones with similar speeds/characteristics together.

Pace

29th Sep 2011, 23:07

That's why there are different procedures for the different categories of aircraft. You bunch the ones with similar speeds/characteristics together

That is not to do with seperation!

I used to fly a Seneca into Dublin main every week and we were slotted inbetween large jets with the request to maintain 160kts until 4 dme.

To hold 160 kts was a lot easier keeping the Seneca clean down the ILS and at 4 dme putting in first stage flap (140 Kts and gear at 128) It was then easy to fly at 128 till almost short finals bring speed back with land flap at 100kts and back to 80 kts over the threshold.

High speed approaches should be practiced even in the club PA28 if not for slotting in with fast traffic but also for strong wind shear conditions to the local airfield.
Its all about speed management and confidence in the aircraft you fly!

Speed is your saviour not your enemy as some consider and high speed approaches and management are not taught enough.

Pace

BEagle

30th Sep 2011, 04:42

High speed approaches should be practiced even in the club PA28 if not for slotting in with fast traffic but also for strong wind shear conditions to the local airfield.

No they should not. The aircraft should be flown in accordance with the POH. Flying at excessive speed on the approach often leads to a poor landing. Failure to trim correctly, overcontrol and ballooning are the result - or a damaged nose undercarriage if the aircraft is flown onto the runway at high speed.

This 'adding 5 knots' for weight / shear or whatever is wholly unnecessary. Pilots should use the POH figure and nothing else.

I'm intrigued to know how a 'freelance' FI / IRI would work in €uroland - I can find no reference to such a creature in FCL.001 and the part-OR requirements indicate that all flight instruction will be conducted at an ATO... Doubtless someone will enlighten me in a few hours' time.....:hmm:

Pace

30th Sep 2011, 06:23

Beagle

Ii hope you never fly into a major airport iin a PA28 at 75 kts from 8 miles out! Or on a very heavy windshear day as I woulnt want to be in the aircraft.
Have I suggested that you land at above the normal landing speed in the POH No. All the stuff you mention like ballooning or landing too fast are indicative of poor pilot technique and not flying a fast approach.

In the Citation I maybe asked to maintain 200 kts (Flaps app speed) I may come back to 160 with gear down and then bleed in full flap which on the Citation is like a speed brake in the drag it creates.

Vref maybe 105 so a speed range of 100 kts

Ok the PA28 is a little aeroplane but there is no reason in the sky why you cannot fly down the approach at 100 kts coming back to 80 and then 70.

Pace

IO540

30th Sep 2011, 06:33

Do you think anyone should be flying IFR airways if they cannot fly to IR standards? I dont!!!!

They won't; the FCL008 IR flight test is just like the full IR flight test.

The other side of the argument is that IFR is by far the easiest way of flying.

I think you'll find a significant proportion of people in Europe do speak English better than the average English speaker speaking any other language in Europe!

That's very true, but not relevant.

That's why there are different procedures for the different categories of aircraft. You bunch the ones with similar speeds/characteristics together.

Not really; you don't see a CatA flying an IAP concurrently with CatD. The different tracks shown on the approach plate are not for traffic separation; they are for the different speeds.

High speed approaches should be practiced even in the club PA28

I don't thinkt his is an issue. In "proper" IFR one needs to be able to fly at the landing gear limiting speed (Vlo) all the way to glideslope intercept, but that's not a problem.

In general, ATC will slot you in.

Timothy

30th Sep 2011, 07:35

Sorry I wasn't clear when I used the expression "TMA", but I was not referring to the speed of a PA28 on finals. That is annoying but not insuperable.

I was referring to the previous 60 miles in the TMA, which is mainly occupied by aircraft streaming in at 220-250 kts. Getting them past a Seneca doing 175, let alone a C150 doing 75, is a real pain.

I was only saying this wrt the comments about airways at F100. There there really isn't a problem, because the airspace is empty and anyway we already "own" it (in the gangsta sense).

The problem is in the TMA, which is already occupied, in some cases, like Heathrow and Schipol, fully occupied, by fast CAT.

However, it is the job of Air Traffic Service Providers to provide a service to all users, so, if there is a massive upsurge in GA IFR, which I doubt, they will have to find a way.

Let's hope it's not "dumped at Detling".

But, to be clear, I expect it to be a relatively small and manageable problem in reality.

soaringhigh650

30th Sep 2011, 09:53

The problem is in the TMA

That is what I mean when I mentioned different procedures earlier on. Some STARs at airports near mine are for prop and turboprops and others are for medium and large jets.

When you depart you are kept low until a space is found in the relevant airway - then you are slotted in and asked to climb.

If the airport has multiple runways you'll find some are mainly used for light/small movements while others are used for medium/heavies to maximize efficiency.

And if there is just one runway, you need to keep your speed up.

Fuji Abound

30th Sep 2011, 11:45

Timothy

Frankly I am a little surprised about these issues of fitting in with CAT.

I do a fair amount of touring and often go to some of our regional airports (in the UK and Europe). In the vast majority of cases unless you happen to pitch up at an unusually busy time the traffic density is pretty low and I have seldom had any issues.

Personally, unless I really have a good reason for going to the largest airports, I try and avoid these and then I would certainly try to avoid peak times. Even at Gatwick you only have to look at the arrival and departure boards to realise outside peak time the traffic density is not that high.

It is a bit like lower airspace, I think all these claims that the traffic is stacking up are vastly over done, and where and when it really is, it is doubtful whether light GA wants to be there anyway either because the weather is so bad or the prices so high.

I think we may be looking for a solution to a problem that does not exist.

justmaybe

30th Sep 2011, 12:11

Only EASA could have concocted the nonsense proposed in the NPA, but in fairness it was fuelled by some of the input from various UK interest groups. The UK IMC has evolved into something close to a full IR, and if taught properly it is unlikely that less than about 25 flying hbours will have been expended in order to not only to make a candidate ready for a test, but more importantly make him/her competent and safe. Why on earth the whole IR issue is not addressed with a view to making it more akin to the US model is beyond me. Regretably, there is very little coming out of EASA that is not overly complicated and expensive, and is far too readily embraced by our CAA. (I will not even mention AOPA). Whilst the NPA can be responded to, do they really listen?

mm_flynn

30th Sep 2011, 12:36

Timothy

Frankly I am a little surprised about these issues of fitting in with CAT.

I do a fair amount of touring and often go to some of our regional airports (in the UK and Europe). In the vast majority of cases unless you happen to pitch up at an unusually busy time the traffic density is pretty low and I have seldom had any issues.

I think Timothy's comments are more directed at operations into Dublin, Geneva, Prague, Barcelona, etc. rather than Southampton, New Castle ....

I certainly have never had a speed issue into the regional airports, but have almost never not had a request to maintain high speed into the major airports.

justmaybe,

The competency based IR in the NPA is not that far away from the FAA model. certainly from the context of where it started it is a massive positive move in the right direction - Yes the TK Learning Objectives remain suspect (but this NPA was not scoped to address that issue), yes it is a PITA that Europe doesn't seem able to do CBT, but the TK test can now be done in a day (even if it is twice as many questions as the FAA it is still way way smaller in scope than the current monster), yes it is a bit of a pain it is 40 hours dual rather than 40 hours time (but most people in FAA land due the 40 hours dual any how as it does take some effort to learn IF)

421C

30th Sep 2011, 12:52

I'm intrigued to know how a 'freelance' FI / IRI would work in €uroland - I can find no reference to such a creature in FCL.001 and the part-OR requirements indicate that all flight instruction will be conducted at an ATO

We had this discussion a while back on the FLYER forum. I believe it is a misconception that EASA regs require all flight instruction to be at an ATO.

Part OR simply describes what is required to qualify as an ATO.
Part FCL does in most instances specifically state that the flight training required for a particular qualification must be at an ATO, but where it doesn't, then the training can be outside of an ATO.

Let me illustrate the contrast (with my underlines): on Class and Type Ratings, FCL.725 says
Requirements for the issue of class and type ratings
Training course. An applicant for a class or type rating shall complete a training course at an ATO. The type rating training course shall include the mandatory training elements for the relevant type as defined in the operational suitability data established in accordance with Part-21

But for Variants, FCL710 says

In order to extend his/her privileges to another variant of aircraft within one class or type rating, the pilot shall undertake differences or familiarisation training. In the case of variants within a type rating, the differences or familiarisation training shall include the relevant elements defined in the operational suitability data established in accordance with Part-21.
If the variant has not been flown within a period of 2 years following the differences training, further differences training or a proficiency check in that variant shall be required to maintain the privileges, except for types or variants within the single-engine piston and TMG class ratings. The differences training shall be entered in the pilot’s logbook or equivalent record and signed by the instructor as appropriate.
It's simple - the absence of the requirement for a course at an ATO makes it clear the training can be done with an independent instructor.

I believe some of the misunderstanding comes from the wording of the CAA's "Expected Effects on Pilot Licensing" paper, which, for example, emphasises that all training must be at an ATO (in the sense that it can not be done in an RTF). But it would be a mistake to interpret that as all training in all circumstances. Pretty much all training needs to be done at an ATO, because the major cases of new licence and rating issue, revalidation and renewal are "pretty much all training". That does not mean there isn't some training that can be done outside an ATO. The variant/differences training is an example. Any elective (non-required) recurrent training can be.

I think it's pretty obvious and non-problematic. I find it odd that you write "how a 'freelance' FI / IRI would work in €uroland - I can find no reference to such a creature in FCL.001 ". The references to instructors are rather extensive and obvious in SubPart J of FCL001!

It would be like saying that you can't find a reference to independent commercial pilots in FCL001, because you expect all commercial pilots to be employed by AOCs. But that isn't how the regs are structured. FCL defines pilot, instructor and examiner regulations. By default, these are "independent" people. Part OPS defines where flights need to be conducted by AOC holders, just as Part FCL defines where training needs to be done by an ATO. The Organisational requirements for AOCs and ATOs are in Part OR.

Let's also remember that the IMCr can be taught by independent instructors - there is no requirement for an RTF, only that an approved syllabus be used. Of course, most of the western world's flight training is conducted under the American 14 CFR Part 61, which is legally, in effect, by independent instructors.

brgds
421C

421C

30th Sep 2011, 13:01

it is 40 hours dual rather than 40 hours time

The wording is not crystal clear, but it is 40hrs time of which 25hrs must be dual and of that, 10 must be at an ATO. The difference with the FAA system is that the 15hrs which could be solo must be instrument time "as PIC on aeroplanes, under a rating giving the privileges to fly under IFR or in IMC" - this could be an ICAO IR, and IMCr or an EIR. (The ICAO IR case would apply to someone who didn't have the 100hrs instrument time needed for the conversion). It means that solo time "under the hood" with a safety pilot, but no IFR qualification, can not be counted, unlike in the USA.

See para 6 on page 21 of the NPA.

I think it makes sense because it gives someone the option to do
- 15hrs EIR training
- 10hrs (minimum) experience in IMC as PIC using EIR privileges, in practice this might mean considerably more hours as PIC under IFR
- ...then 10hrs at an ATO to get the IR

Of course, these are all minimum times, and most people should expect to need some more time - exactly as per the FAA system, where few qualify in 15hrs training, as mm flyn points out. But that's the whole point of competence-based training!

IO540

30th Sep 2011, 13:33

Some STARs at airports near mine are for prop and turboprops and others are for medium and large jets.

I don't think there is any airport in Europe which has a significant traffic density and which actually operates the STARs which it publishes (usually about 50 of them :) ).

It's all radar vectored, and ATC don't have a problem with that.

If an airport goes procedural, its capacity falls by a factor of several times.

SIDs are operated more than STARs but at the busiest airports you get taken over by radar anyway, when departing.

Anyway, GA won't be going to any of these airports (just as they don't currently) because the management there has set up a price-fixed handling cartel comprising of Signature and Harrods handling at £400 a pop :)

Why on earth the whole IR issue is not addressed with a view to making it more akin to the US model is beyond me

BECAUSE the USA is AMERICAN :)

Fuji Abound

30th Sep 2011, 13:48

I think Timothy's comments are more directed at operations into Dublin, Geneva, Prague, Barcelona, etc. rather than Southampton, New Castle ....

That may well be so, but, as I said they are hardly common GA destinations and I on the occasion I went to Dublin and Geneva didnt have a problem, I have no idea about Prague or Barcelona.

IO540

30th Sep 2011, 13:55

Prague is a piece of cake; very relaxed. Radar in and out.

Barcelona I don't know, but Spanish ATC is something else :) Last time I went that way they gave me a DCT to Valencia and changed their mind after a few mins to a DCT to Barcelona...

When I was departing from Valencia (http://www.peter2000.co.uk/aviation/valencia/index.html) the following day, some anonymous Ryanair pilot, who had been calling for a departure clearance for about 20 mins, said "welcome to the 3rd world of Europe". ATC didn't comment; prob99 this exceeded their ICAO Level minus 5 English Language Proficiency.

Timothy

30th Sep 2011, 14:14

I was really more thinking of something like Liege to Denham or Edinburgh to Biggin.

IO540

30th Sep 2011, 14:19

Is this not possible at present?

Timothy

30th Sep 2011, 14:23

This is how these threads meander:ugh:

Yes. It's possible now.

Will it be possible with twice as many GA aircraft in the system?

Four times?

Twenty times?

That was my original question 100 posts ago.

IO540

30th Sep 2011, 14:28

And you are expecting an answer from who? God? Eurocontrol? (same thing)

I wrote mine somewhere back.

Pace

30th Sep 2011, 16:17

Timothy

Flying airways is not always the best option and probably better suited to long trips.
Even moving the Citation I make cost decisions do I fly the pocket rocket VFR below CAS and make the trip from A to B in 25 minutes or file IFR and take 45-50 minutes.
Flying low level IFR in the south of the UK in something like a Seneca is a pain in the kneck. Very often you are routed by ATC in totally the wrong direction and away from everywhere ATC dont want you. Your trip and costs go up dramatically. You end up thinking whether its worth it?
The same will go in many areas of Europe. Trundle down the west coast of france and you may be ok.
Then what aircraft? Is it worth struggling a typical non turbo piston into the levels to get in airways? taking all year to get there?
Go further north into Scotland and how often will you get conditions which allow you to become VMC for a VFR flight at your descent waypoint.

I actually wonder how useful in reality this EIR is going to be?

Pace

Fuji Abound

30th Sep 2011, 19:45

Anything North South North of less than a couple of hundred miles is a complete waste of time airways in the UK. I can cover pretty much anywhere in that distance in not much over an hour and in all but the worst of weather its better to stay below or in it as fight your way up and back down.

IO540

30th Sep 2011, 20:15

That is true - except in the winter in a scenario like

OVC005
Tops 5000ft (stratus)
sfc temp -3C

You can't fly at 400ft :) and you won't want to fly 200nm OCAS i.e. at 2400ft / 3400ft / 4400ft because you will be in IMC and are more or less guaranteed to pick up structural ice over that distance.

If you have an IR, you can climb up to VMC, fly the 200nm at the lowest practical IFR/enroute level (FL090 plus; I would just go for FL140 because that is where the Eurocontrol routings get good and there is less risk of dropping out of CAS which causes London Control to instantly drop you back to London Info and then you are screwed again) and descend at the far end.

Notably also if the tops are 5000ft then you can prob99 climb to VMC while OCAS (e.g. FL054 if on the south coast) and this means you are not going to get trapped in hazardous wx while waiting for the IFR clearance; you can zoom up to FL054 on your own and be in sunshine while waiting for the powers to be to get their act together.

BTW, regarding the postings which fairly forcefully claimed the the EIR is just an IR with a higher MDA ... AFAICS this is not true because of the ban on flying STARs. The upshot of this "little detail" is that if e.g. your enroute section was at FL100 then the EIR is an IR with an MDA of FL100. I suspect this is a c0ckup.

blagger

30th Sep 2011, 20:34

except in the winter in a scenario like

OVC005
Tops 5000ft (stratus)
sfc temp -3C

My plan for that scenario would be to head to my local with the paper and stay there for the day :)

IO540

30th Sep 2011, 21:02

OK but that means no flying during much of the winter.

My scenario can be expanded to more benign ones e.g.

SCT010
Tops 3000ft (blue sky visible through holes)
0C

You would not fly 200nm in that, in southern UK, OCAS.

Pace

1st Oct 2011, 08:10

10540

I would be very cautious of taking off where the temperatures meant any ice I picked up I would hold to the ground.
That is especially true of low powered non deice/anti ice piston singles.
It is hard to determine tops and whther those tops 40 miles down road dont go up.
My best friend a ferry pilot was killed in such an aircraft believing he could get between layers and out of icing.
Its ok picking up ice if you know that dropping to MSA will see the lot melt off.
With any IFR/IMC flying the pilot has to be up to the job but being up to the job means knowing and respecting the limitations of his aircraft.
If both pilot and aircraft are up to the job thats another matter.
Usually icing to the ground and fog are the two states which concern me and I fly all year in almost anything but the smallest aircraft I fly are deiced anti iced turbo Seneca 5s.
I would be very cautious in anything serious if its a single piston.
I do know what you are getting at but just add that word of cautious for our newer less experienced IMCR pilots.

Pace

IO540

1st Oct 2011, 08:30

I would be very cautious of taking off where the temperatures meant any ice I picked up I would hold to the ground.
That is especially true of low powered non deice/anti ice piston singles.
All true but there are degrees of it.

If you have a base of say 1000ft and you can see blue sky, and there is no obvious substantial vertical development, the tops will be about 3000-4000ft, and rarely if ever will ice be picked up during a +1000fpm climb.

It is hard to determine tops and whther those tops 40 miles down road dont go up.You can get a pretty good view of tops (http://www.peter2000.co.uk/aviation/tops/index.html) from various sources e.g. satellite IR. The general situation is also apparent from the MSLP chart; in a high pressure area between fronts the conditions are going to be fairly uniform in the winter, and the preceeding 0000/1200Z ascent data can often be used. But there is no data source which will tell you if the tops are 4000ft or 6000ft, so if the base of Class A is FL055 then this cannot be used for IMCR type flight. But it can be used for IR flight, where you would climb straight to FL100-150 etc.

It needs to be done intelligently, but one needs to be careful to not simply ban all flight in any IMC if the surface temp is below 0C. But yes this issue (landing with any ice picked up) does particularly cripple flight on the IMCR in the winter.

Pace

1st Oct 2011, 09:00

10540

Really for any serious flight you need approved anti/de ice. I scared myself silly years ago in a Saratoga with a pre forecast front moving west to east and me flying north to south from Scotland.
It was just the situation you mentioned happily on top at FL6O below CAS with freezing levels well down into the terrain below.
Staying below airways the aircraft entered cloud and iced up forcing me to climb.
Eventually breaking out into final blue at FL120. Yes in CAS but having informed ATC of the problem.
That was in the days when you could speak to a met briefing guy who told me that I would beat the front if I was off before X time.
FL120 was it! No more climb covered in ice. Not a good situation. Glad when I cleared the frontal system down near Liverpool :E
Suppose thats what they call experience :{

Pace

IO540

1st Oct 2011, 09:48

Yes but you are talking about crossing fronts with sfc temp below zero, which is a different magnitude of risk altogether.

I would never do that and I rarely go anywhere near fronts (except fly straight over the top, enroute, up to FL200 if necessary) even in the summer.

Once, flying with an instructor "who knew everything" (but it turned out had never been anywhere) I was collecting ice rapidly at FL090 over Germany, in August. We had to descend rapidly from FL120 to 080. Best to not play with frontal wx at all, unless you have de-ice and radar :)

Another risk in departing with sfc temp below zero is that any delay in collecting the IFR clearance from London Control is going to put one in hazardous wx, for an indefinite period. So a departure from an unmanned airfield, or one which can't/won't call up LC for the initial clearance, is a no-no if the cloudbase is low.

Pace

1st Oct 2011, 10:25

10540

That is the whole point with long distance flying which knowing about you you have to an art to.
But with this new EIR we are not talking about pilots with experience like yours.
Summertime and you can still be in freezing levels at 10 to 12K. Trundling up and down to the S of France at FL380 or FL390 in the Citation I fly gives a good picture of weather below and it is rare to NOT have fronts of one kind or another for part of the route.
Pilots using the EIR on long distance flying (which will be its main use) Will have to be extra vigilant and selective of when they go especially the Newbie guys and especially in non turbo, non deice/anti ice low powered piston singles.
VFR MAY be the better option? At least you can do a 180 and land somewhere back from whence you came.
They wont all have guardian angels like I have had in my past.

Pace

Timothy

1st Oct 2011, 10:41

Pace,

There is another risk multiplier here, which is that picking up ice does not necessarily mean instant death. I'm sorry about your mate, but his experience does not mean that an unexpected ice encounter in a non-deiced aircraft will kill everyone.

So, if we accept Peter's suggestion that (if you are educated and sensible) mostly there will be no icing, then multiply by the Timothy factor that even if you do, you will almost certainly survive, you end up accepting that death by icing is a rare event which you can rank with death by suction failure or death by engine failure.

Pace

1st Oct 2011, 10:53

Timothy

Totally agree! Thought that was what I said which is basically you have to respect the weather as well as your own and your aircrafts limitations. Then this EIR will work well.

Sadly some wont and I can see no end of problems that the EIR as it stands does not address.

Pace

IO540

1st Oct 2011, 11:18

But with this new EIR we are not talking about pilots with experience like yours.Perhaps true, but I don't see a difference between that and somebody going off to an FTO and doing the JAA IR right now (as I am doing, as it happens). You still come out knowing minus zero, zilch, b*gger-all, nothing, nowt about the practicalities of IFR in light aircraft.

You won't even know how to generate a Eurocontrol acceptable route from say EGKK to say LKPR, and maybe that offers a good protection from icing conditions ;) ;)

In fact I would say, only partly tongue in cheek, that the reason why the present training system hangs together and has hung together for decades is because most people who pass through it either rarely if ever use the privileges, or they don't fly at all (maybe fly a kite) until they get a RHS job in a +6000fpm-capable deiced tank with radar and an old training captain in the LHS.

What is one going to do about that?

EASA doesn't offer a solution. Nobody else does and nobody else ever will because that is how it has always been. The business model is to sell training time and flying time, not to produce pilots who can fly from A to B. If you were to do that you would need to do scenario based training which nobody is doing (in Europe) and it probably would not be ICAO compliant unless you lumped it on the end of the existing sterile stuff.

Fortunately the accident stats suggest that most people are smart enough to fly conservatively, or some unknown % don't fly at all.

Actually I think the uptake of any IR will always be largely limited to aircraft owners, or members of the small number of wholly-IFR syndicates, and these people tend to have the motivation to get clued up. They would get clued up whether they have an EIR or the full IR.

My biggest gripe with the EIR right now is the ban on SIDs and STARs. I think that is simply a c0ckup, done after the whole thing was drafted. The requirement to cancel IFR at the terminating point of the enroute segment, say FL100-FL150 or whatever, is barmy. You could be 50nm from the destination for which you got the tafs and metars, and will have to proceed in VMC, presumably along the STAR route you would have flown anyway (ATC are not likely to want you anywhere else) and then hopefully you will encounter the weather conditions expected.

Pace

1st Oct 2011, 12:50

My biggest gripe with the EIR right now is the ban on SIDs and STARs.

Probably because they dont want some PA28 flying along the Star at 90 kts with half a million fast jets occupying the same airspace?

Your comment regarding weather is a big mistake by EASA. Legally and this is an EASA requirement! What is the point of getting destination weather if your descent point to VFR is 50 miles away?

Really makes you wonder at the knowledge some of these EASA guys really have.

" I followed EASA Requirements and got CAVOK at destination but lost the plot and declared an emergency when I tried to descend into VMC and VFR 50 miles out at my descent point and saw nothing with high terrain below?"

Pace

IO540

1st Oct 2011, 12:54

Probably because they dont want some PA28 flying along the Star at 90 kts with half a million fast jets occupying the same airspace?

They won't be, however.

They will be vertically separated by at least 1000ft.

And most of the time, at most relevant airports, there will be hardly any traffic there anyway.

But the STAR ban is illogical because there is no obvious way to check for VFR wx at the STAR termination (entry) point.

Pace

1st Oct 2011, 13:16

10540

We both know with any IFR/ IMC flying the safest way has to be in CAS from takeoff to touchdown.

Any IFR /IMC less than that has to be less safe.

Take away the approach and instrument landing or departures that the IMCR has and it all becomes less safe again! and with more room for error in transition from IFR to VFR and transition from IMC to VMC not following a procedure.

That cannot be disputed by anyone! especially with no weather at the point you make that transition.
EASA will have to build in a plan B in that eventuality?

IMO EASA will have to build in set procedures to follow if you do not become VMC and VFR in the descent from the descent point by MSA or they will have to strictly limit the airports you can use for these sort of EIR flights?

Pace

Timothy

1st Oct 2011, 13:42

Pace,

I think you just confounded a bunch of things. Yes, the safest thing (whether VMC or IMC) is to be IFR in CAS all the way.

But very often that is not an option. The two obvious exceptions being VFR airfields and IFR airfields outside CAS.

I don't have any stats, but I would suggest that the proportion of flights that an EIR makes, which by definition are V/I/V, which never leave controlled airspace are very small. Most EIRs will be based in Cumbernauld, Popham, Blackbushe, Biggin and so on. There will, of course, be some at East Midlands and Teesside, but they will be the exception by, I suggest, an order of magnitude.

Once you accept that most EIR flights (and GA IR flights for that matter) will have an OCAS element, and a substantial proportion will have a VFR airfield at one end or the other, a lot of these theoretical objections begin to evaporate.

If I were to characterise the EIR flight, it will be from Blackbushe to Troyes. It will be executed exactly as such a flight would be executed today VFR, with the same eye to weather, except that it will be flown in comfort and safety at F090 for the bulk of the flight, and only the two ends will be scrabbling around uncontrolled, low level VFR, just as now.

Pace

1st Oct 2011, 16:23

Timothy

I fully understand what you are saying. I have operated in airports OCAS for years in Senecas and other twin props some disused in a Cessna Crusader.
I am fully familiar with creative approaches, spatial awareness and flying on the edge.
Maybe why i am highlighting what I see as shortfalls in the proposed EIR.
Some are purely legalities such as getting weather which is irrelevant to your descent point! Asking what do EASA propose that you do if on leaving your descent point at MSA you are not visual?
Not such a big problem into a small IFR airport with good weather but a big problem in bigger airports.
The EIR who has a problem enroute with airports below giving RVR 700 overcast 300 ? What do EASA suggest the EIR does then.
These are real concerns through experience not made up in my mind!
It's a bit naive to think the EIR will take off in good weather sit happily at FL100 and plonk down VFR at the other end.
He might have that but life is never so simple.

Pace

BEagle

1st Oct 2011, 16:24

A quick update - the NPA workshop went extremely well on 30 Sep. Constructive suggestions were made regarding all 3 topics (EIR, 'new'IR and Sailplane Cloud Rating).

Of note is that the previously perceived 'dangerous' elements of the EIR, namely the IFR-to-VFR transition and the rather imprecise 'reasonable expectation' of VMC at destination have now been addressed satisfactorily, although further refinement will follow the NPA response. The EIR might complement, not replace the UK IMCR, so we now need to find a 'smart' way ahead for the future of the UK IMCR.

Capitalising on a comment made by a French conferee, I made a proposal which would effectively transfer an existing JAR-FCL regulation into part-FCL. Previously this might have been refused out of hand, but recent European Commission recognition of a need for greater flexibility for national needs now gives us the opportunity to exploit complementary flexibility for part-FCL matters. My proposal was strongly backed by the Europe Air Sports expert, so EAS and IAOPA will now work together to propose a formal amendment to the draft Rules which would provide a possible solution to the current problem regarding national qualifications such as the UK IMCR, the lack of regulations to facilitate non-English speakers flying IFR in their own airspace and the legal difficulties facing sailplane tug pilots at aerodromes with significant elevation. The intention is to take this further with some preliminary exploratory talks with the European Commission; however, EASA's chief rulemaker did NOT rule out such an option.

We also discussed the requirements for FAA IR holders 'converting' to the new part-FCL IR. Let's just say that there is considerable scope for relaxing the NPA proposals with regard to theoretical knowledge requirements, so any sensible responses made to the NPA will be considered.

When repsonding to the NPA:

Don't be silly or abusive
State the reference upon which you wish to comment
State your counter proposal
State the justification for your counter proposal
Compose your response off-line, then copy it into the CRT field!
Do NOT leave everything until the eleventh hour. Start looking at the NPA as soon as you can and learn how to use the CRT.

And the Champignonrahmschnitzel mit Bratkartoffeln was very nice on Thursday - as were a couple of Weißbiers chased later with a couple of Jaegermeister!