Mechanics of Arrivals with EIR

[dublinpilot]

Could someone more familiar with IFR flight explain to me how arrivals might be done for a pilot holding just a PPL + the new EIR.

The pilot can take off under VFR climb on top of an over cast layer (or into it) join an airway and continue unhindered to close to their destination.

That much is clear to me, but I'm somewhat less clear about how the arrival end would operate. I understand that the pilot needs to be VFR by the Initial Approach Fix. How would someone do that in practice?

I understand that the EIR pilot can desend to 1000ft above the highest obstacle within 5nm. Presumably this will always be lower than the minimum altitude for radar vectoring. If so, am I correct in assuming that the first step would be to tell the controller that you can't accept an IFR approach, and ask for a radar vectored desent to the base of the radar vectoring area?

If visual by that point you can change to VFR on continue.

If not visual by that point, but you were still higher than 1000ft above the highest obstacle within 5nm, can you desend lower accepting your own responsibility for terrain clearance? Is this what would be done in practice or would this be considered foolhardy?

If neither of these options got you VFR obviously you can divert. Would it be considered reasonable practice before opting to divert, to climb again, travel to a different area where terrain is lower and try again there, even though this might be outside controlled airspace? Or would this also be considered foolhardy?

In consideration of a slightly different scenario, imagine that the reported weather at he destination was marginal in terms of 1000ft above nearest obstacle within 5nm, the pilot might decide to try to get visual 50nm+ away from the airport where the weather had been reported better, or perhaps the terrain lower. They desend out of the airway expecting to find VFR conditions lower down. However they don't find those conditions. Is it easy to get back into the airways at that point, or once having left 'the system' is there a big delay in getting back in? I imagine if the pilot would like to continue to their destination and try there or divert to somewhere else, they would prefer to do that within the airway system.

I appreciate that some of this is new in the sense that an enroute IFR capable pilot who can't fly an instrument approch is new, and as such perhaps only guesses are possible, but those who currently fly IFR have a much better chance of knowing how this is likely to work in practice and what's acceptabe and what's not, then my VFR only self.

Thanks
dp

[Genghis the Engineer]

I suspect that, if approaches don't become permitted, EIR holders will have two choices:

(1) Can see the ground, descend visually.

(2) Pick a line known to have appropriate (i.e. flat and low) terrain without obstructions, and descend along it: using VOR or GPS most likely, until either breaking cloud at above 999ft agl, or failing to and thus climbing away to divert to an alternate where the procedure is repeated.


I suppose that (2) could be, say, along an ILS or other instrument approach, just it can't legally be an instrument approach? SRA would become radar vectors presumably, and the IFR MSA would be the obvious cloudbreak altitude unless you've pored over the chart and found a lower figure.

G

[IO540]

I understand that the pilot needs to be VFR by the Initial Approach Fix.

You may be right but that is not necessarily how I would play it.

I would file a Z flight plan i.e. VFR to IFR to VFR.

This specifies the two VFR transition points; usually as airway intersections or navaid names (cannot use "Upper Warlingham" on OFR flight plans :) ).

I would not go to the IAF, necessarily, though that is a reasonable approach (no pun intended).

Presumably this will always be lower than the minimum altitude for radar vectoring.

Possibly, possibly not. The radar vectoring area which a radar controller works to is not necessarily obvious where it lies.

If not visual by that point, but you were still higher than 1000ft above the highest obstacle within 5nm, can you desend lower accepting your own responsibility for terrain clearance?

Legally, I doubt it.

Whether it is foolish depends on the due diligence you did before flying ;) For example a descent over the sea, on the way to a coastal airport, is a good candidate for a DIY cloudbreak.

Obviously, doing this to say Biarritz is not quite the same as doing it to St Gallen (Switzerland) :) At the latter one would need to be a lot more careful.

I think the intention is to use the EIR as an IR but with a higher MDA; typically 1000ft AGL.

Whether 1000ft MDA is valuable depends on where you are, and what time of the year. In southern Europe in the summer, during a nice high pressure area, it will be quite useful.

[500 above]

Oh dear...

"Whether it is foolish depends on the due diligence you did before flying For example a descent over the sea, on the way to a coastal airport, is a good candidate for a DIY cloudbreak."

God bless GPWS and TCAS...

The EIR is meant to make things SAFER! I agree that it will probably permit approaches albeit to a higher minima.

[bookworm]

I understand that the EIR pilot can desend to 1000ft above the highest obstacle within 5nm. Presumably this will always be lower than the minimum altitude for radar vectoring.

Where terrain clearance is limiting, MVA will usually coincide with 1000 ft above the highest obstacle within that sector of the airspace. While it may, in principle, be possible to get lower and still remain 1000 ft above the highest thing within 5 miles, it's not really something that the pilot should be expected to be able to do. Thus in assessing the conditions required, I'd treat the MVA as the level by which the aircraft must be visual. In transitioning from IFR to an arrival at an airfield without IAPs, that's essentially what one relies on.

As I've mentioned elsewhere, I think the mechanics (as you put it) of arrivals, and of departures for that matter, needs careful attention, including the detail of what goes into the implementing rule, the AMC and the GM. But I'm reasonably confident that a sensible solution can be found, even if it's not exactly what is in the current NPA. Let's just review what it says:

FCL.825(a)(2)
"The holder of the EIR shall only initiate or continue a flight on which he/she intends
to exercise the privileges of his/her rating if the latest available meteorological
information indicates that at the estimated time of arrival at the planned destination
aerodrome the weather conditions will be such as to allow compliance with VFR on
the approach and landing phase of the flight. On departure the holder of this rating
shall not enter IMC below 1000 feet above the highest object within 5 NM."

AMC1 FCL.825
"1. In order to comply with FCL.825 (a)(2), the holder of an EIR should not commence or continue a flight during which it is intended to exercise the privileges of the rating unless the forecast for the destination or alternate aerodrome one hour before and one hour after the planned time of arrival indicates VMC. If the required meteorological data are not available for the destination aerodrome, the flight should be planned to a nearby
aerodrome for which such meteorological information is available.

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)."

GM1 FCL.825 En-Route Instrument Rating
"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;"

* The prohibition on "arrivals" is unhelpful. Arrivals are effectively an extension of enroute. Some "arrivals" start 100 miles away from destination.
* Visual approaches (under IFR) need consideration
* Departures (under IFR, with the first 1000 ft flown visually) need consideration

In an environment where radar vectoring is the norm, it seems reasonable to allow radar vectoring for a visual approach -- many if not most operational IFR flights are conducted in that way.

For a procedural environment, you probably do need to be visual by the IAF, otherwise you'll end up flying some of the procedure without radar guidance. If we're going to match privileges with training/testing, and the training/testing does not include approaches, it doesn't seem sensible to allow even the initial approach to be flown in cloud. Is it reasonable to allow it to be flown visually? Maybe, though it could still lead to errors and confusion.

I think the underlying principle should be that the EIR holder is trained to fly a heading to reasonable precision, to fly a level where there's 1000 ft margin or separation, and to do a reasonable job of tracking a navaid or to a waypoint. If their life depends on doing something more precisely than that, they probably shouldn't be doing it.

I'm not sure about departures. They're not fundamentally difficult to follow, but it is a high workload time of flight. I don't think it's unreasonable for an EIR holder to follow a SID, as long as it's done visually for the first 1000 ft or so. The idea of departing VFR and getting a joining clearance sounds overly complicated. I hate doing that, particularly in marginal conditions, and I wouldn't wish it on an inexperienced pilot.

[mm_flynn]

Having re-read the NPA the process imagined seems reasonably straightforward.


you file a Y flight plan with the VFR transition before the IAF
The Y Transition tells ATC you will not be making an instrument approach
This is normal practice in countries that do not allow IFR flight plans into VFR only airports
I would expect ATC to descend you on track to your destination down to MVA. As a note, the NPA currently says Minimum Sector Altitude and my view is it should be the least of Min Sector, Min Safe, Min Vectoring altitude
At this point you are either visual with the surface in VMC and land, or not and 'miss' getting a climb and heading to your alternate or a hold to think/wait for better weather

This is how most light GA IFR flights recover in the UK (as most airports don't have instrument approaches). I fly IFR all the time out of Fairoaks and have had to hold once for a cell to go through and divert once. But most of the time the weather is good enough to get visual at or above the MVA.

PS - crossed with BW

With regard to departing 'not IFR' and picking up your clearance on the way... if only I was based at Cambridge or Oxford rather than Guildford ..... better universities AND Airports with approach control! Sadly all my IFR Departures are 'head west young man and ROCAS while we try and get you a join'

[Pace]

In many parts of Europe can see the ground descend visually can mean into a valley with mountains 7000 feet high around you! Not the best place to be.
Over the S uk not so risky!
My biggest gripe with the EIR is using weather actuals and TAFS for an airport which is not weather for the intersection point you leave CAS.
It's not a big problem if your heading to a fairly sleepy airport with few IFR arrivals.
I am sure ATC would be happy for you to fly a straight line at the MDA to their overhead where you know wha the weather is likely to be.
You can then descend to circuit bight and land.
Not so the case into a major airport where you would cause a few controller heart attacks.
In most cases the EIR will work but a plan be option had to be formulated in case it doesn't work.
Also to those who say ATC will descend you on radar many airports in Europe have no radar and have pilot interpretated approaches.
As previously posted my only other gripe is enroute.
You maybe happy as Larry at 10 K in the blue with all the airfields below giving 300 overcast RVR 700 meters!
No problems then no problems but a problem and big problems!

Pace

[bookworm]

This is normal practice in countries that do not allow IFR flight plans into VFR only airports.

And it's a perfectly good way of getting into an airport without IAPs. I'm just not convinced that it's the best way (for ATC, the pilot, or anyone else) of getting into an airport where 99% of arrivals are "vectors for the ILS or report visual and by the way can you give me 160 to 4d?".

[IO540]

That is my main concern over the EIR. The expectations of ATC, and one is not going to retrain ATCOs around Europe to deal with arrivals like that.

It would make sense for the pilot to cancel IFR somewhere further back than the IAF, terrain permitting. Then the flight is largely like a normal long distance VFR flight, except one had an IFR clearance enroute.

Not being able to fly STARs is just daft, because they start a long way before the airport, and I don't think most ATC will be fond of VFR traffic in that airspace (the pilot having cancelled IFR before the STAR starts) - regardless of whether the pilot is flying along the STAR route, or is trying to drop out of CAS or whatever.

Same with SIDs, which are basically trivial (like STARs).

I have no problem with a rating which is IFR enroute only, but they need to tie up the end portions so they make sense.

[mm_flynn]

And it's a perfectly good way of getting into an airport without IAPs. I'm just not convinced that it's the best way (for ATC, the pilot, or anyone else) of getting into an airport where 99% of arrivals are "vectors for the ILS or report visual and by the way can you give me 160 to 4d?".
I think realistically the EIR is not for pilots who want to go into those type airports (i.e. the ones that stream 99% of traffic into a radar vectored ILS with a 'maintain 160 to 4d' speed) in marginal VFR (probably not at all).

Going in to the major air carrier airports and trying to transition to VFR in the middle of a STAR or at the IAF is not really going to work very well. At these airports I think you either need a full IR and be able to follow the procedures end to end or you need to drop out of IFR into a standard VFR arrival some distance out (this is clearly going to require somewhat better than EIR minimums to avoid visiting your alternate location). I have never had the 160 to 4d kind of requirement at a 'sleepy' airport (other than Shannon on the day the UK ATC system fell over and everyone was diverting in ... and it was OVC002 as well!).


Pace - yes of course there are European airports in tough terrain. Quite a lot have no approach at all, so yes you are in a valley under a cloud deck. Or at Sion making your VFR transition at FL170 with a steep visual approach down the mountain (now that the ILS is U/S). These things happen today and need some good judgement to avoid problems.



-------
I re-re-read the NPA and it does in fact say the transition point must be prior to the IAF

[IO540]

I think realistically the EIR is not for pilots who want to go into those type airports in marginal VFR (probably not at all).IME, loads of airports in Europe employ SIDs and STARs but are "OK" for GA. Not microlights/permit types (who won't pay more than a tenner :) ) but people doing longer flights in normal planes.

In the wider European picture, an airport which charges £80 is not considered outrageous. I've just been to Greece and back (LGKC, also LSZR, LGKR, LJPZ) and this kind of thing was fairly normal. These places either operate procedural arrival/deps, or use radar vectors.

The idea of departing VFR and getting a joining clearance sounds overly complicated. I hate doing that, particularly in marginal conditions, and I wouldn't wish it on an inexperienced pilot. Actually that is a nasty situation, for an IR holder too, because until one gets the IFR clearance one is supposed to maintain VMC, and the typical IR holder is no more likely to be carrying VFR charts plus a GPS running a terrain map ;) than the holder of something lesser than an IR... And it is not confined to other countries; one gets it all the time here in the UK, with London Info taking anything up to 30mins to do the handover to London Control, by which time one could be at FL074, collecting ice, etc. just below the base of Class A. Last time I did this I was in French airspace before I got the IFR clearance :) And the UK is organised; last year in Greece I never picked up the IFR/C before I landed an hour later. But this is all a "tactical operational" piece of knowledge, which anybody can be taught by somebody who knows about it. I don't think it is a bigger issue with an EIR because he will have to depart "VFR" and then try to pick up the IFR/C around his filed VFR/IFR transition.

[Fuji Abound]

It would make sense for the pilot to cancel IFR somewhere further back than the IAF, terrain permitting.


I dont see it that way.

I gave before the example of Southampton.

The IAF is almost overhead the airport at SAM, traffic would normally be positioned at 3,000 feet but down to 2,000 feet is available.

As I indicated earlier Pace's concern in this example of descending outside the ATZ and encountering weather other than as indicated by the METAR at the destination is not of concern. I would expect the cloudbase at the IAF to coincide with the METAR.

We all know the easiest way of positioning for both pilot and ATC are vectors. I cant imagine why a EIR pilot would want to cancel IFR before the IAF if a vectored "arrival" were available. In the alternate I also dont see why he wouldnt want to self navigate to the IAF with all the extra protection that would afford. In short what would he have to gain by making up an earleir descent?

So you would ask for vectors to the IAF and request a descent to the minimium available altitude. In all but circumstances where the METAR indiates the cloudbase is on the base of the IAF you know you will be visual, so job done so far as that goes.

I dont see this process would be disruptive to ATC or other aircraft.

It seems to me it gets a bit more complicated after you have pitched up at the IAF. What happens next?

If you are visual it seems to me you and AT have two options. You either continue with the procedure or position for some form of non procedural visual approach. I would have thought flying the procedure in VMC would make more sense in terms of fitting in with other traffic and in terms of ATC being better able to sequence the traffic.

If you are not visual matters are even less clear. Presumably the options would be to request ATC to reposition you for another go which might involve putting you in the hold (but are you entitled to be placed in the hold in IMC), or request ATC to provide you with vectors away from the airport towards your alternate with possibly an airways climb. Both seem to me procedures which are not well rehearsed at the moment by either pilots or ATC. Of course for the reasons given earlier this should rarely happen and only in circumstances where the base is very close to your minimium at the IAF.

It is for that reason that I suggested earlier it still seems far more sensible that if not visual at the IAF the pilot should be entitled to accept vectors to the top of the G/S and only if not visual at the top of the G/S would he be required to break off the approach. It seems to me this makes more sense because the aircraft would continue to be sequenced in exactly the same way as the rest of the IFR traffic and if a go around was required the traffic would simply fly the published missed in the same way as any other pilo breaking off from an IRated pilot's minimium DH.

[Contacttower]

I hope everyone is putting their thoughts in reply to the NPA; it certainly seems like there are a lot of opinions on this out there...we won't get a sensible outcome unless we comment. :ok:

[IO540]

Where does one put comments?

[Whopity]

Where does one put comments? EASA CRT application (http://hub.easa.europa.eu/crt/)

[IO540]

I've just added a comment on the SID/STAR ban issue on the EIR.

However, on a quick skim of the TK syllabus (few people are going to read the 150+ pages) I see a whole load of garbage e.g.

"State where flight level zero shall be located"

What kind of a question is that? :ugh:

There are quite a few more. In a minute or so I found a whole pile of total garbage which will be a b*gger to memorise without a QB.

Whether this is all a step forward depends on where one stands. What has happened is that EASA has shafted the whole FAA licensed pilot community, which are basically Europe's highest-hour, highest-currency, best-equipped, and probably safest pilots, and has now given a bit back, and the "bit back" is being picked over like it is some kind of treasure trove.

Overall, it is a giant step backwards for all the existing pilots because even they have to sit the near-total-bollox exams, for absolutely nothing, nowt, zilch. But yeah it could be worse. EASA could have banned all PPL/IR flight, and for that we must be eternally grateful :ugh:

It is a step forward for ab initio IR pilots, because the new IR is significantly more doable, but it could have been a lot more relevant. What we will have is what we have today under the JAA IR which is a system turning out pilots who can fly IFR from exactly nowhere to exactly nowhere else, because nearly all the theory was absolute crap, and the training was just to pass the flight test which itself bears little relevance to going somewhere.

It's a missed opportunity.

[421C]

A few comments on this interesting discussion. First, there is a version of the NPA here: http://www.pplir.org/images/stories/pplir_files/fcl008%20npa%20with%20markups.pdf which has some bookmarks and sticky notes on the sections that might be most of interest to FAA IRs, IMCr holders and ab initio IRs; the bookmarks in particular make it easier to navigate the 200+ pages than in the original.

Pace:

I find myself thinking that you are coming at the EIR from a different place. I don't know you personally, but I think I've read a bit about your background, so let me illustratively position you as someone with "pro piston twin IFR experience". Well, that kind of experience can be some of the toughest flying around: especially if it's something like night freight and I guess it was even more so in the "old days" when AOC or Part 135 standards weren't enforced as hard. I've heard stories of pilots transporting bank cheques etc who basically flew piston singles and twins in any conditions whatsoever or their jobs were on the line. I've never done anything like that, but as a private IFR pilot with a reasonably equipped twin (deice, WX) at my most current (and more youthful) I've had runs of hundreds of hours (dozens of sectors, night and day, winter and summer, across Europe) without weather causing a single change to my desired departure and causing a diversion perhaps one in 50 sectors. At that level, weather planning is simple and binary - destination and alternate above minima and you go. You cope with enroute weather and weather worse than forecast ad-hoc.

However, I've also flown similar long routes as an IMCr pilot (ie. with no privileges in Europe). There the mindset is very different. You want every reasonable chance that you could complete the flight, or you depart perfectly prepared to turn back or divert. My success rate on "desired" departures was perhaps 30%-70% between winter and summer. I've flown hundreds of hours in Europe like that. I've NEVER EVER had any kind of arrival problem based on the planning criteria I used. Plenty of enroute struggles either to stay on top or scud run below, but never on arrival. Why? Well, what was the point of trying to fly a light airplane on a business trip or to a social event when the odds were significant that you couldn't descend to arrive at your destination VFR? The "go vs no-go" decision-making and the weather planning are completely different from the disciplines in "hard core" piston IFR.

Of course one can always conjecture worst-case scenarios that look undesirable. You can do that for any pilot, PPL-only, EIR or IR - especially at airports with difficult terrain. My point is that the EIR weather planning mindset will need to be much more like "a PPL with a bit of extra privileges" than a "hard core IR with a limitation" to make it safe. I think that is perfectly possible - GA safety entirely depends on pilot judgement, however much we obsess with the regulatory side. I don't think there has ever been a pilot qualification which, if used to the maximum of its legal privileges, without any additional good judgement and discretion, wouldn't be a hazard. The regulations set some necessary boundaries, but that doesn't mean we fly to them every time or any time in private GA (unlike the "tough pro piston" environment I mention). I know capable pilots with turbine aircraft who avoid flying to minima or with risk of storm weather. I know IR pilots who plan weather with great skill and care to assure they fly in conditions their pax will enjoy on long trips. The analogy is obvious with the EIR - you don't plan to fly to some mountain airport with a forecast OVC 100' above MSA, maybe even not to any airport unless it's BKN 1000' above MSA or OVC 2000' above MSA. Whatever the safe margins are.

Let me give you another example. Non-deiced singles and icing. Imagine a universe in which no aircraft had ever been certified for IFR unless it was FIKI capable. Then someone proposes to certify a C172 for IFR. Icing is potentially very hazardous, and incredibly difficult to forecast. The regulation is pretty "lax" about icing - no "known" icing under the FAA and no actual icing under EASA. Based on this I could give you all sorts of disaster scenarios with cloud and freezing levels unexpectedly below MSA etc etc etc. But, in practice, pilots manage the risk effectively by having a more cautious approach than the legally possible limit. I think the EIR will be safe in a similar manner.

Fuji:
I gave before the example of Southampton.

The IAF is almost overhead the airport at SAM, traffic would normally be positioned at 3,000 feet but down to 2,000 feet is available.
IAFs overhead airports are common, but rarely used under radar except in training. Even in a procedural environment, RNAV approaches mean the days of the overhead IAF are near an end. I can not believe Southampton would ever want someone doing a VFR arrival from the overhead!

We don't need to make this more mystifying and complicated than it is. People already fly enroute IFR in airways terminating with a VFR arrival at an IFR airport day-in day-out. We are not inventing something new! You do it when the ATIS suggests a VFR arrival is going to be fine and when you want to avoid the faff of vectors to the ILS or some convoluted routing in the arrival. (or in the Nice TMA to avoid slot restrictions until Nice banned it). The way you do is is to drop out of the IFR route by descent well before the IAF or the start of vectoring. You are never going to fly to the overhead at 3000', that's either silly for you or it's not going to work for ATC.

The other scenario we can look at is a VFR airport which is so close it is practically colocated with an IFR one. A good example is Palma and Son Bonet. How do you arrive VFR to Son Bonet off airways? You do it by descent well, well before you enter the vectored ILS pattern with a dozen jets at 200-160KIAS. No way in hell do you fly to 3000' overhead LEPA or to an IAF and then descend!

I think it's pretty simple. I don't think an EIR pilot will (formally) fly any part of a SID, STAR or approach. Those are not enroute phases of flight. Of course, any pilot should be able to maintain or change a level or heading under radar control, so there may be tactical reasons at certain airports where that's how ATC want to handle EIR traffic, by vectoring them along a terminal route. But in principle, I'd expect my VFR transition point to be the final enroute airway point or some other arrival point that may be specified in an airport's routing information published through the usual sources. (Obvioulsy, where the STARs begin 100nm out, the VFR transition point is going to be well after that)

People have written a lot about the EIR and I've seen the following "incremental creeping syllabus" suggestions
- SIDs from above 1000'
- STARs
- Approaches to 1000'
- A single approach type to lower (or IR) minima

....well, you know what, you add all that up and you would get to something very like an IR. Now that's nice, but it would mean something very like the IR training. The whole point of the EIR is that it offers a meaningfully easier training step than a full IR. No amount of jiggery-pokery with the privilege definitions, IMHO, is going to create the sought-after "euroIMCr" or "Class 2 IR" or whatever, without creating a training requirement which is very close to that of the IR. We could all stretch the EIR priviliges as far as possible in the CRT, but in the unlikely event of it being accepted, think how much of the 10hr training gap with the full IR we'd close.....4hr?5hrs?6hrs? What's the point of one qualification with 5hrs less training than a full IR? How does that encourage more than the present tiny minority to take a step towards developing skills and capabilities beyond the VFR PPL?

brgds
421C

[Fuji Abound]

The way you do is is to drop out of the IFR route by descent well before the IAF or the start of vectoring. You are never going to fly to the overhead at 3000', that's either silly for you or it's not going to work for ATC.



That is interesting.

I dont fully grasp your aversion to joining at our near the IAF.

I used Southampton as an example because from experience they will often vector you near the IAF (Now I agree it is not exactly overhear the IAF) before turning you out bound for the ILS join. If you know the cloudbase is above your EIR minimium, but within some hundreds of feet of it) I dont see why you would want to make up a descent beforehand and I dont see why it would cause ATC any issues at most smaller airports (my comments were not referring to the major airports handling a huge volume of CAT). That seems to me a lot more sensible than working away with the charts and making up your own descent perhaps many miles away from the airport while leaving the protection of CAS and having less assurance of the actual cloudbase where you expect to pop through.

I must be missing something?

[421C]

the "bit back" is being picked over like it is some kind of treasure trove.
By whom? This is arguing against a point no-one has made. No-one has said that compared with the pre-FRA restriction world, the proposed conversion is a wonderful thing. It's just much better than the present FCL outcome, and much worse than an outcome where the whole FRA things gets dropped, derogated or bilaterally treatied away.

Note that the wording of the theory requirements is quite vague. It is clearly NOT the new full (ie. reduced) IR TK. At worst, it's 4 of the 7 IR exams (ie. Air Law, Met, Flight Planning and HPL and not Instruments, Radio Nav and Comms). Those 4 I think are about 70% of the work, so it's perhaps a third or so of the present IR TK (ie. ~~70% of ~~50%). This is a big improvement, since I believe QB-based studying will be available for the new IR TK, as it is for the present exams. BUT, I say "worst case" because the NPA doesn't say you "must take those 4 papers", it says you must "demonstrate acquired knowledge of". I am not sure if that will be implemented as
- taking the 4 exams
- taking a single, composite exam, but a formal EASA one
- taking a single, composite exam at an ATO, the way the single HPA exam is presently done
- demonstrating knowledge in an oral exam with the flight examiner

It's para 8 p22 of the NPA and may be worth people commenting on in the CRT!

brgds
421C

[421C]

A couple of further points on the FAA IR conversion.
- I think it is an excellent thing for FAA IR pilots who might want to occassionally fly EASA-registered aircraft (or who in the future might want to buy one on the EASA-register and keep it there).
- Clearly any conversion is unwelcome for FAA IRs who want to stick with flying N-reg.

I think it is important to seperate the two! I don't think the conversion to a full EASA IR useable on any EASA aircraft is going to be any easier than the one proposed (until and unless we get a Bilateral treaty), except for the issue of TK where I think we should push for the less onerous options I mention above.

However, for the FAA IR sticking to N-reg aircraft, there is a precedent already in EASA FCL. Article 7.4 says


Aeroplane or helicopter type ratings may be issued to holders of Part-FCL licences that comply with the requirements for the issue of those ratings established by a third country. Such ratings will be restricted to aircraft registered in that third country.


The entire FRA problem could be solved with the insertion of the following 3 words at the start of the existing FCL Art 7.4: "Instrument Ratings and"

A lot of the push back on the FRA topic from EASA and EC stakeholders has been a bunch of nonsense about the EU "Basic Regulation" law of 2008. This certainly allows EASA to restrict FRA, but it doesn't make them. At least that is what is clear to me from the fact the Type Rating exemption is there in 7.4. I would suggest that FRA stakeholders lobby for this specific change.

[421C]

I dont fully grasp your aversion to joining at our near the IAF.

There are a number of reasons.

1. As you point out, it's not going to work for many IFR airports from ATC's point of view.
2. Obviously it's not going to work at VFR airports
3. Let's imagine an airport with IAFs and with no problem for ATC. Well, in this case, as a pilot, why do I want to be overhead at 3000' when I can plan a VFR arrival that allows me to be on the ground at the IAF? If the IAF isn't at the overhead, then it's likely to be miles and miles away from the routing of a sensible VFR arrival.

I am not saying there's never going to be a scenario of the IAF being the transition point to VFR. I just doubt it will be systematically so, and that in practice what could happen is pretty much as it is today for VFR arrivals to IFR airports (note: VFR arrivals, and not IFR arrivals accepting visual approaches) where I think IAP arrivals are less common (perhaps Soton is an exception).

making up your own descent perhaps many miles away from the airport while leaving the protection of CAS and having less assurance of the actual cloudbase where you expect to pop through I am afraid this is the essence of the EIR. A pilot who doesn't like it will need a full IR or to stick to VFR. But let's not escalate the enroute descent into something scary and abnormal. It's what private IFR pilots already do when they operate to VFR airports. This is not a special case. It is the norm, day-in day-out for many IR and IMCr holders.

brgds
421C

[IO540]

EASA will never put in those magical 3 words because if they did they would throw away the hammer with which they are trying to beat the FAA on the head, and which represents more or less the entire piece of meat which they have thrown to the dog representing all those interests (FTOs etc) which wanted the N-reg community shut down.

[421C]

You're probably right, but at least it would focus and force the discussion into those terms, rather than all the waffle and dilution about not being able to help FAA IR holders without a bilateral treaty.

It's also important (IMHO) to differentiate CRT comments between the full ICAO IR to EASA IR conversion, and the requirement for FRA pilots to have a conversion.

Clearly some pilots may want a conversion - eg. to fly EASA registered aircraft. My point is that the conversion proposed in FCL008 is vastly better than the present one. It, in effect, takes the proposed 1 year validation (see Annex III of FCL para A4) and makes it a full conversion. A great result. The full conversion is never going to be easier than this - it's no more onerous than the PPL conversion (ie. a written test and a flight test, but no training) and vastly easier than the basically non-existent conversion for CPLs and ATPLs.

The problem for FAA IR operators is the requirement for a full conversion. Therefore the right pushback on the NPA, I believe, concerns the case of pilots with 3rd country IRs who only want privileges to fly 3rd country registered aircraft. For me, that distinction and the precedent of how Type Ratings are treated in this case is useful.

[Pace]

421C

The interesting point is what they will do with current employed FAA ATPs to keep them employed should they be EC citizens without EASA equivalent licences ?
My understanding is they have legal problems in carrying out their requirements as planned

Pace

[Contacttower]

Is there any chat over on the Biz Jet forum about that?