EIR - maybe not such a bad thing after all?

[AdamFrisch]

Just recently back from a 3000nm return trip from LA to New Orleans (surprisingly without a single squawk - a first, bless her). Although I had to scud run in Texas and Louisiana to get under some nasty weather for 2 days, it was still VFR or marginal VFR.

The last days leg went from Lubbock, TX, to LA. Took off early, silky smooth air, beautiful trip all the way until I hit the LA basin - socked in uncharacteristically. An incongruous bunch of pilots took turns in getting through at Banning Pass (the only low level entrance into the LA basin) and the airport there, but all failed (myself included). Almost all of LA was reporting ceilings at 2000ft if one could just get past the pass. We were hearing joyous position reports from people at uncontrolled airports just on the other side of that bl**dy wet curtain of mist and clouds blocking the entrance. Taunting us. Surrounded by mountains and sea, no way around - can't come from the top, can't drop down over the ocean. I gave it a go twice, before I scared myself from trying again.

It was so frustrating to have to fail after 3000 miles only 30 miles from my home airport. Ended up having to leave the old gal at another remote airport and arrange all sorts of complicated and expensive means to get home/pick her up later.

The EIR would have gotten me in that day. And one wouldn't have needed more than an AI, a turn coordinator and a radio - instruments that exist in almost all aircraft. A GPS and a VOR would have made it even better, of course, but strictly not necessary. I'm thinking the EIR might be a good idea for those who just want a bit more utility, without planning on doing approaches to minimums. I will certainly expedite my IR training after this, but would gladly go halfway for an EIR in the meantime, if such a thing existed.

BTW, what is the latest on that?

http://www.adamfrisch.com/images/nola.jpg
In better weather.

[peterh337]

The EIR is indeed a useful thing simply because it is an additional privilege which doesn't currently exist.

It will be useful to pilots who are currently "clever" VFR pilots and who know how to play the game and are flying suitable aircraft, but who cannot currently climb above weather because ATC will not allow them into CAS because the particular ATC unit (or country) refuses to operate ICAO airspace classification (VFR is OK in all airspace except Class A). In fact the EIR will allow access to Class A as well - just like the full IR.

I can see the objections to the EIR but really it is no different to the present ability to fly VFR above an overcast which is already allowed in nearly all of Europe.

My main gripe is the ban on flying a SID or a STAR.

Where is it? Nobody knows. Probably wrapped up in the same fate as the CBM IR.

[bookworm]

BTW, what is the latest on that?

Awaiting the Comment Response Document from EASA.

[BEagle]

Awaiting the Comment Response Document from EASA.

Due for release 'in the summer'.......

Mind you, with 1556 responses and only 1 Review Team meeting (none other planned, it seems), glib responses such as 'noted' will be unacceptable.

Yes, the EIR would add en-route IFR privileges, but that's about all. Incidentally, the ANO PPL restrictions applicable to JAR-FCL PPLs without IMCRs ceased to apply after 8 Apr 2012 when such licences were 'deemed' part-FCL licences by the UK CAA. So you may fly out of sight of the surface without the need for an IMCR / IR if you wish - assuming you can get up and down again in VMC. This does NOT apply to non-JAR-FCL PPLs such as the UK PPL.

[IanSeager]

Adam

With an aeroplane like that in the US, an IR would make so much sense…

Ian

[BackPacker]

Incidentally, the ANO PPL restrictions applicable to JAR-FCL PPLs without IMCRs ceased to apply after 8 Apr 2012 when such licences were 'deemed' part-FCL licences by the UK CAA. So you may fly out of sight of the surface without the need for an IMCR / IR if you wish - assuming you can get up and down again in VMC.

Cute. I never realized that. So basically a plain PPL is now only restricted to whatever the local rules specify as VMC minima for the particular class of airspace involved? (And obviously those VMC minima may still specify "in sight surface".)

Any other hidden gotchas like that? For instance, is there stuff which was previously deemed "aerial work" which can now be done by a PPL, or the other way around? (The two main traditional exceptions obviously were glider tugging and parachute dropping, which could be done by a PPL "for free", instead of having to cost share.)

[peterh337]

The UK sight-of-surface for VFR was never in the slightest enforceable or even verifiable and I have never come across anybody who actually bothered to comply with it and who was able to radio-navigate. (one could say the same for VFR in IMC actually :) ).

It merely generated gigabytes of discussion on pilot forums :)

The way it was worded, seeing a mountain peak 100nm away sticking up from the cloud met with the requirement.

This (http://i101.photobucket.com/albums/m74/peterh337/alps-2010.jpg) would have met the requirement many times over...

[peterh337]

The EIR will be sub-ICAO, as will be the LAPL.

Not sure how this will be handled. The EU could force member states to file differences to ICAO on this, or they could do it individually. If this were done, then these papers could be valid worldwide unless specifically objected to by the airspace owner. But I suspect nothing will be done because, in general, Europe is big enough to fly around and flying outside Europe is a big logistical hassle (avgas, etc).

[AdamFrisch]

If the EIR becomes a reality, I wouldn't be surprised if the FAA followed suite at some point. They are very keen on harmonisation and EASA commonality these days. Last years "line up and wait" etc, etc.

I'm doing my IR as we speak, but the pace has been admittedly rather slow. This trip has certainly re-inforced the idea to ramp it up. With a bit of luck I could be done by late summer, maybe..

[172driver]

Well, Adam, first off, glad to hear the old gal is holding up well! :ok:

Given where you are, the full IR is definitely the better option. That said, something like the proposed EIR would certainly help in many, if not most, cases, especially for those of us flying non-deiced SEP spamcans. Quite often you can / could depart VFR but then need to punch through a cloud layer to get on your way. It may not be the perfect solution (that would be an FAA-style IR), but the EIR would definitely increase the dispatch rate - if one can use that term in an SEP flying context - greatly.

[mm_flynn]

If the EIR becomes a reality, I wouldn't be surprised if the FAA followed suite at some point. They are very keen on harmonisation and EASA commonality these days. Last years "line up and wait" etc, etc.

I would be. A rating which saves 25 few hours of instrument time (which in FAA land can be acquired in your own aircraft, with any safety pilot or instructor on any trip) but 7 torturous exams vs. one reasonably sensible one is not going to be in demand from pilot customers or flight training organisations.

The EIR makes sense in the strange IR world of EASA/JAA where the overhead assoicated with achieving the rating is grossly excessive. A halfway house between a PPL and IR in a world where you can get all the way to the PPL/IR destination in one economical (in comparison to Europe) step would seem like T!ts on a Bull.

[SunnyDayInWiltshire]

If the EIR becomes a reality, I wouldn't be surprised if the FAA followed suite at some point. They are very keen on harmonisation and EASA commonality these days. Last years "line up and wait" etc, etc.Why on earth would the FAA copy the EIR? Their existing full IR is achievable in less time and with much more relevant and proportional theory content. I can't believe that would happen.

The EIR may make some sense in some cases in Europe, particularly for IMC holders, but a more achievable CBM IR would be a better option.

[lasseb]

Note that the suggestion is not ONLY an EIR rating. It's a complete review of the IR rating. That means (if it is accepted) that the theory for getting a full IR will be significantly reduced!!.

I think most people with an IR can agree that there is nothing wrong with the practical part of the IR course, but the theory part is WAY overkill.

What the current document describes is both a reduction in the theory (and it will be the same for IR and EIR), and the possibility to first go for an EIR, and then later take the additional 25 hours and get the full IR.

[peterh337]

I think most people with an IR can agree that there is nothing wrong with the practical part of the IR course

It depends on which one you mean.

The current 50/55hrs is way over the top. While the average ab initio pilot probably needs 40+hrs to pass the northern European IR flight test (IRT) what about those with previous experience? They are just burning money to get the logbook entries, which all have to be done under an FTO, which is expensive.

The CBM IR will retain the present IRT, which in turn means that very few people will be able to take advantage of the proposed zero-training IR conversion option.

[421C]

The CBM IR will retain the present IRT, which in turn means that very few
people will be able to take advantage of the proposed zero-training IR
conversion option


CB means "Competence Based", not "zero-training". There are some tweaks to the IRT coming and some already in place but not properly implemented in the training system. I think the general trend will be an IRT which is less dependent on the ADF work, uses more GPS...and frankly is more like real IFR. No-one expects to do an Initial Test with zero training.

I think the proposed FAA to EASA IR conversion is actually pretty good (one exam and an IRT, no mandatory training), the problem is the silly requirement for 100hrs PIC Instrument Flight Time. Which unless studying the inside of clouds is your hobby takes 500hrs of IFR...

[Hodja]

the problem is the silly requirement for 100hrs PIC Instrument Flight Time.So 100hr of real or simulated *IMC* is required for the conversion, and not just 100hr logged on IFR flight plans?!

[421C]

Yes, that's how it's worded. It is also as PIC, so instrument time during training would not count.

[peterh337]

I think the proposed FAA to EASA IR conversion is actually pretty good (one exam and an IRT, no mandatory training), Where is the reference to the 1 exam? I have seen the LOs (the syllabus) but AFAIK nobody has actually stated how many exam sittings which will translate into, and crucially whether there will be a QB. Absence of a QB dramatically jacks up the workload.

Nobody will pass the IRT - not even a 20k hour airline pilot, and probably especially not a 20k hr airline pilot, without a good number of hours with an instructor familiar with the requirements.

That's why I think the "no mandatory training" part is essentially worthless, while being politically highly provocative (to the FTO industry) and this probably led to:

the problem is the silly requirement for 100hrs PIC Instrument Flight Time. Which unless studying the inside of clouds is your hobby takes 500hrs of IFR...A lot more than 500hrs IFR. More like 1000-2000hrs IFR, for anybody flying IFR "normally" (i.e. in VMC at high altitude) and not merely flying "VFR" in IMC at low levels to avoid route charges in a plane which is over 2T. Which one might think twice about logging in certain countries which prohibit IFR OCAS ;)

I actually wonder what the point of this conversion option is at all. If one pretends one doesn't have any ICAO IR and just does the CBM IR as ab initio (which one is obviously entitled to do) then the min dual training is 10hrs (which I am 99.9% certain will be required by 99.9% of candidates no matter how experienced), with 40hrs instrument time (which can include non-PIC time), so the extra cost is whatever the TK comes out to relative to the "1 exam". Is that correct?

If so, I cannot see what benefit the FTO industry is going to get by killing off the conversion route by demanding the ludicrous 100hrs PIC instrument time. The only extra workload for the student will be the extra TK and the FTOs don't make any extra money from that; the UK ones will still charge ~£1000 to take some homework off you and sign you off for the exams.

Hodja - the gotcha here is not that it is not IFR time (which is easy to log) but that the 100hrs instrument time has to be as PIC i.e. not under training. Most pilots flying normally accumulate very little instrument time because nobody deliberately sits in cloud, turbulence, icing, etc.

Actually I wonder about what "PIC" exactly means. For example if you do an IR in the FAA system, you log the lot as PIC because the actual flying is VFR, under the hood. Only the 250nm x/c flight is traditionally flown on an IFR FP, and only flights above 18000ft will have to be IFR in which case you cannot be PIC. It is only in the JAA system that training is implicitly PU/T. So I reckon an FAA IR holders' training will count towards the 100hrs. Not that that helps much...

[Hodja]

A lot more than 500hrs IFR. More like 1000-2000hrs IFRA 5% IMC ratio sounds about right. (if you exclude night IFR, which even in VMC is a "different" kind of VMC)

I actually enjoy flying non-turbulent, non-icing IMC. The problem is, around these part of the woods IMC equals TCUs & CBs...

[BEagle]

No decision has yet been made concerning the 'demonstration of knowledge' requirement for converting an FAA IR to an EASA CB-IR. Several other recommendations have been made in the NPA 2011-16 response, for example IAOPA (Europe) commented:

IAOPA(EU) considers that the demonstration of acquisition of knowledge can be satisfactorily assessed by the Examiner during the pre-flight preparation and conduct of the C-B IR Skill Test, supplemented if necessary by oral questions. It should be noted that the requirement for the holder of an IR issued in compliance with the requirements of Annex 1 to the Chicago Convention to sit further written theoretical knowledge examinations when converting to a EU IR is widely regarded as an expensive waste of time, which serves very little practical purpose.

An Examiner will be able to make a much more pertinent assessment of the applicant’s relevant knowledge; we strongly recommend that oral assessment in the manner described should satisfy the requirements.

Similarly, the '100 hrs IFR as PIC' proposal is unacceptable. So IAOPA(Europe) commented:

IAOPA(EU) considers that 100hrs of instrument flight time as PIC is excessive. Pilots with considerable flight time under IFR would be disadvantaged; there would be safety implications for a pilot to fly deliberately in IMC, with the attendant risks of turbulence and icing, merely to reach the 100hrs requirement. We therefore recommend that sub-paragraph 8(d) is reworded as follows:

8 (d) have a minimum of at least 50 hrs of flight time under IFR as PIC on aeroplanes.

We remind the Agency that the C-B IR is ‘competency based’ by definition and that, although some relevant experience is clearly needed, the Skill Test will provide entirely sufficient assessment of the applicant’s suitability to be issued with the C-B IR.

We now await the CRD to discover whether the €urocrats have accepted our recommendations.

[peterh337]

There is little evidence that EASA takes any notice of any responses - unless it is on something totally neutral.

[421C]

It's an interesting question. Certainly my stab at 20% is on the high side.
I just looked at an electronic logbook for my time on 2 specific aircraft (a G-reg Seneca and an N-reg C421). The numbers were 14% of logged time as actual instrument and 2% as simulated instrument. I think 5% is too low in Europe unless you simply avoid flying in IMC and don't stay current in the aircraft.

[421C]

I actually wonder what the point of this conversion option is at all. If one
pretends one doesn't have any ICAO IR and just does the CBM IR as ab initio (which one is obviously entitled to do) then the min dual training is 10hrs (which I am 99.9% certain will be required by 99.9% of candidates no matter how experienced), with 40hrs instrument time (which can include non-PIC time), so the extra cost is whatever the TK comes out to relative to the "1 exam". Is that correct?

No. Ab initio the minimum time for the CB IR is 40hrs training of which 10 must be in an FTO. The concession for holders of another instrument qualification is that they can credit time spent as PIC in instrument flight to a max of 15hrs, so that the minimum dual time is 25hrs of which 10 is at an ATO. For example, an ab initio guy with zero instrument time can do an EIR (15hrs dual) then get 15hrs instrument experience then do 10hrs ATO for the CB IR.

The "conversion option" does 2 things
- drops the full IR exam requirement
- drops the 10hrs ATO but not the IRT
Surely you see the value in the latter. Yes, most people do need training. The advantage of the conversion is that you can get to the standard however you want. You don't have to go to an ATO. You aren't the greatest fan of ATOs so surely you see the benefit!
brgds
421C

Sorry, to be clear on the "1 exam", the NPA says "demonstrate that he/she has acquired knowledge of air law, meteorology, flight planning and performance, and human performance;". Worst case is 4 exams. AOPA and PPL/IR argued for an oral exam given by the IRT examiner. The compromise could be 1 exam, we'll have to see.

[421C]

crucially whether there will be a QB. Absence of a QB dramaticallyjacks up the workload. There is no reason at all to think there won't be a QB for the CB IR TK. It's simple - the Learning Objectives (LOs) for the present syllabus are published in the NPA in excruciating detail. It also publishes the LOs deleted under the FCL008 proposal. All a QB provider has to do is delete the corresponding questions. For example, the CATS QB has about 2600 questions for the IR exams. So someone has to spend a few days going through the questions and x-referencing against the LOs, if that isn't automated in some database.

Quite seperately, EASA have published a study about multiple-choice exams that you've referenced and which includes all sorts of potential options for making the QB more obscure or having many many more questions. In the short-medium term I doubt anything will happen. EASA have enough on their plate and there is no sign of a formal rulemaking task or working group or anything to pursue this.

[peterh337]

Ab initio the minimum time for the CB IR is 40hrs training of which 10 must be in an FTOFair enough, but I think most UK candidates doing the CBM IR will have ~20hrs IMCR training in their logbook so they will be able to use that, whereas none of that is usable towards the present IR.

Which is a whole lot better than logging a "genuine" 100hrs instrument time as PIC which will take years. I may have that now, after 10 years of doing ~150hrs/year.

air law, meteorology, ..... and human performanceThose happen to be 3 of the hardest exams for swatting up, so it's not much of a concession for the conversion candidate :)

As always in flight training, it is stitched up so there are no really attractive options. 6 of one....