IMCR - the latest update!

[BEagle]

The CAA has released a revised statement concerning the UK IMCR, see http://www.caa.co.uk/docs/2330/srg_lts_Revised%20Statement%20UK%20IMC%20RATING_April%202012 .pdf

This is simply a clarification of the grandfathering arrangements to which EASA informally agreed in October 2010; it is in accordance with the terms of Article 4 to Regulation (EU) 1178/2011.

This new policy is not a fundamental part of ongoing FCL.008 deliberations, about which no-one should draw any conclusions. It is not the final solution for the future continuance of the IMCR, but it is a sound, pragmatic solution for the period between now and Apr 2014.

Here are some Q&As AOPA discussed with the CAA prior to this statement being released:

Q1. Will applications for UK IMC Ratings to be included in existing JAR-FCL pilot licences made between 1 July 2012 and 8 Apr 2014 result in the holder's licence being converted to a Part-FCL licence with IR(Restricted)?

A1. Yes.


Q2. In other words, that there will be no need to issue a ‘supplementary’ United Kingdom pilot licence for the inclusion of an IMC Rating?

A2. Correct.


Q3. If the CAA receives an application from a UK non-JAR-FCL / non-Part FCL licence holder for an IMC Rating after 1 July 2012, will it simply be included in the licence in the traditional manner?

A3. Yes – but the applicant might prefer instead to convert the UK licence to a Part-FCL licence with IR(R). That’ll be for the applicant to decide.


Q4. Will the UK in future adopt the term 'IR(R)' generally, rather than having 2 identical ratings with different titles?

A4. Unlikely, as this would mean change to the UK ANO, which might prove problematic. Legally we are not in fact adding the IMC rating to Part-FCL licences; what we are doing is granting the Part-FCL IR(A) to pilots who hold IMCR privileges, but with the IR(A) restricted to the privileges of the IMCR.


Q5. Of course the wording of your clause 4: 'There will continue to be provision under the Air Navigation Order to add the IMC Rating to UK (non-EASA) licences into the future, but IMC Ratings will only be valid for non-EASA (Annex II) aeroplanes from 8th April 2014 onwards. From that date forward the IR(R) must be held on a Part-FCL licence to exercise the privileges with EASA aeroplanes.' would still hold true if EASA can be persuaded to adopt the revision to FCL.600 which AOPA, CAA, IAOPA Europe, PPL/IR Europe have all proposed, so that 'new' IR(R)s could then be issued after 8 Apr 2014. The wording leaves the door open for that possibility?

A5. Yes.

Q6. In your clause 5 where you refer to 'the IMCR to IR(R) and other conversions', presumably the IMCR to IR(R) conversion is simply the administrative process as described in your Revised Statement?

A6. Yes.

Q7a. There will be pilots with JAR-FCL pilot licences, now 'deemed' Part-FCL pilot licences, who may not have intended to convert their licences physically to Part-FCL licences before the 5 year re-issue point. If those licences currently include IMCRs, will those IMCRs be 'deemed' to be IR(R)s until they too are physically converted with the licence?

A7a. No. As explained in A4, the IR(Restricted) will be an EASA rating which cannot be included on anything except a Part-FCL pilot licence.

Q7b. Or will it be a requirement for such licences to be converted physically to Part-FCL licences before 8 Apr 2014 if IMCR privileges are to be exercised on EASA aeroplanes?

A7b. Yes

Q7c. So, if you are a JAR-FCL pilot licence holder with an IMCR and you wish to exercise IMC rating privileges on both EASA and non-EASA aeroplanes after 8 Apr 2014, you must have converted your licence to a Part-FCL licence with IR(R) beforehand?

A7c. Yes.

Q7d. But If you wait until the 5 year re-issue point to convert your JAR-FCL licence with IMCR to a Part-FCL licence with IR(R), your IMC rating privileges will be restricted to non-EASA aeroplanes after 8 Apr 2014, until such time as your licence has been converted?

A7d. Yes.


Q8. Will the IR(R) be included in Part-FCL licence conversions of UK non-JAR-FCL professional pilot licences which include IMC privileges, such as the UK CPL(A)?

A8. Yes.

[thing]

Great. I think.

'So, if you are a JAR-FCL pilot licence holder with an IMCR and you wish to exercise IMC rating privileges on both EASA and non-EASA aeroplanes after 8 Apr 2014, you must have converted your licence to a Part-FCL licence with IR(R) beforehand?

A7c. Yes.'

That's me. How do we apply for a Part-FCL licence with IR(R)?

[BEagle]

Wait until the CAA starts issuing part-FCL pilot licences in July 2012, then apply. CAP804 (due to be published shortly) should explain the precise method required.

[thing]

Thank you sir.

[barne_as]

So what does this mean for ppl holders who haven't yet got their imc but are in the middle of training? Do we now have until 2014 to complete, or have we already missed the boat?

[BEagle]

You have until Apr 2014:

Q1. Will applications for UK IMC Ratings to be included in existing JAR-FCL pilot licences made between 1 July 2012 and 8 Apr 2014 result in the holder's licence being converted to a Part-FCL licence with IR(Restricted)?

A1. Yes.



:rolleyes:

[madgav]

Thanks for the info, this is great news, not least for me as I've recently completed the IMCR :D
Let's hope this is another step on the way to ensuring the continuation of the IMCR/IR(R) into the future via issue of new IR(R)'s beyond 2014 :ok:

[Whopity]

How is this IR(R) revalidated? Clearly not within the privileges of a PPL FE to sign an EASA licence for an IR, so presumably must be an IRE or CRE/IRR. Once entered, what is the validity period?

[BEagle]

Whopity, have another read of Clause 2 of the CAA statement. IR(R) revalidation and renewal requirements will be identical to IMCR revalidation and renewal requirements.

Please don't cloud the issue with any more BS about the IR(R) requiring to be examined 'to EASA IR standards' - you caused a lot of unnecessary confusion last time!

The CAA are already working on IRI and examiner solutions for the IR(R); these should appear in CAP804.

[riverrock83]

You have until Apr 2014:



:rolleyes:

Beagle
Just to clarify, I'm still doing my PPL so will likely be getting a Part-FCL licence (and will never have had a JAR licence). Would I be able to add a new IR(r) to a Part-FCL licence before Apr 2014 (I know that after April 2014 is still under discussion)?

Same situation as someone who has to have a minor alteration to a JAR licence which will convert it to a Part-FCL licence for some other purpose. If they then try to add an IMC to their licence it would need to go straight on as an IR(r).
Or are all licences technically Part-FCL now anyway (they just look like JAR licences) so my question is silly?

[riverrock83]

So if you have a JAR licence, you can train for an IMC rating up until April 2014. If you don't have to convert your licence to a Part-FCL licence before you've finished, when you add the IMC rating your your JAR licence you will get back a Part-FCL licence with an IR(r) on it.

But if you were unfortunate enough to have to hand your JAR licence into the CAA for some other reason (lets say, change your address, or re-validate another rating) before you are finished the IMC training, you will only be able to get a UK PPL with IMC privileges, as its not possible to add a new IR(r) onto a Part-FCL licence...

[BEagle]

You will be able to include an IR(R) in a CAA-issued pilot licence after July 2012. That includes a part-FCL PPL(A) issued by the UK CAA.

[riverrock83]

You will be able to include an IR(R) in a CAA-issued pilot licence after July 2012. That includes a part-FCL PPL(A) issued by the UK CAA.

Excellent - thanks!
So I've got just under 2 years to get a PPL and an IR(r) then. If I don't make that - something has definitely gone wrong!

[Pringle 1]

Any thoughts please?

As per Q8, I hold a UK non-JAR-FCL CPL which includes IMC privileges. I also hold a JAR-FCL CPL now 'deemed' Part-FCL licence, valid until 2016 which includes an expired IMC Rating exemption.

From what I see on the CAA's update, if I only had the UK CPL I could convert it to an EASA licence before 8th April 2014 and thereby be granted an IR(R) on the new licence. As I effectively already have a new EASA (JAR Part-FCL licence) how do I get the IMC privileges carried over?

[BEagle]

Well perhaps you should just send your collection of licences to the CAA after July 2012 and ask them to send you a part-FCL CPL(A) with IR(R)?

[Pringle 1]

Thanks Beagle sounds like a reasonable plan. I guess it would be better to do this as close as possible to the April 2014 deadline as I can't see anything to be gained by doing it sooner. I presume I would then have an IR(R) valid for 25 months from that date? or am I missing something?

[dobbin1]

I have read somewhere that you will need an IR in order to fly IFR after 8 June this year. Is this correct?

Does this mean that If you have a JAR licence with an IMC rating you will not be able to fly IFR after June 8th?

[BEagle]

I have read somewhere that you will need an IR in order to fly IFR after 8 June this year. Is this correct?

No, but the CAA's Safety Notice concerning the introduction of 'Night VFR' has failed to include any statement regarding the continued use of the IMCR / IR(R) at night. They have now been advised of this omission.

Does this mean that If you have a JAR licence with an IMC rating you will not be able to fly IFR after June 8th?

No it does not.

[BillieBob]

The effective date is, in fact, 1 July 2012 but you are correct. Under the EASA implementing rules a pilot may not fly under IFR in an EASA aeroplane unless he/she holds an instrument rating. [FCL.600 refers]

[BEagle]

Yet more of your needless obfuscation, BillieBob.

Might I suggest that you read and accept the CAA's Revised Statement, as well as the pertinent sections of CAP 804.

[Cobalt]

Please don't invent problems where there aren't any - as far as I am concerned, the CAA has played a blinder with the IR(R), effectively NOTHING relevant changes for IMCR holders. It took a bit long, but it looks like it was all a game of "Chicken", and EASA blinked first. The only remainig questions are what happens in 2014, and what are the revalidation requirements for UK CPL holders with "implied" IMCR privileges.

Of course non-IR holders can fly in accordance with IFR whenever they want to! Or are you saying than now they MUST NOT fly above 1,000ft over the highest obstacle within 5 NM, but have to stay below, because otherwise they would fly in accordance with IFR, which is prohibited? :} Or that the use of the quadrantal rule is prohibited? Because that's what the Instrument Flight Rules are.

What the EASA regs, badly worded as they are, actually mean in practice is that you need an IR or IR (R)
- in IMC, since you MUST fly IFR
- in CAS under an IFR ATC clearance

So in reality, the only thing being taken away is that a basic PPL holder in a zone transit can no longer get a "cross at..." IFR-in-VMC clearance through a CTR, but only a "cross not above..." VFR clearance. And the CAA can change that, too. Hardly a problem.

EASA is bad enough - with new ratings to blow your nose in the cockpit, taking away "common sense" AMC granted previously by the CAA, and serious drafting errors such as the 6 hour ME for CPL requirement even for a SE CPL, or CRE privileges that cannot be exercises because the underlying CRI rating does not exist...

[BillieBob]

Beagle - You really must control these knee-jerk reactions, they are not good for you. I have read both documents carefully and there is nothing in either that changes the requirement of FCL.600 that a pilot must hold an IR in order to fly under IFR. The fact is that the IMCr will be entered into a Part-FCL licence as an IR (albeit restricted) and so the holder will meet the requirements for flight under IFR, the basic law is not changed.

CAP 804 makes the requirement absolutely clear, stating, in Section 4 Part G, Subpart 1 at the top of Page 2 "Operations under IFR on an aeroplane shall only be conducted by holders of a PPL, CPL, MPL and ATPL with an IR on aeroplanes or when undergoing skill testing or dual instruction." Thus my answer to the first part of dobbin1's question (which was the only part that I addressed) was absolutely correct. Where is the obfuscation?

[Cobalt]

BillieBob, perhaps my previous post was a bit convoluted.

Yes, your statement is technically correct. An IR [restricted=IMCR or otherwise] required to fly IFR.

But in practice, this makes no difference - except for the above mentioned IFR-in-VMC clearance into Class D, there is NOTHING that a non-IR PPL/CPL holder can no longer do under EASA, thanks to the introduction of "Night VFR", which are almost identical to IFR.

Actually, the PPL limitations for flight visibility are gone, so a PPL can now fly VFR in lower visibility than pre-EASA.

[BEagle]

BillieBob, your usual excuse for confusing everyone with your blinkered, individual views just wastes everyones' time.

The CAA has worked well to negotiate a pragmatic solution for the period extending to Apr 2014, yet all you can do is to spread doubt and gloom

Please just stop your pointless negativity - it helps no-one.

I have to agree with earier comments made by bose-x....

[Lukesdad]

Gentlemen

Apologies for being a little dim, but could someone clarify the situation regarding the proposed replacement rating for the IMC?

I realise that there is both concern and confusion regarding the status and ongoing validity of the UK IMC rating, but is the proposed replacement in the form of a Eurpean PPL poor weather rating in place yet?

When I read the early proposals for this rating, split as it was into two parts, I thought it looked quite sensible.

Or am I in a minority of one?

[bookworm]

The FCL.008 rulemaking task came up with two proposals, one a competence-based modular IR (in short, a route to a full-privileges IR with a lot of the unreasonable stuff removed) and the other an Enroute IR. To be pedantic, neither was a "proposed replacement rating for the IMC", which is why BEagle's efforts with regard to the IMC rating are so important.

The next step for those is that EASA publishes a Comment Response Document incorporating a draft with any changes as a result of the comments from consultation (which, as far as I understand, went quite well). You then get a month or two to send a reaction to the CRD (send a nice supportive one!) and then EASA will publish an Opinion. It then moves out of EASA's hands, and typically takes about a year to become law if all goes smoothly. So realistically we're looking at Autumn 2013 before Part-FCL includes those ratings.

[Lukesdad]

Thank you bookworm, that was very informative.

Might I press you further and ask you to clarify what exactly was proposed?

Again, at the risk of alienating the whole forum, my understanding was that there was to be a simpler 'en route' rating allowing PPLs to retain control of their aircraft whilst travelling from one VMC airfield to another, and then a higher standard 'proper' instrument rating which would allow take offs, landings etc in IMC conditions.

If I am correct, and the IMC rating is destined to remain a 'UK only' use, surely IMC holders would have little difficulty in attaining the lower 'en route' IR rating enabling them greater freedom in returning from say, a French trip' to a UK based field.

For my part, as a fairly 'average' PPL, I have resisted the challenge of an IMC rating but would welcome the 'en route IR' rating as a way of improving my safety margins whilst in flight but avoiding the complexity of instrument approaches etc. I would not, in all honesty, conduct a flight where the weather conditions at my destination had not been checked as VMC, but I could envisage a situation where en route weather proved to be not as forecast and required a limited period of 'straight and level' to regain VMC.

In short, is the new proposal for an 'en route' IR qualification to be seen in a positive light?

[Pace]

LikesDad

I cannot answer for Bookworm who supplies an amazing amount of factual detail.
As things look if you can carry on with the IMCR privalages in the Uk and also have an EIR which allows you to fly in CAS within the Uk you will be in the better position of literally having an IR.
With my level of experience I am cautious of allowing people like yourself to as you put it fly straight and level to a VMC destination without proper approach capability.
The amount of times I have flown UK to the south of France to a VMC destination are many. Often the cloud tops rise, the cloud type changes, climbing puts you into icing !
Often with good VMC at destination doesn't mean it's good VMC 20 miles away where you are dumped out of CAS.
Often the airfields you fly over in blind bliss on top can be giving 200 overcast below.
Fine as long as no situation arises where you are forced to land with no solid instrument ability to minima.
For more experienced Pilots it's a workable option but one to use with maximum caution.

Pace

[bookworm]

The proposal is here (http://www.easa.europa.eu/rulemaking/docs/npa/2011/NPA%202011-16.pdf), though in some places it needs to be read alongside the bits of Part-FCL that are changed.

Again, at the risk of alienating the whole forum, my understanding was that there was to be a simpler 'en route' rating allowing PPLs to retain control of their aircraft whilst travelling from one VMC airfield to another, and then a higher standard 'proper' instrument rating which would allow take offs, landings etc in IMC conditions.

That's a fairly good summary, but bear in mind that enroute IFR is often a great deal more than "retaining control of the aircraft". It's about understanding how to plan and execute such a flight, and work with ATC as required. None of it is particularly hard, but like many things in flying it needs thought and familiarity to do it right.

If I am correct, and the IMC rating is destined to remain a 'UK only' use, surely IMC holders would have little difficulty in attaining the lower 'en route' IR rating enabling them greater freedom in returning from say, a French trip' to a UK based field.

The differences between the EIR and the IR are only the skills/privileges to fly approaches and the total instrument flying experience (because ICAO insists on 40 hours instrument time for an IR). The theoretical knowledge exams and revalidation regimes are identical (the EIR test just omits the approaches).

The EIR was created to offer a stepping-stone to the IR -- to offer some operational experience to the student before they had met the 40 hours IF requirement, a bit like the student solo in a PPL course.

An IMC rating holder knows how to fly approaches and by the end of an EIR course would probably have 40 hours IF (15 hours for the IMC rating, 15 for the EIR plus a bit of operational IF). So although I've seen it proposed in a number of places, I don't really see why an IMC rating holder would want to do an EIR rather than an IR.

For my part, as a fairly 'average' PPL, I have resisted the challenge of an IMC rating but would welcome the 'en route IR' rating as a way of improving my safety margins whilst in flight but avoiding the complexity of instrument approaches etc. I would not, in all honesty, conduct a flight where the weather conditions at my destination had not been checked as VMC, but I could envisage a situation where en route weather proved to be not as forecast and required a limited period of 'straight and level' to regain VMC.

Instrument approaches are really not very complex, particularly in these days of GPS approaches. Learn the basic skills, practise, stay current. By all means set personal minima for yourself that reflect your capabilities, but I hope that one you got into instrument flying you'd find flying approaches to be reasonably straightforward, operationally useful and very satisfying.

In short, is the new proposal for an 'en route' IR qualification to be seen in a positive light?

I strongly believe so, yes, though personally I would rather see it as a means to an end than an end in itself.

[thing]

For my part, as a fairly 'average' PPL, I have resisted the challenge of an IMC rating

It's not that hard! Joe Average pilots like me get them all the time.

[Lukesdad]

Thank you, I have had the chance to read through the EASA proposals.

I may be in a minority of one, but it looks very sensible to me and something I would like to pursue if and when it becomes available.

[BEagle]

The only aspect of the EIR which may well prove disappointing to many would be the theoretical knowledge requirement. Although this is around 60% of the current gold-plated IR requirement and is the same as the C-B IR requirement, it seems somewhat disproportionate for a rating which merely adds en-route IFR privileges to a VFR-only licence.

With IFR privileges restricted to the en-route phase only, recovering to a Class D aerodrome will require good weather or some form of SVFR clearance...

[TheInquisitor]

Apologies if this has been answered or clarified before!

As I understand it, the 'old' non-JAR-FCL UK CPL(A) conferred an implied IMC rating, plus the ability to fly to lower limits than 3km / 1800m. Reading the (now-defunct) LASORS, under JAR-FCL CPL(A), this automatic 'inclusion' of an IMCR appeared to have been removed. The EASA part-FCL bits on CPL(A), understandably, contains no mention of such things.

If one were to obtain a part-FCL CPL(A) (without IR), would one therefore need to seperately add an IMCR / IR(R) to said licence, as you would to a PPL?

[BEagle]

If one were to obtain a part-FCL CPL(A) (without IR), would one therefore need to seperately add an IMCR / IR(R) to said licence, as you would to a PPL?

Yes.

However, I understand that if an existing UK (non-JAR-FCL) CPL(A) is converted to a part-FCL CPL(A) before 8 Apr 2014, an IR(R) will be included in the new licence (but will then be subject to normal revalidation / renewal requirements).

[mrmum]

Reading the CAA's revised statement on the IMCr from last month;
http://www.caa.co.uk/docs/2330/Revised%20Statement%20UK%20IMC%20RATING%20May%202012%20_v3.p df
It won't let me copy an extract, but in para. 2, it says that an IR(R) on a Part-FCL licence "grandfathered" from an IMCr before 8th April 2014, "...shall be subject to the same revalidation and renewal requirements that apply to the UK IMCr

The renewal requirements that currently apply to a (pre-JAA) UK CPL/ATPL holder with embedded IMCr privileges are .... none. So, my interpretation of their statement would be that, when I apply for a Part-FCL CPL with IR(R), the renewal requirements will remain the same as they were with the UK CPL, nothing.

[TheOddOne]

As a holder of a UK CPL I understand that I had an 'embedded' IMCr. I use my UK CPL with a SEP rating and a FI rating. Now, I understood that strictly speaking I didn't need to re-validate my IMCr separately in order to maintain IMCr privileges BUT what with all the EASA uncertainties I thought that it was prudent to do so. Now, like all SEP holders, I need to re-validate it every 2 years so this year I chose to use the time re-validating my IMCr. Peace of mind, I think and also a useful brush-up with an IMC examiner rather than a less useful hour.

Just a personal view...

The Odd One

[BEagle]

mrmum, not so!

Once you have an IR(R) in your part-FCL licence, it is a 'rating', not merely a set of 'privileges'. Hence you will need to revalidate it accordingly.

Be grateful that you're actually getting a 'free' IR(R) initial issue!

[mrmum]

Ah, okay I see what you mean. I just don't know how grateful I can be to the CAA/EASA, for only making my life a little more awkward and expensive. However, I do know it could have been much worse and there are some individuals and organisations, whose efforts we should all be genuinely appreciative of.

Am I correct in thinking then, that in addition to a Part-FCL CPL/IR(R), which I'll have to renew every 25 months. I can still keep my pre-JAA UK CPL with non-expiring, embedded privileges, for use on annex 2 aircraft?

[Cobalt]

There are ratings that require no revalidation - for example the "Night Rating" [yes, it is now a Night Rating, not a Night Qualification anymore...].

It depends on what the UK CAA want to do. Up to 2014 it is within their powers to issue an IR(R) with no revalidation requirement. Considering that the first time they will actually issue that IR(R) to CAA CPL holders in September 2012, you could just wait and see what they print as expiry date on the revalidation pages...

[Obi_Wan]

Cobalt,

I thought Night was the other way round - was a rating, then became a "qualification".

Did I miss something?

[1800ed]

I completed my 'night rating' last year, it simply added a sentence to one of the pages of my JAR PPL saying "the privileges of the license may be used at night".

[BEagle]

Am I correct in thinking then, that in addition to a Part-FCL CPL/IR(R), which I'll have to renew every 25 months. I can still keep my pre-JAA UK CPL with non-expiring, embedded privileges, for use on annex 2 aircraft?

I suppose that would be possible, if you really want to be a licence collector....

Night rating pre-JAR-FCL became night 'qualification' under JAR-FCL.....and now back to night 'rating' under EASA.........:\

[Phororhacos]

Perhaps this has been asked before but if I could find the answer I would not have posted, so...

It has been suggested to me that if I want to convert my (current) IMC rating from my Lifetime PPL(A) to an IR(Restricted) on an EASA PPL, then I must first get it transferred as an IMC rating onto a new shiny 5 year JAR FCL PPL.

Is that correct?

If so, is there a time limit?

Thanks

P

[BEagle]

Is that correct?

No. It's bolleaux. Which particular idiot suggested it to you?

Just convert a valid UK PPL(A) with valid IMC rating to an EASA part-FCL pilot licence after 17 Sep 2012 and you will receive an EASA PPL(A) with IR(R).

[MrBrightside]

Slightly off topic.

Can someone direct me to a document/web page with the IMCr application fee. Having spent about 40minutes navigating the CAA website I am no wiser. An email has been sent to the CAA also but as yet I have had no response.

Thanks

[hoodie]

Here you go, MrB (http://www.caa.co.uk/docs/175/269PLSCorr[1]SchemeOfCharges2012.pdf).

Unless one happens to know that the CAA call their fees document the "Scheme of Charges", it's not easy to find.

It appears from a quick squint that the IMCR application fee 2012/2013 is £89.00 (see Table 5 (f) on p6: "Any other rating or qualification not shown above").



As an aside, I wonder how much the Government charges for a licence to print money...?

[MrBrightside]

Much appreciated. :ok:

[Phororhacos]

Reassuring reply to my earlier question. Thanks BEagle..

[1800ed]

Well, I passed my IMCr skills test last Friday and my ground exam today. A little frustrating that I rushed it and then half way through the deadline was extended, but at least I'll have it for some 'summer' flying :\

[BEagle]

...the deadline was extended...

There never was any such 'deadline'!

[Aware]

If the NPA on IF delivers what it states, what would be the conversion of an IR/R to a full IR. I am assuming IR exams new 3hrs 50 mins with a credit of two of them if you hold a CPL EASA, (Cap 804) 10 hrs dual and a test.

I personally have about 60 hrs IF am an IMC instructor but exams have expired for any IR rating. I am current on ndb holds and approaches and have been an ATPL ground instructor so IR exams shouldnt be a problem. I am fully aware of the way the CAA ask questions. But am I inow in with a chance of getting a full IR without shedding out vast sums of cash ?

[peterh337]

I don't know the answer to the conversion (if indeed this is in any way finalised) but how much dual training you will need to pass the IRT will depend on the syllabus and the actual training setup.

I have just done the FAA IR to JAA IR conversion and took 20-30hrs (depending how you count it - I had a break for some weeks, which is a big currency killer for that particular type of hand flying NDBs etc) and it is readily apparent that the biggest factor by far is whether NDB procedures remain potentially in the IRT (which I am sure they will) and if so what the tolerances are.

Some 80% of my 20+hrs were spent on NDBs.

For example, the requirement, on the NDB hold, to be established within 5 degrees on the inbound to the beacon was reduced from 30 secs to 15 secs and very recently to 5 secs. However, on an NDB approach, you cannot descend from the platform until you are within 5 degrees of the inbound track - end of story! And if you ever go outside that 5 degrees limit, you have to go around. In reality, the NDB system is so crap that examiners cannot work it rigidly, but how good do you need to be? It's a matter of judgement, for whoever is training you and deciding whether you need to do "one more flight" before you are good enough to be given the 170A course completion certificate and to go for the IRT.

That's before one gets onto the 170A "pre-test test" stuff which some FTOs run as a bit of a scam to make more £££, on which there are no defined standards, and the 170A examiner might well choose to operate the 30-second requirement.

I believe the CBM IR will allow a defined credit from previous instrument time, up to 40hrs. But IMHO you will still need to allow for say 20hrs FTO time to reach the IRT standard. But maybe not - nothing stops you being a bl00dy good pilot via unlogged flying; the difference is that now you will need just 10 official dual hours whereas previously it was 50, which is a big cost difference for people with "inadmissible" training/experience.

[BillieBob]

For example, the requirement, on the NDB hold, to be established within 5 degrees on the inbound to the beacon was reduced from 30 secs to 15 secs and very recently to 5 secs.There is not (and never was) any requirement to be established on the inbound track for a specific time before reaching the beacon. Doc 8186 states merely that "Due allowance should be made in both heading and timing to compensate for the effects of wind to ensure the inbound track is regained before passing the holding fix inbound." Even the current requirement of 5 seconds is open to challenge if it can be shown that the ICAO requirement was met.

I thought we had laid to rest the concept of CAA 'Skygods' making up the rules as they went along but, clearly, the current crop of examiners are trying to re-invent a wheel that was long ago proved to be square.

[peterh337]

BB; I have long lost count of how often I have seen the 30/15/5 requirement in writing, in the FTO document environment.

Gawd knows how much else going is incorrect.

But the bottom line is that you have to go with the flow if you want the magic piece of paper issued by the CAA............