IR(R) -

[englishal]

Hola,

I have a JAA PPL w/ IMCr due for renewal (the licence that is) in May 2014. I also have FAA CPL/IR, and fly an N reg in Euroland. I have just been reading some of the stuff regarding the IMCr and IR(R) and have a couple of Q's.

The CAA statement here http://www.caa.co.uk/docs/2330/Revised%20Statement%20UK%20IMC%20RATING%20May%202012%20_v3.p df says that the holder of an IR(R) will have the same privileges as a IMCR holder in UK airspace - so shoot approaches, flying an Airspace class D and below IFR.

My question is two fold....first, it seems to me that I am better to swap my licence to a part FCL licence sooner rather than later, as I understand that if done after April 2014, then I would be limited to Non EASA aircraft (whatever they are)? Is this correct?

Secondly the way I understood an IR(R) is that it allowed IFR enroute, but no approach capability. With an IMCR issued IR(R), does this hold true in Europe? So in UK airspace, I would be limited to IFR in Class D and below, but can shoot approaches, but in EASA airspace, I would have no airspace limit, but cannot shoot approaches? Or is this IR only valid in the UK airspace?

Seems kind of confusing to have two IR(R)'s labeled the same, but with differing privileges?

If the second point is true, is there any way to convert my FAA IR to an EASA IR(R) but not restricted to UK only airspace?

TIA....

[Pace]

E :)

As far as I read it you can fly approaches in the UK as you can with your IMCR and with the EASA IR(R) Fly enroute in CAS.
Hence in the UK it can be used like an IR albeit with IMCR minimas.

Out of UK airspace you can only use the EASA IR(R) for enroute IFR in CAS NO Stars or Sids NO instrument approaches.
I can see loads of pitfalls and serious problems with the European part

Happy to be corrected :ok:

Pace

[Level Attitude]

I have a JAA PPL w/ IMCr due for renewal (the licence that is)
JAA (5 year) Licences are no longer issued. You need to apply
for a (non-expiring) Part-FCL PPL.

As you already have an IMCr you will be given an IR(R).
This is effectively an IMC in another name. Same privileges as
an IMC and still restricted to UK airspace only.

Secondly the way I understood an IR(R) is that it allowed IFR enroute
No
You are thinking of the En-Route IR (ERIR) which does not currently
exist, but has been proposed.

[Pace]

You are thinking of the En-Route IR (ERIR) which does not currently
exist, but has been proposed.

LA

That is pretty obvious! and what he is referring too. I personally think there are huge pitfalls in an enroute IR without approach and instrument landing abilities either end and in the middle :{

Pace

[Fuji Abound]

I would be limited to IFR in Class D and below, but can shoot approaches, but in EASA airspace, I would have no airspace limit, but cannot shoot approaches? Or is this IR only valid in the UK airspace?

We dont know of course but I dont think that can be so.

It seems certain the EIR will allow en route IFR in all classes of airspace and since it is an EASA rating will include the UK. In the UK the IMCR (now the IRR) will permit any approach with the same minima as an IR other than in respect of runway visibility in which event it is slightly more restrictive although unlikely to be relevant for GA.

In Europe the IRR will have no validity BUT we dont know how the IRR will deal with the off airways segment.

We also dont know whether their will be a conversion route from the IRR to the EIR.

It is still a mess but at least those years ago when we campaigned for the IMCR to be retained has rightly paid the most wonderful dividends in spite of the nay sayers; and thank you Englishal for the part you played.

[BEagle]

1. The EIR is an 'enroute only' EASA IFR rating which is still only a proposal.

2. The IR(R) is exactly the same as the UK IMCR - same privileges, restrictions, revalidation and renewal requirements. For boring technical reasons, an IMC Rating cannot be included in a Part-FCL licence, so it has been termed the Instrument Rating (Restricted) at my suggestion.

3. Currently, or at least until some sense is knocked into the blinkered, stubborn €urocrats in Köln, only those pilots whose licences included IMCR privileges prior to 8 Apr 2014 will be able to exercise them on EASA aeroplanes (and if you don't know what those are, you need to find out!) after that date. To do so, such IMC privileges must have been converted (paperwork exercise) to an 'IR(R)' - if they haven't been, pilots will only be able to exercise such privileges on non-EASA aeroplanes until their licence does include an IR(R).

4. Pilots who don't already have one will still be able to obtain IMCRs after 8 Apr 2014, but only for use on non-EASA aeroplanes.

The fight for new issues of the IR(R) after Apr 2014 is still being fought - at pretty high level.

It is by no means certain that the EIR will be adopted; at least one NAA is firmly against it on safety grounds.

[englishal]

Thanks. So I'll renew my jaa ppl early to get an IRr added to use in easa aeroplanes in the hope of getting an ERIR by default, seeing as my faa ir wont be good enough one day. Bit of a stupid name that, easa aeroplane, my easa Rockwell Commander is actually an FAA aeroplane and was built in america too :)...

[Fuji Abound]

Not many easa aerocraft built in europe, diamond is about the only current generation that springs to mind and they build the other side of the pond as well.

It may say something in itself about easas attempts to strangle ga

[BillieBob]

The IR(R) does not exist in reality, it is merely a device to allow the UK IMCr to prolong its existence in the EASA environment. Whilst it exists for the moment, there is no certainty that it will survive into the future, although BEagle will, no doubt, be strident in its defence. The EIR, on the other hand, is a perfect example of a 'committee' solution - it neither satisfies nor offends anyone and is, as a result, totally useless in practice. Whoever dreamed up the idea (and I know who it was) should be smeared in honey and strapped over an anthill!

Considering that it is now approaching a year since the Aircrew Regulation became law, there is a worrying lack of understanding of the definition of an EASA aeroplane. Only slightly less worrying is the confusion that is apparently being caused by the ersatz IR(R).

[Level Attitude]

Quote:
You are thinking of the En-Route IR (ERIR) which does not currently
exist, but has been proposed. LA

That is pretty obvious! and what he is referring too.

I don't think so since he originaly said:
Secondly the way I understood an IR(R) is that it allowed IFR enroute, but no approach capability.........

Seems kind of confusing to have two IR(R)'s labeled the same, but with differing privileges?

and I think he is still confused:
I'll renew my jaa ppl early to get an IRr added to use in easa aeroplanes in the hope of getting an ERIR by default

englishal

You will get an EASA Part-FCL PPL and, yes, you will get an IR(R).

You will not get an EIR by default.
1) Because it does not yet exist (and may never)
2) You will have to do the Training Course, and pass the
Test like anyone else (though you may be credited with
some elements due to having an FAA IR).

There is no need to rush - Your JAA PPL + IMC will remain good for EASA
aircraft until the Licence expires (May 2014).

[Pace]

The IR(R) does not exist in reality, it is merely a device to allow the UK IMCr to prolong its existence in the EASA environment

Billie Bob

EASA have a real problem! They are supposed to be safety regulators! The french have a very poor safety record under VFR the UK has a good safety record in comparison with the IMCR.

EASA cannot ignore the safety argument for allowing a certain level of instrument flight below a full IR on safety grounds for VFR pilots.

Frankly they have not got a clue about what they are doing and are desperate to put something in place which does not water down their own IR plans but which improves the poor safety record of VFR only in France

Pace

[Deeday]

BEagle, thanks for the bullet points, although I have a doubt now.

If I had a plain JAR-PPL right now, I could add an IMCR to it (no later than 8 Apr 2014) and then convert the lot to an EASA PPL(A) + IR(R). Fine.

What if I had already a Part-FCL licence right now (plain vanilla EASA PPL - Aeroplanes): would it still be possible, up to 8 Apr 2014, to add an IR(R) rating to it (not an IMCR, since you said that it's not possible due to a technicality)? Or is the former the only route to an EASA PPL(A) + IR(R)?

[bookworm]

If the second point is true, is there any way to convert my FAA IR to an EASA IR(R) but not restricted to UK only airspace?

While everyone seems to rush to condemn the EIR, I'm surprised that nobody has mentioned to englishal the other part of the FCL.008 group's work, which was captured in the CRD as:

8. Applicants for the competency-based modular IR(A) holding a Part-FCL PPL or CPL and a valid IR(A) issued in compliance with [ICAO] requirements may be credited in full towards the training course [for the IR]. In order to be issued the IR(A), the applicant shall:
(a) successfully complete the skill test for the IR(A) ...;
(b) demonstrate to the examiner during the skill test that he/she has acquired an adequate level of theoretical knowledge of air law, meteorology and flight planning and performance (IR);
(c) [have English Language Proficiency];
(d) have a minimum experience of at least 50 hours of instrument flight time as PIC on aeroplanes.

(d) is likely to be changed to "50 hours of flight time under IFR" when the Opinion is published.

Whether that part of the amendments to Part-FCL becomes law before April 2014 may be too close to call, but either way, as long as you have a valid FAA IR, you should eventually be able to get yourself a Part-FCL IR (no 'E', no 'R') with minimum hassle -- effectively just a check ride.

[Pace]

Implementation is likely to be delayed to 2016 anyway as nothing is sorted or set in concrete still and there would be chaos trying to Implement in 2014.
That was readily but unofficially accepted by EASA at the last big meeting.

Pace

[BEagle]

What if I had already a Part-FCL licence right now (plain vanilla EASA PPL - Aeroplanes): would it still be possible, up to 8 Apr 2014, to add an IR(R) rating to it (not an IMCR, since you said that it's not possible due to a technicality)?

Yes. No matter whether you have JAR-FCL PPL or a Part-FCL PPL, you will do the same IMCR course and send off your licence for inclusion of the Rating. When it comes back, it will be a Part-FCL PPL(A) with IR(R). It is impossible for the CAA to add anything to a JAR-FCL licence now - even something as simple as a change of address.

(d) have a minimum experience of at least 50 hours of instrument flight time as PIC on aeroplanes. is an error - they have assured me that this was supposed to read '50 hours flight time under IFR as PIC on aeroplanes' and have apologised (as far as Germans know how....:rolleyes:) for their sloppy proof reading.

The NPA2011-16 CRD reads:

Accepted

Thank you for providing this comment.

The Agency and the Review Group experts agree with IAOPA (Europe) and have amended 8(b) to allow an applicant to demonstrate adequate theoretical knowledge to an examiner during the skills test.

The Agency and the group also agreed to amend 8(d) by reducing the minimum experience required to 50 hours flight time under IFR as PIC on aeroplanes.

[englishal]

But if I renew after April doesn't that mean it will be restricted to non easa aeroplanes? Ie I have to change to part FCL before my license expires?

[Pace]

Bookworm

Not maybe so much for this forum but there is still a long silence on the dual licencing requirements and conversion route for FAA ATP conversion for working European pilots flying N reg in Europe?

There is supposed to be another big meeting this summer EASA FAA where things should be clearer and I cannot see pilots waving new bits of paper till 2016 which was unofficially accepted by EASA as a likely implementation date at the last meeting.


Pace

[bookworm]

But if I renew after April doesn't that mean it will be restricted to non easa aeroplanes? Ie I have to change to part FCL before my license expires?

From April 2014, you will need a Part-FCL licence to fly "EASA aircraft" (i.e. those that don't fall under Annex II of the Basic Regulation). Your JAR-FCL licence is deemed to be a Part-FCL licence. When you convert (or "replace", long story) your JAR-FCL licence to a new Part-FCL licence (which you must do before the JAR-FCL one expires in May 2014), the new one will have an IR(R) attached to it, which will allow you to continue with the privileges you currently have. After April 2014, you may not exercise the privileges of an IMC rating attached to a JAR-FCL licence on an EASA aircraft until it is converted to a Part-FCL licence with an IR(R) attached.

Implementation is likely to be delayed to 2016 anyway as nothing is sorted or set in concrete still and there would be chaos trying to Implement in 2014.
That was readily but unofficially accepted by EASA at the last big meeting.
...
Not maybe so much for this forum but there is still a long silence on the dual licencing requirements and conversion route for FAA ATP conversion for working European pilots flying N reg in Europe?

There is supposed to be another big meeting this summer EASA FAA where things should be clearer and I cannot see pilots waving new bits of paper till 2016 which was unofficially accepted by EASA as a likely implementation date at the last meeting.


Big meeting of what, Pace? And implementation of what?

[Pace]

Regarding requiring dual licences to fly N reg aircraft in Europe! If you remember EASA had a bilateral agreement with the FAA already in place to which they hoped to attach FCL.
Last summer there was a joint meeting between the FAA and EASA to look at ways of bringing a bi lateral about dual licences being declared by EASA as not being their route of choice as well as being legally riddled with potholes for them regarding working pilots in Europe.

Pace

[cessnapete]

I have a JAA PPL issued in Feb 2012 when my ATPL expired,this PPL expires 2017.
I have a valid UK IR which I will let lapse this year due cost. I recently sent to CAA the application and cheque for the inclusion of an IMCR on the basis of my current full IR.
It took two months for them to reply refusing to add an IMCR/ IR/R to my PPL as it is not an EASA license,and I would have to apply for issue of new EASA PPL as they now only issue EASA licences, with associated costs. Two new licenses in less than a year!

I thought after 4/2012 all licenses would be deemed an EASA license and then a proper EASA license would be issued on renewal in 2017?

[bookworm]

I thought after 4/2012 all licenses would be deemed an EASA license and then a proper EASA license would be issued on renewal in 2017?

Correct, but the CAA requires you to replace the JAR-FCL licence with an EASA one if you make any changes. At least the new EASA Part-FCL one would be valid for life.

[bookworm]

Regarding requiring dual licences to fly N reg aircraft in Europe! If you remember EASA had a bilateral agreement with the FAA already in place to which they hoped to attach FCL.
Last summer there was a joint meeting between the FAA and EASA to look at ways of bringing a bi lateral about dual licences being declared by EASA as not being their route of choice as well as being legally riddled with potholes for them regarding working pilots in Europe.

News to me. The requirement for an EASA licence for operators established or resident in the EU is law. It's not going to be changed before April 2014. AFAIK, the Commission and EASA are working their empennages off trying to get the BASA implementation procedures for licensing in place by April 2014.

[Pace]

Bookworm

I have a letter from EASA staing that they are going all out to get a bi lateral for FCL with the FAA to attach to the existing bi lateral already in place! Dual licensing not being the preferred option!
The conversion with ICAO licences from
IR to EASA IR with just a flight test and oral exam you posted would appear to show flexibility by EASA in that respect ( if it happens ? )
Austria already do not feel that such dual licence requirements are enforceable and with pilots who's jobs depend on this I doubt such requirements would stand scrutiny in a court of law regarding existing EU employment laws!

There most certainly was a joint meeting with the FAA last summer with the intention whether genuine of adding FCL to a bi lateral already in existence!
Remember too that the existing structure was only passed into law by reassurances given to MEPs who opposed that their concerns would not be concerns! If that was all a con trick only time will tell but the proposed conversion to an EASA IR from an ICAO IR sounds promising
Pace

[bookworm]

I have a letter from EASA staing that they are going all out to get a bi lateral for FCL with the FAA to attach to the existing bi lateral already in place! Dual licensing not being the preferred option!

Well they're certainly trying very hard to get the licensing part of the BASA in place, but that's the first I've heard about it not being "dual licensing". You seem to be applying that it would be mutual acceptance rather than just simpler conversion. I guess we'll see.

The conversion with ICAO licences from IR to EASA IR with just a flight test and oral exam you posted would appear to show flexibility by EASA in that respect ( if it happens ? )

Yes, but definitely a separate route. I think they'd like to get both the CBM-IR (with the third country conversion part) and the BASA with the FAA in place by April 2014, but it's touch and go on both.

I can't comment on Austrian or EU employment law.

[S-Works]

Pace, I wonder at what point you will realise you are going to have to do the exams or give up flying.....l. :p

[Pace]

Yes, but definitely a separate route. I think they'd like to get both the CBM-IR (with the third country conversion part) and the BASA with the FAA in place by April 2014, but it's touch and go on both

Hence why in the last summer meeting I had it on good authority that 2016 was a more likely date although for obvious reasons not official.

No one mentioned mutual acceptance but a more realistic and sensible conversion route between licences.

The ICAO IR to an EASA IR with just a flight test and oral examination is a major move from the previous 7 exams.

That would be opposed by flight training organisations while an ATP conversion where the pilot has already more than 1500 hrs from FAA ATP to EASA ATP would be of little interest to flight training organisations so should theoretically be a simpler conversion.
Yet employed pilots in Europe would cause a bigger headache for EASA on legal grounds than private pilots.

Lets wait and see but I would put money on a further implementation date to 2016
Also correct me if I am wrong but the legislation regarding 3 rd country licences is already in place 2014 was an EASA Option not a directive! Only 3 countries opted into that option yet no one has been charged yet?
Technically if the above is correct you are NOW just as uninsured flying over countries which have not opted into the 2014 extension on dual licences for 3 rd country aircraft as you would be after 2014 for the simple fact that flying into or over those countries you are NOW doing so without the required licences?

[Pace]

Bose

I have never failed a flight test in my life so happy to sit an EASA flight test tomorrow and an oral exam?
If that is all that it takes no problems!

As for higher licences ie ATP and working pilots I already know of legal challenges which would occur if a simple conversion does not arise and those challenges would be successful.

Pace

[Fuji Abound]

Technically if the above is correct you are NOW just as uninsured flying over countries which have not opted into the 2014 extension on dual licences for 3 rd country aircraft as you would be after 2014 for the simple fact that flying into or over those countries you are NOW doing so without the required licences?

I dont think so.

It is a matter between you and the insurance company whether or not you are insured.

[S-Works]

I stand to be corrected but for commercial operations dual licensing is already in force. And be commercial I mean a pilot being remunerated.

[Ellemeet]

I fly nreg with IR.

Basically I just wait for FCL.008 and do the conversion with an oral and checkride. This should be end of the year.

If the Basa comes it will be a bonus but in converting I also get to fly IR on EASA regs. The pressure for the Basa is very high as The boss of EASA promised it as the solution when this stupid law was passed.

[Pace]

Bose

I believe it is in force but postponed to 2014 at present but countries should have opted into that postponement which only 3 had done!
Austria refuse to acknowledge the legality of the dual licensing requirements and technically if we are insured now we will be in 2014 if the dual licence was confirmed across the board by EASA.
At that point it would be interesting on who would try to make the first summons and where they get with it as the whole thing is badly flawed!
My guess is there will be a completely different picture if not by 2014 but more likely 2016

Pace

[bookworm]

I stand to be corrected but for commercial operations dual licensing is already in force.

I think that's correct (provided when you say "dual licensing" you mean the requirement for an EASA licence).

And by commercial I mean a pilot being remunerated.

But that's not correct. A CPL or ATPL is required for a commercial operation, and is also required to get remunerated for acting as a pilot. But the payment of the flight crew does not make an operation commercial.

[BEagle]

A CPL or ATPL is required for a commercial operation, and is also required to get remunerated for acting as a pilot. But the payment of the flight crew does not make an operation commercial.

However, under FCL.205.A (b), a PPL/FI may receive remuneration for conducting flight instruction at LAPL/PPL level, although his/her licence is restricted to non-commercial operation.

[Pace]

The most interesting point in this thread is the fact that dual licencing is already in force.
There is an opt out till 2014 but only three countries actually signed up to that.
As such there are aircraft flouting the law crossing or landing in these non signed up to 2014 countries every day of the week.

That beggars the question that if a serious accident occurred TODAY in one of the countries who have not signed up to the 2014 extended deadline and technically have a dual licence requirement in force now how does the insurance stand TODAY?

If the Insurance is fine today on N reg aircraft where the pilot has all the legal FAA licences in order to fly that aircraft then post 2014 the same will stand.
The EASA licences are not relevant to an FAA aircraft and as such insurance could not force you to hold licences which are not valid on an FAA aircraft.
To me this would be a technical infringement of an airspace requirement.

As stated that is relevant to aircraft flying over these countries at present and not post 2014

Pace

[mad_jock]

Pace its going to take a crash and a load of money spent in court to find out.

Unitl the point when they actually start enforcing it.

When they do you the legal case will start. By the time its finished either everyone will have got dual licenses and those that can't are the only ones left fighting. Just purely because most won't be able to not work for the 2-3 years it will take for the court case to run.

[S-Works]

I was not aware the UK CAA had opted out. From what I was told by them they had not and they require a UK resident who is flying a N Reg as a Commercial Pilot to hold an equivalent EASA Part FCL License.

[Fuji Abound]

That beggars the question that if a serious accident occurred TODAY in one of the countries who have not signed up to the 2014 extended deadline and technically have a dual licence requirement in force now how does the insurance stand TODAY?Pace

I suspect your understanding of how the insurance market works is different from mine.

1. If you infringe the law, and without any specific agreement to the contrary it is up to the insurance company and the courts to decide whether or not you were insured. For example if you have an accident on the road and the car hasnt got an MOT the insurance company potentially have an "out". If the accident had nothing to do with the car's mechanical state some will pay, some will attempt not to. The courts have taken their own view when it has got that far.
2. If you have an agreement with the insurance company they will (or should) honour that agreement. For example when I had just an IMCr and there was the tiresome debate about approach minima I had in writing from my insurance company (and the CAA for that matter) what their position was in the event of an accident.

If I were going to any of the countries in question and was NOT dual licensed I would want to have had the discussion with my insurers at the very least.

However in a case like this an equal risk is having the aircraft grounded (awaiting a qualified pilot) or the pilot "held" for flying the aircraft without a valid license following a ramp check - should it actually ever happen potentially very embarrassing (if a commercial op.) and more than a nuisance.

If you can afford the embarrassment and the cost carry on, if you cant I suspect either hope you stay lucky or get something in writing from each of the relevant countries and the insurance company.

[Pace]

Fuji

The fact is Austria thinks the EASA regs are legally flawed so ignoring them and TODAY it's business as usual with many FAA flying into these countries with the FAA licence only!
I would go further and state that most have no clue either ; ) As with most of this EASA rubbish either!
Piss up in a Brewery springs to mind

Pace

[mad_jock]

very few would argue with that Pace.

But currently your outwith the law as it stands.

[Fuji Abound]

Pace - you know I also have every sympathy, but as with MJ, sympathy matters not one wit in the land in of the Euro (and £). I guess any of them could be grounded / uninsured IF they get caught, and IF the authorities decide to do something about it. You might "win" but at a cost and with a lot of hassle - the usual way it works!

In the UK you can fill up your yacht with pink diesel, the UK is acting outside EU remit, sail to Belgium and you can be impounded / heavily fined AND they have actually done so in a few well published cases. The RYA has gone some way to sorting out the mess - but it is still a mess.

For the same reason if you get "caught" or have an accident you (and any of the rest) could face all sorts of hassle. Of course most rely on it never happening and usually it doesnt.

[englishal]

Not to labour this subject too long....:).....what about pvt flying ?

[Pace]

Mystic Meg prediction :ok:

Firstly flying with FAA licences in Europe without EASA perefectly legal! at present in all EC Countries! Another BASA in june. Continuation of study of FAA and EASA regs and common ground with idea of simplifying.

Presently dealing with PPL licences which will be in concrete by september!
Excellent progress in that direction!

September moving onto professional licenses!

Nothing will happen until everything is complete so watch this space for a further extension to 2016! No way 2014

Mystic Meg is very accurate and not me :E

So bets taken and will be honored on 2014 will be dead in the water (sorry air) :ok:

Pace

[mad_jock]

Its already law pace.

And as you have already said only a few have got the 2014 extension.

The fact that nobody is actively enforcing it doesn`t change the fact its law.

[Fuji Abound]

What are the consequences of breaking the law?

Leaving aside the insurance aspects, which are only relevant in the event of an accident, if you are caught, can the "authorities" prevent you flying, can they impound the aircraft (I suspect not if owned by a third party and / or the aircraft is flown out by a qualified pilot), can they detain the pilot, or must they issue proceedings and allow the matter to be heard in Court?

What is BALPA's view?

Their recourse might be relevant to how willingly you flout the law.

For me the hassle of finding out is not worth it.

I dont agree with the whole pink diesel issue I referred to earlier and IF the Belgium's only recourse was to take me to court, on principle I would be only too pleased to argue my corner (assume as well the potential fine and costs were not earth shattering) but since they use to be able to impound the vessel that gave them one power to far for me.

[mad_jock]

can they detain the pilot

The french certainly do until any issues are sorted out and fines payed.

[Ellemeet]

I believe there are some thoughts which are not correct.

One has to sperate two things:

When will a country switch over to EasA licensing
&
From what date should a resident of an EASA country also hold an equivalent EASA license for the priveleges he wishes to use.

The adoption date differs but the latest possible opt out date is april 2013. All Member countries have to adopt EaSA licensing by april 2013.

Lapl may be introduced at a later date.

For all of the member countries the date at which you need an EASA license as well is set firmly at 8 april 2014.

Now I believe you can also apply for a validation .. But you can only do this once. This would mean that you can extend till april 2015. However .. I am not entirely sure if this is correct.

[Pace]

So bets taken and will be honored on 2014 will be dead in the water (sorry air)

All the soothsayers bets taken and recorded here at pprune :ok:
No more words! Money where mouth is please ;)

Pace

[mad_jock]

Its not really worth betting on if you already have a JAR or EASA license.

Because it really won't effect us.

And to be honest you know perfectly fine that if we are correct there is no way we would take money off you when you can't work.

[Fuji Abound]

Pace

I am not quite certain what the bet is. Is the bet that none of this will come to pass and something will be worked out?

If so you are probably correct - so much of this still seems very fluid, with so many vested interested and lobbying groups.

You only have to recall the IMCr debacle and those on this very forum who said the IMCr was dead in the water and were taking all sorts of bets. I told them it wasnt because I believed it was worth fighting for. There was a petition on the No 10 forum which a few sort to scupper or ridicule and AOPA got the whole thing around there neck before coming to their senses (for a change). Any way the comeuppance was the nay sayers were wrong and the IMCr is here to stay with real progress on the EIR - these things are well worth the fight.

However you better get enough influential people to fight your corner - and there probably are plenty because that is the only way change is brought about. Personally I suspect there are enough EASA policy makers who would still love to see Europe having effective oversight of every pilot operating in its airspace. ( I wish I could say "our" airspace but the policy makers think its theirs ;)).

[S-Works]

Fuji, the last time I looked the last date you can add an IMCr to a Part FCL license is next April. That hardly looks like you won your battle.

I think Pace is widely over optimistic about this, but only time will tell. However it does not change the situation that he is flying illegally at the moment if operating commercially in a N Reg aircraft without a reciprocal EASA requirement as required by law.

[Fuji Abound]

Bose be careful you are close to making another dubious prediction ;).

[S-Works]

Bose be careful you are close to making another dubious prediction .

I am a lot closer to the issue than you give me credit for. Whilst I agree there are still discussions on trying to extend this beyond April next year or even make it permanent, at the moment it is not making much progress.

As it stands at this moment in time the last date which you will be able to add an IMCr to a Part FCL license is 8th April 2014.

So perhaps more honesty and less trying to use smoke and mirrors to infer that you have a solution is the call of the day?

Of course if you have an outright fact about the situation that corrects what I have said then please state it..... ;)

[BEagle]

Whilst I agree there are still discussions on trying to extend this beyond April next year or even make it permanent, at the moment it is not making much progress.

Discussions are certainly ongoing, not least because of the EASA Management Board's endorsement of Principle 4.2 of the “European General Aviation Safety Strategy” which states:

‘Accept flexibility for continuation of specific local activities under NAA responsibility when they have not proven harmful to safety, to fair competition or to free circulation.’

This principle was endorsed by the EASA MB and at the meeting of the Board on 11 December its importance was specifically attested to by a number of Board Members.

EASA rulemakers could have made things easier for everyone by agreeing to IAOPA Europe's FCL.600(b) proposal - which would restore the flexibility of JAR-FCL 1.175(b). We haven't seen the draft opinion yet, but reactions to the CRD (including from the UK CAA) have renewed calls for such flexibility.

If there has to be an 'all or nothing' vote on FCL.008 as it now stands, the UK might have to vote against it, delaying the EIR, C-BM IR and SCR. Which would be a pity, but the blame would rightly fall on EASA's rulemakers for their intransigence. Hopefully they will be given firm political direction and revise their position before the draft opinion is released, otherwise lobbying will have to continue.

Incidentally, we already know that the IAA is firmly against the EIR and I suspect that at least one other NAA is too.....:hmm:

[mad_jock]

personally I don't think this is anywhere near finished and there are still several game plans to come into view depending on the direction things go.

Personally I suspect there are enough EASA policy makers who would still love to see Europe having effective oversight of every pilot operating in its airspace

Thats about the some total of it. And never mind just EASA types there will loads of none aviation types who on a point of principle would prefer hell freezing over than anyone being able to dodge the oversight who is a citizen who lives and works in the EU.

[Gertrude the Wombat]

As it stands at this moment in time the last date which you will be able to add an IMCr to a Part FCL license is 8th April 2014.
So if I've got an IMCr on a CAA lifetime PPL that means I must convert to a Part FCL licence before 8th April 2014? (I knew I would have to do it one day, just checking the date.)

[VMC-on-top]

I thought after 4/2012 all licenses would be deemed an EASA license and then a proper EASA license would be issued on renewal in 2017?
Correct, but the CAA requires you to replace the JAR-FCL licence with an EASA one if you make any changes. At least the new EASA Part-FCL one would be valid for life.

Does this apply for an IMCR renewal (mine expires Sep 2013) which isn't a "change" and my JAR PPL in Sep 2014?

There are a few guys in our group with lifetime CAA PPL's who seem completely unaware of this so I imagine there will be many more who are in the same boat as Gertrude.

Finally, whatever happened to the french led team ??http://www.pprune.org/private-flying/480971-aopa-reports-easa-changes-air.html

[Pace]

I think Pace is widely over optimistic about this, but only time will tell. However it does not change the situation that he is flying illegally at the moment if operating commercially in a N Reg aircraft without a reciprocal EASA requirement as required by law.

Bose

I too am a lot closer to this than you realize :) BTW just checked with an aviation lawyer and no I am not operating illegally at present!
Still up for a bet with you on 2014 being extended £1000 ???

Pace

[S-Works]

Why would I bet against something I dont want to see happen? I have no vested interest in supporting something that stifles freedom of choice.

As an already dual qualified on the types that I fly it has no impact on me at all.

However I think your desperation in avoiding hedging your bets has the potential to lead others astray and possibly into trouble.

I would suggest you seek in writing from the UK CAA confirmation that you are operating legally. After all it will be them that brings any prosecution against you. Having been told categorically at our last inspection that dual licences came into force on the 17th September for commercial operators.

[BEagle]

So if I've got an IMCr on a CAA lifetime PPL that means I must convert to a Part FCL licence before 8th April 2014? (I knew I would have to do it one day, just checking the date.)

Yes - if you wish to continue to use IMCR privileges on EASA aeroplanes.

Does this apply for an IMCR renewal (mine expires Sep 2013) which isn't a "change" and my JAR PPL in Sep 2014?

There are a few guys in our group with lifetime CAA PPL's who seem completely unaware of this so I imagine there will be many more who are in the same boat as Gertrude.

You may revalidate your IMCR in Sep 2013 and use them on both EASA aeroplanes and non-EASA aeroplanes unti Apr 2014. Therafter you won't be able to use IMCR privileges on EASA aeroplanes until you convert your JAR-FCL PPL to a Part-FCL PPL. Then, as it'll still be valid, your IMCR will appear as a valid IR(R) on your new lifetime Part-FCL licence, with a validity expiry date of Oct 2015 and will again be valid on both EASA and non-EASA aeroplanes.

If losing 5 months of the JAR-FCL licence time for which you've already paid is of more concern to you than losing 5 months of IMC privileges on EASA aeroplanes, then you can wait until Sep 2104 to convert your licence. But it will probably be a lot easier if you convert before Apr 2014.

Although AOPA and other organisations have been attempting to keep their members aware of the changes, it is recognised that not everyone chooses to be a member of such organisations - and I share your view that there will very probably be a huge number of 'unaware' pilots flying EASA aeroplanes on UK IMC Ratings after Apr 2014......:uhoh:

[peterh337]

BTW just checked with an aviation lawyer and no I am not operating illegally at present!

Of course you are legal - what you do is Part 91 ops. Non AOC. You are good till April 2014 - as things stand.

After that, you either need to collect the EASA pilot papers, or arrange a non-EU-based "operator", or maybe something will happen.

If there has to be an 'all or nothing' vote on FCL.008 as it now stands, the UK might have to vote against it, delaying the EIR, C-BM IR and SCR.

That would be really stupid.

The pilots who have the technical capability to use the EIR properly are doing just that right now, on plain PPLs, probably illegally, and certainly illegally once outside the UK.

[mm_flynn]

I would suggest you seek in writing from the UK CAA confirmation that you are operating legally. After all it will be them that brings any prosecution against you. Having been told categorically at our last inspection that dual licences came into force on the 17th September for commercial operators.

I don't think Pace works for a commercial operator. I seem to recall he is paid to fly Part 91 operations (I.e. someone's privately operated aircraft).

[Pace]

However I think your desperation in avoiding hedging your bets has the potential to lead others astray and possibly into trouble.

Bose

With all respect you are talking ??? Firstly I would not advice anyone to needlessly spend a fortune in time and money getting European licences now when I am very reliably informed that when all this mess is cleared up yes both licences will be required but the route to that conversion will be quick and simple!
Ok if you have time and money to burn convert now
We already now it's likely that someone with a FAA PPL IR and a set experience level is now unlikely to sit seven exams but purely fly a flight test and have an oral exam! It's likely that a similar route will be offered on commercial licences!

So if someone wants to go ahead now and spend six months doing 14 exams and all the flight costs on top then that's what they should do!
That is not what I am advised!

You could be right and then I will have egg on my face but I don't think it's me who will have the egg to wipe off!

And yes I think you would hate a sensible conversion from an FAA ATP to an EASA one

Pace