Enroute IR - Practicabilty and Implications

[worldpilot]

In a discussion with a group of pilots and flight instructors at an ATO, there were strong doubts in terms of the practicability of exercising the privileges associated with enroute IR rating in the en route phase of a VFR flight when it comes to navigating IMC conditions and avoiding hazardous conditions such as icy conditions.

The perspective is that most GA aircrafts are not adequately equipped for flights in icing conditions and it also posses a challenge to establish an ice-avoidance flight plan in the en route phase of a VFR flight.

At least, all pilots involved in that discussion were of the opinion that the enroute IR rating is a gambling rating that is not worth pursuing. VFR flight operations into IMC environment must be avoided and is really not recommended.

Navigating IMC territory is very complcated and I personally would advice to go the full IFR route (get the full IR rating) instead of striving for a gambling rating.

WP

[mm_flynn]

There are certainly arguements against the EIR and in favour of an IR. However, the specific concerns you highlight sound more about typical GA aircraft not being suitable IFR platforms, which I think is an unreasonably conservative position (of course we recognise a two crew, two turbine powered aircraft has much more instrinsic capability than a single crew with a single piston engine).

Almost all of my IFR flight could be flown with an EIR. It has the full knowledge and all of the enroute flying of the IR rating.

Flying in dead smooth air at FL100 above the overcast rather than bouncing around at 2000 feet makes flights much more enjoyable. However, the EIR does have the risk that the forecast VFR weather goes south so you need to divert (or shoot an emergency approach). Of course with an IR you weather could go below minimums and you be in the same boat (although it is very rare for the weather to go from 600 and 3km to less than 200 and 550m unexpectedly!)

[ChickenHouse]

First: I guess there is a misunderstanding of EIR in such discussions: executing the privileges of EIR requires an IFR equipped and certified plane. There is no way to take a VFR-only airplane into IMC by this.

Second: Yes, there is a certain risk that people transfer typical VFR "there will be a hole in the clouds over my destination" thinking to EIR and take more risk than b4. But, thy will sit in an IFR plane and if they can't handle that FIS will help'em.

The benefit for EIR is clearly not for the typical sunday traffic-circle bagger, but it may bring back the joy of flying cross country, an art which the younger ones seem to have forgotten by fear.

[bookworm]

At least, all pilots involved in that discussion were of the opinion that the enroute IR rating is a gambling rating that is not worth pursuing.

That would seem to be because they haven't understood the concept.

In a discussion with a group of pilots and flight instructors at an ATO, there were strong doubts in terms of the practicability of exercising the privileges associated with enroute IR rating in the en route phase of a VFR flight when it comes to navigating IMC conditions and avoiding hazardous conditions such as icy conditions.

Where did you get "VFR flight" from? With an Enroute IR, you plan a flight as an IFR flight, except for the departure and arrival. That is a critical part of the concept.

The perspective is that most GA aircrafts are not adequately equipped for flights in icing conditions and it also posses a challenge to establish an ice-avoidance flight plan in the en route phase of a VFR flight.

Again you talk about a "VFR flight". The enroute part of the flight is flown under IFR. There are VFR segments only at the beginning and end of the flight. If these cannot be flown in VFR, don't make the flight, just as you wouldn't make a wholly VFR flight.

Icing is a hazard whether you have an IR or an EIR. If you choose to make an IFR flight in such conditions, you need to have a plan to deal with the icing.

At least, all pilots involved in that discussion were of the opinion that the enroute IR rating is a gambling rating that is not worth pursuing. VFR flight operations into IMC environment must be avoided and is really not recommended.

It is exactly because "VFR flight operations into IMC environment must be avoided"

Navigating IMC territory is very complcated and I personally would advice to go the full IFR route (get the full IR rating) instead of striving for a gambling rating.

I think most of us would prefer to have an IR. But that requires 40 hours of instrument time. The EIR exists because even with 15 hours of instrument time, most pilots are competent enough to hold a heading and a level under IFR, and it's safer to have them do that than scud run VFR below the cloud on the same journey.

[BEagle]

I tried to get EASA to change the meaning of 'EIR' to 'En-Route IFR Rating' (rather than the somewhat misleading 'En-Route Instrument Rating') - because that would better describe its privileges.

The stipulations for the VFR segments are now quite clear, as are the requirements for the VFR/IFR transition points.

Nevertheless, there is a lot of ATC doubt (particularly in Ireland) about the wisdom of this rating. It does not enable the pilot to fly the STAR and and IFR approach, so there is quite some concern about arrival off-airways at a busy terminal area.

But on a nice summer's day when a pilot wants to fly on lower level airways in the en-route phase, it probably has something to offer.

UK pilots are much better placed though - they can obtain an Art4(8) authorised IR(Restricted) and in UK airspace, fly IFR outside CAS and fly IFR approaches to recommended minima - albeit more restrictive than IR minima. Then, once they've gained sufficient instrument flight time, they can convert to the IR with significant credit against the full requirements, rather than wasting time on the EIR.

A pity that the rest of Europe doesn't have such a sensible system - but the non-UK representatives told EASA that you didn't want it and that you wanted the EIR instead.......:rolleyes:

[ChickenHouse]

Isn't the UK special way IMC/IR(R) only until April 2019?

[BEagle]

ChickenHouse wrote: Isn't the UK special way IMC/IR(R) only until April 2019?

As I understand it, that's only because 5 years (from Apr 2014) was the maximum allowable period under current €urocracy - the intention is for the IR(R) to become permanent once sufficient "We told you so!" safety data has been collated by the CAA.

[Lukesdad]

An interesting discussion chaps, but I appear to be the only PPL I know that thinks the new EIR is to be applauded.

The risk for me as a limited ability pilot is in having taken off from my home airfield in good VFR conditions heading for my destination which I have already determined is also enjoying good weather, and encountering poor, unforecasted conditions en route.

The new EIR appears to offer me the ability to continue the journey without incident and arrive at my destination and land with the sun shining.

Yes, an IMC rating would be better. And,yes, a full IR would be better. But for the old and slow amongst us, I think it might help.

[maxred]

The new EIR appears to offer me the ability to continue the journey without incident and arrive at my destination and land with the sun shining

Sorry, disagree somewhat. An IFR flight, is a delicate, time intrusive plan, having to be well thought out prior to departure. The need to understand your transit levels, which frequency and service you would require, cloud tops, icing levels, etc etc. Also, the full knowledge, of IFR arrivals be they STAR, ILS, or VOR/DME, SRA, et al.

The thought that it is all a simple piece of cake, popping up, then popping down, is not my take on it.

I have the full boona so to speak, in ratings, but still require regular instructor led training in order to remain current, to competently fly IFR, to a standard where I do not scare myself ****less. IMO, this is where it is at, regular, and competent recurrent training in IFR flight, and of course, VFR:)

[Fuji Abound]

Maxred

You have a point, but I think there is a tendency to over complicate an IFR flight.

In the UK you have for a very long time been able to depart IFR without the need for any form of instrument rating. In the first instance (in the UK) the clearance said nothing about the weather conditions only the flight rules. Of course OCAS no one cared and in reality you could do much as you liked.

In reality the EIR doesnt change that concept all that much. Although you are flying in CAS in reality the lower levels of CAS are like a desert, no one is there and the airspace is empty.

Of course you have weather responsibilities for conducting the flight safely, but you are just as much a fool if you place yourself in conditions with which you or the aircraft cannot cope as you would be OCAS. I accept that OCAS you have more freedom to make up your own diversions but with an EIR you are able to cope with IMC and you should have a far better appreciation of weather. I doubt that because you have an IR this would significantly increase your appreciation.

So it is back to the age old argument of thinking that all the training that goes with an IR is necessary to enable pilots to do whatever they have done with an IMCr (now IRR) and which they appear to do with an extraordinary safety record.

Time will tell but I think we will find that enabling pilots to get above the weather will actually promote safety, not detract, and lest we forget for most GA pilots and aircraft, en route IFR is all about flying above the weather, not "banging" through it and if that is not possible leaving it to the commercial boys to put up with the bumps and shakes and waiting a day or two for the weather to be more conducive to GA flight.

In short more a practical observation about real life IFR for GA, which I suspect for most pilots is very different for commercial IFR ops - notwithstanding that whatever rules you make up the fool will still depart in weather beyond him or the aircraft and you are just as capable of killing yourself OCAS as CAS, in fact thinking about it more likely in the former.

[worldpilot]

@Bookworm

Where did you get "VFR flight" from?Bottom line is, you're transitioning from VFR-to-IFR to deal with deteriorating weather conditions in the en route phase of the VFR-flight, with subsequent VFR-landing at the destination airport.:ok:

@Lukesdad

The new EIR appears to offer me the ability to continue the journey without incident and arrive at my destination and land with the sun shining.If ceilings and visibilities are heading downhill in the en route phase of your flight, being prepared (in advance of the flight) for tackling associated challenges is the key to have the safest possible outcome.:ok:

Your experience and comfort level might not be appropriate to handle the dynamics evolving around the en route flight envelope, and that's something you should understand.:rolleyes:
The implication is that you might end up not enjoying that sunshine at your destination airport.:ugh:

Appropriate & effective strategies to tackle adverse weather conditions are best ascertained on the ground in advance of the flight and not in the air.

WP

[bookworm]

Bottom line is, you're transitioning from VFR-to-IFR to deal with deteriorating weather conditions in the en route phase of the VFR-flight, with subsequent VFR-landing at the destination airport.

No, that's not the concept. You're planning an IFR flight, albeit with a VFR departure, so that it doesn't matter if the en route weather deteriorates because you have planned the flight without relying on being in VMC all the way along the route.

It is no different from an instrument rated pilot planning a flight between two VFR airfields. He must depart VFR and arrive VFR, but may choose to fly IFR for the enroute portion of the flight so that successful completion of the flight does not rely on VMC all the way along the route.

[Whopity]

In the UK you have for a very long time been able to depart IFR without the need for any form of instrument rating.That all changed with the JAA licence in July 1999. Schedule 8 and then 7 of the ANO stated that the privileges of the PPL(A) and CPL(A) were subject to the provisions of JAR-FCL 1.175 (one of the few JARs to be incorporated into UK Law.JAR–FCL 1.175 Circumstances in which
an IR(A) is required
(a) The holder of a pilot licence (A) shall
not act in any capacity as a pilot of an aeroplane
under Instrument Flight Rules (IFR), except as a
pilot undergoing skill testing or dual training,
unless the holder has an instrument rating
(IR(A)) appropriate to the category of aircraft
issued in accordance with JAR–FCL.

[172510]

In France, if you fly IFR to an airfield without an IFR approach, the French regulation requires that you are in sight of the surface and out of clouds at 3500 AMSL.
An IR rated pilot would fly an approach at a nearby airfield, and once below clouds, would cancel IFR and continue to destination.
Unless the French regulation changes, I can't see much legal use of an EIR for flights to France...
I don't know whether the new European Rules of the Air will waive the French requirement that IFR flying must be over 3000 AMSL or not.
I very much suspect that in France pilots won't care about regulations, and will fly approaches anyway, or worse, will fly self made GPS approaches.

[BEagle]

But Whopity, there was also JAR-FCL 1.175(b):


“In JAA Member States where national legislation requires flight in accordance with IFR under specified circumstances (e.g. at night), the holder of a pilot licence may fly under IFR, provided that pilot holds a qualification appropriate to the circumstances, airspace and flight conditions in which the flight is conducted. National qualifications permitting pilots to fly in accordance with IFR other than in VMC without being the holder of a valid IR(A) shall be restricted to use of the airspace of the State of licence issue only.”

So while it was no longer legal for a pilot without any relevant qualification, our UK national qualification (the IMCR) was entirely adequate to meet the requirements of JAR-FCL 1.175(b). EASA didn't adopt this flexibility, so it took several years of hard arguing before finally the EC came up with the Article 4(8) easement. Which is probably a much greater safety benefit than is the EIR.

[172510]

In France, if you fly IFR to an airfield without an IFR approach, the French regulation requires that you are in sight of the surface and out of clouds at 3500 AMSL.
An IR rated pilot would fly an approach at a nearby airfield, and once below clouds, would cancel IFR and continue to destination.
Unless the French regulation changes, I can't see much legal use of an EIR for flights to France...
I don't know whether the new European Rules of the Air will waive the French requirement that IFR flying must be over 3000 AMSL or not.

[Whopity]

Unless the French regulation changes, I can't see much legal use of an EIR for flights to France... EASA Regulation superceeds French National Regulation!

[172510]

Yes EASA regulation, as any European Regulation, supersedes French one. That's not the question I raised. I wondered what SERA will say about IFR at low level.
SERA.5025 IFR — Rules Applicable to IFR flights outside controlled airspace
(a) Cruising levels
An IFR flight operating in level cruising flight outside of controlled airspace shall be flown at a cruising level appropriate to its track as specified in the table of cruising levels in Appendix 3, except when otherwise specified by the competent authority for flight at or below 900 m (3 000 ft) above mean sea level.
So France is allowed to keep forbidding IFR below 3000ft AMSL
I could see nothing in SERA that would prevent France from forbidding to descent below 3000 AMSL in IMC if no apprach procedure is available.

[worldpilot]

@Bookworm

No, that's not the concept. You're planning an IFR flight,

Nevertheless, you must depart VFR and land VFR.:D

If VFR minima at origin and destination airports is not prevailing, then EIR is not applicable.:ok:

WP

[BackPacker]

What you're planning is an IFR flight on a combination of a Y and Z flight plan.

It's the exact same thing as a full-IR holder planning an IFR flight between two VFR-only airports. You depart VFR, pick up your IFR clearance en-route, climb into the airways and enjoy the glorious sunshine on top. Near your destination you descend, cancel IFR and continue VFR to your destination.

If your departure or destination airfield is below VMC minima, you can't make the flight, so you have to cancel or divert.

Obviously the transition from IFR to VFR is notoriously tricky since you and the controller need to work together to find a location where you can still be controlled as an IFR flight, but you need to be in VMC so you can cancel IFR. So you need to have VMC conditions above the MVA/MCA or whatever minimum the ATC controller needs to control you IAW IFR. And that minimum level may actually be well above what you'd require for a full-VFR flight.

That last bit may actually be the biggest catch. Suppose your destination airfield is widespread OVC015. It would be perfectly possible to fly to that destination VFR at 1000', but if the MVA/MCA level is 2000', you would not be able to achieve VMC conditions while under IFR, so you can't cancel IFR. And without a full IR, you cannot fly a STAR or instrument approach, either for cloudbreak purposes (using the ILS of a nearby field for instance, to get below 1500' and into VMC) or for a full stop landing.

[172510]

BackPacker you are right, although technically it needs clarification.
All over France, an IFR flight may not descent below 3500ft without the ground in sight, unless on an instrument approach. You may land IFR at a VFR airfield, provided that you remain out of clouds and with the ground in sight continueously below 3500ft
You certainly may cancel IFR even if you don't see the ground, provided you are out of cloud, and provided that you know you can remain in VMC until landing.
If it's overcast at 3000 AMSL, even if it's perfectly flyable below, the EIR won't be of any use.
Most private pilots who fly for pleasure don't fly when the weather is not VFR at all, but enjoy their rating to fly above cloud without being worried about finding a hole in the cloud layer at destination.

[BackPacker]

All over France, an IFR flight may not descent below 3500ft without the ground in sight, unless on an instrument approach.

I've got the feeling it's not as clear-cut as that. I can well imagine that the en-route phase of your IFR flight has to be conducted at 3500' or above. That's got to do with radar and radio performance - below approximate this level there's all sorts of ifs and buts associated with radio and radar performance, and you don't want to worry about those when flying IFR.

But the exceptions to flying IFR below 3500' cannot be limited to instrument approaches only. For starters, instrument departures have to be flown partly below 3500' as well (duh). But also, near airfields, ATC has to have the ability to vector you onto the instrument approach while your altitude is below 3500'. I mean, you don't intercept the ILS from 4000' when being vectored, right? That's typically done at 2000' or so.

So my gut feeling is that within terminal areas ATC can vector you around at 2000'-ish while fully complying with IFR. The minimum altitude in such areas would be the sector altitude, or something else that's locally established based on geography, radar performance and maybe some other factors. But definitely lower than 3500'.

And if ATC can vector you around in their terminal area at 2000' or thereabouts to set you up for an ILS approach, they can also vector you around in their terminal area to your designated IFR-to-VFR transition spot. And the chances of being in VMC with the surface in sight are significantly higher at 2000' than at 3500'.

Then again, this requires that you make the IFR-to-VFR transition near a major airport, and they might not be happy with the additional workload, if that airport is not your destination. Plus, that airport may not be conveniently located next to your destination. But if your IFR-to-VFR transition is planned to take place far away from a major airport, then the minimum at which this can happen may indeed be 3500' or even higher.

But regardless of the actual altitude at which the IFR-to-VFR transition has to happen, it is something to think about and plan ahead. Because there will be a minimum altitude at which ATC can control you while IFR. And you have to find VMC conditions at that altitude, or else you cannot make the IFR-to-VFR transition.

[worldpilot]

And without a full IR, you cannot fly a STAR or instrument approach, either for cloudbreak purposes (using the ILS of a nearby field for instance, to get below 1500' and into VMC) or for a full stop landing.Now, that represents serious limitations for such a critical phase of flight (approach and landing).:{

You've attained the EIR qualification, and assuming you are ace at instrument procedures, what sense does it make then not to exercise these competencies during approach and landing?:=:=

In IFR flying, exercising required privileges during crucial phase of approach and landing should not be constrained, since evolving weather limitations may necessitate execution of instrument procedures.:)

WP

[BackPacker]

You've attained the EIR qualification, and assuming you are ace at instrument procedures, what sense does it make then not to exercise these competencies during approach and landing?

The EIR doesn't require you to be an ace at instrument approach procedures. In fact, I don't think instrument approaches are taught, except perhaps as a "get out of jail for free" capability.

If you want instrument approach (and departure) capabilities, get the full IR.

[worldpilot]

If you want instrument approach (and departure) capabilities, get the full IR.

That's right, BackPacker.:D

WP

[172510]

I bet that people will get their EIR, then say there able to fly in clouds, then travel under IFR, then say they are VMC and cancel IFR although it's overcast at destination, then use their GPS to illegally brake out at 1000 ft overhead their destination, and swear to god that there was a hole in the cloud layer when the gendarme asks.
Maybe that's what EASA people want anyway

[Fuji Abound]

they will, because they can, except for the last bit, but you are right how will pilots actually end up managing the final flight segment if conditions are not erhm, exactly VFR.

It is well rehearsed but the point is you establish that the final segment will be VFR, but the EIR enables you to overfly en route IMC (or even en route in IMC), because, to be fair the TAFS are rarely that wrong.

[Contacttower]

I bet that people will get their EIR, then say there able to fly in clouds, then travel under IFR, then say they are VMC and cancel IFR although it's overcast at destination, then use their GPS to illegally brake out at 1000 ft overhead their destination, and swear to god that there was a hole in the cloud layer when the gendarme asks.
Maybe that's what EASA people want anyway

Well for all we know that is happening already - just as a fully IR rated pilot may be tempted to do exactly the same thing arriving into a VFR airfield. Maybe we should ban IFR flights into VFR only airfields? :E

Whether the holder has an IR or and EIR I don't see why it should make a difference to their behaviour when confronted with that situation. :ugh:

[thing]

I guess what it boils down to is people will over extend their capabilities (as they always have done) and we'll speculate about the accident on here (as we always have done).


I can see Fuji's point about TAFs but would you be willing to bet your life on it? I bet a lot of people would.

[Wrong Stuff]

You're not "betting your life" on a TAF using an EIR, just the same as with an IR. That's just plain stupid.

At airways levels, METARS are available from VOLMET to give an idea of how the weather's panning out in the general region. Information services - eg London Information or Langen Information - are always happy to provide updated METARs and TAFs for any airfield you'd like to request. In a pinch, if he's not busy, ask the sector controller. You don't just sit there in the airway, following the purple line and praying that the TAF turns out right. During quieter moments you update yourself on how the actual weather is shaping up at your destination, so you can plan an early diversion in the light of actual conditions, if necessary. All of this is truly basic stuff for an IR holder, just as it should be for an EIR holder.

Really, if after all the training somebody cannot safely plan and execute an airways flight with a VFR sector at the end, it would be a total waste of time them doing an IR. An IR has lower minima, but it doesn't give you a magic wand to land if the weather turns out bad over a widespread region. You have to plan, monitor the trends, and make sensible decisions in the light of actual conditions as they develop.

[Fuji Abound]

Quite so.

A TAF would have to be more than substantially wrong to meet the criteria for an EIR and fall so far adrift as to make the arrival impossible, and, moreover, in that unlikely event the TAF at the designated alternate would have to fall into the same degree of error. Should that happen the EIR holder is trained and qualified to fly on instruments. Should an arrival at both the planned and the alternatives all require an approach in IMC then the pilot will call a PAN and will (should) receive all the vectoring and support required so as to avoid the complexities and "risk" associated with a procedure ending with an ILS or SAR which they should be capable of flying safely.

[BackPacker]

And let's be honest. To a very large extent this problem is identical to what a non-(E)IR holder faces when he decides to fly VFR-on-top. Which is fully legal under EASA on just a plain PPL (airspace permitting). In this respect, the only difference between a vanilla PPL and an EIR holder is that the EIR holder can enter class A and fly the airways.

[worldpilot]

In this respect, the only difference between a vanilla PPL and an EIR holder is that the EIR holder can enter class A and fly the airways. With assumptions that the aircraft performance envelope allows that.

Apparently, EIR is not applicable on HPA, right?

WP

[Level Attitude]

And let's be honest. To a very large extent this problem is identical to what a non-(E)IR holder faces when he decides to fly VFR-on-top. Which is fully legal under EASA on just a plain PPL (airspace permitting). In this respect, the only difference between a vanilla PPL and an EIR holder is that the EIR holder can enter class A and fly the airways.Initially I thought the EIR was a ridiculously dangerous concept but I realised this was probably a UK centric view: UK issued National or JAA Licences not allowing flight 'Out of Sight of the Surface' unless some form of Instrument qualification was held.

Is there a history of non-UK Licence Holders getting in to difficulty/having accidents as a result of flying 'VMC on Top'?

If yes, then the EIR is a dangerous concept.
If no, then I cannot now see the problem. All the EIR allows pilots to do is to fly closer to (and even in) clouds en-Route than someone with only a PPL and to take advantage of the airways structure/added "protection" from ATC.

[bookworm]

Apparently, EIR is not applicable on HPA, right?

No, the EIR is applicable to single-pilot high performance non-complex aeroplanes. For single-pilot high performance complex aeroplanes and all multi-pilot aeroplanes, a multi-engine IR is a pre-requisite for the type rating.

[worldpilot]

So, that means EIR is valid on Cessna 182, but it is not applicable on Cessna 182RG or Beech Bonanza, right?:ugh:

Now, that's a drawback for individuals with EIR and are flying Beech Bonanza or Cessna 182RG. They won't be able to exercise EIR privileges in the event of IMC situation.

The Cessna 182RG and Beech Bonanza are HPA and complex.

WP

[stevelup]

The Cessna 182RG and Beech Bonanza are HPA and complex.

No they aren't - HPAs are generally jets and large turboprops.

Here's a list (check the 'HPA' column) (http://easa.europa.eu/system/files/dfu/EASA%20T_R_List_Aircraft%2025062014.pdf)

[BillieBob]

Apparently, EIR is not applicable on HPA, right?Wrong! The privileges of the EIR are "to conduct flights by day under IFR in the en route phase of flight, with an aeroplane for which a class or type rating is held. The privilege may be extended to conduct flights by night under IFR in the en route phase of flight if the pilot holds a night rating in accordance with FCL.810." No mention there of it not being valid on HPA.

No, the EIR is applicable to single-pilot high performance non-complex aeroplanesNo, the EIR is applicable to any aeroplane for which a class or type rating is held.

So, that means EIR is valid on Cessna 182, but it is not applicable on Cessna 182RG or Beech Bonanza, right?Wrong! In EASA-speak, 'complex' means an aeroplane:


with a maximum certificated take-off mass exceeding 5 700 kg, or
certificated for a maximum passenger seating configuration of more than nineteen, or
certificated for operation with a minimum crew of at least two pilots, or
equipped with (a) turbojet engine(s) or more than one turboprop engine

So, in fact, neither the 172RG or the Bonanza are either HPA or complex.

[thing]

You're not "betting your life" on a TAF using an EIR, just the same as with an IR. That's just plain stupid.


I'm not arguing with what you say, of course it's eminently sensible to do exactly what you suggest; I'm merely commenting that some pilots are indeed 'plain stupid.' Otherwise the accident stats would be a lot lower.

[bookworm]

No, the EIR is applicable to any aeroplane for which a class or type rating is held.

Well yes, but you can't get a class or type rating on a single-pilot high performance complex aeroplane or a multi-pilot aeroplane without an IR.

Actually, you're right, it's a pre-requisite. So if your IR has lapsed but you still have the relevant type rating, I guess you could use an EIR.