IR(R) on EASA license

[BEagle]

slw29 wrote:

I seem to remember that there was a condition that the IR(R) training can only be put towards the new EASA IR ratings if it has been given by an instructor qualified to teach the full instrument rating

Regrettably, that rumour came about from people who had jumped the gun and hadn't waited for the AMC&GM to be released In any case, the course needed to obtain the qualification needed to instruct for the IR was the same as for the IMCR, bar the FI/IRI's own experience pre-requisites. And just how would you know whether or not someone who taught IF 30 years ago was qualified to teach for the IR? The problem was one of EASA's own making, as it didn't have anything between the PPL and the IR which required an IF instructor. Whereas we do.

Eddie Seymour wrote:

Is there anything different on TK, Basically these are 7 exams.

No, there are 7 subjects. Perhaps some exams could be combined? AOPA UK will be pressing for the C-bM IR exam(s) to be able to be taken at an ATO rather than at Gatwick / Oxford / Shuttleworth etc.

[slw29]

Ah - I got that from reading the PPL-IR website, is that not correct then?

Dual instrument time undertaken as part of a UK IMC Rating course can only be used as creditable dual hours (up to 15) for an EIR or CBM IR if it was conducted by an IRI or FI(A) qualified to teach for the full IR. However, flight time as PIC under IFR using the privileges of the IMC Rating is creditable up to the 15 hours allowed in the CBM IR. Therefore, a UK IMC Rating holder, having completed the 15 hour IMC training course and having completed a further 15 hours PIC under IFR will require

• only the 10 hour ATO course, as a minimum, to complete the CBM IR training if their IMC Rating instructor was qualified to teach the IR
• if not, they will require a further 15 hours instrument training by an IRI or FI(A) qualified to teach the IR
  
• in either case, they will need to complete the IR TK course and pass the exams

[Level Attitude]

An IR(R) holder who has gained 15 hrs instrument flight time as PIC on aeroplanes (not simply 'IFR time')

How do you do that then? - I have never bothered to log the 15 seconds or so that it takes to go through a cloud, and I'd have to do a lot of that to add up to 15 hours!

You don't

I have just re-read the Amending Regulation and it says you can count up to 30 Hours of 'PUT IF' and/or 'PIC IFR' towards the 40 Hours IF requirement for a CB IR.

I must admit I don't understand this as I thought 40 Hours IF was a minimum ICAO requirement to obtain an IR and, it seems, EASA are allowing IFR experience to negate this requirement?

[BEagle]

Level Attitude, please read Annex to ED Decision 2014/022/R. On .pdf p104/105 you will find the following, the last clause of which I have indicated in red:

AMC5 to Appendix 6 Modular training courses for the IR

SECTION Aa IR(A) – COMPETENCY-BASED MODULAR FLYING TRAINING COURSE (6)(a)(i)(B); (6)(b)(i)(B) PRIOR EXPERIENCE OF FLIGHT TIME UNDER IFR AS PIC

A rating giving privileges to fly under IFR and in IMC referred to in (6)(a)(i)(B) and (6)(b)(i)(B) may be any of the following:
(a) an EIR rating issued by a competent authority of a Member State; or
(b) a national instrument rating issued by a Member State prior to the application of Commission Regulation (EU) No 1178/2011; or
(c) an instrument rating issued in compliance with the requirements of Annex 1to the Chicago Convention by a third country; or
(d) an authorisation issued by a Member State under Article 4(8) of Commission Regulation (EU) No 1178/2011.

The amount of credit given should not exceed the amount of hours completed as instrument flight time.

slw29, I do not know for sure whether the PPL/IR website comments were written before the AMC&GM were released (although I suspect they probably were); nevertheless, the AMC&GM does represent the true facts of the matter, which discussions with the CAA have also indicated to be an area of common understanding.

[Level Attitude]

AMC5 to Appendix 6 Modular training courses for the IR

The amount of credit given should not exceed the amount of hours completed as instrument flight time.

'Should' is not mandatory.

I am not disagreeing with the sentiment as I think it would be ludicrous to require one person on an initial short, intensive, course to have completed a minimum of 40 Hours IF where as someone spreading the same course over several years would require less.

If they meant only PIC time which was coincidentally both IFR and IF was countable then they should have said so.

Possibly another case of primary legislation being written by someone who didn't understand what they were writing (difference between IFR and IF)? With that paragraph subsequently inserted in to the AMC to try and rectify the error?

An IR(R) holder who has gained 15 hrs instrument flight time as PIC on aeroplanes (not simply 'IFR time'), will probably also have flown 15 hrs instrument flight instruction time for the IR(R).

All he/she then has to do, in order to convert to a full C-bM IR, is to:

• Pass the C-bM IR theoretical knowledge exams
• Fly an additional 10 hrs instrument flight instruction time at an ATO
• Pass the IR Skill Test

The problem here is:

Part-FCL Ammended
Aa. IR(A) — Competency-based modular flying training course
FLYING TRAINING
(i) When the applicant has:
(A) completed instrument flight instruction provided by an IRI(A) or an FI(A) holding the privilege to provide training for the IR; or .....
......these hours may be credited towards the 40 hours above up to maximum of 30 hours,

(d) The completion of the instrument flight instruction provided by an IRI(A) or FI(A) in accordance with point (a)(i) or (b)(i) shall be documented in a specific training record and signed by the instructor.


AMC Amended
The assessment to establish the amount of training to be credited and to identify the training needs should be based on the training syllabus established in Appendix 6 Aa.

(b) TRAINING RECORD


(1) Before initiating the assessment the applicant should provide to an ATO a training record containing the details of the previous flight instruction provided by the IRI(A) or the FI(A). This training record should at least specify the aircraft type and registration used for the training, the number of flights and the total amount of instrument time under instruction. It should also specify all the exercises completed during the training by using the syllabus contained in Appendix 6 Aa.

(2) The instructor having provided the training should keep the training records containing all the details of the flight training given for a period of at least 5 years after the completion of the training.

Although the AMC gives flexibility ('should') it doesn't take away the fact that any prior IF training has to have been documented ('shall be') to be allowable as credit against the CB IR requirements.

Can anyone who passed their IMC Rating 15, or even 2, years ago confirm their training was documented in an acceptable manner for CB IR purposes? Can they prove it, ATOs will want to see a record?
Is it written anywhere that a Flight Test Pass/Rating Issue is an acceptable alternative to a Training Record?

[BEagle]

The word 'should' is not supposed to be used in AMC&GM; where EASA has done so in the past, they have subsequently corrected such an error. This ridiculous €urocracy then gives rise to daft statements such as 'the applicant should pass the Skill Test'. However, NAAs are expected to follow either the relevant AMC or an AltMoC submitted to the Agency.

Back to the recent amendment, Commission Regulation 245/2014 goes on to state:

(ii) When the applicant has prior instrument flight time under instruction other than specified in point (a)(i), these hours may be credited towards the required 40 hours up to a maximum of 15 hours.

AMC5 and AMC6 to Appendix 6 have now provided sufficient guidance to the CAA to enable them to formulate conversion requirements from the IR(R) to the C-bM IR.

[slw29]

AMC5 and AMC6 to Appendix 6 have now provided sufficient guidance to the CAA
to enable them to formulate conversion requirements from the IR(R) to the C-bM
IR.

BEagle, thanks for the explanations. I suppose then that we need to wait for the CAA to publish these requirements, since ultimately it's going to be their precise interpretation that matters. Do you know what the timescale is supposed to be for this?

[Level Attitude]

Back to the recent amendment, Commission Regulation 245/2014 goes on to state:
Quote:
(ii) When the applicant has prior instrument flight time under instruction other than specified in point (a)(i), these hours may be credited towards the required 40 hours up to a maximum of 15 hours.

BEagle, my apologies, I had missed that the above paragraph was not covered by the 'Training Record' requirement. However how to prove such training to an ATO remains an issue - of course anyone who was ever issued an IMC/IR(R) (or a CPL?) must have done at least 10 Hours of IF Instruction.

AMC5 and AMC6 to Appendix 6 have now provided sufficient guidance to the CAA to enable them to formulate conversion requirements from the IR(R) to the C-bM IR.

BEagle, thanks for the explanations. I suppose then that we need to wait for the CAA to publish these requirements, since ultimately it's going to be their precise interpretation that matters. Do you know what the timescale is supposed to be for this?

As I surmised, nothing in writing yet - but hope for the future.

[BEagle]

slw29, probably about a year from now, given the number of higher priority near-term projects with which the CAA's depleted workforce are currently having to deal.

Level Attitude, I had a very successful discussion with the CAA a week or so ago concerning all this - it took a while for their penny to drop but they do now see the requirements more clearly.

I suspect that delays will come from:

• Formulating the exams and deciding whether they may be taken at an ATO.
• A decision regarding whether any IRE other than a CAA Staff Examiner may conduct the C-bM IR Skill Test.