Enroute IR - Practicabilty and Implications

[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.

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?

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.

[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?

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)

[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 aeroplanes

No, 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.