I just don't know why there can't be a "PRIVATE" and "COMMERCIAL" IR (or my preferred wording "not authorised for public transport ops". For the Private there should be training as required to pass the flight test, one exam, and credit for previous instrument time (for example then the IMC time would count). The flight test could be to the same standards too
Englishal,
There is today exactly the Private IR you describe. It is the JAA IR. You can't use it for public transport ops unless you have considerable additional training and qualifications
- in a light piston aircraft; CPL writtens, a CPL and all the line/base training and checks required under the operator's approvals
- in a larger aircraft, all the above, plus a Type Rating passed to higher (ATPL) standards and an MCC and the ATPL writtens
and there is
nothing in the current flight training and testing which is specific to public transport. The written exams have a few remnants in airlaw which might be considered as such, but let's remember the JAA IR syllabus is already signficantly slimmer than the present one in the UK. It's simply that the UK CAA have not chosen to implement the JAR-FCL amendment and the new question bank that have been available for a year or two.
I wrote a post earlier with a bit about the "privilege limitation fallacy". I don't mean for 'fallacy' to sound derogatory - perhaps 'problem' or 'conundrum' would have been better, but the earlier discussion was a bit more heated...
Let me repost it adding your restriction to the list in underline.
......At its heart is a misunderstanding some people may have; let me call it the "Privilege Limitation Fallacy".
The IMCr is a rating which permits a pilot to fly under IFR in IMC in every phase of flight. From the point of view of knowledge, training and skills, there is no meaningful difference between the IR and the IMCr, if, as EASA does, you took the current IR as the baseline and said "how can the training be reduced if we removed Class A privileges and recommended higher minima"; what would the answer be?
- a tiny bit of air law relating to Class A and airways
- the dog-leg join of an airway you do on IR test routes (one of the easiest bits)
- the ~40s on each ILS it takes to descend from 500' to 200'
Teaching a non-precision approach would be identical, except there'd be a different number on the altimeter at MDA.
Therefore, from the perspective of the EASA IR, the reduction in IMCr privileges simply does not correspond to the reduction in training and "approval" standards for training.
Let's take the example of all the other ideas for "limited privileges" I've seen on various threads.
- can't be used in RVSM airspace
- can't be used in pressurised aircraft
- can't be used in Type Rated aircraft
- can't be used in Oceanic routes
- can't be used in aircraft with more than 6 seats.
- can't be used for public transport ops
It's all clap trap. The JAA/EASA IR is conducted in a light piston aircraft at low level. What could you eliminate from the flight training as a result of all these "restrictions"?
- err, nothing
What FCL008 is proposing is
- a further reduction in the IR TK syllabus to eliminate items not relevant to the privileges granted. These are not 'commerical' items, they have already been elminated. They are irrelevant
depth in the private items.
- a training method more flexible than the current ones, which were primarily designed for the purpose of turning zero-hour cadets into 190hr junior FOs for the RHS of transport jets
But, the irony is that, although the JAA IR training structure was designed to fit the Integrated/Modular routes to a frozen ATPL, the actual content is wholly focused on low-level IFR in small piston aircraft, with no meaningful 'commercial' elements.
EASA has already decided the standards needed to operate a light aircraft under the priviliges of a 'private' IR. They are those of the current JAA IR. All the extra stuff (from Commercial/PT to operating a 3 engine pressurised aircraft with more than 6 seats in RVSM/Oceanic airspace) needs a bunch of extra training in addition to that of the current JAA IR.
No 'privilege limitation trick' is going to change this. If the current JAA IR immediately qualified a PPL to fly commercial or jet stuff, then privilege limitation would work. But it doesn't, because it qualifies you for nothing more, as a PPL holder, than to operate a light aircraft privately under IFR in all phases of flight. Which is exactly what we want in a 'private' IR and exactly what the IMCr does outside Class A. But see above my points on the "Class A limitation".
We may all agree that the FAA methods, lock stock and barrel, are as safe and a lot more flexible and efficient than the European ones. But until someone has a masterplan to overthrow the entire regulatory model in Europe, I think our best bet is to support the FCL008 outcome within the EASA model. Outside of the EASA model, of course, the UK can try and save/exempt/grandfather the IMCr and good luck to those efforts.