A few comments on this interesting discussion. First, there is a version of the NPA here:
http://www.pplir.org/images/stories/...%20markups.pdf which has some bookmarks and sticky notes on the sections that might be most of interest to FAA IRs, IMCr holders and ab initio IRs; the bookmarks in particular make it easier to navigate the 200+ pages than in the original.
Pace:
I find myself thinking that you are coming at the EIR from a different place. I don't know you personally, but I think I've read a bit about your background, so let me illustratively position you as someone with "pro piston twin IFR experience". Well, that kind of experience can be some of the toughest flying around: especially if it's something like night freight and I guess it was even more so in the "old days" when AOC or Part 135 standards weren't enforced as hard. I've heard stories of pilots transporting bank cheques etc who basically flew piston singles and twins in any conditions whatsoever or their jobs were on the line. I've never done anything like that, but as a private IFR pilot with a reasonably equipped twin (deice, WX) at my most current (and more youthful) I've had runs of hundreds of hours (dozens of sectors, night and day, winter and summer, across Europe) without weather causing a single change to my desired departure and causing a diversion perhaps one in 50 sectors. At that level, weather planning is simple and binary - destination and alternate above minima and you go. You cope with enroute weather and weather worse than forecast ad-hoc.
However, I've also flown similar long routes as an IMCr pilot (ie. with no privileges in Europe). There the mindset is very different. You want every reasonable chance that you could complete the flight, or you depart perfectly prepared to turn back or divert. My success rate on "desired" departures was perhaps 30%-70% between winter and summer. I've flown hundreds of hours in Europe like that. I've NEVER EVER had any kind of arrival problem based on the planning criteria I used. Plenty of enroute struggles either to stay on top or scud run below, but never on arrival. Why? Well, what was the point of trying to fly a light airplane on a business trip or to a social event when the odds were significant that you couldn't descend to arrive at your destination VFR? The "go vs no-go" decision-making and the weather planning are completely different from the disciplines in "hard core" piston IFR.
Of course one can always conjecture worst-case scenarios that look undesirable. You can do that for any pilot, PPL-only, EIR or IR - especially at airports with difficult terrain. My point is that the EIR weather planning mindset will need to be much more like "a PPL with a bit of extra privileges" than a "hard core IR with a limitation" to make it safe. I think that is perfectly possible - GA safety
entirely depends on pilot judgement, however much we obsess with the regulatory side. I don't think there has ever been a pilot qualification which, if used to the maximum of its legal privileges, without any additional good judgement and discretion, wouldn't be a hazard. The regulations set some necessary boundaries, but that doesn't mean we fly to them every time or any time in private GA (unlike the "tough pro piston" environment I mention). I know capable pilots with turbine aircraft who avoid flying to minima or with risk of storm weather. I know IR pilots who plan weather with great skill and care to assure they fly in conditions their pax will enjoy on long trips. The analogy is obvious with the EIR - you don't plan to fly to some mountain airport with a forecast OVC 100' above MSA, maybe even not to any airport unless it's BKN 1000' above MSA or OVC 2000' above MSA. Whatever the safe margins are.
Let me give you another example. Non-deiced singles and icing. Imagine a universe in which no aircraft had ever been certified for IFR unless it was FIKI capable. Then someone proposes to certify a C172 for IFR. Icing is potentially very hazardous, and incredibly difficult to forecast. The regulation is pretty "lax" about icing - no "known" icing under the FAA and no actual icing under EASA. Based on this I could give you all sorts of disaster scenarios with cloud and freezing levels unexpectedly below MSA etc etc etc. But, in practice, pilots manage the risk effectively by having a more cautious approach than the legally possible limit. I think the EIR will be safe in a similar manner.
Fuji:
I gave before the example of Southampton.
The IAF is almost overhead the airport at SAM, traffic would normally be positioned at 3,000 feet but down to 2,000 feet is available.
IAFs overhead airports are common, but rarely used under radar except in training. Even in a procedural environment, RNAV approaches mean the days of the overhead IAF are near an end. I can not believe Southampton would ever want someone doing a VFR arrival from the overhead!
We don't need to make this more mystifying and complicated than it is. People already fly enroute IFR in airways terminating with a VFR arrival at an IFR airport day-in day-out. We are not inventing something new! You do it when the ATIS suggests a VFR arrival is going to be fine and when you want to avoid the faff of vectors to the ILS or some convoluted routing in the arrival. (or in the Nice TMA to avoid slot restrictions until Nice banned it). The way you do is is to drop out of the IFR route by descent well before the IAF or the start of vectoring. You are never going to fly to the overhead at 3000', that's either silly for you or it's not going to work for ATC.
The other scenario we can look at is a VFR airport which is so close it is practically colocated with an IFR one. A good example is Palma and Son Bonet. How do you arrive VFR to Son Bonet off airways? You do it by descent well, well before you enter the vectored ILS pattern with a dozen jets at 200-160KIAS. No way in hell do you fly to 3000' overhead LEPA or to an IAF and then descend!
I think it's pretty simple. I don't think an EIR pilot will (formally) fly any part of a SID, STAR or approach. Those are not enroute phases of flight. Of course, any pilot should be able to maintain or change a level or heading under radar control, so there may be tactical reasons at certain airports where that's how ATC want to handle EIR traffic, by vectoring them along a terminal route. But in principle, I'd expect my VFR transition point to be the final enroute airway point or some other arrival point that may be specified in an airport's routing information published through the usual sources. (Obvioulsy, where the STARs begin 100nm out, the VFR transition point is going to be well after that)
People have written a lot about the EIR and I've seen the following "incremental creeping syllabus" suggestions
- SIDs from above 1000'
- STARs
- Approaches to 1000'
- A single approach type to lower (or IR) minima
....well, you know what, you add all that up and you would get to something very like an IR. Now that's nice, but it would mean something very like the IR training. The whole point of the EIR is that it offers a meaningfully easier training step than a full IR. No amount of jiggery-pokery with the privilege definitions, IMHO, is going to create the sought-after "euroIMCr" or "Class 2 IR" or whatever, without creating a training requirement which is very close to that of the IR. We could all stretch the EIR priviliges as far as possible in the CRT, but in the unlikely event of it being accepted, think how much of the 10hr training gap with the full IR we'd close.....4hr?5hrs?6hrs? What's the point of one qualification with 5hrs less training than a full IR? How does that encourage more than the present tiny minority to take a step towards developing skills and capabilities beyond the VFR PPL?
brgds
421C