AMC1 FCL.825 states:
A VFR transition point should be used in order to enable the pilot to conclude the flight under VFR to the intended destination. For this purpose, when filing a flight plan in accordance with operational rules, the holder of an EIR should include IFR/VFR transition points. If an IFR approach procedure is established at the destination airfield, this IFR/VFR transition point should be passed before reaching the Initial Approach Fix (IAF).
'Should' in EASA-speak is a recommendation, not a mandatory requirement. The circumstances described above need to be changed to become mandatory as they will then have legal strength. This could be achieved by the use of 'shall' instead of 'should'.
That is one example of the type of comment I will be making at the forthcoming workshop. It will be neither the time nor place to argue the relative merits of the IR, its theoretical knowledge requirements, nor whether they are proportionate for the proposed EIR, nor the EIR itself. To me the EIR theoretical knowledge requirements seem disproportionate for the privileges conferred - so the option to do an 'EIR' exam first, followed by a delta for the 'IR', would seem a reasonable alternative.
The workshop will really only be an information gathering session and will not be suitable venue for indicating the direction the NPA response of an individual or organisation will take. However, it may be necessary to advise EASA that, given the very short period of time which has been available to study the NPA, it does not at present seem to meet the UK's position as regards the IMCR. Rather than press the point on Friday, I hope that my fellow UK representatives and I will restrict ourselves to a few basic questions concerning the IR, EIR and 'sailplane cloud rating' within the scope of the NPA, but will be taking up the matter of the UK IMCR in UK airspace with the UK CAA and 'others' over the coming weeks.
It's possible that the EIR
might be considered a 'student' rating, allowing IR students to gain the relevant experience towards the IR, rather than an indefinite V/IFR rating. Why? Because that could be a strategem to reduce opposition from ATS providers who are known to be concerned at the impact of additional IFR activity in busy sectors.
Typical questions I am already considering:
1. Define 'busy IFR airspace' for EIR training.
2. Define 'emergency IFR approach' for EIR training.
3. Were ATS providers consulted during FCL.008?
4. What is the minimum cloudbase permitted for a sailplane / powered sailplane pilot to fly in cloud with the sailplane cloud rating?
I'm aware that the level of 'bull$hit' in the IR theory requirements has already illuminated the 'BS' caption - it will take people quite a while to wade through it all, but please do so!
It will hopefully be a productive information-gathering session in Friday - and I'm looking forward to a Schnitzel und Weißbier tomorrow night at the usual place!