Ok, then I have misread your initial post. I thought some change had been agreed at the workshop, but now understand that no change has been made.
No, this was a workshop. The normal NPA/CRT/CRD/CRD response/Draft Opinion process will now follow. We highlighted a few points and made a few suggestions for the way things could go, but the statutory process is the next stage.
IO,
This was why I started the other thread about how the arrivals would work in practice. My own interpertitation is that EASA want an EIR pilot to desent to a lower altitude which will almost certainly be outside the airway system and quite probably outside controlled airspace, but no lower than 1000ft above the highest obstacle within 5nm. Presumably they'll use VFR charts for this. They'll need VFR charts anyway because they need to depart and arrive under VFR. My understanding is that the departure and arrival is VFR, not just VMC.
As Pace says, and yourself, it's not so easy to determine that the weather 50nm away from the airport will be VFR, as there might be no metar/taf there.
The transition procedure from IFR to VFR will be more exercising than simply flying IFR all the way to the FAF. EIR pilots will need to have good radio standards and to have good back-up plans for their intended flight; they will also need to be quite sure of what the rating will or will not facilitate. So the trip profile might not be as efficient as ideal, but it should at least be possible. If the descent and transition proves to be too difficult for some aerodromes, then this will probably act as a spur to upgrade from EIR to the 'new' IR!
Prob the usual EASA tea and biscuits Meeting with emty promises ?
No, it was a very useful and equable workshop. And there weren't any biscuits!
The "demonstrate knowledge" should be an oral exam, for holders of ICAO (what EASA derisorily calls "thord country") IRs.
Might I suggest you make that point in your NPA response? Others at the meeting made similar comments, as will I when I submit my personal NPA response.
If you can find time, comment on totally silly TK items. There are not many for the FCL008 IR because the "X" does not appear against many items, but there are some like the "flight level 000" pointless/trick question.
Quite so. But to be taken seriously, please remember to:
1. State the reference upon which you wish to comment
2. State your counter proposal
3. State the justification for your counter proposal
Jim has already done a good job of de-bolleaux-ing the LOs, but any further constructive suggestions will of course be followed up.