2. The C-B IR is a good proposal. People should comment on any Learning Objective they feel to be superfluous.
There were a number of superfluous areas left in there, which I commented on (like the one asking where you would find "Flight Level Zero" - what kind of a trick Q is that?) but I think the wider issue there is that the proposed reduction in the TK syllabus makes this proposal extremely vulnerable as a whole. You only need to post some comment in the prof pilots' forum here about some of the utterly bogus JAA IR TK stuff and see the vigorous comments defending the TK. These people are going to lobby hard to re-instate the old TK. This is why I decided to do the JAA IR now.
'Third country' IR conversions do not mandate theoretical knowledge examinations in the NPA, merely that the applicant can demonstrate that the requisite level of knowledge has been achieved. So please suggest ways of achieving this when responding to the NPA. My opinion is that the Examiner can make sufficient assessment from the pre-flight planning and in-flight conduct of the C-B IR Skill Test.
The words "demonstrate knowledge" have been in the regs for far more years than I would know about, and it has always meant
sitting the exams.
So unless you know "something" is in the cooking, I would not expect this to change.
I agree 100% than an FAA-style oral exam would be wonderful because basically any experienced IFR pilot would pass it straight off. But an oral exam (instead of writtens) would terrify most of those passing through the fATPL factory - because they have virtually no flying experience, never mind any IFR experience, by the time they sit their 14 exams. And there are big commercial interests (the FTOs) riding on that. I realise that the CBM IR TK is going to be a different process to the ATPL TK, but that in turn gives ammunition to those against the CBM IR by claiming that the holders of the latter have done a "lesser" IR. Such an assertion would be bogus (because some 90% of the JAA ATPL TK is a load of bollox irrelevant to any form of aviation) but that belief will be held by all of the FTO establishment and nearly all of the transport pilot population
Which is why I am doing the JAA IR now. I think the CBM IR is a great proposal but I think it is politically very vulnerable.