EASA AND THE IMCR - NEWS [Archive] - Page 3

peterh337

18th Dec 2011, 18:29

I wonder what will change from the current procedure for that, bookworm.

I have had no trouble getting JAA IR training done in my TB20, N-reg too. AFAICT the FTO did not have any significant work to do with that.

The JAA IR flight test itself needs the aircrtaft to be specially approved (http://www.caa.co.uk/docs/33/srg_fcl_07_A.pdf) but most reasonable IFR types should not have a problem - assuming they are legal to fly in the first place ;) Similarly, I would guess, for VFR too but IMHO very few people will be doing an ab initio PPL in their own plane (and those that do are probably ones who bought something quite nice and brand new).

If the current EASA proposals come to pass post-2014 and the IFR community really gets shafted as EASA plans to do, and the N European ATOs fail to grasp the business opportunity to do IR conversion courses in customer aircraft, all that will happen is that everybody involved will sod off to a certain ATO in Spain and knock the whole lot off in 1 week... The pilots will be losers because they won't have got training on the type they fly, but the ATOs up here will have cut off their nose to spite their face.

Continuation training will have to be done informally, for cash :)

God knows how the mandatory annual IR renewals will be done, if they can't be done in customer aircraft. That would be the most stupid thing of all, effectively screwing the CBM IR. But that creates yet another business opportunity: an "IR Renewal ATO" which processes the paperwork for a small fee say £50 and whose "affiliated" IREs are a load of freelancers working around the UK :)

BEagle

18th Dec 2011, 18:58

Yes, well fine - nice story but impossible in brave new €uroland.

The 'approval to be trained / tested in own aircraft' issue might be a useful bargaining tool to use when the CRD is issued in March. If all EIR/IR training has to be conducted under the auspices of an ATO (including those which are presently RFs), then it is only reasonable that straightforward evidence of 'suitability for training' is submitted for the aeroplane. That should be a simple no-cost, post-annual box-ticking exercise, but it would probably be necessary to fight off CAA revenue-generation attempts....

I don't know whether there will be a mandatory requirement for the owner's aircraft to be modified to include those wretched bits of tin / plastic the CAA insists on (which can cause problems... http://www.aaib.gov.uk/cms_resources.cfm?file=/dft_avsafety_pdf_502021.pdf ), or whether a simple set of foggles will suffice for EIR / C-B IR training. Hopefully the latter!

peterh337

18th Dec 2011, 21:36

The window screens are supposed to disappear under EASA.

But I bet the UK CAA will find some way to continue them.

I made my own, out of Correx - took me a day and a half with a knife, tinsnips and a hot glue gun. No metal involved at all. Right horrid job though; I suspect most people would find it quite difficult to do. But they work well; a lot more comfy to fly with than foggles.

The problem is that all these things add up... a day and a half spent making the screens will alone push most people into just popping on Easyjet to the south.

WorkingHard

31st Dec 2011, 09:09

I have just received this from our wondeful Minister who seems to be under an illusion that all is well in EASA land!
Your comments for a suitable response would be appreciated if you think it of any use.

many thanks

Department for
Transport

From the Minister of State The Rt. Hon. Theresa Villiers MP
House of Commons London
SW1A OM
Great Minster House 33 Horseferry Road London SW1 P 4DR
Tel: 02079443082 Fax: 020 79444492
E-Mail: [email protected]
Web site: Department for Transport - Department for Transport (http://www.dft.gov.uk)
Our Ref: MC/24578 Your ref: 4054
2 3 DEC 2011

Thank you for your letter of 24 November, on behalf of your constituent, Mr ***** about the Instrument Meteorological Conditions (IMC) rating for private pilots.
As you may be aware, the European Aviation Safety Agency (EASA) now has responsibility for developing pilot licensing standards for the EU. Over the last two years it has developed and consulted on implementing rules based on existing European requirements and the international standard adopted by the International Civil Aviation Organisation (ICAO). These implementing rules have now been adopted under a Commission Regulation and will come into force in April 2012.
The IMC rating is unique to the UK. EASA's rule making group, which included pilot representatives from across Europe, decided not to include a similar rating in the implementing rules. However, there is scope for existing holders of IMC rating to be given a restricted instrument rating which will give the same privileges as the IMC rating. The Civil Aviation Authority (CAA) is currently reviewing the process for issuing a restricted instrument rating to the holder of an IMC rating but it does not believe that this will involve any additional training or examinations.
The consultation on the implementing rules highlighted the need to simplify the requirement for instrument ratings for private pilots. In consultation with general aviation organisations and the national aviation authorities, EASA has drafted new requirements for a competency based instrument rating and an en route instrument rating.

Consultation on the draft requirements will close on 23 December. These requirements are supported by the CAA and have been welcomed by general aviation organisations in the UK. I would hope that Mr *****( has responded to EASA's consultation to ensure that the Agency is aware of his views.

I hope this is helpful.

Regards

THE RT. HON. THERESA VILLIERS

md 600 driver

31st Dec 2011, 09:24

Maybe I am cynical but she replied on the 23 dec the same date as the consultation finished maybe she didn't want any more consultation

FREDAcheck

31st Dec 2011, 09:24

However, there is scope for existing holders of IMC rating to be given a restricted instrument rating which will give the same privileges as the IMC rating. The Civil Aviation Authority (CAA) is currently reviewing the process for issuing a restricted instrument rating to the holder of an IMC rating but it does not believe that this will involve any additional training or examinations.
Well, job done then! I am quite sure we can have full confidence that this is 100% accurate, or a Minister of State would not have said it.

Where do I get the forms to convert my IMC to an equally-privileged restricted instrument rating without any additional training or examinations, please?

Gertrude the Wombat

31st Dec 2011, 09:58

My experience of dealing with Ms Villiers (about other matters) is that she is extremely cautious about what she says, like most sensible politicians. You won't get her to promise anything unless she is completely certain she can deliver.

BillieBob

31st Dec 2011, 13:45

The aircraft used are part of the certification of the ATO.The requirement for aircraft used by an FTO for training to be approved is not carried forward to Part-ORA. The only requirement is for an ATO to provide to the Competent Authority "a list of aircraft to be used for training, including their group, class or type, registration, owners and category of the certificate of airworthiness, if applicable". It is, therefore, the ATO's responsibility to ensure that training aircraft meet the relevant requirements.

bookworm

31st Dec 2011, 17:48

The requirement for aircraft used by an FTO for training to be approved is not carried forward to Part-ORA. The only requirement is for an ATO to provide to the Competent Authority "a list of aircraft to be used for training, including their group, class or type, registration, owners and category of the certificate of airworthiness, if applicable". It is, therefore, the ATO's responsibility to ensure that training aircraft meet the relevant requirements.

So can that work with students' aircraft? Doesn't it mean the ATO has to get re-approved when it puts a new aircraft on its fleet?

MrAverage

1st Jan 2012, 15:07

peterh337

1st Jan 2012, 15:19

Genghis the Engineer

1st Jan 2012, 15:55

Quote:

I don't know whether there will be a mandatory requirement for the owner's aircraft to be modified to include those wretched bits of tin / plastic the CAA insists on (which can cause problems... http://www.aaib.gov.uk/cms_resources...pdf_502021.pdf (http://www.aaib.gov.uk/cms_resources.cfm?file=/dft_avsafety_pdf_502021.pdf) )

--------------------------------

I just read this report and cannot see where it puts any blame on the screens. I would genuinely like to know - did I misread it?

Having flown all three of screens, hood and foggles at various points of my training, I'd take screens any day - and well designed screens should present no particular problem for lookout from the right hand seat.

For me screens at-least permit me to look around the cockpit unrestrictedly, and don't give me a headache with a headset on. Not true of foggles or a hood.

G

FlyingStone

1st Jan 2012, 15:58

It doesn't, but the screens cannot help in the lookout. If you have ever sat inside an aircraft equipped with them (particularly the standard FTO ones which cover the entire windscreen including the upper portion) you can see that lookout has to be compromised.

I agree that the ability for lookout (for the FI) during instrument training with screens is severely reduced, but they are far better than the hood, since you have the ability to see the instrument panel as you would see it in actual IMC. That being said, one should know better when to use screens and when to use hood/nothing at all (both pilots maintain the lookout) - surely it is pretty OK to put screens on at the lineup (and have the instructor watch that the aircraft doesn't veer to the edge of the runway) when departing a quite airfield with little or no significant traffic, but what I've read in the report (I didn't read the entire report though), it was nor time nor place for instrument training with screens. For example, I flew the departure section of my IR exam without hood/screen in 50km vis VMC, since it would be very dangerous to do otherwise (4 aircraft in traffic patterns + couple of mixed VFR and IFR arrivals). I think some logical thinking solves most of the problems concerning lookout in instrument training.

LowNSlow

1st Jan 2012, 16:10

peterh337

1st Jan 2012, 17:50

Aren't the CAA IR exam screens going to disappear under EASA?

Maybe not till 2014 or whatever.

For me screens at-least permit me to look around the cockpit unrestrictedly

I agree with that, too. For the student, they are much better than foggles. I have had no problem flying with them.

However IMHO one should not take off with them, and one should not land with them, particularly at an airport which is in Class G and which could therefore easily have incursions. I've had one airprox already (while I had foggles on; spotted by the instructor) and this is sure to become more common now that the CAA have moved away from fixed test centres and doing IR tests out of smaller "GA" airports. Places like Shoreham and Lydd are constantly getting people flying straight through their approach paths.

In an IR test, there is no reason to do either because you are not being tested on your takeoff technique and you are not being tested on your landing technique :)

And if departing a Class G airport, you are not going to be flying a SID.

AIUI the current CAA practice, from instructors I have flown with recently, the decision whether you pass or partial pass or fail is taken, and given to the candidate, during the flight (after the various bits have been completed) and then the screens can be removed for a normal landing. So, all approaches with screens in place could be planned and executed as missed approaches i.e. not below the MDA.

Genghis the Engineer

1st Jan 2012, 20:37

Doing both my CPL and IMC, I used screens, and the drill was straightforward - have them off, take-off, climb to appropriate altitude, then instructor/examiner took control whilst I put the screens up.

G

BEagle

2nd Jan 2012, 07:36

I have a long lapsed (7 years) IMC rating. When do I have to get it revalidated by to get one of the new, shiny IMC equivalent ratings into my CAA PPL so that I can take advantage of the CAA/EASA/LAA allowing IMC flight in LAA aircraft at some time in the dim and distant future?
1. The CAA doesn't yet know the answer to the renewal query. Despite being told several times that 'grandfathering' must apply to those who hold, or have held, IMCR privileges, they keep talking only of 'current IMCR holders'.

2. The situation regarding 'LAA' aircraft being permitted to fly in IMC is at an early stage of consideration.
Is there any way I can renew my IMC in Oz or do I have to get back to Blighty to get the job done?
I doubt whether you'll be able to find a CAA-authorised IMCR Examiner in Australia; however, if you can then you should be able to complete the relevant training and testing.

WorkingHard

2nd Jan 2012, 08:20

Beagle you clearly have a much better grasp/knowledge of the detail than do I so has Ms Villiers got it wrong when she says:

"The Civil Aviation Authority (CAA) is currently reviewing the process for issuing a restricted instrument rating to the holder of an IMC rating but it does not believe that this will involve any additional training or examinations"

or can we assume "reviewing" will mean the CAA will find a way to either not do so or make big fees from the process?
Thanks

abgd

2nd Jan 2012, 08:29

My question (which I can accept there may not yet be an answer to) is whether if I start an IMC course - perhaps doing a lesson or two and the theory before April 2012 I may be able to finish it over the next year or two, as has been suggested previously.

I would love to do the IMC; I accept that it would be better to book a course right now. But unfortunately I just don't see that I'll be able to.

peterh337

2nd Jan 2012, 08:31

I think the CAA is keeping its powder dry.

This whole process is intensely political. EASA is headed by exceedingly clever and cunning political animals (who has met Eric Sivel for example?) and the whole of the EU machine has had about 50 years of practice in top class political cunning, trickery and general deceit. They need every bit of that to bang together the heads of all the very different member states and get them to sign those massive treaties. Can you imagine for example how much gets agreed under the table to do stuff like getting Switzerland to relax its banking secrecy in return for trade concessions?

The French are the only country in Europe with any kind of "up yours" backbone, which is why they did their own "IR" up front. The UK CAA is not that bold and they are going to be exploring every little avenue to keep the IMCR going.

Fortunately the EU is getting weaker by the day and this is to the UK's advantage. EASA did not help itself with its stupid and obviously politically ("screw America") motivated broadside attack on the N-reg community and the business jet operators, and a lot of political capital has been wasted on that. If the CAA is clever, they will exploit this deepening weakness to get what they want - within limits of the laws already passed which are both fortunately and unfortunately very vague.

BillieBob

3rd Jan 2012, 11:01

Doesn't it mean the ATO has to get re-approved when it puts a new aircraft on its fleet?Details of the aircraft to be used for training do not appear on the approval certificate and, therefore, no re-approval action is required should aircraft be added to or removed from the training fleet. The approval certificate remains valid so long as: "all operations are conducted in compliance with Part-ORA, Part-FCL, other applicable regulations, and, when relevant, with the procedures in the organisation’s documentation as required by Part-ORA." The procedure for adding an aircraft to, or removing it from the training fleet should be included in an ATO's Management Manual.Aren't the CAA IR exam screens going to disappear under EASA?AFAIK There is currently no EU Regulation, either in force or planned, that would prevent the UK CAA requiring the use of IF screens on test. The Authority did some research about 12-15 years ago into alternative methods of screening, including amber screens/blue goggles, polarised screens/glasses, foggles, hoods, etc., but came to the conclusion that the existing method provided the best balance between effectiveness and cost. Included in the research was an assessment (using data provided by what was then the JAWG/JAAP) of the adverse effect of properly designed and fitted screens on lookout, which was considered to be insignificant.

peterh337

3rd Jan 2012, 11:11

Interesting... a lot of people have claimed the screens will have to stop under EASA but I agree nothing I have read actually stops the CAA continuing.

Well, apart from the ability to have the flight test itself conducted in say Spain ;)

This stuff has a huge impact on aircraft owners. Currently, if you want training+test in your own plane, you are generally able (according to my research of FTOs) to do it in a G-reg plane, in most places in Europe, although your choice of FTOs is reduced by perhaps 2/3. But for N-reg the UK is the only option for both training and test. In Switzerland for example you can train but not test. I guess informal deals may be possible but I never found any. OTOH the UK needs the screens, and does a not of NDB work which for an IR conversion candidate represents perhaps 90% of the flight training. It's a pretty severe tradeoff, and I think most N-reg owners will not do what I did, and they will sod off to Spain or Greece and throw away 2 weeks into a PA28.

Making up the screens is 1-2 days' work for a competent DIY-er with a pile of ex-Ebay Correx and a hot glue gun. They can be suction cup attached so no need for aircraft-interior-damaging velcro.

I don't buy the "no effect on lookout" :)

421C

3rd Jan 2012, 11:16

AFAIK There is currently no EU Regulation, either in force or planned, that would prevent the UK CAA requiring the use of IF screens on test.

I disagree, I think there is actually a very fundamental change contradicting the underlying premise here that it takes a specific regulation to prevent the CAA requiring something.

The first thing to realise is that EASA regulations are EU law, and there are quite powerful mechanisms and precedents that allow EU citizens access to the provisions of EU law. This is a very fundamental change from the JAR environment.

As a result, the CAA can not "require" anything that is not specified in EASA FCL in respect of the IR test. Part OR/AR does give the CAA powers to approve ATOs and courses and to "monitor" and "evaluate" examiners. But, since Part FCL makes it perfectly clear that a view-limiting device is acceptable for an IR test, (IMHO) it will not be possible for the CAA to "require" screens, or for that matter any of the gold-plating of JAR FCL that was applied in the UK. Any EASA IRE will be able to conduct any IR test, subject only to a briefing from the CAA for non-UK examiners. The old model of approving examiners and appointing them to tests will fall away.

brgds
421C

...having said that I prefer screens for IF training...but only in a training aircraft with purpose built screens. It is unnecessary otherwise.

abgd

4th Jan 2012, 01:07

Another (probably) unanswerable question - though I appreciated Peter's reply to my earlier one:

What is likely to be the nature of revalidation and the IMCr?

People with a lapsed IMCr are looking to revalidate before April, but if you get an IMCr before April will you still be able to revalidate it if it ever lapses?

Genghis the Engineer

4th Jan 2012, 06:50

Whopity

4th Jan 2012, 08:23

subject only to a briefing from the CAA for non-UK examiners.And the new charge in the latest draft Scheme of Charges (http://www.caa.co.uk/docs/1352/PLS%20Enclosure%201213.pdf)Upon making an application for a non-UK EASA authorised examiner/instructor to be able to examine/instruct in the UK, the applicant shall pay a charge of £630

BillieBob

4th Jan 2012, 09:36

But, since Part FCL makes it perfectly clear that a view-limiting device is acceptable for an IR testExactly where is this made perfectly clear? I can find no reference to the means of simulating IMC in Part-FCL except that AMC2 to Appendix 6 and AMC3 to Appendix 6, both state "If instrument flight training is in VMC, a suitable means of simulating IMC for the student should be used". There is no similar statement in Appendix 7 or 9 relating to the skill test or proficiency check

Don't get too carried away by the perceived power of the individual under EU law. Provided that the 'hard law' is complied with, the competent authority still has considerable flexibility through the approval process to determine what is and is not acceptable. Unless hard law states specifically that a particular device may or may not be used then the suitablility of the various means of simulating IMC may be determined by individual competent authorities.The old model of approving examiners and appointing them to tests will fall away.That may be true, although recent information from the Chief Flight Examiner indicates that, despite forceful opposition from existing FEs, the UK CAA still intends to continue the practice of allocating examiners to CPL and IR skill tests more or less unchanged. Part-ARA only requires the competent authority to allocate examiners for the MPL and ATPL skill tests but does not prohibit it from doing so in other cases. Whether this position will be supportable in the medium to long term is questionable and will, to an extent, depend on the wish/ability of EASA to enforce a common standard.

In any case, the competent authority is permitted by Part-ARA to ".... provide examiners it has certified and examiners certified by other competent authorities exercising their privileges in their territory with safety criteria to be observed when skill tests are conducted in an aircraft." and there is no reason that such criteria should not include the means of simulating IMC.

enq

9th Jan 2012, 12:17

Afternoon All,

Is anything actually happening to the status of the UK IMCR in April 2012 or is a date further in the future now set?

I'm committed to completing the training for personal development / safety reasons so just trying to assess whether there is any advantage to finishing the training in the next 3 months under the added pressure of an imposed deadline versus a more leisurely 4ish months.

Apologies if this appears a lazy question but I've been through the thread, CAA response etc & it still seems like something drafted in the style of M C Escher.:hmm:

Tks, enq.

421C

9th Jan 2012, 14:20

Exactly where is this made perfectly clear?
I apologise, you are right, that reference far from perfectly clear! However, I believe the general intent of Part FCL and its AMCs is that an interpretation, such as what is "a suitable means of simulating IMC" should be a standardised interpretation across Europe, and not down to NAAs to apply as they see fit. I believe there are mechanisms in place to make that happen (for example, the AMC model, where an Alternative Means of Compliance approved by an NAA is submitted to EASA and, if they agree, it is published an available to all stakeholders regulated by EASA).

Don't get too carried away by the perceived power of the individual under EU law. Provided that the 'hard law' is complied with, the competent authority still has considerable flexibility through the approval process to determine what is and is not acceptable. Unless hard law states specifically that a particular device may or may not be used then the suitablility of the various means of simulating IMC may be determined by individual competent authorities.
Equally, I think you shouldn't get to carried away by the power of the authority. If something is published as an Acceptable or Alternative Means of Compliance with hard law, I think the CAA will struggle to gold plate it.

the UK CAA still intends to continue the practice of allocating examiners to CPL and IR skill tests more or less unchanged. Part-ARA only requires the competent authority to allocate examiners for the MPL and ATPL skill tests but does not prohibit it from doing so in other cases. Whether this position will be supportable in the medium to long term is questionable and will, to an extent, depend on the wish/ability of EASA to enforce a common standard. The problem will be that Part FCL makes it perfectly clear that an non-UK EASA qualified examiner can conduct a test in the UK subject to only a "briefing". I don't believe the CAA has the power to insist that examiners must be "approved" by it and appointed to conduct tests. We'll see......it's not just whether EASA wants to enforce standardisation, it's also whether anyone wants to pursue the legal remedies available....

Whopity - I have a sense that recent scheme of charges is an interim document trying fit the CAA's economics (GA regulation funded by approvals etc) with EASA regulation (where the power to approve is not there in some cases!).

brgds
421C

awqward

9th Jan 2012, 21:36

There are a couple of JAA Instructors at the Royal Aero Club in Perth....I don't know their qualifications but they may be able to do an IMCr renewal.... Tel +61 8 9417 0000...

AQ

WorkingHard

26th Jan 2012, 09:50

Sorry about the title but I have jsut received from Ms. Villiers this:
"The CAA believes that it will be able to issue current holders of an IMC rating with a restricted instrument rating which will give them the same priviledges as as their IMC rating. The legal basis for issuing such a rating is contained in Article 4 of Commission Regulation 1178/2011"
So we can all stop worrying can we? We shall be able to travel throughout EASA land without hindrance!!!!!

neilgeddes

26th Jan 2012, 10:15

That's good if true but I suspect the cavaet will be "... the privileges of which can only be exercised in the UK ..."

mm_flynn

26th Jan 2012, 10:20

That's good if true but I suspect the cavaet will be "... the privileges of which can only be exercised in the UK ..."
Which is what the quote says ('...same privileges as...' which are of course limited to the UK and not Class A)

BEagle

26th Jan 2012, 10:39

Villiers can only go on the information the CAA has provided - which in this instance is incomplete as discussions and consultations are still ongoing.

For more up-to-date information see Future of the UK IMC Rating (http://www.aopa.co.uk/index.php?option=com_content&view=article&id=581:future-of-the-uk-imc-rating&catid=1:latest-news) .

And no, you won't be able to use IMCR privileges across the rest of €uroland.

peterh337

26th Jan 2012, 11:17

If the restricted rating is based on the new IR I guess we also will have to do a yearly revalidation instead of 25 months.

Yes; I think a lot of effort has gone into avoiding the creation of a "second class private IR" which could then give some airspace owner(s) an excuse to ban that traffic from some airspace.

So the CBM IR will have the full JAA IR flight test, as done at present, and an annual reval with an IRE, for about £100-200 depending on who you know.

BEagle

26th Jan 2012, 12:08

The wording "current holders" seems to imply grandfathering rights only. If the restricted rating is based on the new IR I guess we also will have to do a yearly revalidation instead of 25 months.

Any 'IR Restricted (UK)' will be identical to the current IMCR in every way - so please don't confuse people with such rumours.

If you look at the link I posted, it spells this out.

So the CBM IR will have the full JAA IR flight test, as done at present, and an annual reval with an IRE, for about £100-200 depending on who you know.

Yes, unlike the FAA IR which may be maintained without any formal requirements to demonstrate skill periodically, the EIR, C-B IR and Sailplane Cloud Rating will all have to meet normal EASA requirements for periodic retesting.

Genghis the Engineer

26th Jan 2012, 12:18

Here's a thought.

There may be a loophole opening up here.

According to the AOPA website, the IMC will become called the Instrument Rating (Restricted UK).

There are certain things - such as type ratings on multi-crew aeroplanes, or the new EASA Flight Test Rating that require an IR.

Could the newly renamed IR(R-UK) become by default an IR for those purposes I wonder? It will probably not benefit many people, but those few could find it quite helpful.

G

derekl29

26th Jan 2012, 12:41

I guess the question on my mind was whether I had to race against time to get my IMC training and exam finished before April.

The AOPA site seems to suggest that I don't, and that an IMC rating can be added to my JAA PPL licence "into the future".

Am I right in saying I have a little more time here? In any case I`m going to try and get it finished by April anyway, unless the weather conspires against me!

BEagle

26th Jan 2012, 16:03

derekl29, please RTFM!!!

1. Is there a deadline by which time I need to have completed my IMC Rating training and testing?

The answer to this "No!". Our CAA friend Cliff Whittaker has stated "It will be possible to add or renew an IMC rating on a UK non-JAR/non-EASA licence into the future, but within a few years those licences will no longer be valid for EASA aircraft". The CAA website already indicates that those of you who do not hold a 'UK non-JAR/non-EASA' licence will shortly be able to apply for a supplementary United Kingdom licence, within which your new IMC Rating may be included. However, under current EASA proposals, as Cliff has said, within a few years the IMC Rating may not (unless 'grandfathered') be valid for use on EASA aircraft.

Genghis,

There may be a loophole opening up here.

According to the AOPA website, the IMC will become called the Instrument Rating (Restricted UK).

No it doesn't say that! It says:

EASA admits that it cannot remove any existing privileges from those so qualified. So the likely effect of this is that anyone who 'holds or has held IMC Rating privileges' before a certain date will be able to have these privileges included in an EASA pilot licence, probably as an 'Instrument Rating (Restricted UK)' which, despite the description (and anything else you might have read elsewhere), will be identical to the existing IMC Rating.

No loophole at all. There is absolutely NO intention to extend the present ANO-defined IMCR privileges. We had enough problems with people trying to use other aspects of regulation for inappropriate purposes - and if people start putting the word around about such (non-existent) 'loopholes', then they will be playing into the hands of those who would wish to see the IMCR killed off.

Genghis the Engineer

26th Jan 2012, 16:04

Fair point.

G

BEagle

26th Jan 2012, 22:15

No.

1) Pilot with current, valid JAA PPL and IMC right now.

>Post April will receive an EASA PPL with a "UK National Basic IR", valid for tootling around in a C172 or whatever, in IMC, in UK airspace only

Such a pilot will probably be able to apply for an EASA PPL with whatever the legacy IMCR will be called, but the date upon which this will be possible has not been decided. In any case, the pilot may continue to fly using a JAR-FCL PPL with IMCR for private purposes until 8 Apr 2015 and doesn't need to apply for an EASA PPL until the JAR-FCL PPL reaches its 5 year expiry date.

2) Pilot with current, valid JAA PPL *only* but who adds an IMC after April this year.

>Post April will receive an EASA PPL and may apply for a "UK National PPL with IMC". However, from 2015 will only be allowed to fly a C172 VFR as the "UK National PPL" will not be valid and the post-April IMC cannot be attached to the EASA PPL. To fly IMC will have to find a Permit-To-Fly Bulldog or similar.

Again, such a pilot may apply for an EASA PPL after July 2012 but doesn't actually need to do so until the JAR-FCL PPL reaches its 5 year expiry date. He/she will also need to apply for a supplementary United Kingdom PPL (not an NPPL) within which the IMCR may be included. He/she may use IMCR privileges on both EASA and non-EASA aircraft until Apr 2015, after which the IMCR privileges may only be used on non-EASA aircraft. At the moment Permit to Fly aircraft may not be flown in IMC, but that might change. A Bulldog with a CofA will be fine though.

However, nothing is 100% certain at this stage, because the CAA are still deliberating and the EASA ruling following NPA 2011-16 will not become law until probably Q4 of 2013 at the earliest.

Cows getting bigger

27th Jan 2012, 06:36

Thanks Beagle, now my head hurts.

chubbychopper

27th Jan 2012, 19:28

BEagle, do you undertake any kind of private work in this field by any chance? I think I might have a client who is in need of your EASA "rule making/interpreting" talents and knowledge.

flybymike

27th Jan 2012, 23:55

Patrick Goudou? Eric Sivel?

BEagle

28th Jan 2012, 07:57

BEagle, do you undertake any kind of private work in this field by any chance?

The only work I do is unpaid assistance in this field for AOPA(UK), GAPAN and IAOPA(UK).

thing

28th Jan 2012, 08:23

He/she may use IMCR privileges on both EASA and non-EASA aircraft until Apr 2015, after which the IMCR privileges may only be used on non-EASA aircraft.

I hardly dare mention this for fear you may pull my brains out through my nose, but does this mean (in simple terms that a thicko like me can understand) that unless you fly non EASA like a Spitfire or such like then the IMCR rating is finished after April 2015? IE if I have one now I can't use it after then? Please be gentle.

S-Works

28th Jan 2012, 08:38

Not finished, just not much use. The hope is to get something else in place that works.

peterh337

28th Jan 2012, 10:25

I simply do not believe the IMCR will cease to be usable for CofA aircraft operated under Part M.

Politically this would be a very hot potato because of the obvious safety angle and the total absence of any supporting evidence for removing it, and the totally obvious fact that the entire drive behind this is a purely political piece of EU empire building :yuk:

Anyway, you could always go N-reg. I have it in writing from the FAA that the IMCR is valid for an N-reg (complies with FAR 61.3). Not everyone agrees, of course.

Genghis the Engineer

28th Jan 2012, 10:32

N reg in the UK, or USA, or both?

G

thing

28th Jan 2012, 10:36

Not finished, just not much use. The hope is to get something else in place that works.

Is that as in 'Yes you can still keep it but you can't use it'? I was under the impression, ludicrous though it may seem that the IMCR was going to be made a partial EASA IR that you can only use in the UK. In other words it will still be an IMCR rating and everything carries on as before except they may call it something different.

Do they employ people at the CAA/EASA whose sole aim in life is to produce inpenetrable regulataions? Or to say 'After x years and 90 squillion quid of your money spent the answer is that we don't know what the answer is'?

It seems whenever you ask there's always an underlying 'Ah well there are things going on that are best kept quiet at the moment.' In other words, no one has a clue. Can we just turn them into pies and feed the poor?

peterh337

28th Jan 2012, 11:06

N reg in the UK, or USA, or both?

Anywhere, possibly (http://www.peter2000.co.uk/aviation/misc-privileges/index.html).

rats404

4th Feb 2012, 20:38

Please, before I'm b****cked for not reading through the thread, I really have and have tried to understand things.

So, here is my situation.

1. I've recently revalidated an old brown CAA "for life" PPL, which I was awarded in 1991.

2. I really want to obtain the IMC rating, because I can see how important it can be to provide an extra safety margin in UK weather.

My questions are.

A. Do I have to have passed an IMC rating test before 1st April 2012 to be able to exercise the privileges?

B. if the answer to (A) is no, when must I have passed the test to ensure I can use the privileges of the IMC rating?

C. If the answer to (A) is yes, and I am unable to pass the rating test before 1st April 2012, what are my alternatives? Do I have to train for a PPL/IR?

Sorry if I'm being dense, but I have read every post in this thread, and my flying club (which is excellent) has no clear answer.

All responses appreciated, just remember you are responding to a thick ex-squaddie :)

Rats404

peterh337

4th Feb 2012, 20:53

The short answer is that nobody actually knows.

It would however appear wise to get the IMCR before April 2012, just in case.

rats404

4th Feb 2012, 20:55

Thanks Peter, that was the impression I'd obtained, but wondered if I was just being thick.

Edit: Actually, on reflection, I'm going to send exactly the same questions to personnel licencing at the CAA and see what response I get.

Rats404

Gertrude the Wombat

4th Feb 2012, 21:23

I'm going to send exactly the same questions to personnel licencing at the CAA and see what response I get.
Those of us who have tried that tend to get answers along the lines of "nobody knows, but why don't you send us £84 for luck anyway". (Or whatever they think it costs this week to swap your lifetime CAA PPL for a 5 year expiring JAA one.)

rats404

4th Feb 2012, 21:35

Erm, thanks. I think I'll hold off then and keep my head below the parapet...

Some of the best advice I ever got was "be the grey man".

Rats404

peterh337

5th Feb 2012, 06:47

Actually the best advice, for a GA pilot, is keep one step ahead of the powers to be in the paper collection exercise :)

That is why I did the JAA IR even though I already have the FAA CPL/IR and the EASA proposal is not due till April 2014. The 15hr conversion route becomes undefined after April 2012...

BEagle

5th Feb 2012, 07:52

Your United Kingdom PPL will be acceptable for use on EASA aircraft until April 2014 and with reduced privileges until Apr 2015. Its use on non-EASA aircraft will not be affected by EASA.

There is no reason why a UK IMCR cannot be included on a valid UK PPL and used as above.

The problem comes with conversion to an EASA PPL. The future of the UK IMCR for use on EASA aircraft has yet to be agreed and is unlikely to be agreed before the end of 2013.

You should advise the CAA that you will be seeking inclusion of an IMCR on an existing UK non-JAR PPL. There is no point in converting your UK PPL earlier than necessary UNLESS the €urocrats accept the UK's NPA 2011-16 comment response proposals.

For pilots with more than 100 hrs instrument flight time as PIC, the conversion of a PPL/IR to an EASA PPL/IR is loosely described in Annex III to the Basic Regulation. Several comment responses have proposed lesser requirements for conversion of a third country IR to the proposed competency-based modular IR.

peterh337

5th Feb 2012, 08:07

For pilots with more than 100 hrs instrument flight time as PIC, the conversion of a PPL/IR to an EASA PPL/IR is loosely described in Annex III to the Basic Regulation. Several comment responses have proposed lesser requirements for conversion of a third country IR to the proposed competency-based modular IR.

Indeed... and the proposal is

- still have to do the/some exams (which are undefined, so that aspect is vulnerable to gold plating before/if this proposal is adopted, and whether or not a QB will exist is undefined but a QB reduces the study workload by about 10x)

- no flight training required; you go straight for the IRT (which nobody will actually pass without 10-30hrs of flight training, because the IRT is not changing and the syllabus will still contain the NDB procedures on which a converting IR candidate can expect to spend some 90% of his flight training time)

So, all in all, I do not see a substantial change for ICAO IR holders, from the package on the table at present, to a realistic implementation of what is being proposed (but may or may not come).

Mind you, they have only till April 2012, which is not enough time to even pass the exams now, unless the 15hr route is continuing.

I thus suspect what will happen is that, post-April, nobody will do anything to convert until the CBM IR is here, maybe a couple of years later, or until they are about to be screwed (if they get screwed; other outcomes are possible e.g. a de facto meltdown of the proposal).

Aware

5th Feb 2012, 08:10

Aopa website has some fairly up to date info, It looks like the rating will continue for annex 2 aircraft, position on an EASA aircraft which is what most of us fly, its unsure. It will impact lots of folk, however I have considered getting a share in a bulldog , which are fun and aerobatic, and one could still use your IMC privileges and stick two fingers up at the eurocrats.

I personally think there will be an answer forth coming. Which will of course cost money. The best option is to get a SEIR, but not cheap and not particularly easy, and most people can't justify that.

I have been flying 30 years and there always has been times when people where unsure what to do with regard licenses, becauseof changes in the rules. I had a FAA PPL/IR into our school this week, he can't get a CAA medical so no chance to get SEIR, he can maintain his NPPL with a medical declaration, but can,t even get an IMC.

Its totally unfair as he has been operating his complex ac in UK for years quite safely. In his case money can't sort the problem. Unless he moves to the US I guess.

I have considered hanging up the flying gloves, but I have been through the hassle of changing my CAA licenses to JAR,which can then go to EASA. As the CAA told me my UK licenses would be no good for teaching in EASA world.

Unfair again, but have no choice if I want to continue what I am currently doing. It all depends I guess how much hassle you want to maintain what you already have, thanks to the Eurocrats.

S-Works

5th Feb 2012, 09:07

It looks like the rating will continue for annex 2 aircraft

Slight fly in the ointment in that one. Take a look at the number of Annex II aircraft that are IFR capable and come back to me with a number....

As it stands the rating could be kept but is next to useless. What we need is the rating to be grandfathered onto an EASA licence not lip service paid to the situation by giving rights that are useless.

BEagle

5th Feb 2012, 09:53

Take a look at the number of Annex II aircraft that are IFR capable and come back to me with a number....

See CAP747 Section 1 Part 2 Chapter 3 for the current list of Annex II aircraft. Of course only a few have approval to fly under IFR

I understand that the LAA has proposed an easing of the restrictions which currently apply to Permit to Fly aircraft, so that certain PtoF aircraft may in future be permitted to fly under IFR. If the proposal is successful, hopefully a few more people will be able to ignore the nonsense which is €ASA.

Genghis the Engineer

5th Feb 2012, 10:47

http://cdn-www.airliners.net/aviation-photos/middle/7/3/3/1955337.jpg

Is Annex II ! (And well known to most of us from her regular appearances in the NOTAMS, callsign "Metman").

So of course are Bulldogs, Chipmunks, any ex-military warbirds on permits; I have a share in a 1947 American taildragger on a CofA that is on a private CofA, and remains IMC capable (just!): this is Annex II. It really wouldn't take much, if anything, to get many Europas, RVs, etc - which are all Annex II, IMC capable.

If Concorde was still flying, that would be Annex II as well.

G

thing

5th Feb 2012, 11:16

Beagle, excuse my ignorance but is Your United Kingdom PPL will be acceptable for use on EASA aircraft until April 2014 and with reduced privileges until Apr 2015. the UK PPL different to a JAR-PPL? I have a JAR PPL so does the above apply to me? And if it's different what exactly is a UK PPL and why would anyone get one?

peterh337

5th Feb 2012, 12:04

I understand that the LAA has proposed an easing of the restrictions which currently apply to Permit to Fly aircraft, so that certain PtoF aircraft may in future be permitted to fly under IFR. If the proposal is successful, hopefully a few more people will be able to ignore the nonsense which is €ASA.

It's not that simple, which is why the "permit/sports" bunch have had the "IFR tomorrow" situation for more years than anybody cares to remember.

The airframes have to meet various requirements e.g. lighting protection.

It could be done on a sub ICAO basis, like the USA does it, but that isn't likely to happen under EASA. AFAICT the only sub-ICAO thing which EASA is interested in is the LAPL which will be sub-ICAO due to the GP medical.

oldspool

5th Feb 2012, 12:31

A lot of the questions and comments have concentrated on ways to stick two fingers up to EASA and continue to exercise the (IMCr) privileges on national licences and on Annex II aircraft, however for pilots with JAR licences and a current IMCr (before April 2012) the proposals outlined in the recent NPA (flight in instrumental meteorological conditions) potentially make IMC flying much more accessible within EASA.

As I understand it, those with an IMC rating attached to a JAR licence before April 2012 will continue to be able to exercise the privileges as before, but in addition the IMCr hours will count towards the new competence based modular IR. To my mind, that's much better situation that we have today; i.e. those who have a current IMCr and only want an IMCr will continue to be able to use it (probably called a restricted UK IR), and those who want a full IR will be able to use the IMCr as credit within the new modular system.

thing

5th Feb 2012, 12:57

As I understand it, those with an IMC rating attached to a JAR licence before April 2012 will continue to be able to exercise the privileges as before, but in addition the IMCr hours will count towards the new competence based modular IR. To my mind, that's much better situation that we have today; i.e. those who have a current IMCr and only want an IMCr will continue to be able to use it (probably called a restricted UK IR), and those who want a full IR will be able to use the IMCr as credit within the new modular system.

Hurrah, this is what I've been wanting to know. Thank you sir.

Prop swinger

5th Feb 2012, 13:10

Thing,
Yes, JAR PPLs & UK PPLs are treated differently under the new rules.

Your JAR licence will be considered an EASA licence, valid for flight in EASA aircraft even beyond 2014 or 2015, at least until the licence expires. When you apply for a new licence, you will be given an EASA licence, no conversion required. Anyone who has just passed their test & been issued a JAR PPL will be able to continue flying on that licence in EASA aircraft until Feb 2017.

Those of us that gained our PPL before the advent of JAR possess UK national PPLs & will have to convert to EASA before 2014 or 2015 (depending on what type of flying we do.)

thing

5th Feb 2012, 13:18

Ah, thanks, so the UK PPL is what you got before some previous date when they renamed it the JAR one then? Was there a difference in the flying training? ie why is it considered different to a JAR one other than the name.

I thought being a UK citizen that I would naturally have a UK PPL called a JAR PPL but obviously not, but then I know very little about the regulations apertaining to these things. They seem rather labyrinthe though.

BEagle

5th Feb 2012, 13:19

...the UK PPL different to a JAR-PPL? I have a JAR PPL so does the above apply to me? And if it's different what exactly is a UK PPL and why would anyone get one?

The 'UK PPL' is the legacy 'lifetime' PPL which was issued in the days before JAR-FCL came along with the 5-year PPL (which the CAA calimed was 'cheaper' in its flawed Regulatory Impact Assessment!).

Conversion from a UK PPL to a JAR-FCL PPL was not compulsory, hence many people still have them.

Under the nonsense of €ASA, there will be some ratings which cannot be included in an €ASA PPL, but can be included in a UK PPL. Hence the CAA is preparing to issue supplementary licences (for £35) within which those ratings can be included. But people will not be able to 'train' for a new-style United Kingdom PPL, it will purely be an administrative method of ensuring that people do not lose any privileges under €ASA. The whole thing is an utter dog's breakfast and there are bound to be dozens of people flying outside their privileges thanks to the insane €urocracy coming our way soon.....:mad:

thing

5th Feb 2012, 13:26

I see...I think. Thank you.

Aware

5th Feb 2012, 13:38

I feel allowance of IMC hours for new IR is a good idea. As was allowed pre JAR - 12 I believe. Under new system the proposal is 30 hours, leaving 10 hours training for the CBM IR. However as money is always the major factor with most of us, reduction in training minima is welcome, however 10 hours will not be enough to pass the IRT test for most. So the cost will increase.

One of my PPL students has just completed his IR will an IR approved school, not me, he is a competent pilot and instructor and took three attempts at his SEIR test, overall cost £14K for a single rating. To much for most of us, with our flying as a hobby, on top of our normal expenditure.

Just because the minimum requirement goes down does n't really mean lower cost.

As an instructor I am being constantly asked about rules and regs of licences, Im no expert, but have been reading loads lately, we are all becoming more wrapped up with over regulation, as in other industries.

peterh337

5th Feb 2012, 14:49

3 IRT fails is a pity. He should have done the syllabus, picked up the 170A form completed, and then privately rented a freelance IRI to "get good" with, and then (when happy) booked himself an IRT directly with the CAA.

My IR conversion took 32hrs (partly due to a break in training which cost a fair bit of currency, and some other hassles, and I then flew quite a lot with a freelance instructor to be really sure) and the costs were

Ground FTO course material and IR exam signoff (with 3 days' ground school) £1020
Online QB £13
CAA IR Exams £476
Training (instructor charge only) £2000
Approaches £350
CAA IR Aircraft Approval and IR Test fee £962
Adding the IR to the licence £87

On top of that was the cost of flying in my aircraft - another £2500 or so, but I fly regularly for currency anyway so don't think that should be counted anywhere near fully.

IOW, credits for previous training are worth a good deal less than they appear. That said, the present minimum 50/55hrs is way OTT and it should be almost entirely competence based (as the CBM IR would be if/when it comes).

thing

5th Feb 2012, 15:53

I have to put ten characters but the answer is yes.

thing

5th Feb 2012, 17:07

Ooh, sounds even better. Stupid question but how much would one of these EIR's cost?

peterh337

5th Feb 2012, 17:09

Depends hugely on factors like whether you do it in your own plane, etc.

A few k and upwards is a fair estimate.

thing

5th Feb 2012, 17:13

Thanks Peter.

BEagle

5th Feb 2012, 17:18

A few k and upwards is a fair estimate.

Unlikely to be quite that costly, but will depend upon agreed 'conversion report' terms. Conversion theoretical knowledge requirements would also need to be agreed.

One dark cloud on the horizon. Mutterings reaching me are that objections to the EIR have been lodged by a certain €uropean NAA - which clearly doesn't understand the old aircrew maxim "No stick = no vote!".

peterh337

5th Feb 2012, 17:28

Unlikely to be quite that costly

Not one to usually disagree with you Beagle but I cannot see that.

Look at my costs posted above for the IR conversion. I did that at 1400hrs TT, on my own aircraft.

The marginal cost of flying my TB20 is less than the rental cost of a C150 from a school (RF) never mind an FTO/ATO.

Virtually nobody will reach the standard for a UK IRT (as it currently stands) in less than about (very roughly) 30hrs - unless of course they have previous experience/training, or they do some unusual kind of focused training.

The only way to do it in less time is to drop the NDB stuff (leaving GPS and VOR and ILS) but nobody seriously thinks NDBs will be removed in Europe anytime soon. There are far too many around. But even then you are looking at a few k.

The IMCR could be done at the low end of "few k" but only because it tends to be trained minimally (usually in planes which are barely airworthy for VFR never mind IFR) and examined minimally. It does the job but only if people take care afterwards to get good on their own.

The EIR will not be much cheaper than the CBM IR, too. The difference in the syllabus is too small.

Ultimately the costs of doing these things are not significant on the scale of flying something IFR capable afterwards, and the biggest burden for most people doing them is not the cost but the exams and the various other hassles resulting from the "FTO" restrictive practices. The "IR business" is not really set up for private pilots and while I have seen really worthwhile positive changes when doing mine, including a very modern kind of IRT, changing the underlying culture will take more time.

thing

5th Feb 2012, 17:58

The "IR business" is not really set up for private pilots

Is that just a cultural thing or isn't it cost effective for FTO's?

chrisbl

5th Feb 2012, 18:02

The time to convert all depends. assuming on is confortable with flying the aircraft, its then down to being able to use the instruments and manage the mental agility required to keep situation awareness.

Flying with the autopilot following the magenta line is not always the best experience in preparation for the IR.

The flying required for the test is predicated on IFR in IMC (hence the screens) and as long as NDBs feature in the IAPs the it would be reckless for prospective IR pilots not to be able to fly them.

I recall when I did my FAA IR I specifically asked the examiner about flying an NDB procedure as that was what I was likely to find in the UK. I have to say he was surprised but agreed with the rationale and incorporated it in the test.

After that I always practiced NDB approaches as part of retaining currency.

thing

5th Feb 2012, 18:14

Speaking from my own very limited experience I found ILS and PAR approaches easy and NDB's a damn sight harder so I suppose it makes sense to keep up to speed on them. What's an autopilot?....:)

peterh337

5th Feb 2012, 21:17

and as long as NDBs feature in the IAPs the it would be reckless for prospective IR pilots not to be able to fly them.

I would partly agree, but OTOH everybody knows that NDBs are not tested if the JAA IR is done at certain southern European locations.

I say "partly" because nobody in their right mind will fly an NDB procedure using the ADF, when they have an IFR GPS with the OBS mode, which they must have to be legal in the first place in enroute CAS anyway.

BEagle

6th Feb 2012, 07:44

I say "partly" because nobody in their right mind will fly an NDB procedure using the ADF, when they have an IFR GPS with the OBS mode, which they must have to be legal in the first place in enroute CAS anyway.

No they don't have to have an 'IFR GPS'. See: EUROCONTROL - Requirements for civil aircraft (http://www.eurocontrol.int/avionics/public/standard_page/16_Avionics_civil.html)

The first aircraft in which I had to fly NDB approaches without DME using just an RMI and stopwatch was the VC10. The only information you were allowed to be given by the navigator was drift and an estimated time from overhead the beacon to the start of the inbound turn. Hand flown NDB approaches aren't really that difficult if you have a decent gyro compass and RMI - but are the very devil if using a fixed-card RBI and DI.

VMC-on-top

6th Feb 2012, 09:20

I'm playing devils advocate but for those who currently have FAA IR's only, if there was no cost (or at least minimal cost a la JAR to FAA route), would you all (a) readily do the JAR / EASA IR without issue and (b) convert registration to G from N? If the answer is yes, is the biggest hassle factor in this the cost of converting, the time or the ground school / exams? I suppose what I'm asking in a round about sort of way is, do the benefits of having an aircraft on an N reg with the added hassle and hardship of constantly thinking what are EASA going to do to get rid of us next, outweigh the negatives of having the aircraft on a G reg and paying for annual IR renewals etc. - and more to the point, what are the comparable costs?

Finally, does anyone think there is any realistic chance that EASA may entertain the idea of a more staggered approach to these changes and propose genuine grandfathering of FAA IR's with a new line in the sand from say, 2014 / 2015 for their new proposals?

I've sat on the fence with which route to an IR for the last year and this issue just seems to get no nearer a certain conclusion - Europe in turmoil, huge backlash at Eurocrats etc. etc. - so I'm still no nearer knowing which way to jump and quite frankly, this looks like it could run on and on for years and years?

wsmempson

6th Feb 2012, 09:35

"Quote:
I say "partly" because nobody in their right mind will fly an NDB procedure using the ADF, when they have an IFR GPS with the OBS mode, which they must have to be legal in the first place in enroute CAS anyway.
No they don't have to have an 'IFR GPS'. See: EUROCONTROL - Requirements for civil aircraft

The first aircraft in which I had to fly NDB approaches without DME using just an RMI and stopwatch was the VC10. The only information you were allowed to be given by the navigator was drift and an estimated time from overhead the beacon to the start of the inbound turn. Hand flown NDB approaches aren't really that difficult if you have a decent gyro compass and RMI - but are the very devil if using a fixed-card RBI and DI."

Thanks for the link; in the navigation section of the requirements, there is a requirement for BRNAV compliance for flights within controlled airspace. I don't believe that an ADF and a stopwatch constitutes BRNAV compliance, regardless of whether you have a navigator feeding you drift and ETA calculations whilst you fly your VC10.:E

peterh337

6th Feb 2012, 09:39

I've sat on the fence with which route to an IR for the last year and this issue just seems to get no nearer a certain conclusion - Europe in turmoil, huge backlash at Eurocrats etc. etc. - so I'm still no nearer knowing which way to jump and quite frankly, this looks like it could run on and on for years and years?

There are two separate issues there:

- having to get the EASA papers
- moving N to G

The first has been done to death here and elsewhere... I've done mine as an insurance policy, just in case, even though it spread itself over much of the past year. It is possible (though IMHO unlikely) that EASA will give an EASA IR to every FAA IR holder, in 2014 or whatever. The French are proposing to do exactly that, after all. But if you look at the political history of the "JAA/Euro IR", I cannot see it happening without at least a flight test, which in turn means X hours training to pass that, etc, etc... and the general approach around the world to accepting another ICAO license is to sit the local air law exam also, so you have exams, so you have to study for those too..... you get the idea. Once you believe that a flight test will be required, and I do, it directly follows from that that a whole lot of stuff (basically some form of the present 15hr conversion route) will be required. And if there isn't a flight test on the day of conversion, there will be one at each anniversary because there is no way that politically EASA will accept the FAA 6/6 rolling currency. It's 100% politics and 0% safety - the FAA system is as safe or safer.

The second is something which EASA has fortunately backed away from, presumably because they are smart enough to realise that long term parking limits are unenforceable. I guess that the growth of the N-reg community will decrease greatly once the FAA IR route is undermined by the duplicate EASA papers requirement.

Like I always say: if you want a specific capability today then you need to get off your backside and get it now :) I started my PPL in 2000 and an "easier IR" has been just "around the corner" every day since then. The CAA IRT has been significantly modernised over the past year or two but the FTOs are still stuck firmly back in the olde days.

Re BRNAV, yes, in the days when Beagle was flying VC10s there was no BRNAV requirement :) Today, an IFR GPS is de facto mandatory for enroute IFR in CAS.

BEagle

6th Feb 2012, 12:29

Sorry, Saul but I fail to understand your :E comment about NDB approaches as having any relevance to en route BRNAV requirements. Anway, we actually had a PRNAV FMS system with Y-code GPS-augmented LINS plus a secondary INS also available. Which meant when flying NDB approaches in the -K variant you could 'cheat' by using the inbound NDB course set in the FMS, then select the compass 'source' to INS and use the CDI bar to give azimuth error whilst the RMI still showed the raw ADF value. Of course this GPS overlay was only a 'back up' and no-one really used it, did they......:\ The 'raw NDB' with only a stopwatch was something we only practised for operating into out of the way, austerely equipped aerodromes; some instructors also required it to be flown at night with no VASIs/PAPIs or approach lighting, just runway edge lighting, in order to practise for 'worst case' scenarios. Even more fun was a 3-engine NDB to go-around at night as this took you right over the station commander's house, so if you timed the go-around just right he would be treated to the 'sound of freedom' of 3 Conways at max thrust....:eek:

Ah - a de facto requirement for an IFR GPS now, is it? Whilst I would certainly agree that for any serious long-distance IFR cruising an IFR GPS system would be very highly desirable and people would be daft not to have one or two systems fitted, there still isn't any actual mandate to have an IFR GPS for en-route navigation. There are probably a few folk coping quite happily with a KNS80 or similar.

Use of the proposed EIR for serious 'airways touring' will certainly depend upon the availability of suitably equipped aircraft, so may well become the province of the private owner. How much of the rental wreckage available for hire these days actually has reasonable IFR kit or a reliable autopilot?

Finally, does anyone think there is any realistic chance that EASA may entertain the idea of a more staggered approach to these changes and propose genuine grandfathering of FAA IR's with a new line in the sand from say, 2014 / 2015 for their new proposals?

There is a considerable swell of opinion regarding conversion of third country IRs to require far less than the current requirements. IAOPA(EU) has proposed:

IAOPA(EU) considers that the demonstration of acquisition of knowledge can be satisfactorily assessed by the Examiner during the pre-flight preparation and conduct of the C-B IR Skill Test, supplemented if necessary by oral questions. It should be noted that the requirement for the holder of an IR issued in compliance with the requirements of Annex 1 to the Chicago Convention to sit further written theoretical knowledge examinations when converting to a EU IR is widely regarded as an expensive waste of time, which serves very little practical purpose. An Examiner will be able to make a much more pertinent assessment of the applicant’s relevant knowledge; we strongly recommend that oral assessment in the manner described should satisfy the requirements.

IAOPA(EU) considers that the requirement for 100hrs of instrument flight time as PIC is excessive. Pilots with considerable flight time under IFR would be disadvantaged; there would be safety implications for a pilot to fly deliberately in IMC, with the attendant risks of turbulence and icing, merely to reach the 100hrs requirement. We therefore recommend that sub-paragraph 8(d) is reworded as follows:

8 (d) have a minimum of at least 50 hrs of flight time under IFR as PIC on aeroplanes.

We remind the Agency that the C-B IR is ‘competency based’ by definition and that, although some relevant experience is clearly needed, the Skill Test will provide entirely sufficient assessment of the applicant’s suitability to be issued with the C-B IR.

soaringhigh650

6th Feb 2012, 12:53

Saul but I fail to understand your comment about NDB approaches as having any relevance to en route BRNAV requirements

I think Saul is saying that en-route BRNAV requirements requires much more than just one NDB. Therefore IFR aircraft will be equipped to meet those requirements.

It therefore sounds strange that you get aircraft equipped with only an NDB to fly the approach. (as how can you fly the approach without flying en-route?)

wsmempson

6th Feb 2012, 13:26

What I believe we are talking about, Nick, is "EASA and the IMCR - News" as opposed to what you might have been doing 30 years ago in a military VC10, with or without the assistance of a navigator.

Today, the expectation is rightly that there is other equipment that is available (and indeed required) for the safe execution of civilian GA flights other than and NDB and a stopwatch. The BRNAV compliance point was made because
a. It was made in the link that you posted

and

b. In order to arrive at the place where you are going to make an instrument approach (and if you choose to do that with only a stopwatch and an NDB, be my guest) the likelihood is that you will need to be BRNAV compliant to arrive there. An NDB and stop-watch alone will not fulfill that function.

peterh337

6th Feb 2012, 13:47

Ah - a de facto requirement for an IFR GPS now, is it?There are only two ways to comply with BRNAV:

1. INS (which is how airliners do it)

2. IFR GPS (the only relevant means for GA including most light jets)

Well, you can get the old KNS80 BRNAV certified but it will be useless as soon as ATC give you a DCT to a waypoint which is 200nm away :E (which they do all the time; ATC all over Europe treat all waypoints as RNAV regardless of whether it is a navaid e.g. SFD or a virtual one like ORTAC).

IAOPA(EU) considers that the requirement for 100hrs of instrument flight time as PIC is excessiveYes that proposal is ludicrous, but it's obvious why it was put in: to pacify the FTOs which are going berserk because if you make conversion too easy, it will make sense for airline pilot wannabees to get a CPL/IR in the USA first and then come back to convert here. This would all but wipe out the FTO business.

So various GA groups are trying to go for something smaller e.g. 50hrs instrument time, which would make conversion viable for an FAA PPL/IR holder who actually flies, while maintaining a reasonable barrier to the "21 year olds" who want to be airline pilots. Whether EASA will listen I have no idea.

On average, to reach 100hrs instrument time you will be looking at someone with 1000hrs total time, and even that is assuming that he has done a lot of dual time e.g. IMCR, FAA IR, and done a lot of IFR trips in bad weather. That would make the conversion route worthless for most private pilots. I have ~150hrs myself, 1400hrs TT so I would be OK but I don't think this is fair.

That's the trouble with aviation. No matter which way you turn, you bump into the same old axe grinders. You go to some aviation show and queue up for a sandwich and the people in the queue before and after you are the same ones as the year before :) And MONEY always talks.

soaringhigh650

6th Feb 2012, 13:59

There are only two ways to comply with BRNAV:

1. INS (which is how airliners do it)
2. IFR GPS (the only relevant means for GA including most light jets)

Ain't there three more:

3. VOR/DME,
4. DME/DME, and
5. Loran C

?

BEagle

6th Feb 2012, 14:04

In order to arrive at the place where you are going to make an instrument approach (and if you choose to do that with only a stopwatch and an NDB, be my guest) the likelihood is that you will need to be BRNAV compliant to arrive there. An NDB and stop-watch alone will not fulfill that function.

Of course I wouldn't ever wish to fly an NDB approach if there was any other option available! But we had a training requirement to do so.

It will be interesting to see whether the IAOPA(EU) proposal is given a fair hearing by the Comment Response Team - or whether we'll end up involved in some souk-haggling nonsense.

peterh337

6th Feb 2012, 15:37

Ain't there three more:

3. VOR/DME,
4. DME/DME, and
5. Loran C

Not in Europe.

soaringhigh650

6th Feb 2012, 15:49

Really (http://www.ecacnav.com/content.asp?PageID=95)? Hmmm...

For ECAC airspace the primary sources of navigation information are VOR/DME, DME/DME and GPS.

peterh337

6th Feb 2012, 16:15

I'd love to answer but it would be another long one so I will leave it to somebody else while I get onto the VAT return :)

BackPacker

6th Feb 2012, 16:34

Okay, I'll try. Soaring, the list you referred to is the INPUT into a navigation system that provides BRNAV capabilities. Using that input the system is then able to compute its position, and uses that position to navigate you somewhere else.

Unless your mathematical abilities are so good that you are as quick and accurate as the average microchip that does this calculation, and thus you are able to calculate your exact position from raw VOR/DME input, just having two VORs, a single DME and a single ADF does NOT provide you with BRNAV capability.

As Peter said, there are only two systems (GPS and INS) that have the ability to continuously calculate an accurate position, and supply you with a heading, distance and ETA to an arbitary point in space. Of these two, only GPS is feasible in a light aircraft.

mad_jock

6th Feb 2012, 16:40

You get systems which use DME/DME then VOR/DME VOR/VOR and then only then will they use GPS raw.

All the GNS family do it this way. Alot of commercial system don't have GPS as the primary but use DME/DME as the primary.

So soaring is completely correct.

As much as peter doesn't like to admit most IFR flights don't reference GPS commercially which is why there is no drive to get GPS approaches.

S-Works

6th Feb 2012, 16:50

To be fair to Peter, what he is actually saying is the only way to get BRNAV in a light aircraft is with a BRNAV GPS and he is quite correct.

Commercial aircraft are using FMS that are updated from different sources including a DME/DME fix but I have not seen many FMS equipped light aircraft.

VOR/DME
DME/DME
Loran C

Don't quite meet the requirements for BRNAV certification in a light aircraft....

soaringhigh650

6th Feb 2012, 17:13

Okay - BackPacker is quite right. This was what I missed from the FAA AC 90-96 Appendix 2:

The following system functions are the minimum required to conduct BRNAV/RNP-5 operations:

1. Continuous indication of aircraft position relative to track to be displayed to the pilot flying on a navigation display situated in his primary field of view;
NOTE: In addition, where the aircraft type certificate requires more than one
pilot, information to verify aircraft position must be displayed in the non-flying
pilot’s primary field of view.
2. Display of distance and bearing to the active (To) waypoint;
3. Display of ground speed or time to the active (To) waypoint;
4. Storage of waypoints; minimum of 4; and
5. Appropriate failure indication of the RNAV system, including the sensors.

Now I understand peterh337's point. Thank you.

peterh337

6th Feb 2012, 17:34

You get systems which use DME/DME then VOR/DME VOR/VOR and then only then will they use GPS raw.

All the GNS family do it this way. Alot of commercial system don't have GPS as the primary but use DME/DME as the primary.

MJ you haven't got a clue, sorry!

The GNS430/530 (which I assume you refer to by "GNS") have no DME functionality whatsoever. They are pure GPS receivers. They have built-in VOR/LOC/GS navigation receivers but those do not participate in the RNAV solution.

frontlefthamster

6th Feb 2012, 17:58

Mad Jock's reply was, in fact, quite correct, if he meant something other by 'GNS'.

There are a very significant number of commercial types which prioritise rho-rho or rho-theta over GPS. It is only recently (the last decade, off the top of my head) that some airliners prioritise GPS for the navigation solution, and even this is with a 'confidence check' from available ground stations (the manufacturers are known to be guarded about precisely how the navigation solution is derived in these situations).

Although MJ may have meant something by 'GNS' other than that which you inferred, Peter, you should not make bold statements like that.

You're too often wrong.

Cows getting bigger

6th Feb 2012, 18:02

Sure, for the average spamcan the only practical way to meet BRNAV is with GPS. However, there are, theoretically, other ways of skinning this particular cat.

S-Works

6th Feb 2012, 18:06

There may indeed theoretically be other ways of meeting the requirements. However the practicality is you will need an IFR GPS in a light aircraft.

Even our turboprop work aircraft use the GNSx range to meet the requirements. We canned the Honeywell FMS a couple of years ago.

peterh337

6th Feb 2012, 18:54

To install something in an aircraft with an ICAO CofA it needs to be certified, and a navigation source needs to be more strictly certified than most other stuff.

I am not aware of a certified product for piston-level GA which meets BRNAV, other than

- an IFR GPS (TSO-C129 etc), or

- a KNS80, with antenna filters for FM Immunity

However, as I said before, you need practical RNAV capability and while there are KNS80 hacks which can navigate you to a straight line to a virtual waypoint say 200nm away (and do so in a manner which doesn't upset the radar controllers too much), a GPS is the only practical solution.

On a route like e.g. this (http://www.peter2000.co.uk/aviation/kithira/egka-ljpz-big.jpg) you are likely to get several DCTs which are over 100nm and thus out of the DOC of the usable navaids. And that's before one gets onto the subject of most French VORs not having a co-located DME ;)

There are no DME/DME solutions on the GA market. I vaguely recall some old-timer in the USA telling me Collins (?) developed a DME/DME / VOR/DME RNAV "GA" box in the 1980s but abandoned it because the introduction of GPS caused the bottom to drop out of the navigation market.

In theory you could install an INS in a light GA aircraft http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/evil.gif I believe somebody in the USA has done that... one out of some jet fighter.

Although MJ may have meant something by 'GNS' other than that which you inferred, Peter, you should not make bold statements like that.

You're too often wrong.

This forum is called

Private Flying LAA/BMAA/BGA/BPA The sheer pleasure of flight.

and "GNS" means only one thing in that context. Maybe there is an airliner FMS called GNS-something? I wouldn't know about that.

Anyway, frontlefthamster, please put in the time to point out whenever I am wrong and how exactly. As I told you before, I am happy to learn new things :ok:

mad_jock

6th Feb 2012, 19:12

I meant "gobal navigation systems".

Not some garmin moving map.

I think A & C said there was a NARCO unit that did DME/DME for light aircraft.

Bose how many garmins did you have to install to cover the BRNAV requirment?

peterh337

6th Feb 2012, 19:27

I think A & C said there was a NARCO unit that did DME/DME for light aircraft.Maybe that was the one I heard about. Narco have gone bust. Most of the stuff they made was junk - the worst quality avionics that ever existed for GA.

The KNS80 has also been discontinued, for longer than I have been flying.

The European BRNAV requirement is met with a single suitably approved GPS (the recently discontinued GNS430 perhaps being one of the cheapest options, though the also recently discontinued KLN94 might be even cheaper :) ) plus a suitably located CDI indicator and some annunciators, IIRC.

In technical nav terms, BRNAV (http://www.ecacnav.com/content.asp?PageID=95) is hardly onerous. It is within 5nm of track 95% of the time.

frontlefthamster

6th Feb 2012, 19:51

Peter,

You could start by avoiding making posts like these:

Most of the stuff they made was junk - the worst quality avionics that ever existed for GA.

and "GNS" means only one thing in that context

MJ you haven't got a clue, sorry!

In each case, you boldly present your opinion, without substantiation.

You need to realise that there are others here, and everywhere, with more experience, expertise, and ability. A degree of moderation in your statements, and some humility, might improve your contributions significantly.

You did ask.

thing

6th Feb 2012, 20:21

But that's like asking a cat to be a dog. We are all different, that's the only thing we all have in common.

peterh337

6th Feb 2012, 20:36

frontlefthamster

I congratulate you on your appointment as a moderator :ok:

With people like me on here, Genghis, BRL and the rest of the crowd need all the help they can get.

I am sure they will be very grateful :E

BTW, I thought that

Most of the stuff they made was junk - the worst quality avionics that ever existed for GA.

was self evident fact, which anybody who repairs avionics would wholeheartedly agree with :)

mm_flynn

6th Feb 2012, 21:32

I meant "gobal navigation systems".
I had a quick google for what that phrase could reasonably mean. All I saw were various GPS systems and references to Decca and Omega (and Loran for wide region) (along with some network traffic management systems :confused:).

I am interested, what current technology for global navigation exists other than GPS or INS with DME/DME,DME/VOR position updates? The second of which introduces the joy of 'Map Shift'.

mad_jock

7th Feb 2012, 01:12

peterh337

7th Feb 2012, 06:48

Here we are again out of the GA context, but obviously DME/DME is not going to work where there are no DMEs, and the only ways to maintain lateral navigation will be either inertial (INS) or GPS.

Its a tool but most of the time it comes down very low on the list of Nav data.

If you have DME/DME, that is a reasonable policy. It's just that there are no GA products for that, so it's a bit irrelevant.

Preferring VOR/DME over GPS is slightly nutty but normal for attitudes from say 15 years ago :)

BEagle

7th Feb 2012, 07:40

Most current GNSS use the GPS constellation. However, with commercial use of GLONASS being promoted by Russia and with Galileo sloooowly emerging, will any existing Garmin Wonderbox navigation systems be capable of using systems other than GPS?

I note that EGNOS is supposedly able to improve the accuracy of my automotive Garmin using signals from Inmarsat (ID33) and Artemis (ID 37). However, in practice I've noticed no difference and the system rarely sees any EGNOS signal. Presumably aviation systems track EGNOS in Europe these days?

wsmempson

7th Feb 2012, 07:53

"Most current GNSS use the GPS constellation. However, with commercial use of GLONASS being promoted by Russia and with Galileo sloooowly emerging, will any existing Garmin Wonderbox navigation systems be capable of using systems other than GPS?

I note that EGNOS is supposedly able to improve the accuracy of my automotive Garmin using signals from Inmarsat (ID33) and Artemis (ID 37). However, in practice I've noticed no difference and the system rarely sees any EGNOS signal. Presumably aviation systems track EGNOS in Europe these days?"

Nick,

I'm not convinced that this constant sneering at Garmin GPS navigation systems really does a man in your position much credit. However, in case you had forgotten, the commonest certified GNS fitted to GA aircraft, the Garmin 430 is perfectly able to operate as a VOR in VLOC mode, so the suggestion that they can't operate in any other mode using data from another source is simply not true. As for using the Russian system, I suspect that if there were any suggestion of our systems relying on a Russian satalite network, the CAA would attempt outlaw any kind of GPS navigation, which isn't far from the position we have at the moment.

BEagle

7th Feb 2012, 08:08

Saul, I really don't know why you think I doubt GPS. I've been using it for years and think it's truly excellent.

The latest Garmin systems are superb; my question was whether they are capable of processing GNSS signals other than the GPS constellation in order to provide additional redundancy. This will be of particular importance with the emergence of the Galileo GNSS.

I'm fully aware that the GNS430 can use terrestrial signals, the question related to alternative space-based systems.

RTFQ!

S-Works

7th Feb 2012, 08:16

I understand it the GLONASS system and GPS are compatible. I read somewhere that the ruskies and yanks were cooperating.

wsmempson

7th Feb 2012, 08:29

Nick,

I did read the question - after all, it wasn't me who speared off at a tangent burbling away about flying VC10's using an NDB and a stopwatch....

I'm delighted to hear that you use GPS, but refering to the systems we use in aircraft as "Garmin Wonderbox navigation systems" gives the impression of sneering, rather like the Judge in the "not the nine o'clock news" sketch when confronted with a digital watch...

mm_flynn

7th Feb 2012, 08:41

doesn't have to be INS to have DME /DME etc.

Most Turbo props won't have INS and alot of the regional jets won't have either. So no map shift, you can get the difference between GPS position and DME /DME derived if you go through a few pages but the unit bins the gps position if there is a conflict and goes with DME/DME.

...

The idea that the world s commercial aircraft are flying around putting all there trust in GPS is rather stretching it. Its a tool but most of the time it comes down very low on the list of Nav data. Hence why there really isn't that much of a push from commercial operators to have GPS approaches. So there is no one to pay for the surveying and production which is why nothing is really progressing on that front.

However, when the unit bins GPS you Appear to have to have INS or your RNAV capability is degraded (at least in FAA world) and you need to have three DMEs to use it for approaches without GPS. So GPS does seem to be rather higher up the list than you indicate. However, the essence of yournpntnis of course correct, there are DME/DME and DME/VOR FMSs without INS (and not requiring GPS) that will achieve the European BRNAV requirement. (There was an interesting near accident in North Africa where a corrupt VOR signal resulted in a a commercial aircraft being in the wrong location and coming within 59 feet of the ground while maneuvering - without a GPW due to the lack of GPS signal, INS not yet resynched and the corrupt VOR signal)

As an aside, I don't believe there are any GPS approaches - I believe they are all RNAV, GNSS, or RNP. So the issue with a lack of RNAV approaches in Europe is not that commercial operators don't use GPS. It is much more likely that the overlay concept was not approved by the Various NAAs and a rather burndonsome approach to approving new procedures.

PS
I believe that GPS and GLONASS are compatable but not interoperable as they have different bit rates and different (but similar) carrier frequencies. It is unlikely a box designed 15 years ago would support a speculative Russian system.

mad_jock

7th Feb 2012, 09:18

I don't think he was sneering.

It just that its quite a common point of discussion with examinors and experenced pilots that there is to much heads down and furious button punching for the most simple tasks which the easy solution is just to flick up a NAV beacon and fly the aircraft. Using a 1 in 60 fudge or WAG for an intersection.

Look out suffers as does SA. Some may say SA is improved with moving map etc which I would agree with up to a point as long as the data goes in smoothly. It is quite common though for any interuption due misspelling etc to have the aircraft not being navigated until thats sorted. Where as the old boys/girls will have already turned to a rough heading towards the point in space and by the time the box of tricks have been beaten into submission you will find its only out by < 5 degs.

And to be honest I was going to keep out of this usual hampster wheel about GPS but for Peters incorrect statements about what airliners do and use.

He will never defer away from GPS is King. Any experence that the rest of has that its not quite as golden bollocks as he would have us believe is put down to.

1. We are ****e pilots
2. Our aircraft have some sort of dodgy installation.
3. We are mistaken with what we experence.
4. We arn't using it properly
5. Your just unlucky (well I do over 1800+ flights a year compared to the high end GA usage of what 100?)
6. GPS jamming never occurs, a garmin can defeat the might of the military and can get a decent signal when there mil spek GPS can't get a thing (well I presume they can't get anything as they seem to have the Jammers on whenever there is an exercise)
7. Solar flares and storms don't occur.
8. We know what the USA's intentions are for the next 20 years (maybe N reg owners that use the loophole get a special brief that the rest of us don't) don't )

I use GPS every day but I am glad that there are some cooler heads out there that arn't putting all our eggs in one basket.

Most boxes are DME/DME first and only give you a message when they go to GPS. After giving up on VOR/DME VOR/VOR

There are plenty of RNAV approaches in europe and SIDS and STARS. As you say no GPS ones. And the DME/DME boxes of tricks usually use 6-9 DME's to get the position and when it can't see that many it shiggles the combinations including using VOR/DME to keep the error within limits (not that the pilot would have a clue)

peterh337

7th Feb 2012, 09:31

A good rant from MJ :ok:

Presumably aviation systems track EGNOS in Europe these days? The 430W/530W and all the Garmin IFR ones that came later can use EGNOS.

Whether they can use it today I don't know. EGNOS has been transmitting for years but with a "test" flag active and all IFR approved GPSs were banned from using the signal with that flag set. Only handhelds like the 496 could use it. Then Eurocontrol finally approved EGNOS for "safety of life" ops and that flag should have gone away but due to some Brussels cockup it didn't, and this was quite recently (months ago). It may be sorted now.

EGNOS is not currently operationally relevant, because GPS without SA is easily accurate enough for everything short of LPV. As for LPV approaches, AFAIK the UK has only one of those, in Alderney.

EGNOS is relevant when it comes to integrity checking. I don't know the details but vaguely recall that in the USA if you are receiving WAAS (the US version of EGNOS) then you can proceed with a GPS approach even if a RAIM check does not compute - or something like that. If/when I need to know about this I will check it out; my current GPS (KLN94) is not EGNOS capable anyway.

Re GLONASS, I am not aware of any current IFR GPS which can receive the signals right now. It cannot be hard to do and "should" be possible with just appropriate firmware... unfortunately Galileo and Glonass are not simply extra satellites to supplement the American constellation. They are on slightly different frequencies, etc.

What people also forget is that the Americans are updating their satellites too. The various wild claims for Galileo accuracy and reliability are all based on the Navstar system remaining as it was when originally launched in the 1980s.

mad_jock

7th Feb 2012, 09:54

Its not a rant Peter.

Its just a statement about how its pointless engaging in the discussion of the subject because it doesn't matter what others experences are or thoughts.

BEagle

7th Feb 2012, 10:43

Thanks for the EGNOS information, Peter - that explains a lot. But yes, I also note m_j's point about 'head down' button pecking. It's something we specifically address during training for flying in certain environments.

Given how similar certain intersections both sound and spell quite similar (e.g. in the south of France), if given a direct, you can enter it but confirming the spelling can be awkward - so commonsense and situational awareness to avoid a Gi-Go error is, as you rightly say, of paramount importance. Presumably airlines have SOPs, but if directed to an unfamiliar intersection, it would seem prudent to use HDG rather than NAV until the new point has been confirmed?

Back to the IMCR. One of the current IMCR benefits is that a PPL holder in the UK may fly VFR above cloud, which rather stumps the 'must only use GPS as a back up to visual navigation' luddites at a Certain Aviation Authority who regard it as a tool of Satan. Under EASA, that well-loved SAFETY agency, plain vanilla PPL holders (or LAPL holders) won't be restricted by the ANO criteria applicable to UK PPL (or JAR-FCL) PPL holders without IMCRs / IRs, so assuming they can find suitable holes at both ends, in a couple of years there are likely to be a lot more pilots navigating with non-IFR GPS above cloud than there are at present.

As I understand the TSOs, 'IFR' GPS approval applies to the entire system, including antenna and external feeds, but applies only to en-route IFR cruising and terminal approaches (subject to additional TSO requirements). So if you're flying under VFR and navigating above cloud, you don't actually need an 'IFR' GPS. But what about the IMCR pilot climbing up through cloud to reach a VFR level, or descending below it at the other end? "No, I just note the heading and ignore the GPS until I become visual" Oh really? :rolleyes: As they do with their own SatNavs in hire cars, many pilots are going to prefer to use their portable GPS units in clubs' rental wreckage and the CAA will have to accept that 'VFR' GPS is going to be used more and more often as a primary navigation tool. "Fly and navigate visually, only use the GPS once you have verified its accuracy against something else, and cross-check regularly", as SSL 25 puts it, is going to be observed less and less often in future.

peterh337

7th Feb 2012, 11:23

Given how similar certain intersections both sound and spell quite similar (e.g. in the south of France), if given a direct, you can enter it but confirming the spelling can be awkward - so commonsense and situational awareness to avoid a Gi-Go error is, as you rightly say, of paramount importance. Presumably airlines have SOPs, but if directed to an unfamiliar intersection, it would seem prudent to use HDG rather than NAV until the new point has been confirmed?

Yes. When flying along, one has the route printout and should be aware of the intersections along the route. They should be loaded into the GPS anyway. ATC tends to issue shortcuts, and one tends to ask for extra ones all the time anyway. If ATC issue a DCT to some intersection which is not immediately recognisable then I normally immediately ask them to spell it.

What happens when it is entered as a DCT depends on the autopilot mode at the time, and the type of HSI. If one is in NAV mode, and the HSI is a mechanical one, the AP will not do anything (much) until you manually turn the course pointer (CP) to the new track as indicated on the GPS. If the HSI is an electronic one (EHSI, or one of the "glass" products) then the CP will flip round by itself and the AP will turn onto the new track automatically, and yes it could be embarrassing if you entered the wrong waypoint ;) But the track will be obvious on the moving map anyway, where it will appear about the time the AP is turning onto it.

It is obviously good practice to always have the HDG bug set to the current heading, even when flying in NAV mode, so you can revert to HDG mode, or even fly manually, immediately, at any time.

In some cases switching over to HDG is highly advisable during track changes. One case if where one is intercepting a track. Most GA autopilots do not do intelligent intercepts. They use the CP as the initial "heading" and then tweak the heading according to the lateral track error, so a lot of intercepts happen slowly, and slowly enough to irritate ATC. The Honeywell APs in particular will not do a clean intercept unless the track error is at least 3 divisions (about 60% HSI full scale) or greater when you press NAV.

So one has to know how to play one's system :)

I flew up to Coventry the other day and spent about 80% of the flight in HDG, with ATC vectors... The rest of it in HDG without ATC vectors :)

I also note m_j's point about 'head down' button pecking

I don't see that an issue if one knows one's equipment.

As I understand the TSOs, 'IFR' GPS approval applies to the entire system, including antenna and external feeds, but applies only to en-route IFR cruising and terminal approaches (subject to additional TSO requirements).

That depends on the approved flight manual supplement (AFMS) detailing the GPS. In the USA, the GPS AFMS normally permits all IFR i.e. including GPS approaches. In Europe, those I have seen tended to allow only enroute and perhaps not even sids/stars. This can now be corrected, under both EASA and FAA regimes, but it can be nontrivial especially under FAA (N-reg) if based in Europe. It is just a paper exercise but one needs it to be legit.

So if you're flying under VFR and navigating above cloud, you don't actually need an 'IFR' GPS. But what about the IMCR pilot climbing up through cloud to reach a VFR level, or descending below it at the other end? "No, I just note the heading and ignore the GPS until I become visual" Oh really? :rolleyes: As they do with their own SatNavs in hire cars, many pilots are going to prefer to use their portable GPS units in clubs' rental wreckage and the CAA will have to accept that 'VFR' GPS is going to be used more and more often as a primary navigation tool.

VFR GPS has been used for GA nav for longer than I have been flying, and it doesn't need to be an IFR approved installation. The ANO (etc) specifies equipment to be carried, not equipment to be used. I think too many people like to read between the lines on that one, but one is either debating legal requirements, or not. There is no middle ground. Legally, any handheld is legit for primary or even sole navigation (regardless of the wisdom of it, etc) provided you carry the prescribed equipment, and this is true even in high altitude IFR (airways) flight (non AOC, obviously).

"Fly and navigate visually, only use the GPS once you have verified its accuracy against something else, and cross-check regularly", as SSL 25 puts it, is going to be observed less and less often in future.

Of course, but that is the way the world is moving.

And I support that (with the usual caveats, like backing up with VOR/DME) because GPS is far more reliable than visual nav, dead reckoning, whatever.

I fly 100% on GPS, with VOR/DME backup where possible.