Worth removing 'no applied Instruments' restriction?

[MalteseJambo]

Dear all,

I have recently been considering removing this restriction on my FI license and was looking for some advice. I am aware of the planned changes to the IMC rating and the fact that it will become an IR(R) under EASA up until 2014; what happens after that is anybodies guess.

Will it be worth removing the restriction? given the uncertainty about the future of the rating perhaps people may not be too keen to do it; on the other hand will it lead to a flurry of people wanting to get it done so that they can obtain the license before the cut off date in 2014?

Any advice would be much appreciated.

Regards,

[Level Attitude]

A couple of questions as you say your location is Malta:

Is the UK CAA the Competent Authority for Malta?

Both IMC and IR(R) can (currently) only be attached to UK issued Licences,
and their Privileges are restricted to UK Airspace - would you have any
students?

If you have an IR yourself and have, or are likely to get, 200 hours
IFR Flight Time then you are entitled to train for the IR.

As EASA refuse to have any instrument qualification which is not
called "IR" then teaching for the:
"IR (Restricted)" or proposed "En-Route IR" would (should) keep your
privileges valid.

Whether it is worth removing your "No Applied Instrument" restriction
now is a question only you can answer but consider:
It is possible now. Will it be possible in the future (without further
requirements being thought up)

[Whopity]

Is the UK CAA the Competent Authority for Malta?No it's the CAD Malta.

If you meet the qualification requirements to add IR instructional privileges to your FI rating then I would have thought it would be the obvious choice as there will soon be a severe shortage of FIs qualified to teach instrument flying. If you are not qualified then you are one of those caught in the trap.

[MalteseJambo]

Re. Level attitude; Appologies! Im now in the UK, instructing in the UK with a CAA(EASA) license - forgot to update my profile.

My only intention at the monent is to remove the restriction to teach IMC ratings; therefore my understanding is that i only require 10 hours of Instrument time (also have my instrument rating) is that Correct?

Regards

[Whopity]

You have left it too late see AIC W 109/2012 (http://www.ead.eurocontrol.int/eadbasic/pamslight-51C449E55B4A63A16FB45BEB689150D5/7FE5QZZF3FXUS/EN/AIC/W/109-2012/EG_Circ_2012_W_109_en_2012-07-12.pdf)the rules changed and you now need 200 hours under IFR and an IR.

[Level Attitude]

AIC W 109/2012
Interesting! I hadn't seen this before. Thank you Whopity

It does however only explain that "1xIF = 4xIFR" will no longer apply
for the gaining of full IRI Privileges under Part-FCL.

MalteseJambo:
You have said you have an EASA Licence - In which case I would
assume you are completely governed by Part-FCL and would need to
comply fully with their requirements for full IRI privileges.

If you have a JAA (deemed to be EASA) Licence you could argue that you
could apply for IMC only teaching privileges based on the old UK requirements.

An email to the CAA asking the question might be in order.
[NB: They could reply that no one teaches for the IMC any more
(not strictly true ie revision instruction for existing holders) as
only IR(R)s are now issued]

You have not said what personal Instrument qualification you hold.

If you meet the requirements for IRI privileges it doesn't mean you
have to instruct for the IR. Just use it for teaching for the IMC/IR(R).
It's the same 5 hour course (though test might be different).

[Ex Oggie]

If you have a JAA (deemed to be EASA) Licence you could argue that you could apply for IMC only teaching privileges based on the old UK requirements.

It ain't going to happen! The IRI is an EASA qualification and EASA requirements have to be met.

It's the same 5 hour course (though test might be different).

An IRI test is an IRI test. Again, it has to meet the requirements. The course also consists of 10 hours technical training in addition to the 5 hours flight training.

[Level Attitude]

It ain't going to happen!
You may be correct - but for the 2 minutes it takes to email the
CAA and ask the question of them.....

The IRI is an EASA qualification and EASA requirements have to be met
True but, as you insisted on another thread, the IMC (and hence instructing for it) is a National Rating

NB: Has any FI who had IMC (but not IR) Instruction Privileges on their JAA
Licence lost those privileges on conversion to a Part-FCL Licence?

An IRI test is an IRI test. Again, it has to meet the requirements.
Your statement is completely true but:
An FI who does not meet IRI requirements, and only wished to teach
for the IMC, would be/would have been very unlikely to be asked to
demonstrate "Teaching planning and flying through CAS" as part of their
test to remove "No Applied IF" privileges.

[Whopity]

I am aware of an FI who completed the IRI Course prior to 17 Sep; the application was not submitted until after 17 Sept and the rating was refused on the grounds that the applicant did not meet the EASA requirement. So on that basis no chance!

[Rithalic]

I went though all of this last year, there were quite a few threads on it at the time.

Essentially my understanding is you have left it too late.

You now need to comply with the minimums required for the IRI.

Only the IRI seems to give privileges to new instructors Instruct for the IR and IMC Rating or IR/R in Easaspeak.

If you note on section 4 part P page 31 it does give the option:
Rating Previously issed under the ANO:
FI(A) IMC Rating

Part FCL Rating/Certificate:
FI(A) with the privilege to instruct for IR/R - UK Only.

Conversion Requirements:
Hold a Valid FI with a valid IMC rating PRIOR to 8 April 2014 or a UK CPL/ATPL issued prior to 1 July 2000


CAP804

http://www.caa.co.uk/docs/33/CAP804Jan2013.pdf

[2close]

What about those of us who already hold the Applied Instruments 'qualification' AND a current IR but for whatever reason have not instructed 10 hours for the IR (no reference to IMC under EASA) in the 12 months prior to revalidation?

I assume that the Applied Instruments 'qualification' will also be revalidated but that the holder would not be able to teach for the IR only the IMC, which it is also assumed includes the IR(R).

How does one then requalify for instructing for the IR?


:confused:

[Whopity]

To teach for the IR you would need undergo in house training at the ATO where you intend to teach for the IR as it has been for the past 13 years.

[Level Attitude]

Essentially my understanding is you have left it too late
Rithalic,
Thank you for providing the CAP804 references, but this is not what is written.

It says:

If you want this (when applying for your Part-FCL Licence):
Part FCL Rating/Certificate:
FI(A) with the privilege to instruct for IR/R - UK Only.

Then you need this on your previous Licence:
Conversion Requirements:
Hold a Valid FI with a valid IMC rating PRIOR to 8 April 2014 or a
UK CPL/ATPL issued prior to 1 July 2000

It does not even say you need to have done the course to remove
the "No Applied IF" restriction - it goes away automatically.

Daft - Perhaps
A mistake - Possibly

But current "plain" FIs who have an IMC rating (or IMC Licence privileges)
can now qualify to teach the IR(R) simply by converting to a
Part-FCL Licence.

[Level Attitude]

What about those of us who already hold the Applied Instruments 'qualification' AND a current IR but for whatever reason have not instructed 10 hours for the IR (no reference to IMC under EASA) in the 12 months prior to revalidation?

Everything is an IR under EASA:
As EASA refuse to have any instrument qualification which is not
called "IR" then teaching for the:
"IR (Restricted)" or proposed "En-Route IR" would (should) keep your
(IRI) privileges valid.

[Level Attitude]

To teach for the IR you would need undergo in house training at the ATO where you intend to teach for the IR as it has been for the past 13 years.

Whopity,
Could you provide a current reference for the above please.
(13 years is a long time, but I no longer believe anything unless I have
seen it in writing that it applies in the UK post 17 September 2012)

[Rithalic]

Level Att.

If i'm mistaken then obviously my apologies. I'm not an expert and have no ties to the CAA and believe me have no warm feelings whatsoever about easa.

You do make an interesting point. However in order to teach the IMC prior to easa an fi would have to remove the no applied if restriction by doing the course, albeit with less hours (10 by sole reference to instruments).

Point to note it also says in that same section,

Rating previously issued: FI(A), IR(A)
Part FCL: FI(A) with the privilege to instruct for the IR(A)
Conversion Requirements: Hold a Valid FI(A), IR(A)

In order to allow ones privileges to carry over from JAR to EASA, you had to previously be entitled to teach the IR and or IMC via your FI rating and have a current IR or IMC rating.

This is further evidenced in the same table where it states the following:

Rating Previously Issued: FI(A) No Applied IF
Part FCL: FI(A) Without Instrument instruction Privileges
Conversion Requirement: Hold a Valid FI(A) No Applied IF

My understanding from this is that if you previously had the no applied if restriction you are now an easa instructor with no instrument instruction privileges. Just because you hold an ir/imc doesn't entitle you to teach it.

If you already had the privilege to instruct for the imc then you are now entitled to instruct for the IR/R.

As I said i could easily be wrong, this is simply my understanding of the text. The best people to speak to would be licencing at your friendly neighborhood authority.

[BEagle]

But current "plain" FIs who have an IMC rating (or IMC Licence privileges) can now qualify to teach the IR(R) simply by converting to a
Part-FCL Licence.

The reference you quote does indeed refer to conversion of existing qualifications when the instructor converts his/her licence and ratings to Part-FCL. The wording is far from clear.

Currently there is no reduction from the FCL.905.FI(g) requirements for IR instruction. Because EASA doesn't recognise any 'applied instrument' training for anything except the IR, for new FIs who wish to teach 'applied instrument' flying there is as yet no equivalent to the previous IMC rating instruction requirements for the IR(R).

AOPA proposed a solution to the CAA last year, based on the previous system but turned into EASA-speak; however, the CAA wasn't prepared to take it to EASA in case the big boys made them cry. Hence the only people who can instruct for the IMC rating or IR(R) are those who are already qualified to do so. We intend to revisit the situation once the outcome of current CAA / EASA discussions regarding continuance of the IR(R) is clear.

[MalteseJambo]

Thanks for all the advice guys; I had a feeling it would open a can of worms!

The fact that an instructor with an existing IMC is eligible to teach the IMC (with the required training) leads me to believe someone with an IR should also qualify to do so as well....Ive emailed the CAA to ask the question specifically.

Thanks again.

[S-Works]

The holder of an IR with either an IRI or the instrument restriction removed can teach for both the IMC and the IR.

[nick14]

I did hear that in order to teach for the IR the CAA required a certain number of hours instrument instruction time? Or is that just a rumour.

Also how do you retain the privilege to teach for the IR with out having te 10 hours instrument instruction time?

[nick14]

I might have just found it in the FEH, to retain the privileges without the 10 hours and AoC must be taken.

I really should read before posting....

[Whopity]

Level Attitude
Could you provide a current reference for the above please.

AMC1 ORA.ATO.230(b) Training manual and operations manual Para D4
The sames as IEM No3 to JAR-FCL 1.055

[Level Attitude]

AMC1 ORA.ATO.230(b) Training manual and operations manual Para D4
Whopity,
Thank you for the reference, however I do not believe it is relevant.

ORA.ATO.230(b) Tells ATOs that they must ensure their Instructors are
'Up to Scratch', have a method of checking they remain so, and confirming
they teach a standardised course.

It says nothing about how to gain, or regain, Instructor Privileges
in the first place - that surely must be governed by Part-FCL - and
the question was:
What about those of us who already hold the Applied Instruments 'qualification' AND a current IR but for whatever reason have not instructed 10 hours for the IR (no reference to IMC under EASA) in the 12 months prior to revalidation?

[Level Attitude]

The reference you quote does indeed refer to conversion of existing qualifications
when the instructor converts his/her licence and ratings to Part-FCL.
The wording is far from clear.
Actually the wording is quite clear (even if we think it is non-sensical).

For 2) and 3) below they should have put "Previous Rating: FI(A) with privileges
to instruct for IMC / IR(A)". But they didn't so these conversion requirements apply.

1) Previous Rating: FI(A) No Applied IF
Part-FCL Rating: FI(A) without instrument instruction privileges
Conversion Requirements: Hold a valid FI(A) No Applied IF

2) Previous Rating: FI(A), IR(A)
Part-FCL Rating: FI(A) with the privilege to instruct for the IR(A)
Conversion Requirements: Hold a valid FI(A), IR(A)

3) Previous Rating: FI(A), IMC rating
Part-FCL Rating: FI(A) with the privilege to instruct for the IR(Restricted) – UK only
Conversion Requirements: Hold a valid FI(A) and a valid IMC rating prior to 8 April
2014; or a UK CPL(A)/ATPL(A) issued prior to 1 July 2000. The requirement of
Part-MED,MED.A.030(g) shall not apply to the IR(R)

[Bob Stinger]

FCL.915.IRI IRI – Prerequisites
An applicant for an IRI certificate shall:
(a) for an IRI(A):
(1) have completed at least 800 hours of flight time under IFR, of which at
least 400 hours shall be in aeroplanes; and
(2) in the case of applicants of an IRI(A) for multi-engine aeroplanes, meet the
requirements of paragraph FCL.915.CRI (a);

Does this mean its 800 as opposed to the 200 hrs being talked about on here?

[Whopity]

Its 800 hours to be a standalone IRI, and 200 hours if you are already a FI

FCL.905.FI FI — Privileges and conditions
(g) an IR in the appropriate aircraft category, provided that the FI has:
(1) at least 200 hours of flight time under IFR, of which up to 50 hours may be instrument ground time in an FFS, an FTD 2/3 or FNPT II;
(2) completed as a student pilot the IRI training course and has passed an assessment of competence for the IRI certificate; and
(3) in addition:
(i) for multi-engine aeroplanes, met the requirements for the issue of a CRI certificate;

[BEagle]

Level Attitude, you are quite incorrect.

Have you tried discussing the matter with the CAA?

To make it simple, if an FI is not currently qualified to instruct for the IMC rating / IR(R), they will have to wait until either:

1. They've achieved 200 hrs flight time under IFR and have completed the IRI course requirements; or
2. I've persuaded the CAA to re-assess the proposals put to them last year.

Bob Stinger, yes. If anyone really wants to be a standalone IRI, they will need to have achieved the hours figures you quote.

[172510]

From CAP 804: Flight time under Instrument Flight Rules (IFR)is "All flight time during which the aircraft is being operated under the Instrument Flight Rules."

What does it mean?
Under the hood with an instructor, you usually operate VFR. Does it count? I suppose so but it's not what the definition says.
You may elect to fly under IFR in VMC conditions, does it count? Does it count if you have an IMC rating, or should you have a full IR? Must you file a flight plan for the IFR time to count?
You may even fly under IFR rules in VMC condition without any instrument rating at all...

[Whopity]

You may even fly under IFR rules in VMC condition without any instrument rating at all...That is still possible on a UK National licence but has never been legal on a JAA or EASA licence!

What does it mean?It means what it says, flight in accordance with the Instrument Flight Rules so provided the flight was legal, any flight where you complied with the rules counts.
Assuming you flew under UK Rules: Rules 20 and 32 applied
Choice of VFR or IFR
20 (1) Subject to paragraph (2) an aircraft shall always be flown in accordance with the Visual
Flight Rules or the Instrument Flight Rules.

Instrument Flight Rules
32 (1) For flights within controlled airspace rules 33, 34, 35, 36 and 37 shall be the
Instrument Flight Rules.
(2) For flights outside controlled airspace rules 33 and 34 shall be the Instrument Flight
Rules.

If you held a JAA licence you should be aware of:
JAR–FCL 1.175 Circumstances in which
an IR(A) is required
(a) The holder of a pilot licence (A) shall
not act in any capacity as a pilot of an aeroplane
under Instrument Flight Rules (IFR), except as a
pilot undergoing skill testing or dual training,
unless the holder has an instrument rating
(IR(A)) appropriate to the category of aircraft
issued in accordance with JAR–FCL.
(b) In JAA Member States where national
legislation requires flight in accordance with IFR
under specified circumstances (e.g. at night),
the holder of a pilot licence may fly under IFR,
provided that pilot holds a qualification
appropriate to the circumstances, airspace and
flight conditions in which the flight is conducted.
National qualifications permitting pilots to fly in
accordance with IFR other than in VMC without
being the holder of a valid IR(A) shall be
restricted to use of the airspace of the State of
licence issue only.

IFR has nothing to do with Hoods or Weather!

[172510]

If I understand correctly your answer, for the 200 hours of flight time required:

- My 10 hours under the hood during my CPL training would only count if my instructor has a valid IR(A) or IMC rating, and the flights were executed under IFR rules. It's a captain's decision to fly under IFR if the conditions are met. Has my FI during my training logged the time while he was teaching me instrument flying under IFR? I doubt so. So the time under the hood probably does not count.

- The training for IMC rating probably counts, as the FI has probably logged the time as IFR flying. But if under VMC, the FI may elect to log under VFR, and in that case, the time would not count for the student.

- May an instructor log VFR navigation teaching (for PPL or CPL) under IFR? If above MSA, why not, is there any rule that forbids it? In that case, any FI would easily fly 200 hours under IFR, and the student could log IFR time as well.

[S-Works]

- May an instructor log VFR navigation teaching (for PPL or CPL) under IFR? If above MSA, why not, is there any rule that forbids it? In that case, any FI would easily fly 200 hours under IFR, and the student could log IFR time as well.

Since when has the PPL or the CPL been an IFR course?

This is not really difficult to understand guys. You need 200hours under IFR. To fly under IFR you need an IR. Most IMC Instructors do not hold an IR so that time can't be counted. The PPL and the CPL are VFR courses so I challenge you to explain to the CAA why you were conducting them under IFR.

You are talking about hours counting towards a qualification that allows you to teach others to fly under IFR in IMC conditions. In order to teach others you have to have the experience yourself in order to pass it on. Blagging IFR in VFR conditions does not exactly bring much experience to the table does it?

I am one of the rare people that Whoppity refers to that did the IRI(A) as a standalone rating when you needed 800hrs IFR or 200hrs sole reference to Instruments. It was not difficult to get the time over a couple of years and I think that I brought a lot of real IFR experience to my students that they benefited from.

As an FE its is easy to tell the IMC candidates that were taught by Instructors with real IFR flying experience...... Perhaps a bit of food for thought?

[BEagle]

Most IMC instructors do not hold an IR so that time can't be counted.

Untrue. As an IMC instructor, you do not need to hold an IR.

As an FE, I found it easy to tell which applicants had been trained by instructors with sound instrument flying skills and teaching ability, rather than by those who liked flying in straight lines playing airliners, with the occasional ILS now and again...

[S-Works]

Untrue. As an IMC instructor, you do not need to hold an IR.

I did not say that they did. Not sure how much IMC teaching I have done under an IFR flight plan though?

As an FE, I found it easy to tell which applicants had been trained by instructors with sound instrument flying skills and teaching ability, rather than by those who liked flying in straight lines playing airliners, with the occasional ILS now and again...

If that was a pop at my response then I think you will find that we are violently agreeing. My point was that trying to blag IFR time teaching PPL and CPL courses does not give real IFR experience.

[172510]

My point is that common sense would be that training under the hood should count towards the requirement, but that the rule does not say so. That's why I think it needs clarification.

[BEagle]

Not sure how much IMC teaching I have done under an IFR flight plan though?

What difference does a flight plan make? I've flown thousands of IMC hours without any such thing.

All IMC flight requires the aircraft to be flown under IFR; there seems to be a growing misconception that an IFR FPL is essential in order to comply with the Instrument Flight Rules. Which simply isn't true.

[172510]

In the UK, flying under IFR out of controlled airspace is a captain's decision, you don't have to tell anyone, you just decide you do, and provided you're above MSA and fly according to the quadrantal rule (rules 33 and 34), and have at least an IMC rating, it's legal. If the weather is fine, it's just like flying VFR, but you may legally log IFR time.

If you have an IMC rating, and fly above MSA according to the quadrantal rule don't forget to log IFR time even if the weather is fine

In some other countries, for instance France, you may not fly under IFR, even out of controlled airspace, without a flight plan.

[Level Attitude]

Untrue. As an IMC instructor, you do not need to hold an IR.
I did not say that they did

Bose, I think you did given you wrote:
To fly under IFR you need an IR. Most IMC Instructors do not hold an IR so that time can't be counted
Post 17Sept 12 an instrument qualification (IR or IMC/IR(R)) is required
to fly IFR. Prior to 17 Sept 12, provided they flew within their Licence
privileges plain PPLs could elect to fly IFR otside CAS (and indeed, prior to
June? 2012, it was mandatory to do so at night in theUK)

[Level Attitude]

If you have an IMC rating, and fly above MSA according to the quadrantal rule

What has the MSA got to do with the Quadrantal Rule?
(Transition Altitude perhaps?)

What has the Quadrantal Rule got to do with IFR flight?
(Semi-Circular Rule perhaps?)

[S-Works]

Post 17Sept 12 an instrument qualification (IR or IMC/IR(R)) is required
to fly IFR.

Fair comment.

However I still don't believe that teaching VFR courses and claiming to be IFR in order to fudge the numbers is legitimate whatever Beagle may think.

The requirements are there to ensure that experienced IFR pilots (read that as Instructors experienced in IFR operations in IMC including tracking and approaches) are eligible to teach for Instrument qualifications.

[Level Attitude]

My point is that common sense would be that training under the hood should count towards the requirement, but that the rule does not say so. That's why I think it needs clarification.

The rule is, and has always been, 200 hours IFR.

However, prior to 17 Sept 2012, the CAA agreed with your "common sense"
and gave a dispensation that "1 hour IF" would count as "4 hours IFR"

This dispensation ended on 17 Sept as EASA do not allow it.

The rules do not need clarification.
You may wish the rules were different, and want them changed, but
that is a very different issue...................

[Level Attitude]

However I still don't believe that teaching VFR courses and claiming to be IFR in order to fudge the numbers is legitimate

Totally agree.
Also it does not seem valid, to me, to claim that all of an IMC or IR course
was flown IFR.
eg Lesson 1: Look out the front see where horizon is, now look at AI.
Look out and Bank acft 15deg to right, now look at AI, etc, etc

[Level Attitude]

Level Attitude, you are quite incorrect.
BBeagle
That is a very blunt statement.
I belive I quoted verbatim from CAP804 vJan 2013
What reference(s) can you provide that overide this?

Have you tried discussing the matter with the CAA?
Why would I ask the CAA what needed to be done in order to obtain
"FI(A) with IR(R) instructional privileges" on conversion to a Part-FCL
Licence? They would only refer me to, and quote from, CAP804.

The wording in CAP804 is unambiguous, even if it does not convey the
meaning that was originally intended.

[BEagle]

However I still don't believe that teaching VFR courses and claiming to be IFR in order to fudge the numbers is legitimate whatever Beagle may think.



I certainly do NOT countenance any such thing!

Neither do I accept that Level Attitude's interpretation of CAP 804 is correct. Any IMCR / IR(R) application will require an applicant to submit their personal flying logbook. Which will be checked....so any 'IMCR FI' not properly qualified might well find themselves under unwelcome scrutiny.

[172510]

Quote:
What has the MSA got to do with the Quadrantal Rule?
(Transition Altitude perhaps?)

What has the Quadrantal Rule got to do with IFR flight?
(Semi-Circular Rule perhaps?)

Answer: IFR is a set of rules. Out of controlled airspace, in the UK, you may elect to fly according to these rules. One of these rule (rule 33) is the Quadrantal rule, the other (rule 34) is the MSA. So when you fly above MSA, and according to the quadrantal rule, you fly under IFR, by definition.

[172510]

"Also it does not seem valid, to me, to claim that all of an IMC or IR course
was flown IFR.
eg Lesson 1: Look out the front see where horizon is, now look at AI.
Look out and Bank acft 15deg to right, now look at AI, etc, etc

Common sense has nothing to do with EASA regulation.

To fly IFR is, by definition, to fly according to rule 33 and 34. It has nothing to do with simulated or actual IMC. So if your IMC training was under 1000ft height, even the part under the hood will not count as IFR flying. Nothing in the EASA regulation say that flying under simulated IMC counts in the 200 hours required.

It is against common sense, but that what the Aircrew regulation says.

[Whopity]

Nothing in the EASA regulation say that flying under simulated IMC counts in the 200 hours required.Actually, FCL.905.FI FI — Privileges and conditions states 50 hours may be Instrument ground time!(1) at least 200 hours of flight time under IFR, of which up to 50 hours may be instrument ground time in an FFS, an FTD 2/3 or FNPT II;

[Level Attitude]

Rule 33 (MSA) says, with multiple exceptions, one has to fly at least 1,000'
above the highest object, etc. It does not tell you what Alt/FL you
require and is nothing to do with the Quadrantal Rule.

Rule 34 (Quadrantal Rule) says what FL you must select for a particular
Track once you are higher than the Transition Altitude.

TA does not equal MSA

The Quadrantal Rule has nothing to do with MSA
NB: I had thought, with advent of EASA, Quadrantal Rule no longer
existed, only Semi-Circular Rule. Happy to be corrected.

So when you fly above MSA, and according to the quadrantal rule, you fly under IFR, by definition.
Not at all.
To fly IFR then Rule 33 and 34 must be complied with.
However the converse is not true. Just complying with 33 and 34 does not
necessarily mean you are flying IFR.
You could fly above MSA and above Transition Altitude and according
to the Quadrant Rule and still fly VFR (assuming VMC).

So if your IMC training was under 1000ft height, even the part under the hood will not count as IFR flying
Being "under the hood" or not makes no difference as to whether the
flight was IFR or not, neither does the height:

How could you fly an Instrument Approach down to minimas otherwise.

Can even elect to fly a Circuit Detail IFR if so qualified, indeed prior to June 2012 all Night Circuits were so flown.

Nothing in the EASA regulation say that flying under simulated IMC counts in the 200 hours required
Correct (though note Whopity's post re Sim)

It is against common sense
That is your opinion.
If you feel strongly then start a lobbying campaign to get the rules changed.

[Level Attitude]

Neither do I accept that Level Attitude's interpretation of CAP 804 is correct
What interpretation? CAP804's wording on the subject is hardly ambiguous.
I note you do not supply any reference to support your opinion.

Any IMCR / IR(R) application will require an applicant to submit their personal flying logbook
Completely agree, but the subject we are debating is about a conversion
of a non-EASA Licence to a Part-FCL Licence and, unless additional
ratings are being claimed, no log books are required.

SRG1104 does not require Licence Holders to apply for the licence(s)/rating(s), etc that they
want. It only requires them to state what they currently/previously hold.

The CAA will (or should) then apply its own, stated, conversion criteria (ie CAP804) to
produce a Part-FCL Licence with the appropriate Rating(s), etc.

[Whopity]

but the subject we are debating is about a conversion
of a non-EASA Licence to a Part-FCL LicenceTrue Thread Drift from the original questionWorth removing 'no applied Instruments' restriction?

[FlyingOfficerKite]

If the purpose of 'removing "no applied instruments" restriction' is to enable you to teach for the IR and IR(R) and you have the requisite IFR experience then it seems there is likely to be a high demand for your skills in the future.

However, the question must be: for what reason have EASA determined the level of IFR experience to be greater than that previously required to instruct for the IR?

Perhaps the truth lies in statements made above regarding the type and particular experience of the pilots EASA hopes will train the airline pilots of tomorrow.

Maybe the main flight academies see retired airline pilots with in-depth knowledge of their 'trade' as being the instructors of choice, rather than a PPL who, with all due respect, has worked his/her way through the flying school environment to CPL/IR FI level but without any real knowledge of airline flying.

When all said and done the TREs and TRIs who train for the airlines are airline pilots or ex-airline pilots themselves.

Perhaps the hope is to bring this level of knowledge and experience out of the airline environment and into the flying schools so that trainee pilots are immersed in a 'professional' training regime from the start - such as is evidenced by the ab initio First Officer training programmes and the MPL courses now offered by the professional flight academies?

Unfortunately, how else will the flight academies recruit instructors able to teach from first lesson to B737 sim in a seamless manner and convince their airline clients that their particular courses are able to provide a standard of instruction borne out of 'real' airline experience?

The trainees themselves will, I suggest, have greater respect and faith in the teachings of a former airline pilot than someone with a background of flying Cherokees and Senecas at the local club.

I don't mean to demean the competence of any IMC and IR instructor with the above comments, but in this highly competitive commercial world of professional flying training it seems there is a trend away from the 'local club or school' when it comes to the delivery of professional level flying training?

Otherwise there would seem no sense in the new requirements?

KR

FOK :)

[S-Works]

FOK, while I agree 98% with what you say above, the remaining 2% question is, who caters for the people who don't want to fly a people tube to Malaga?

I know it may surprise you but the world does not actually revolved around training airline pilots. There are people who want to fly IFR for their own purposes and commercial pilots who have no desire to fly for an airline.

The training needs to be all encompassing, not airline selective.

[BEagle]

Maybe the main flight academies see retired airline pilots with in-depth knowledge of their 'trade' as being the instructors of choice, rather than a PPL who, with all due respect, has worked his/her way through the flying school environment to CPL/IR FI level but without any real knowledge of airline flying.

That's the problem. Historically, the IR has been misused by the CAA has a 'fit to fly airliners' yardstick, rather than as an assessment of instrument flying skills... As one of their staff once told me "It's our last chance to make sure that the wrong sort of people don't end up flying airliners"....:rolleyes:

Retired airline pilots might well have thousands of hours spent sitting in the sun at FL350 watching the autoflight system drive their 2-pilot people tube along the airways, but very little in the way of single pilot instrument flight experience or instructional skills.

Those of us who used to fly high performance interceptors at low level on black wet cloudy nights, without the benefit of an autopilot, quite frankly laugh at the ridiculous notion that ex-airliner drivers are the best people to teach single pilot instrument flying!

[mad_jock]

I think there is another motive for the change which is to make the traditional way of training airline pilots via single pilot planes nearly impossible.

The big schools want to move away from this and get the whole lot going through MPL training to cut out the modular method of training airline pilots.

There will then be jobs for the boys for TRI's and TRE's.

Most of the large schools have pretty old knackard fleets which will need changed in the next 10 years and not alot to replace them with that doesn't cost a fortune. Far more cost effective to replace the lot with simulators which can run 24h

[Whopity]

FOK
However, the question must be: for what reason have EASA determined the level of IFR experience to be greater than that previously required to instruct for the IR?The answer to you question is very simple, they copied it from the JAA lock stock and barrel. No thought process involved at all!

The JAA committees were probably made up from a collection of retired airline pilots and their reasoning may well have been along the lines you suggest. Most of Europe followed the JAA model, the CAA chose to amend it and then we have the ICAO model which worked perfectly well for many years until the JAA decided to mes with it. By now there should be enough statistics to show which system is the safer; or is there no discernible difference?

[Level Attitude]

However, the question must be: for what reason have EASA determined the level of IFR experience to be greater than that previously required to instruct for the IR?

The answer to you question is very simple, they copied it from the JAA lock stock and barrel. No thought process involved at all!


What is this greater level of IFR experience required by EASA?

The only difference I can think of is the loss of the "1hr IF = 4hr IFR" dispensation which, as far as I am
aware, was UK specific and not used in other JAA Member States.

So is it not just EASA not allowing national differences (which we
know they are loathe to do)?

[pipertommy]

Have to disagree FOK, why does airline background provide a better background when teaching for IR or IMC ? Autopilot engaged and monitoring systems hardly compares to a GA pilot who has built hours of experience in light pistons.
Shouldn't dismiss an instructor just because of non airline background.

[FlyingOfficerKite]

Hi PiperTommy

I understand your point of view which reflects the '2%' referred to by Bose-X above.

I also note that whilst you have a Frozen ATPL you appear to fall within the category of 'someone with a background of flying Cherokees and Senecas at the local club'?

With the greatest respect, if you understood the airline training environment you would appreciate there is far more to airline flying training than operating with 'autopilot engaged and monitoring systems'.

It does not compare with 'a GA pilot who has built hours of experience in light pistons'.

The two types of aviation activity differ widely. My point is that the EASA requirements tend towards the 'pilot sausage factory' approach and not that of GA.

The '2%' of pilots wishing to further their qualifications with either an IR(R) or IR are going to find it both expensive and difficult to obtain these ratings outside of the larger ATOs in the future (cost and lack of instructors).

I came through flying training by the 'self-improver' route. In those days the only issue I can remember which produced anything like an obstacle to progress was when the CAA changed the rules so that a pass in Perf A was no longer a cover all and you had to take Perfs A, C and E!

You don't have to look through rose-tinted spectacles to see that the process of becoming qualified was cheaper, more flexible and, dare I say it, more fun than it is today.

We live in a Euro-World of aviation which makes the Campaign Against Aviation (CAA) an amateur player in this new order.

I can't think of many of my instructors who would be qualified to teach me were I venturing forth today - and I certainly wouldn't have been able to achieve my new EASA instructor ratings without the years of airline flying.

My point is that EASA appears to be gearing itself towards the airline pilot trained by the Flight Academies and not catering for the GA pilot.

The needs of GA and the requirements of the airlines are sure to differ - EASA seem to have backed one at the expense of the other?

KR

FOK :)