Pity we do not have the balls of the French more on IR and IMCR

[Pace]

EASA IR regulation expected ‘soon’

Moves towards a more attainable Instrument Rating in Europe are
running behind schedule by about two years, AOPA Germany’s Managing
Director Michael Erb reported to the Regional Meeting. Publication of
EASA’s ‘opinion’ – effectively its plans for rulemaking – are expected
shortly, however.
After pressure from the French, Dr Erb said, there was reason to hope
that third country Instrument Ratings might be transferable into
European IRs simply by having a check ride with an examiner. “Every
year, Instrument Rating holders have to have check ride, anyway, and
this would be an enormous advantage to the holders of third country
IRs. They must hold a European PPL, to which they can attach their
IR.”
Emmanuel Davidson of AOPA France said checks in the United States on
pilots with a current medical, an Instrument Rating and a European
address showed there were more than 11,000 on the FAA’s books.
Martin Robinson said the UK CAA was determined to retain the IMC
Rating in the UK, although EASA continued to stand out against it.
While IMC rating holders had grandfather rights, under EASA new pilots
could not be extended the protection of the rating, leading to a
strange situation where one pilot would be flying with the increased
safety provided by the rating, while the next was denied it. “The UK
is not saying it wishes to impose its IMC rating on the rest of
Europe,” he said. “It is saying, please read your own rules and allow
the IMC rating to continue in the UK.”

Now UK stand shoulder to shoulder with the French for an easy transferable and attainable IR and forget the red herring distraction of the IMCR

The UK
is not saying it wishes to impose its IMC rating on the rest of
Europe,” he said. “It is saying, please read your own rules and allow
the IMC rating to continue in the UK.”

How Gentlemanly of the UK? Pretty please nice Mr EASA, Tea and biscuits cozy chats and nothing achieved! whats new?


Pace

[172driver]

Now UK stand shoulder to shoulder with the French for an easy transferable and attainable IR and forget the red herring distraction of the IMCR

Well said, Pace, couldn't agree more.

[mad_jock]

But the UK is one of the countries trying to block a transferable IR. So why would the side with the French?

[Pace]

MJ

Because the UK are stupid maybe? There is no sensible reason why an FAA IR should not convert to a EASA IR without any more than a flight test and I will even add a differences exam :ok:
You give me a good reason why not which does not involve petty protectionism or terratorialism?
So safety grounds please which is supposed to be EASAs mandate!

Pace

[mad_jock]

There is none which is why it won`t happen.

And the N reg crowd have pissed to many people off telling them how crap the UK/EU system is. You might get something in 10-20 years when enough of the old crew have retired.

But like it or not there are a large number of people who want to punish FAA EU pilots for sticking there middle fingers up at their home countrys regulations.

Safety has nothing to do with it.

[peterh337]

The French IR is nothing like the IMCR, in the training process for starters.

Some details were posted here (http://www.euroga.org/forums/flying/55-what-happens-to-the-imc-after-april-2014?page=2) by a French pilot.

The UK IMCR is unique in its accessibility.

[Johnm]

What you have to understand is that EASA like all EU bureaucrats believes that uniform high level of safety is achieved through uniform complex paperwork the French understand that the paperwork and the activity are separate and largely unrelated.

[BEagle]

More nonsense, eh Pace?

1. Read the FCL.008 CRD to understand the latest proposals for conversion of FAA IRs to EASA IRs. This will involve experience and testing, but no theoretical knowledge examinations will be required; practical assessment of relevant knowledge will be included as part of the Skill Test.

2. Understand that the UK will continue to strive for the regulatory flexibility of JAR-FCL to be included in part-FCL. Should you wish to research this, you will need to consider JAR-FCL 1.175(b) and the IAOPA proposal for a new FCL.600(b). Which the CAA strongly supports in its own proposals.

3. The French national IR will face the same fate as the IR(R) after Apr 2014 unless EASA accepts FCL.600(b). Hence FCL.600(b) is not a UK-centric proposal.

Incidentally, mad_jock, far from 'blocking' such proposals, the UK fully supports the FCL.008 proposals with regard to the conversion of FAA IRs to EASA IRs.

[Pace]

more nonsense eh Pace

Expand ?;)

Beagle

You know for over two years I have written in these forums my opinion on the IMCR being retained.
I value its benefits both from a safety angle as well as making flying more practical for the PPL but in the new EASA times it has past its sell by date and fighting to retain it rather than replace it with an FAA style full IR has purely diverted focus away from demanding a PPL IR (Full) which the ordinary working man with work and family obligations can achieve.
Without the influence of the french I very much doubt such an IR would be on the cards and I find it pathetic that the UK has not been equally vociferous in DEMANDING such an IR for GA pilots.
If the IMCR has such proven safety attributes then a full IR would have even better.
I say DEMAND because that is what we should have done.
So what victory retaining the IMCR? To me that would be winning a battle and losing the war

If you think that is nonsense so be it we disagree on this point

[englishal]

There is no sensible reason why an FAA IR should not convert to a EASA IR
ESPECIALLY seeing as most people who have or fly an N reg are currently using their FAA IR in their N reg plane, in Europe, quite legally and safely!!!!! Surely this speaks volumes, are there ANY incidents of an FAA IR holder getting into trouble while flying IFR which is directly related to the use of a foreign IR in Euroairspace?

Does an M or 2J's validation of an ICAO certificate and ratings now make that an EASA licence for all intents and purposes?

Who cares if the EASA require half scale deflection and the FAA 3/4 or the FAA is tougher on partial panel. That becomes largely irrelevant the minute you have used your rating in anger, and as time goes on, more irrelevant. There is no reason EASA couldn't directly convert an FAA IR for someone with 100hrs actual or simulated instrument time as I bet they are probably more competent than a brand new EASA IR holder.

[BEagle]

There is no reason EASA couldn't directly convert an FAA IR for someone with 100hrs actual or simulated instrument time as I bet they are probably more competent than a brand new EASA IR holder.

The requirement is expected to be 50hrs IFR flight time as PIC of aeroplanes, plus the Skill Test (which includes assessment of relevant practical knowledge).

Due to the fact that, unlike the IMCR, the FAA IR does not require any periodic retesting, meaning that in theory it could have been years since a pilot demonstrated adequate competency under IFR (or even the ability to fly safely in IMC...), it is virtually certain that a Skill Test with an IRE will be a mandatory requirement for conversion to a part-FCL C-b M IR(A).

[Fuji Abound]

There is no sensible reason why an FAA IR should not convert to a EASA IR

We need to stop using words like "sensible".

Sense is not the driving force and sense is very unlikely to win the day.

EASA have a wholly different agenda.

Beagle

Validation is an interesting point.

My problem is with a scientific background I like evidence to support legislative change - rather than it seeming a good idea.

You will recall there was no validation for the VFR rating, then there was validation by C of E, and then by a flight with an instructor maybe one day there will be a compulsory flight test. The point being I am not aware of any evidence this has made things safer. There may be evidence, but I am not aware of it.

With regards the IR the FAA have done things their way for as long as I can remember - is there any evidence that changing to an annual test will make things safer?

If there is any justification I suspect much of this is directed at the rare exceptions. I think most pilots do a pretty good job of policing themselves - there is the odd individual who think their skill levels are better than they are, or perhaps are self deceivers, and just maybe re-validation does prevent these individuals killing themselves.

Perhaps my "problem" is making an exception for instrument flight. Also it is an interesting dichotomy that the FAA require a compulsory VFR test every two years, but self validation for IR privileges, whereas we require no basic test of a pilot's flight skills but we test IR privileges.

As I said earlier - "sense" doesn't come into it.

[englishal]

If there is any justification I suspect much of this is directed at the rare exceptions. I think most pilots do a pretty good job of policing themselves
This is true. I normally do an FAA IPC (Instrument Proficiency Check) every two years, despite not needing to, as this is probably about the frequency that I travel to the USA these days. It also re validates my IMCr and also proves to the FAA flying school that I am competent to take their aeroplanes so kills a number of birds with one stone so to speak. Last time I combined this with learning to fly the Cessna C510 which was a lot of fun !!!:E

[flybymike]

You will recall there was no validation for the VFR rating, then there was validation by C of E, and then by a flight with an instructor maybe one day there will be a compulsory flight test. The point being I am not aware of any evidence this has made things safer. There may be evidence, but I am not aware of it.
There is indeed evidence, but the evidence is that the introduction of BFRs, 90 day rules, annual MEP tests etc made NO difference at all to the accident statistics. The CAA's own safety review indicated no detectable improvements following the introduction of all this eurocrap at the turn of the century. We had all been flying just as safely for decades before this whole new layer of bureaucracy and cost was brought in.
The CAA safety review is here;
CAA Paper 2007/05: The Effect of JAR-FCL on General Aviation Safety | Publications | About the CAA (http://www.caa.co.uk/application.aspx?catid=33&pagetype=65&appid=11&mode=detail&id=2820)
and one of the the rather telling conclusion states:

"The introduction in 1999 of new revalidation requirements contained within JAR-FCL had no significant effect on the number of serious incidents and accidents involving fixed-wing GA (Single Engine Piston) aircraft for both private pilots and instructors."

[Pace]

Englishall

I have not done a BFR for years basically because I keep a current type rating going which requires recurrent validation on a yearly basis.
Beagle I never suggested that EASA take the FAA IR as is without tailoring the package to suit their own requirements.
An annual IR flight test or recurrent type rating should suffice.
I also have nothing against a differences exam be that oral or written.

Pace

[flybymike]

Due to the fact that, unlike the IMCR, the FAA IR does not require any periodic retesting, meaning that in theory it could have been years since a pilot demonstrated adequate competency under IFR (or even the ability to fly safely in IMC...), it is virtually certain that a Skill Test with an IRE will be a mandatory requirement for conversion to a part-FCL C-b M IR(A).

However;

1. There is an ongoing currency requirement.

2. The absence of any data to suggest that lack of recurrent testing has resulted in poorer accident statistics seems to indicate that currency rather than testing is equally, or perhaps even more effective, even for pilots "who have not demonstrated adequate competency" (except of course by failing to have an accident.)

[dublinpilot]

maybe one day there will be a compulsory flight test.

EASA's first draft at FCL rules had a compulsory flight test every 3 (or was it 6?) years. But that got quickly removed.

dp

[Fuji Abound]

Again, I suspect part of the dichotomy stems from the IR being considered a "professional" rating in Euro land whereas in FAA IR land it is a rating for everyone.

This means the powerful professional lobby has a significant part to play in the dialogue.

It is bizarre really because light GA mixes no more or less with CAT whatever the flight conditions. It is equally bizarre given that most CP were once in charge of rubber bands. Perhaps as soon as they have an ATPL they forget their roots. ;)

[OpenCirrus619]

In my humble opinion one reason that there is so much disagreement, in the UK, is the way the PPL IR advocates tried to torpedo the IMCR to further their own aims.

Personally I value the IMCR - it provides precisely the training the privileges I want/need.

At the moment I do not have the time, or money, to get any new ratings - in particular something which will involve a lot of training. Should the IMCR be replaced with some sort of IR (unless I get the new rating on "grandfather rights") it will impose a reduction in safety for me, and those in my position.

I agree that I would probably be better equipped IF I had a full IR but, in my case, it is not an option: If the IMCR is removed then I will be worse off / LESS safe.

In light of this I, along with many others, will oppose anything that will remove the IMCR without replacing it with something the provides similar privileges at a similar cost - perhaps the PPL IR folks would like to consider this.

OC619

[mm_flynn]

In my humble opinion one reason that there is so much disagreement, in the UK, is the way the PPL IR advocates tried to torpedo the IMCR to further their own aims.

Personally I value the IMCR - it provides precisely the training the privileges I want/need.

At the moment I do not have the time, or money, to get any new ratings - in particular something which will involve a lot of training. Should the IMCR be replaced with some sort of IR (unless I get the new rating on "grandfather rights") it will impose a reduction in safety for me, and those in my position.

I agree that I would probably be better equipped IF I had a full IR but, in my case, it is not an option: If the IMCR is removed then I will be worse off / LESS safe.

In light of this I, along with many others, will oppose anything that will remove the IMCR without replacing it with something the provides similar privileges at a similar cost - perhaps the PPL IR folks would like to consider this.

OC619

You are rehashing a dead issue. You do have exactly what you personally want (the protection of your IMCr into the future) so you can retain the rating with the training/skills tailored to what you want (in the form of the already being issued IR(R) - which you get with your new blue licence)

The issues now are
1 - Conversion of other IRs (which has a programme of work)
2 - Bending the Euro rules to try and keep the ability to issue new IMCrs (which BEagle and Co. are working on)
3 - Getting the competency based IR, sensible ATO requirements, and maybe the EIR - which would provide for not a lot of extra training the ability to operate IFR all over Europe, a massive safety benefit to non-UK pilots, and the chance for IMCr pilots to upgrade to being able to legally operate IFR into and out of France, Ireland, etc.

It's possible some IMCr pilots might even find it a useful privilege to get above the weather rather than slog through ;-).

[OpenCirrus619]

mm_flynn - don't disagree with anything you've said.

My outpouring was a response to some earlier posts:
So what victory retaining the IMCR? To me that would be winning a battle and losing the war

I have no objection (indeed fully support) the push for an accessible PPL IR - as long as the IMCR isn't bartered away in the process. I regard it as a shame that the IMCR and PPL IR seem to have become linked - meaning there is now disagreement about what constitutes "victory". It seems to me it would have been much better had:

Getting an accessible PPL IR
Retaining the IMCR in an acceptable form for existing holders

had not been linked in the first place.

OC619

[S-Works]

Retaining the IMCR in an acceptable form for existing holders

Thats already been done. If you are an existing holder you will keep the IMCr as an IR(Restricted). You can currently add an in IR(R) to your licence up until next year.

Its what happens after that for new comers that is still in sway.

[bookworm]

In light of this I, along with many others, will oppose anything that will remove the IMCR without replacing it with something the provides similar privileges at a similar cost - perhaps the PPL IR folks would like to consider this.

It's not obvious what you mean by "PPL/IR folks", but just to be clear, the PPL/IR Europe organisation:

* supports the accessible instrument rating
* supports the CAA's conversion report from IMC rating to IR(R) for current holders (http://www.caa.co.uk/docs/2330/Revised%20Statement%20UK%20IMC%20RATING%20May%202012%20_v3.p df) (which is what you need OC619, but appear not to have heard about)
* supports the continued existence of the IMC rating as a rating available to new pilots in the UK.

It seems to me it would have been much better had:
* Getting an accessible PPL IR
* Retaining the IMCR in an acceptable form for existing holders
had not been linked in the first place.

I don't believe they have been linked, except in forum posts. They should not, of course, be linked, except in that it would be desirable for the administrative and organisational requirements for the IR to be as straightforward as they currently are for the IMC rating.

[Pace]

MM

3 - Getting the competency based IR, sensible ATO requirements, and maybe the EIR - which would provide for not a lot of extra training the ability to operate IFR all over Europe, a massive safety benefit to non-UK pilots, and the chance for IMCr pilots to upgrade to being able to legally operate IFR into and out of France, Ireland, etc.

The problem with the EIR is that a number of member states will not accept it on safety grounds.
EASA would never accept the IMCR because it was not enroute to anywhere!
What I mean by that is that they saw the concept of the EIR as being a half way house to a full IR allowed enroute privalages ie part of the full IR package.

The problem with the EIR is having pilots who do not have the skills needed to fly approaches or departures or the legal rights to do so.
It all sounds great! Takeoff VFR climb on top and descend VFR the other end.
Reality is very different. Take off VFR climb on top, find the cloud tops are increasing or a line of thunderstorm and what then?
Have a problem enroute which requires a landing? Cloudbase below 200 RVR 700 Meters and what does the EIR holder do?
Leave the airway before the Star over mountains maybe 30 to 50 miles out and although destination is CAVOK it is not where you are trying to get visual.

You cannot have a safe halfway house with instrument flying hence why many countries oppose it!

They will never accept the IMCR in Europe so at best it will be a local unsupported rating to keep the brits happy and to deflect attention away from what should be an easily achievable FULL IR along American lines with full IFR privalages takeoff enroute and landing!

That is the only way you can do it and there are 11000 FAA IR rated pilot in the EU

had not been linked in the first place.

But they are linked as the safety objective is to have instrument ability which is a safety angle as proved by the IMCR.
Sadly it will never be accepted Europe wide and hence we should fight for something which will be accepted Europe wide which gives us full departure enroute and landing privalages and not take a massive more effort than getting the IMCR



Pace

[Ellemeet]

There is always the french angle.

Latest I heard is that they are forming a front with the UK and even the Germans. They want to have their IR rating recognized and transferrable. They will support the IMCr and even would consider allowing to extend those priveleges into France.

The strange thing is that everybody always focusses on EASA, however, from what I have heard, EASA was very much in favor for a much more progressive advance. It are member states that block certain advancements.

I can understand that EASA wants one set of rules for all her members.

[mm_flynn]

Pace,

I am fully aware there are a number of people and organisations opposed to the EIR. Notwithstanding that, it is in the current opinion going forward to comitology (spelling and process state may be wrong!). Hence why I said 'maybe' to that part. The key is to try and get this package through with as little dilution as possible. The package is of course, the sensible conversion, the CB IR, the EIR (and I believe cloud flying for gliders) and for AOPA BEagle etc to continue the drive to enable the CAA to issue IR(r)s after 2014, which is a totally separate initiative which I believe is not in anyway linked.

I would certainly agree the CB IR and conversion bits are vastly more important and logical than the EIR.

[englishal]

Well if I can get an IR(R) because of my FAA IR (which I do - the CAA give me one), and then later on I am offered an EIR due to the FAA IR or IR(R) (I cannot see a test for someone with a full IR to be able to fly En route....if there were a test it would be the easiest test ever).....then that gives me FULL IR privileges in the UK, other than perhaps fly an IAP into a Class A airport (unlikely to happen anyway).

That would do me ;)

[wsmempson]

The problem with the EIR (other than the obvious flaw of allowing pilots to fly in instrument conditions in controlled airspace with no means of departing or arriving in IMC - life is rarely arranged in such a convenient fashion) is that the pilots will need to take the full Theoretical knowledge exams to qualify for this rating.

Given that the barrier to achieving a PPL IR has never been the flying per se, but the ludicrously overblown theoretical knowledge exams, I believe that the EIR misses the point of what is needed to change in order to make the IR accesible to the ordinary pilot who has a full time day-job.

If you then consider that with the new EASA licences, an ordinary PPL has the right of "VFR on top" (ie flying in good VMC on top of an unbroken cloud-base), it is difficult to see how the take-up of the EIR is going to add up to much. After all, if the arrival and departure is always going to be a total fudge, why go through the full TK exams to do what you can more or less do under the privileges of an ordinary PPL?

I would be surprised if the new PPL IR & EIR comes into being as proposed. I would not be surprised to see the French PPL IR being adopted in it's stead. I would like to think that the IMCR rating gets adopted by a small sub-group of european countries, on a national basis with mutual recognition treaties.

Here's hoping...

[Pace]

I must admit some of the proposals seem almost too good to be true especially coming from EASA !
More known for manipulations, broken promises and slight of hand ; (
Any lesser IR would have always been a part 1 to a full IR.
Without as you say departure / arrival benefits its a dangerous rating and the IMCR would have been a better choice but not one which would work in many areas if Europe!

Pace

[bookworm]

The problem with the EIR is having pilots who do not have the skills needed to fly approaches or departures or the legal rights to do so.
It all sounds great! Takeoff VFR climb on top and descend VFR the other end.
Reality is very different. Take off VFR climb on top, find the cloud tops are increasing or a line of thunderstorm and what then?
Have a problem enroute which requires a landing? Cloudbase below 200 RVR 700 Meters and what does the EIR holder do?

I've never really understood this argument. A sensible pilot plans a flight so that there's a contingency to reasonably foreseeable eventualities within the capability of pilot and aircraft.

With an IR I can plan a flight where I depart IFR, find the cloud tops are increasing or a line of thunderstorms are between me and my destination, and all the potential diversions are below Cat 1. What then? To avoid a nasty moment, I make sure that there's always an alternate I can get to that is within my capability and within my aircraft's (Cat 1) capabilities.

Similarly, I would expect EIR pilots to make sure that there's always an alternate they can get to that is within their capability -- it's just that in their case that means VMC below the MSA rather than Cat 1.

[Fuji Abound]

I essentially agree with BOOKWORM, but if there is a problem with the EIR it is the inexperienced pilot who creates a problem for himself. Have we all done that? The theory is fine, but the pilot mistakenly thinks he can get through a line of en route CBs, which even for the most experienced pilot can develop more quickly than the experienced pilot might predict, then shows some sound reasoning and diverts, but had not planned all his en route diversion that well and ends up with a diversion where the weather is more marginal than it should be, now without the best reserves of fuel. It happens, it shouldn't. The difference with the IMCr (or IR) holder is they are now better equipped to deal with the "unexpected" approach.

So having reflected at much length on the EIR it is better than nothing, in fact it is a lot better than nothing, in fact I am not opposed to it, but it is not perfect.

All that said I cant say I understand exactly how it will work. I have read the speculation, but that is presumably all it is.

[englishal]

I think the EIR is going to be a very useful rating for me. It will mean the end of airspace as we know it :E which is great.

I do think though that it should include precision approach capability, ie. just an ILS or GPS LPV approach, so that you could fly into any airport with an ILS or LPV GPS approach. The reason for this is as per Fuji's argument, and to have no approach capability is madness. For myself, it doesn't worry me, I'd just shoot the approach anyway, but if a newly minted EIR pilot hasn't ever shot an approach and then has to do it in anger?!?!

By all means call this an IR(R) in Euroland to differentiate between a "Full IR" and a non full IR. Current UK IR(R) holders could add this rating with no formality - or with an airways flight with FE - and new IR(R) candidates could add by test.

Hey what do you know, I have just solved three problems. 1) Current IMCr holders will be grandfathered, 2) There will be life after the IMCr and 3)This will satisfy those in need of a "cheap", easily achievable IR without all the overhead of the full IR.....

(PS I don't want to fly NDB approaches, and if I did fly one it would be using GPS anyway!)...

[S-Works]

While we are at it Al, we could stick some wings on pigs as well.......

[bookworm]

I think the EIR is going to be a very useful rating for me.

What on earth do you need an EIR for? You'll just convert your FAA IR.

[englishal]

So long as the conversion process doesn't include months of ground study, cost thousands, and I can do the flying in my own aeroplane ;) Considering I fly an N reg, really this whole business doesn't actually give me anything that I don't already have.

[Ellemeet]

@englishal

you will do it in your Commander.

You will do a refresher for your theory and some specific eu items which should not take more than a good weekend. You will do some refresher flight with an FI so as to refresh ndb and vor approaches, holdings and intercepting odd radials.

and you will do your oral and your skilltest. It should not be very complicated. It will be a good and valuable refresher.

[Pace]

That makes you wonder if the best way forward now for many would be to get an FAA IR and convert?

Pace

[englishal]

Sounds good to me!

[Ellemeet]

@pace

that is still the best way forward with one tiny problem.

You need to get you FAA IR .. and then you need to fly 50hrs plus on a ifr flight plan as pic. The window for doing the latter in the eu is now less than a year. After april 2014 this would be impossible as you would need to have a EASA ir.

And to just fly 50hrs ifr in the us after passing is definitely interesting but also a bit crazy.

But if you have the opportunity and you have an n-reg nearby ..go for it!

[peterh337]

Nobody currently knows whether the FAA IR to CBM IR conversion route will require

- 50hrs IFR time
- 50hrs instrument time
- 25hrs instrument time

All three have been reported as discussed behind closed doors.

The original proposal was 100hrs instrument time! This is all done to stop hordes of ATPL cadets doing the FAA CPL/IR and then converting.

Technically, the 1st could be logged by a plain PPL flying IAW IFR in UK VMC ;)

The other two will strongly encourage copious time in G-BIRO ;)

I suggest nobody bases their planning on something vague and then gets shafted.

[flybymike]

Technically, the 1st could be logged by a plain PPL flying IAW IFR in UK VMC
I may be wrong but I don't think this is possible any more (ever since the UK night IFR requirement was dropped) and IFR now requires an IR/IMC/IRR rating.
May still be possible with Old CAA UK lifetime PPL though?

[Level Attitude]

Technically, the 1st could be logged by a plain PPL flying IAW IFR in UK VMC
Not any more. PPL does not allow IFR Flight. An IR of some description is
now required.
(IFR flights completed, legally, before 17 Sept 2012 would, however, count)

NB: Just noticed FBM has already answered

[Ellemeet]

@peter

I disagree.

With the latest proposal the requirement was changed from 100hrs actual instrument time to 50hrs flight under ifr rules. I have a confirmation from EASA on this.

The discussion is wether this should be reduced even further or not to 25 hours. At that time this was the best compromise.

It is clear that the working committee at EASA understands that the original requirement was totally out of line. The main reason against a further reduction has nothing to do with EASA's view against the FAA IR but .. this is law towards ICAO IR .. not FAA IR .. in other words .. also licenses from BoRaBora or .. (figure of speech). and that is where some people were concerned.

So the maximum is this present requirement which is very much in reach of anyone who has an ir.

[BEagle]

With the latest proposal the requirement was changed from 100hrs actual instrument time to 50hrs flight under ifr rules. I have a confirmation from EASA on this.

Correct. In response to the comments I raised on behalf of IAOPA Europe, EASA responded:

The Agency and the Review Group experts agree with IAOPA (Europe) and have amended 8(b) to allow an applicant to demonstrate adequate theoretical knowledge to an examiner during the skills test. The Agency and the group also agreed to amend 8(d) by reducing the minimum experience required to 50 hours flight time under IFR as PIC on aeroplanes.

[Pace]

Beagle

On a personal note thanks for all your efforts and dedication in trying to bring some sense into all this with EASA

Pace