Latest EASA PPL IR looking good especially for FAA IR holders

[Pace]

EASA opinion on new rules for the Instrument Rating

EASA has published its final opinion on 'Qualifications for flying in Instrument Meteorological Conditions (IMC)' - the new rules intended to make the instrument rating more accessible for private pilots. The opinion does not solve the UK concerns over the IMC rating, but it does contain a number of significant proposals that will make it more realistic for a private pilot to obtain an IFR rating.

This includes significant reductions in the theoretical knowledge requirements, a competency-based approach which will accommodate pilots holding an instrument rating issued outside Europe and an enroute instrument rating (EIR) with limited privileges, but which can serve as a stepping stone towards the full IR.

The theoretical knowledge requirements today involves a whole range of subjects not relevant for a PPL pilot who wants to fly IFR in Europe in a light piston-engine aircraft and have been an unnecessarily big obstacle. The proposal is now to remove the advanced and high-performance subjects from the curriculum and cut down the required ground-school hours from 200 to 80 hours, most of which can be done as distance learning, so that the number of classroom hours requiring physical presence is limited to eight hours. Remaining subjects can be taken later if the pilot wants to transition to a high-performance aircraft. This makes the theoretical knowledge much more accessible for the typical PPL who has a full-time job.

For holders of an instrument rating issued outside Europe there is also good news. Both the theoretical knowledge requirements and the practical skills will be assessed during the skill test, so for a pilot with 50 hours of IFR experience as PIC and for instance holding an FAA IR, the EASA IR requires only skill test.

This is particularly important considering the new FCL requirements that a pilot based in Europe and flying for instance an N-registered aircraft must in the future have a full EASA FCL certificate and IR rating to fly IFR in Europe.
The last major new proposal is for en enroute instrument rating (EIR) which will be a sub-ICAO rating limited to the en-route phase of the flight, with no approach privileges. Jacob Pedersen of AOPA Denmark says: "The EIR will serve as a stepping stone towards the full IR and can also prove useful where airspace is not allowing VFR operations and in some weather conditions. The EIR will hopefully inspire more pilots to receive instrument training, but with the lack of approach privileges it should not be considered as anything close to a full instrument rating - something that is also reflected in the requirement for just 15 hours of IFR flight training."

Finally the EASA opinion proposes to remove the English language proficency requirement for the IR in general and also introduces a daylight-only variant so pilots not holding a night-qualification can still get an IR for day-only operations.

The full EASA opinion can be found at EASA - Opinions The proposal now lies with the European Commission and must go through the comitology process before it becomes law.

While the proposals represent an improvement for much of Europe, they are seen as a catastrophe in Britain, where the loss of the FAA IR for what are considered to be chauvinistic reasons, not related to safety, and the killing of the UK IMC rating, have made flying more difficult, more expensive and more dangerous.


Pace

[2high2fastagain]

I also saw this and have written to my MP and the Transport Secretary. I suggest everyone else does the same.

UK GA does need a consistent position to project. In my opinion, the best answer is to retain the IMC in the UK indefinitely and introduce the accessible full Euro IR asap. As far as the en-route (EIR) is concerned, I simply can't see how anyone could possibly think this is a good idea. Are we all expected to have divine powers that will cause the clouds to disappear when we want to land (and if so, where is that mandated in Part-FCL and will we also require classroom training for it and another exam)?

Time to act.

[421C]

Are we all expected to have divine powers that will cause the clouds to
disappear when we want to land
Err no, I think we are meant to use a "TAF" and plan accordingly.

[BackPacker]

I'm a UK-issued PPL holder but not based in the UK, nor the holder of an IMC rating, so I consider this an enormous improvement over the current situation.

Is there any timeframe available when this will be implemented and available?

[peterh337]

Apart from the proposal for the CBM IR to be available without a colour vision test pass (presumably), and that is good news, though presumably it will still not be available to anybody with one bad ear, is there actually anything new in this?

The CBM IR has still to go via Comitology, which has been the situation for many months now...

[Pace]

Peter

What I have and so far it appears accurate is that the PPL side of things will be complete by October. Then they will move to working out commercial licences.
Looking at it the best route is to get an PPL FAA IR now and when the time comes convert it with a simple flight test and oral exam.
As for commercial licences ???

Pace

[mad_jock]

An EASA full IR doesn't require a colour safe pass.

They have moved the colour safe to the CPL requirements.

[2high2fastagain]

Quote:

Are we all expected to have divine powers that will cause the clouds to
disappear when we want to land
Err no, I think we are meant to use a "TAF" and plan accordingly.


Good luck mate. I hope the weather doesn't change on you in flight. I've got an IMCr in case that happens to me.

[Pace]

They have moved the colour safe to the CPL requirements.

Mad Jock

Are we talking about knickers here? I presume it more important to have color safe for commercial pilots rather than PPLs?
Maybe color safe for first solo?

Pace

[mad_jock]

I know its bollocks.

They are admitting now that you can be a bit colour blind and still not crash.

To be honest I do know commercial pilots that are completely colour blind which developed with age (which is not meant to happen) who don't crash either. And one that knows all the ishra plates and the order, who he got off his mates going before him and got through outside Europe but flys in regularly. He can see the difference though in the PAPI's

So the new word in the regs is colour safe. And it used to be a requirement for the IR and now they have deemed it a requirement to fly commercially. It seems they don't want any day only commercial pilots which is going to screw up some instructors as you have to hold the license you are teaching for.

There is a huge thread in the medical forum about it all.

[Pace]

MJ

I will tell you my story ;) 7 years ago went for my medical and the AME stated that i needed glasses for short work.
he refused to issue my medical and I trundled off the 50 miles back to my hometown and an urgent appointment with the local Specsav+rs.
Now being a funny individual I requested the glasses look more like sunglasses and had them tinted.
£300 worse off I trundled the 50 miles back to be told I had to do the whole vision thing sporting my new glasses.
All fine with the vision thing but he wanted the color tests doing again!
I could not read a thing or see any correct numerals :{
What had happened to my color vision.
Then it dawned on me while he was saying I needed other tests! For instance put on yellow glasses and the best color vision guy in the world looking at blue will see green. Ok my glasses were brown!
I explained this and argued that every pilot wearing sunglasses which most do are color blind! I argued that in which case the wearing of sunglasses by pilots should be banned!!!
I was banished yet again to buy a set of clear glasses.
Last medical 1 month ago the new AME removed the "must wear corrective glasses"! completely as I passed the vision test with flying colors without glasses :ugh:

Pace

[421C]

Good luck mate. I hope the weather doesn't change on you in flight. I've got an
IMCr in case that happens to me.

So the IMCr stops the weather ever changing below minima?
What's the difference between depending on a TAF for a VFR flight, depending on a TAF for a EIR flight, depending on a TAF for a IFR flight by an IMCr holder or an IR holder or a CAT II/III transport aircraft for that matter.

Aren't the issues the same
- the TAF is a forecast
- you use your judgement based on the forecasts, minima, available alternates, fuel, currency etc etc to plan a reasonable and legal course of action

Why is it a more dire risk for an EIR holder to be surprised by Dest and Alternate forecast ceilings above 1000' to be below, than for an IMCr holder to risk ceilings forecast above minima to be below? If anything, I'd rather be an EIR holder needing (gasp) an SRA (or other approach I have trained for in an EIR course for emergency use) because my 1500' ceiling ended up being 800' than and IMCr holder having to do an approach that would be below mins for a 2 crew CAT operation in an emergency?

[mad_jock]

the two old boys that are completely colour blind it makes not one bit of difference to them even though they can't tell the difference in the PAPI's.

Some AME's are proper gits when it comes to some stuff and your stuffed if they get there teeth in.

Mine is dead against glasses until you really really need them as it apparently makes matters worse very quickly. to be honest though he could do with changing his testing board as I know the bottom line is ECONMPHFZLJ

Mind you he has had a few pilots die a couple of weeks after seeing him over the years so he is rather sceptical about the whole medical business.

[Genghis the Engineer]

Thanks for flagging this Pace, which is really clear and helpful - and well done all who have been pushing EASA to bring some common sense into this.

For anybody who wants the original EASA docs, they're here...

PRESS RELEASE - EASA publishes new rules for pilots flying in Instrument Meteorological Conditions (http://www.easa.europa.eu/communications/press-releases/EASA-press-release.php?id=117)

G

[172driver]

Sounds like great news to me! Makes the IR much more accessible, which can only be a good thing.

[Genghis the Engineer]

Having now read the full official document, I see as an IMC holder planning on an IR that the critical number is my "PiC IFR" time - thank goodness my logbook is in Excel, as that thankfully was quite an easy new column that I just had it generate for me.

G

[mad_jock]

That is if it gets through the schools will be lobbying hard, it will mean the death of IR ATO's around Europe if it works out cheaper to go through FAA then convert than going through EASA commercial training from the start.

Its the fact that the IR is a rating and not linked to a license type.

There will need to be a method of blocking commercial students looping back and converting the IR onto there PPL then just doing the commercial course.

You can say safety safety all you like but its a multi million pound industry you are killing off.

I can't see it happening to be honest unless you can get a block.

[BackPacker]

it works out cheaper to go through FAA

Does it? The way I read it is that you have to have 50 hours of PIC under IFR, after the issue of your FAA IR, in order to qualify for the conversion route.

I know flying in the US is cheaper, but I don't think 40 hours FAA IR training plus 50 hours hour building under IFR in the US will be cheaper than 40 hours EASA IR training.

What I am missing here, though, is a requirement that training for the IR needs to be done in European airspace, and/or on an EASA Annex I aircraft. That would mean that the US schools that currently already offer training for various EASA licenses and ratings, can now also offer training for the IR. Am I right?

[mad_jock]

It would be because you need to build up to 150 hours anyway before you can start your CPL course. So you have missed out a block anyway by hour building IFR if you would have any sense you would do it at night as well to get night hours. About a 5k plus saving already. IR course is in the 15-18k range.

How much to do a FAA IR and 50 hours spam can time currently in the US? You would also need the MEP and muti engine IR I would have thought.

By doing it the FAA way you will reach 150 hours convert your IR which then gives you 10 hours off the CPL course dropping it to 15 hours. You need 200 hours before you can apply for your CPL.

From the prices of the FL sausage factorys for PPL/MEP/IR and mutli IR I reckon it will undercut the Western European FTO's by 10-15k.

[BackPacker]

Okay, I see. You're looking at the all-inclusive price for a modular ATPL. I was just looking at the IR as a PPL-addon.

[BEagle]

Quote:
They have moved the colour safe to the CPL requirements.

Mad Jock

Are we talking about knickers here?

Or, dare I say it, headsets?

Regarding attempts to use the CbM IR to short circuit the CPL/IR route, note that the additional 'HPA' course will not include credit towards a future IR(A):

A pass in any theoretical knowledge subjects as part of the HPA course will not be credited against meeting future theoretical examination requirements for issue of a CPL(A), IR(A) or ATPL(A).

It's not immediately clear how someone will obtain credit towards a 'normal' CPL/IR or an MPL if they hold a CbM IR.....

[Genghis the Engineer]

For a PPL or CPL who holds either an IMC or a foreign IR however, it looks pretty good.

For a UK/JAR/EASA IMC holder with 30+ hrs PiC/IFR it looks like 5 hours in an FNTP1 and another 5 airborne training, nominal 2 weeks self study, one day in the classroom, written(s) and a skill test.

Assuming, of-course, you can get to test pass standard in those hours, which is always an issue for anybody.

[mad_jock]

This is it Beagle.

As ATPL theory exams trump all others I presume if you hold them that will take care of the theory side of things for all flavours of IR.

The only way I could see it working is if you couldn't hold it on a CPL and it wouldn't count as a pre course requirement for any type rating. The cross over experience was 500 hours IFR or 250 hours IFR on a multi engine or something of that order and held the full set of ATPL theory if you wanted it to go onto a EASA CPL

I don't think the schools will care if there is a definite block on a work round skipping the 55/45 hour IR course.

[AN2 Driver]

Thanks Pace, good to see that this will finally go forward.

Means that I'll probably get my IR back any time within a few months of this becoming law. (Mine lapsed due to a > 7 year hiatus and I'd have to retake the whole current theoretical exam, decided to wait, good by the looks of it).

For those who have a problem with the EIR, I think it needs to be seen in a broader context than most seem to do here. Personally, while I will go for the full one, I find it an extremely useful thing to propose.

Looking at the airspace mess many countries have, not least huge Class A airspaces in the stupidest places, an EIR will allow the holder to fly airways quietly and relaxed rather than dodiging all that red and other marks on a 1:500k map at low altitude. It will do away with the need to do scud running in the Milano and Rome TMA (and other equally useless airspace monstrosities) but allow you to fly at normal flight levels consistend with safety and options in case of emergency.

Flying with an EIR does not mean you HAVE to fly solid IMC all the time, but it gives you the distinct advantage to fly an airways enroute part of your flight, in VMC or within the limits of your airplane in IMC too.

Most of the airplanes available to the average PPL who might want to go that path do not allow "hard" IFR anyhow, in as sofar that they are not FIKI equipped, are single engine. Many of our airports do not have IFR Approaches either. So for many of those people, having the option to fly the enroute part with a pick up and release after departure and before landing, becomes a very viable thing to do.

One question I will want to have addressed is what of the airplane itself. Will it need to be fully IFR equipped for it to be able to fly EIR legs or will the equipment necessary do. As EIR Pilots do not have the authority to fly approaches, it consequently would not need to have (certified) approach aids on board but rather needs enroute navigational equippment up for the task. Probably the answer will be yes, fully IFR certified. But seeing as the facilitating of getting an IR was a distant dream not 2 years ago, one never might stop to wonder.

[mm_flynn]

AN2,

Given the EIR holder is going to fly in the airway system, he needs BRNAV. Which either means e is hard core and has an FM immune KNS80 or he will have something like a G430 which gives pretty much all the approach aids you would want. You then just have left the question of needing a DME and/or ADF for enroute (which I think is going away or has gone away ).

[AN2 Driver]

Yes, that is what would make sense. BRNAV in most probably the form of one GNS430, Mode S XPDR is technically all you need for the purpose, plus the DME/ADF Combo we are so fond of in Europe...

The question however will be what the regulators will prescribe. European rules say, the aircraft has to be IFR equipped AND approved by the authorities before it can fly the normal IFR. Question is, will there be exemptions to that for flights by EIR rated pilots? I guess not, IFR is IFR and that is quite a lot more in Europe.

As it stands any airplane flying IFR needs at least:
- BRNAV device
- 2x COM FM immune (pretty soon with 8.33 enabled )
- 2x NAV of which one with GS
- DME
- ADF
- HSI or other slaved gyro
- 2 axis AP system for single pilot ops.
and the aircraft needs to have "IFR CAT I" written into it's docs.

[Pace]

As ATPL theory exams trump all others I presume if you hold them that will take care of the theory side of things for all flavours of IR.

MJ

Stop being such a miserable old sod :ok: We all know the ATPL theory exams are mostly a load of irrelevant junk!!!
Oh well they move onto commercial licences in October and when I get my exchange EASA ATP through the post as a direct swap via parcel force you really will be doing this :)

:ugh: :{ :ugh: :{ :E :ok:

Pace

[mad_jock]

Dream on mate until there is a direct swap with no exams to be passed the theory will still be required unless the FAA budge on that which they have no real reason to do so.

I don't actually know that because I have actually used a fair bit of mine. And every year or new area of operation I use a bit more of them.

[Pace]

MJ

Only an affectionate tease :ok: If they do not give me a sensible conversion You will find me under the arches with a begging hat and and a card stating ex FAA ATP unable to work because of a load of Burocratic and protectionist NONSENSE" Please give 50 p so the poor old sod and ex Biz Jet Captain can get a cup of tea :E

Pace

[421C]

It's not immediately clear how someone will obtain credit towards a 'normal'
CPL/IR or an MPL if they hold a CbM IR.....


It's not clear because there is nothing to clarify IMHO. An IR(A) is an IR(A) whether it's obtained through a Modular route, and Integrated route or a Competence-based Modular route. It should be crystal clear that the "CB IR" is a new training route to the IR(A) not a new qualification. Please let's not let this myth slip into the psyche that there is a new IR. It's a competence-based training method for the existing IR.

You can have all the privileges of a CPL/IR having trained through the CB route. The only subtle distinction is that to get an IR(H) you need the HPA exam because the new TK for the CB IR omits certain learning objectives considered relevant.

For multi-pilot aircraft or an ATPL you obviously need the ATPL TK.



The only way I could see it working is if you couldn't hold it on a CPL and
it wouldn't count as a pre course requirement for any type rating. The cross
over experience was 500 hours IFR or 250 hours IFR on a multi engine or
something of that order and held the full set of ATPL theory if you wanted it to
go onto a EASA CPL

I don't think the schools will care if there is a
definite block on a work round skipping the 55/45 hour IR course.
Fortunately, EASA FCL is not primarily about assuring ATOs of artificially long courses. Competence-based training is the principle that the training fits the candidate's needs, not one size fits all. You absolutely can hold a CPL/IR with the IR trained by the CB method.

Having said that, the difference between the CB IR and traditional Modular IR is 15hrs FNPT2 time, so £2-3k in principle. However, I would imagine most ab-initio candidates seeking a "frozen" ATPL would be better off with the structured approach and full-time training model of a Modular IR. The benefit of the Competence-based is mainly for people who either want to accumulate experience in steps over time, train ad hoc on their own aircraft or who simply can't take 6 weeks off for a Modular course (try asking an ATO if they can fit an IR into you work schedule, mainly training on weekends and on your own aircraft and you will get blank stares from most). Having said that, it's quite likely that one could end up spending more on the CB route in many scenarios (certainly on a fully allocated cost basis if flying one's own aircraft).

It's also analogous to the present Modular vs Integrated. Why doesn't Modular kill-off Integrated, given how much more expensive Integrated is? There are candidates who perceive that Integrated suits their needs better as a training structure and that it will serve their career prospects better. The same view may drive ab-initio pro pilot candidates away from the CB IR. On the other hand, if the airline industry and the trainee pilot community find the CB route is successful, then that's a good thing surely?

The CB IR makes little difference to the attractions of the FAA route for an ab-initio candidate IMHO. The old conversion needed only 10hrs of FNPT2 and 5hrs aircraft training, the difference in the new conversion is that it needs 50hrs PIC time under IFR but conceptually no minimum training. But everyone is going to need some training before an IR Skills Test.

brgds
421C

[BEagle]

The only subtle distinction is that to get an IR(H) you need the HPA exam because the new TK for the CB IR omits certain learning objectives considered relevant.

No. The CbM IR is not available to helicopter pilots.

In order to extend the privileges of the CbM IR to include other types or classes of aeroplanes under IFR, the CbM IR holder will be required to pass the HPA examination.

This is not the case with the current IR(A), but is a result of the 40% reduction in theoretical knowledge requirements for the CbM IR.

Whether commercial schools will embrace the CbM IR for its prospective airline pilots, particularly if any IR training is outsourced to freelance IRIs, remains to be seen.

[mad_jock]

50p! I will go to a haggis supper covered in curry sauce for you mate.

[peterh337]

While I agree with 421C on the technicalities, I fully expect the FTO business to sabotage the CBM IR in every way they can, because about 30hrs of the required instrument time (yeah I know they call it "IFR time" but a plain PPL could log time flown IAW IFR) can be done with freelance instructors, and any ATPL cadet who is clued up (most aren't but some will be) is going to spot the cost saving opportunity.

People don't change.

[BackPacker]

a plain PPL could log time flown IAW IFR

Not anymore under EASA-SERA (or -NCO, or -OPS, or -FCL), as I understand. You can only file and fly IFR if you are properly rated, in an IFR certified aircraft and so forth.

[Pace]

Peter

I thought that due to the high costs over here most of the large remaining training organisations sub contract out to USA organisations who do both FAA and JAA anyway ?

Pace

[Fostex]

You cannot do a JAA/EASA IR in the USA, only in a JAR/EASA state. You can however do a JAR/EASE PPL/CPL out in the USA. Most schools who sub-contract out the training to the US do the PPL/CPL over there along with perhaps an FAA IR and then do the JAR/EASA IR back in Euro-land.

[Pace]

ou cannot do a JAA/EASA IR in the USA, only in a JAR/EASA state. You can however do a JAR/EASE PPL/CPL out in the USA. Most schools who sub-contract out the training to the US do the PPL/CPL over there along with perhaps an FAA IR and then do the JAR/EASA IR back in Euro-land.

Fostex

So with the new IR situation they could do the lot there adding the EASA CPL but with an FAA IR and purely convert the IR with a flight test and oral on return?

Pace

[BEagle]

So with the new IR situation they could do the lot there adding the EASA CPL but with an FAA IR and purely convert the IR with a flight test and oral on return?

Only after having first achieved 50 hrs IFR time as PIC on aeroplanes. And that means real PIC time, not American time!

[peterh337]

And that means real PIC time, not American time!No prejudice here, clearly.

Not anymore under EASA-SERA

Yes but it could be past logging.

[BackPacker]

Yes but it could be past logging.

Mmm. I wonder if that's going to fly (pun intended). EASA have clearly defined what the criteria for conversion are, what IFR really means and what the requirements for IFR are.

If you have logged "I've got a PPL but no IR, am outside CAS, in VMC but fly according to the quadrantal rule for IFR, am above the MSA, and am looking at my instruments" IFR time, my gut feeling tells me that that is not acceptable both to the letter and the intent of the legislation.

What's more interesting, is whether IFR flight as an IMCR holder will count.

[AdamFrisch]

Hang on - wasn't EASA supposed to ruin aviation with their Stalinistic bureaucracy?......:}:E

[englishal]

but with an FAA IR and purely convert the IR with a flight test and oral on return?
Could that not be done in the USA too? I know certain situations where a US based school cannot examine for an INITIAL IR abroad, or for that matter a PPL, so what some schools do if have a UK examiner resident, then you do the FAA PPL, and as you are now CONVERTING an existing PPL to a (then) JAA one, you could do the conversion in the USA. I wonder if this might become possible for the IR under EASA?!

IFR time is a stupid concept which no one logs. IFR can be anything really, bimbling along in class G "In accordance with IFR" or on an "IFR flight plan with ATC directed routing". However one thing which is undeniable is "Actual instrument time" or "Simulated Instrument Time" and which everyone logs. I have done many IFR trips in Gin Clear weather purely because it is a lot easier to negotiate airspace (i.e. you don't have to). I have no idea how many hours "IFR flight" I have done at all!

Speaking of sabotage in the UK....When I did my JAA PPL in the USA in 2000, I came back to the UK and did a check out at a large flying club. On the taxi out, chatting with the old boy FI, he asked where I learned to fly. When I said the USA his snooty response was "oh we don't like those here". I thought Fjsdfwk you mate, and actually at the end of the check out he did admit that "I flew very well".

Luckily the second FI I flew with learned to fly in South Africa, so he didn't have an attitude.

[BackPacker]

IFR time is a stupid concept which no one logs. IFR can be anything really, bimbling along in class G "In accordance with IFR" or on an "IFR flight plan with ATC directed routing".

That was only true in the UK. EASA have now clearly defined what "IFR" and "IFR flight time" really is, what the requirements are and how it should be logged. In fact, the explanatory note that accompanies the NPA goes into this issue specifically.

http://easa.europa.eu/agency-measures/docs/opinions/2013/03/Opinion%2003-2013%20-%20Explanatory%20Note.pdf Para 2.4.2.9.

Here's the draft regulation which details the conversion rules (A.2.IR(A))

8. Applicants for the competency-based modular IR(A) holding a Part-FCL PPL or
CPL and a valid IR(A) issued in compliance with the requirements of Annex 1 to the
Chicago Convention by a third country may be credited in full towards the training
course mentioned in 4 above. In order to be issued the IR(A), the applicant shall:
(a) successfully complete the skill test for the IR(A) in accordance with Appendix
7;
(b) demonstrate to the examiner during the skill test that he/she has acquired an
adequate level of theoretical knowledge of air law, meteorology and flight
planning and performance (IR); and
(c) have a minimum experience of at least 50 hours of flight time under IFR as
PIC on aeroplanes.

So what you need is 50 hours "flight time under IFR".

EASA-FCL.010:

‘Flight time under Instrument Flight Rules (IFR)’ means all flight time during which the aircraft is being operated under the Instrument Flight Rules.

EASA-FCL.600 as it will be amended by this new regulation:

FCL.600 IR — General
Except as provided in FCL.825, Operations under IFR on an aeroplane, helicopter, airship or powered-lift aircraft shall only be conducted by holders of a PPL, CPL, MPL and ATPL with an IR appropriate to the category of aircraft or when undergoing skill testing or dual instruction.

(FCL.825 basically says the same thing, but applies to EIR holders.)

So regardless of how many hours you have logged as "IFR" in your logbook in the past, for the purpose of the conversion you can only count those hours where you were the PIC of an airplane that was operated under IFR rules, and you held an IR.

That doesn't make those "UK-style IFR in VMC outside CAS" logging entries retroactively wrong or illegal, but just means you cannot use them as credit towards the license conversion.

At least, that's the way I see things. It looks pretty watertight to me.

[englishal]

That doesn't make those "UK-style IFR in VMC outside CAS" logging entries retroactively wrong or illegal, but just means you cannot use them as credit towards the license conversion.
I don't see that. For example, I did my FAA IR when I had 125 (+40) hrs. Since that time I have flown numerous flights IFR on an IFR flight plan, but also I have bimbled around in UK Class G IAW IFR....Therefore surely that Bimbling can count towards the hrs rqd for a conversion if I so wished?

[BackPacker]

If you had a valid IR while bimbling, then I don't see why not.

My comment is directed at non-IR holders who could fly IFR in the UK, as long as they maintained VMC, remained OCAS and complied with a few other rules. In fact, that kind of IFR was the only way you could fly at night if you did not have an IR or IMC.

As EASA-FCL now clearly states that you can only operate under IFR if you have an IR or EIR, I can't imagine they intend to let those UK-style non-IR IFR hours count towards license (*) conversion.

(*) Spelled as "license" since you are converting a US license to an EASA licence.:zzz:

[Ellemeet]

flight time under ifr only starts counting after you ave got your ir.

[peterh337]

flight time under ifr only starts counting after you ave got your ir.That's obviously not the case for UK IMCR holders, but I think there is little point in guessing, since the whole thing has not even been through comitology and could be modified heavily, or even chopped completely.

And, ultimately, the acceptance of previous training will be at the hands of the FTO, who will have zero commercial incentive to accept any of it. So any ambiguity will be resolved in their favour ;)

[421C]

And, ultimately, the acceptance of previous training will be at the hands of the FTO, who will have zero commercial incentive to accept any of it. So any ambiguity will be resolved in their favour http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/wink2.gif


There is a precedent - the conversion of ICAO IRs to JAA ones, where in the UK the previous training was credited for all but 10hrs FNPT2 and 5hrs aircraft training. Very analogous to the new model where all but 10hrs can in principle be done outside an ATO.

In my experience of speaking to a good number of people (and in my personal experience) doing the FAA to JAA conversion, I never met a single one who felt the ATO had required them to do any more than the minimum hours needed to be ready for the test.

I know of one exception (;)) who feels the ATOs are a bit of a scam, using all sorts of tricks, like the 170A, to get people to spend more money on training they don't need. But that is an unusual exception and otherwise I think people will be able to depend on ATOs judging competence fairly.

[Fuji Abound]

I have never met a single one

I know of one exception

Is that nearly unique. ;)

[pmh1234]

An EASA full IR doesn't require a colour safe pass.

They have moved the colour safe to the CPL requirements.

Since when?
I know this is in the new proposal, but it is new to me that it is already like that.
I'm restricted day only being color unsafe and I have asked CAA several times during the last years if I could train for an IR rating and have been denied every time.

[englishal]

I know of one exception () who feels the ATOs are a bit of a scam,
(this was a few years ago....)

£200 + VAT per hr for a FNPT2, £350+VAT per hr for a Duchess, £150+VAT per hr for instructor (it is IR training after all!), all to fly between Bournemouth, Yeovil, Southampton and Alderney! Oh and don't forget the 170A, plus the Duchess, so add another grand. Don't forget the CAA test fee either, though of course this is nothing to do with the ATO.

This is the situation my buddy encountered when he converted the FAA to JAA IR. He did it in 15 hrs (10 FNPT2) + 2ish hrs for the test, and it cost him near on 10 grand. All this for a bit of paper even though he was already perfectly well qualified to fly IFR and had done for a while under the N reg. this doesn't include the ground school either which adds another grand plus significant time input. Plus accommodation too, the school only flew 1 hr per day with him so he sat twiddling his thumbs in rented accommodation for the rest of the time.

I guess this is why FAA IR holders object to "conversions" with an ATO as it essentially means we sign a cheque for 10 grand for a new bit of laser printed paper. Conversely in the USA, you employ a freelance CFII and pay him or her directly if you so wish and fly as much or as little as you wish. Oh yea, and you don't have to wear shirt with stripes and black trousers and you don't get a bollocking for walking out to the aircraft with a baseball cap on!

Interestingly I flew a flight sim in the USA which was equivalent to an FNPT 2. In fact it WAS an FNPT 2 under a different authority. Software was EXACTLY the same, it could have been an FNPT 2 with the right certification, and it was only $95 per hour.

[mad_jock]

it does seem to be the south coast that rapes the punters

[421C]

This is the situation my buddy encountered when he converted the FAA to JAA IR. He did it in 15 hrs (10 FNPT2) + 2ish hrs for the test,.

Thanks, you support my point. Your friend did it in minimum hours.
That was my point, the ATO did not scam him for unnecessary training.

Flying is expensive in the UK. I am not defending that, although I tend to think anyone who thinks they can run an ATO with lower costs is welcome to try. It's a business I would not touch with a barge pole. As I understand it, no-one is forced to go to an ATO and they do publish their prices. There is a difference between a reasonably competitive market which ends up with a high price point and a scam.

The high cost of training can either be
a) because the ATOs are a secret money-making machine, lavishing returns on employees and owners through their scammily-high pricing
or
b) the ATOs costs are high because of the perfect storm of UK circumstances of provincial airports that charge £100 for a light twin approach, fuel at £2/l, CAA approval charges etc etc etc

I have a view that it's b. But anyone convinced it's "a" should surely consider going into the ATO business?

[421C]

it does seem to be the south coast that rapes the punters
I see you are based in Aberdeen. I am on the South Coast but fly to Scotland a few times a year, went to Aberdeen a few weeks ago. The avgas pricing in Scotland is the most eye-watering I have seen anywhere in the world. Try the South Coast for that! Flying in Scotland is great but landing at Aberdeen with handling for a light twin 1 crew no pax 4hr stay came to a total of £300....

[peterh337]

Of course the 170A "flight test" is a moneymaking scam, because by definition you are not going forward for the 170A until you are ready for the real IR test, so this is just another way to get an extra £1k or so from the average ATPL punter who is ready for the IRT and doesn't know any better.

And since there are no set standards for the 170A, the FTO can just fail you, and get another £1k. The one I had was a complete farce, with the examiner not liking power checks with tailwind, not liking my perfectly reasonable choice of alternate, etc.

However recent changes mean the FTO is no longer obliged to give you the 170A course completion certificate upon completion of the approved course (which then enabled you to book the IRT with the CAA directly) so the old scam has been formalised in favour of the industry.

When everything has been said and done, gigabytes of bandwidth used on the internet talking about stuff, very little actually changes in reality because the people are the same and their commercial motivations are the same.

[mad_jock]

I was talking about flying schools.

And there is very good reason why Aberdeen is expensive. They don't want GA there. So NATS fire on a navigation charge, Landing fee through the roof and mandatory handling as well.

Just the same as MAN,LGW,STN take your pick of other international airports in the south that everyone avoids in a SEP.

If you had flown to Inch or Dundee you would have been fine.

[421C]

The one I had was a complete farce I did say with one exception. Many people do the training (full or conversion) in minimum hours so there is no scope for the 170A to be a scam, since it occupies training hours that would otherwise be required.

However recent changes mean the FTO is no longer obliged to give you the 170A
course completion certificate upon completion of the approved course (which then
enabled you to book the IRT with the CAA directly) so the old scam has been
formalised in favour of the industry.

When everything has been said and
done, gigabytes of bandwidth used on the internet talking about stuff, very
little actually changes in reality because the people are the same and their
commercial motivations are the same.

But the change is a very meaningful one. There is no longer a requirement (or perception of a requirement) for a 170A. Yes, you need a course completion certificate. You need the equivalent for just about any qualification - eg. the endorsement from an FAA CFI before you take a test.

[BillieBob]

Yes, you need a course completion certificate. Not quite, you need a recommendation for test. It may seem like a fine distinction but having completed the approved course does not necessarily mean that a candidate is ready for the test.

[peterh337]

I did say with one exceptionNot so; an IR instructor I know who used to be a 170A authorised examiner for a well known southern UK FTO tells me about 25% of the 170A flight tests they did were in his view scams.

And a lot of the punters took 80-100hrs to do their ME IRs (min time is 55hrs).

Yes, he went along with it. One needs the job...

An often expressed sentiment in the trade is that the 170A flight test, which has no set standard so the FTO can repeat it several times, having the punter over a barrel especially at such a late stage in his IR training, has been used to make the FTO's first time IR pass rates (which are published) look good. What isn't published of course is the # of hours they took or how much money they spent.

It may be true that a lot of FAA PPL/IR holders did their JAA IR in the minimum time of 15hrs but that's because they have a lot of instrument experience.

Not quite, you need a recommendation for testWhat exactly does that mean in reality? Specifically, is the option to book the IRT direct with the CAA now gone?

I recall reading a CAA document, about a year ago, which basically said that the option to use a 170A examiner from a different FTO is being removed. It used to live here (http://www.caa.co.uk/docs/620/Revised%20pdf%201%20March%2012CAA4459_EASA_quickguide_emaile r.pdf)... I thought this was an odd move, especially in view of Cabair's then very recent bankrupcy and the number of nearly-done-CPL/IRs who were left hanging by their goolies and looking at spending some thousands re-doing some training which they had already done.

[mad_jock]

Since when?

Last year when EASA FCL came in.

[Richard Tamir]

I read your message and the ones below, and I am truly stunned. No one has expressed the thought that the entire regulatory scheme is unreasonable and should be rejected. (For an example of a well-reasoned rejection, see EU parliamentarians' letter from 2010 at https://www.pilotundflugzeug.de/artikel/2010-10-07/FAA_and_Europe_Safety_Record.) The bureaucrats first raised an outrageous proposal of regressive laws, you objected - and they revised it downward to something that is only half as outrageous. And now you all seem appeased.

The entire scheme should be rejected, but it's gone so far that it seems impossible. There is no need for these laws. They cause inconvenience and extra expense for all GA pilots in Europe, and basically make it impossible for the US pilot to live in Europe with an N-reg aircraft. The simple question: WHY? and again, WHY? Read the 4 MEPs' letter at the URL above: petty bureaucracy is the reason, and these laws should be repealed. It's time (maybe past time) for a "redress of grievances".

Or are you all happy now with the 50%-outrageous proposal?

EXCERPTS FROM THE 2010 LETTER BY 4 MEPs RE EASA PROPOSALS:

The common european JAR-system of licenses, in place now for 10 years, has failed to even come close to the US-system in terms of safety delivered for General Aviation.

The main reasons for Europe’s dismal safety-record are not higher costs or ineptness of the actors, but mostly bureaucratic barriers to advanced pilot qualifications and continuative training.

EASA is now proposing to fight this very problem with yet more bureaucracy. We do not believe this to be successful….

In the interest of safety we therefor call on EASA to:
1. Short-Term: Immediately lower the administrative barriers for private pilot instrument qualification …
o Permitting training – at least for the instrument rating – in any properly certified aircraft, irrespective of where it’s registered or owned.

[Pontius Pilatus]

Umm! so if the Met Office get it wrong (which they do) people who hold an EIR are meant to die or break the law. Bit of a Hobson's Choice if you ask me.