The future of EASA Instrument Qualifications

[Timothy]

There is as full an explanation of the new EASA Instrument Qualifications as we can come up with on the PPLIR Website.

Click here (http://www.pplir.org) for the home page, then follow the link to THE FUTURE OF EASA INSTRUMENT QUALIFICATIONS

[Pace]

Timothy

Basically EASA were working on the PPL stuff supposed to be complete by October this year and would then move onto commercial licences.

the most exciting part is conversion of 3rd country IRs to EASA. As most PPL IRs are based around N reg it would appear sensible to put something in place which is attractive making the need to fly N reg in Europe less attractive.
This appears to be the case with the conversion process on the table.
We have to see Whether this runs the course or whether negative influences in Europe put a spanner in the works and damage it.

As for moving onto 3rd country BASA on commercial licences? Thankfully the current regulations have been delayed for a further year.
hopefully something more sensible will come along before the now April 2015 deadline.

This has to happen as GA in Europe is dying through over regulation and high costs a point the training industry lobbying against these changes fail to see!
Ok if they keep lobbying and sadly were successful it would very much be an own Goal on their part so I very much hope these negative forces see the light and Lobby for the benefit of their Industry and not to destroy it as they appear to be doing at present.

Pace

[daxwax]

I may have read this wrong but the implication seems to be that if you have an imc rating you will have an ir(r) which gives you the same privileges as current imc rating. But for no more training you will also be able to get an enroute ir which will allow you to fly in airways across Europe including in the uk.
Have I read this right? If so a current imc holder has pretty much all the priveges of an ir holder in the uk with the only restriction being the ability to fly approaches in mainland Europe.
Correct?
Will there be a training requirement for imc holders to get an enroute ir?

[AN2 Driver]

Pace,

the most exciting part is conversion of 3rd country IRs to EASA. As most PPL IRs are based around N reg it would appear sensible to put something in place which is attractive making the need to fly N reg in Europe less attractive.

The conversion is only part of it, arguably an important one, but the far more significant part is the proposed new IR rating for PPL's which is supposed to get a much reduced and changed theoretical part, similar to the French national IR, which in turn was inspired by the FAA IR. So the idea behind it is to get people to do their training in Europe in the first place rather than going abroad and then converting.

We have to see Whether this runs the course or whether negative influences in Europe put a spanner in the works and damage it.

I am very pessimistic on that issue after seeing that there are even FTO's here (who would profit massively from a realistic IR) who are against it as they feel they can make more money with the 7 subject current test :ugh: Equally, there is a VERY strong lobby against having more "insects" flying IFR in Europe from ATC, who wish GA to go away and not possibly to "intrude" into "their" airspace!! :yuk:

This has to happen as GA in Europe is dying through over regulation and high costs a point the training industry lobbying against these changes fail to see!

They have two vital issues in their argumentation, both of which will eventually kill them. A) The training industry is NOT interested in PPL and PPL/IR students but focus almost 100% on future Multi Crew "Pay to Fly" airline pilots. B) Those who still have a few PPL/IR candidates going, want to milk the few they have, not seeing that they would get a lot more if regulations were changed to encourage much more people to go for the IR.

GA dying is just what a lot of regulators and also some ATC exponents hope for. For them, GA is just a disturbing influence. Not to speak of lots of politicians who have made GA their pet hate as they feel fighting it will bring them votes while offending a negligable quantity of voters.

I never wished so much that I am wrong, but fear that developments will prove me right... Personally, for me the decision on the IR will be the stop or go decision whether to continue flying or to hang it all up. Flying without an IR in Europe is nonsense and a waste of time if you want to do any travelling.

[Pace]

Daxwax

That would appear to be the case! In the UK you would have the approach and landing ability of the IMCR topped with the enroute airway privalages of the IR R enroute so basically an IR with higher minima

Pace

[tmmorris]

One thing I think wasn't clear in the PPLIR paper was: is there a requirement for an IR(R) holder to get the EIR before applying for the IR?

If not, an IMCR holder with plenty of hours IFR (e.g. me!) would only require to complete the 10 hours at an ATO followed by IRT, and the writtens, to be issued with a full IR.

The paper appears to assume you'd want to complete an EIR on the way but I can't see why I would...

Also, what are the renewal requirements of the EIR? I don't go abroad, so if IR(R)+EIR offers everything I want and a biennial renewal, I'd be inclined to stick with it rather than go through the IR upgrade process.

Tim

[bookworm]

I may have read this wrong but the implication seems to be that if you have an imc rating you will have an ir(r) which gives you the same privileges as current imc rating. But for no more training you will also be able to get an enroute ir which will allow you to fly in airways across Europe including in the uk.

No, you have read that wrong. There are no credits towards the EIR for the IMC rating -- you have to do the full 15 hours. There are credits towards the CBM route to the IR, to the extent that an IMC-rated pilot may require as little as 10 hours.

I've seen this complicated EIR+IMC thing mentioned a lot in the discussions on FCL.008 over the years. Keep it simple: if you want to fly approaches and the IMC rating alone doesn't give you what you need, do the IR.

[bookworm]

Also, what are the renewal requirements of the EIR?

It's a prof check every year, like the IR, just without the approaches.

[BEagle]

It's a prof check every year, like the IR, just without the approaches.

Really? What happened to:


(g) Validity, revalidation, and renewal.

(1) An EIR shall be valid for 1 year.

(2) Applicants for the revalidation of an EIR shall:

(i) pass a proficiency check in an aeroplane within a period of 3 months immediately preceding the expiry date of the rating; or

(ii) within 12 months preceding the expiry date of the rating, complete 6 hours as PIC under IFR and a training flight of at least 1 hour with an instructor holding privileges to provide training for the IR(A) or EIR.

(3) For each alternate subsequent revalidation, the holder of the EIR shall pass a proficiency check in accordance with point (g)(2)(i).

[bookworm]

I am very pessimistic on that issue after seeing that there are even FTO's here (who would profit massively from a realistic IR) who are against it as they feel they can make more money with the 7 subject current test Equally, there is a VERY strong lobby against having more "insects" flying IFR in Europe from ATC, who wish GA to go away and not possibly to "intrude" into "their" airspace!!

The chair of FCL.008 was nominated by IAAPS (http://www.iaaps.info/).

I've seen a fair amount written here about both of these "lobbies". I've never seen any evidence that they exist. They didn't comment on the NPA, didn't react to the CRD, and apparently didn't manage to get a single member state to vote against the proposals. When are they going to come crawling out of the woodwork, and what exactly are they going to do to get their way?

[BEagle]

No, you have read that wrong. There are no credits towards the EIR for the IMC rating -- you have to do the full 15 hours. There are credits towards the CBM route to the IR, to the extent that an IMC-rated pilot may require as little as 10 hours.

If the EIR is accepted by the European Parliament, of course credit for pilots granted IFR authorisation in accordance with draft Article 4 (8) will be sought towards the requirements of FCL.825 (c) (2) (i).

[bookworm]

Really? What happened to:

You're right, for revalidation it's a prof check or training flight (with currency) each year, with every other year having to be a prof check. For renewal it is a prof check, but I doubt Tim intended that.

[bookworm]

of course credit for pilots granted IFR authorisation in accordance with draft Article 4 (8) will be sought towards the requirements of FCL.825 (c) (2) (i).

I'm not having a good reading evening, am I? :) Yes, 5 of the 15 hours can be prior instrument instruction.

[Pace]

maybe I am not reading this right but we are not talking about the EIR but the restricted IR which will be issued to IMCR Holders.
Unless something has changed ( would not surprise me in the mess of EASA regulating) An IMCR will be validated onto a EASA licence as an IR restricted to enroute airways only?
With the IMCR in the Uk giving departure approach and instrument landing ability and the EIR( R) giving enroute airway privileges then a UK IMCR will get the best of both world in UK airspace being able to fly airways and fly an instrument approach?

Pace

[BEagle]

maybe I am not reading this right but we are not talking about the EIR but the restricted IR which will be issued to IMCR Holders.
Unless something has changed ( would not surprise me in the mess of EASA regulating) An IMCR will be validated onto a EASA licence as an IR restricted to enroute airways only?


An IMCr included in a non-EASA licence will become an IR(R) upon conversion. The IR(R) is identical to the IMCr in all respects; for example, it is only valid in UK airspace. It has nothing at all to do with the 'EIR'.

If accepted, the EIR will be an EASA-only rating which grants en-route IFR privileges in all classes of airspace within the airspace of 'EASA' nations.

[Pace]

I think the posters question was if he has the enroute airway EASA rating which does not allow the flying of SIDS or STARS or instrument approaches but holds the UK IMCR will that not effectively in the UK only give him the same privates as a full IR albeit with IMCR instrument approach minima ?

Pace

[BEagle]

I think the posters question was if he has the enroute airway EASA rating which does not allow the flying of SIDS or STARS or instrument approaches but holds the UK IMCR will that not effectively in the UK only give him the same privates as a full IR albeit with IMCR instrument approach minima ?



But it was you who posted the question?

Neither the IMCr/IR(R) nor the EIR include privileges to fly a SID/STAR in Class A airspace. The IMCr/IR(R) does not include privileges to fly IFR in Class A airspace and the EIR does not include privileges to fly any SID/STAR - even in VMC.

[mad_jock]

Are the IMC recommended minima now hard minima if using the rating?

Sorry I never instructed for the IMC and got mine off the back of my SPA-IR. I know they were only recommended when I initially got it.

[daxwax]

Thanks - I think I've got it now.

IMCr/IR(r) - allows me to fly IFR in class D and above in the UK and fly approaches and takes me 15 hours plus test (no airways flying)

Separately I can gain an EIR which will allow me to fly in class A airways all over Europe and take me another 15 hour (no approaches in mainland Europe)

Then I can do another ten hours to take me to the minimum for a full IR which will allow me to do all of the above plus fly approaches in mainland Europe.
And for the EIR / Full IR I need to do the new IR ground syllabus.

I realise that the above is overly simplistic and based on minimum hours but is that about the size of it?

[Genghis the Engineer]

A clear and useful document - complements to PPL/IR.

However, it's not saying much very new, and doesn't answer the question I've had for at-least a year now.

When, and where, will either the EIR or CBM IR training become available?

G

[englishal]

No, you have read that wrong. There are no credits towards the EIR for the IMC rating -- you have to do the full 15 hours. There are credits towards the CBM route to the IR, to the extent that an IMC-rated pilot may require as little as 10 hours.
What about conversion to the EIR from ICAO IR?

I have the FAA IR and on top of that IR(R) due to the FAA IR. Obviously flying airways is a piece of cake and I have done hundreds of hours of IFR flights.

For most of my flying, if I had the EIR, IR(R) and FAA IR then I would be more than happy. Most of my flying time is spent in the UK (or USA), rather than Europe and for Europe the biggest advantage would to be able to get back home again - where approaches would be legal. I don't plan to fly approaches at LHR, but even that will become class D one day, so effectively this Combo would give me a full IR in the UK.

The biggest benefit of the EIR is "airspace avoidance". You file your FP and all airspace disappears......it is great stuff. It also means I can get up high in the UK, where out TC'd aircraft really comes into its own.

Of course this is nothing new and nothing that we don't already have by virtue of a N reg and FAA IR, but I would be quite happy with this combo. I am presuming the IR(R) and EIR could be re-validated in one flight?

[BEagle]

Are the IMC recommended minima now hard minima if using the rating?

AOPA proposed this to the CAA several months ago; however, no response has yet been received.

[Genghis the Engineer]

AOPA proposed this to the CAA several months ago; however, no response has yet been received.

AOPA proposed creation of an additional restriction where there wasn't a safety problem? At-least, I'm not aware of any safety problems being caused by IR(R)/IMCR holders flying occasionally to somewhere between IMCR recommended minima, and IR hard minima?

G

[Cathar]

If the EIR is accepted by the European Parliament

It is the Regulation as a whole that is subject to scrutiny by the European Parliament and the Council. They cannot reject the EIR and keep the rest of the Regulation. They can only vote to oppose the adoption of the Regulation in it entirety on certain legal and procedural grounds. If that happens the CBM IR, Article 4(8) and the extension of the derogation for third country licence holders would also be lost. Given that there does not appear to be anyone lobbying against the Regulation it is hard to imagine that it will be rejected.

So far as I am aware, EP scrutiny has lead to only one motion to oppose the adoption of a Commission Regulation giving effect to EASA implementing rules. That was on flight time limitations. The motion was defeated in the vote.

[Pace]

Sorry if some of these IRs are confusing ; ) if we are talking about the enroute IR where you have to drop out of CAS before the STAR and cannot fly an instrument approach then there are a number of safety issues
1 where do you get your destination weather? Fly to Barcelona surrounded by big mountains and the coastal weather given for Barcelona can be very different to your departure from CAS point maybe 25 miles away over heavy terrain!

2 with no instrument landing ability what happens to Joe Bloggs sitting in the sun at 10k who has a problem which means he had to land?
Using the Bsrcelona example I have departed UK in CAVOK Barcelona CAVOK and had the airfields enroute reporting 800 meters overcast 200 what does our intrepid enroute pilot do when forced to land enroute ?

We discussed this before there has to be inbuilt safeguards for those eventualities

Pace

[bookworm]

So far as I am aware, EP scrutiny has lead to only one motion to oppose the adoption of a Commission Regulation giving effect to EASA implementing rules. That was on flight time limitations. The motion was defeated in the vote.

For those interested: motion (http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-%2f%2fEP%2f%2fTEXT%2bMOTION%2bB7-2013-0440%2b0%2bDOC%2bXML%2bV0%2f%2fEN&language=EN), vote (http://www.votewatch.eu/en/technical-requirements-and-administrative-procedures-related-to-air-operations-motion-for-resolution.html), rule of procedure (http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+RULES-EP+20130701+RULE-088+DOC+XML+V0//EN).

And, as Cathar says, I think that's the only such motion on EASA Committee output.

[BEagle]

Genghis the Engineer, the idea is to add credibility to the IR(R), so that it cannot be thought of as an IR-by-stealth by those who would discredit it.

IMCr holders are NOT assessed to IR minima, which require a faster scan and corrections to be applied more promptly closer to the RW for obvious reasons.

Why the UK AIP lists the IMCr minima as 'advisory' is beyond me. In 40+ years of holding IMC approach qualifications, I'd never come across 'advisory' minima before. Fortunately most, if not all, IMCr pilots are not so stupid as to press on below these limits though.

[BackPacker]

Sorry if some of these IRs are confusing ; ) if we are talking about the enroute IR where you have to drop out of CAS before the STAR and cannot fly an instrument approach then there are a number of safety issues

First, I don't think you have to "drop out of CAS". I don't see an inherent restriction or rule that prevents you from cancelling IFR while still inside CAS - unless that CAS happens to be class A. The only real issue is that you have to (be able to) descend into VMC and cancel IFR, before dropping below the MSA/MVA (or whatever it's called). Whether that happens inside or outside CAS is largely irrelevant as far as I can see.

As far as the rest is concerned, yes, I see and share the concern but shouldn't that be solved by normal planning: Making sure the flight can be executed within the privileges of your licence?

You should not commence a VFR-only flight if the forecasted weather is below VMC anywhere on your route, or have a solid plan B.
You should not commence a Y or Z flight if the VFR portion of your flight is below VMC anywhere on that part of your route, or have a solid plan B.
You should not commence an IFR flight if your origin or destination is below IFR minima, or have a solid plan B (which, admittedly, is easier to create and execute than the previous examples).

And with the EIR, the additional consideration is:
You should not commence an EIR flight (a VFR-IFR-VFR flight executed with EIR privileges) if your origin or destination is below VMC, or have a solid plan B.

In all cases you've got to keep up to date with the en-route and destination weather during the flight, to avoid being suckered into a situation where there is no easy or legal way out.

And as for trouble en-route: The exact same would be true for VFR-on-top flights, or for instance SEP flights over water: It becomes a risk management issue. In those cases, I'd prefer doing an EIR flight (high, in the airways, with constant ATC oversight), than doing the equivalent flight as a VFR or VFR-on-top flight. After all, in large parts of Europe, VFR or VFR-on-top means at a significantly lower altitude and with less ATC support compared to an IFR flight. Up high it's all class A (or class C with additional restrictions that for all practical purposes it's class A anyway) so if you want to have safety in altitude, you need an IR or EIR.

I can well imagine that from the point of view of a full-IR rated pilot, the EIR seems to be a step down in a lot of things. But from the point of view of a VFR-only pilot it's a very welcome step up. A step up that can bring additional safety, as long as you use it responsibly.

[englishal]

They may not be assessed to IR minima, but I bet you after 40 years of holding an IMCr a person could fly a stabilised ILS down to minima! Actually flying an ILS to minima, is, should I be so bold as to say, easy in calm non convective conditions, if the approach is stabilised early on - which it should be anyway. This means knowing your aeroplane, the power settings etc..

Still interested to know if ICAO IR holders will be given credit towards the EIR?

[mad_jock]

Fortunately most, if not all, IMCr pilots are not so stupid as to press on below these limits though.

All the ones I know wouldn't think twice about going down to mins. In fact most if not all IMC examiners that I know tested down to IR minimums.

On the bias that if they need it they better know how to do it. There is one that teaches down to 50ft, for when the poo hits the fan and sod the mins.

[IRpilot2006]

AOPA proposed this to the CAA several months ago; however, no response has yet been received.

Not suprising as the cloudbase is pilot interpreted and is unenforceable!

Can't believe AOPA is doing this kind of proposition to the CAA.

[bookworm]

Not suprising as the cloudbase is pilot interpreted and is unenforceable!

BEagle didn't say anything about cloudbase being involved. Just a mandatory higher DH/MDH.

[bookworm]

Still interested to know if ICAO IR holders will be given credit towards the EIR?

FCL.825 (i) Applicants for the EIR, holding a Part-FCL PPL or CPL and a valid IR(A) issued in accordance with the requirements of Annex 1 to the Chicago Convention by a third country, may be credited in full towards the training course requirements mentioned in point (c) . In order to be issued the EIR, the applicant shall:
(1) successfully complete the skill test for the EIR;
(2) by way of derogation from point (d) , demonstrate during the skill test towards the examiner that he/she has acquired an adequate level of theoretical knowledge of air law, meteorology and flight planning and performance (IR);
(3) have a minimum experience of at least 25 hours of flight time under IFR as PIC on aeroplanes.’

But bear in mind:

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 paragraph 4. 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 if you have 50 hours IFR, you might as well convert to the IR.

[Barcli]

Understood - so that's all for someone having an IR(A) then Englishal, not an IR(R) - so give Timmy a ring and do the training and test !!;)

[BEagle]

Can't believe AOPA is doing this kind of proposition to the CAA.

Why? 'Advisory' limits are utterly meaningless and merely give ammunition to IMCr / IR(R) detractors who like to suggest that it is a rating for amateurs who are quite happy to ignore limits.

Or have I flushed out a couple of scud runners?

All the ones I know wouldn't think twice about going down to mins. In fact most if not all IMC examiners that I know tested down to IR minimums.

On the bias that if they need it they better know how to do it. There is one that teaches down to 50ft, for when the poo hits the fan and sod the mins.

Little wonder that the IMCr has such a poor reputation in some quarters...:rolleyes:

[englishal]

Roger that. Might as well do the full IR(A) in that case :ok:

[Pace]

Backpacker

It's just my personal opinion flying 3000 hrs in various piston twins around Europe!
I cannot see a halfway house in instrument flying you either can do it properly or not at all! Too many times I have seen weather go down and IMO you have to have the Skills to fly instrument approaches to minima!
It is so easy to fly on top of broken cloud only to find that the holes close up, the tops rise and the bottoms descend!
There are IMCR pilots who fly out of CAS who are very skillful at what they do but it's usually with years of experience but they can fly instrument approaches often down to IFR minima.
This idea of having a half way house pilot flying on top without the ability to fly a full set of IFR procedures worries me!
Too many times I have seen the weather go pear shaped!
One trip was forecast good VFR from Paris to the coast!
I filed VFR for the short trip to suddenly being on top of scud cloud which went solid! I filed IFR in the air to land at my destination on minima for the airfield!
Ok if a pilot is very self disciplined he won't go but many do!

The IMCR is the minimum proper IFR rating which allows an instrument approach if need be!
The enroute restricted IR is a halfway house which is asking for trouble

Pace

[mad_jock]

Don't know the accident stats for up North aren't to shabby on that front.

And if you decide to go around at Wick because you can't see the ground you really don't have many options about especially if the wind is up from the wrong direction.

And for those of us with a MPA-IR its not really saving us from anything we don't do day in and day out at work.

[BEagle]

Don't know the accident stats for up North aren't to shabby on that front.



In English, please....:confused:

[mad_jock]

We don't have many if any IMC holders crashing off instrument approaches.

The TAF's up North are not the best either as the metoffice computer doesn't seem to know about Sea Haar or the tide. And whatever sorts the predicted cloud base out doesn't always get it right.

And if east coast starts going out its a long way to Glasgow/Prestwick.

[AN2 Driver]

The enroute restricted IR is a halfway house which is asking for trouble

That depends strongly on how it's used.

I can see one use for it which has nothing to do with weather but with the horrible airspace restrictions all around us for VFR.

Northern Italy and the Rome Area are gigantic "A" airspaces which make VFR there unsafe and dangerous. With an EIR one could fly quietly and legally on airways through this airspace and not at 1500 ft AGL or worse, over the sea. The same goes for the airspace mess in France, Belgium and elsewhere. Take off VFR, join up and fly airways until close to destination and then descend and land at the airport of your choice.

A LOT of small planes hardly ever use IFR equipped aerodromes. They are based on non IFR strips and they fly to non IFR strips. In all those cases, the EIR will allow them to do exactly what they need to and not even make a difference if they had the full IR.

The "interesting" thing is that as usual in Europe, people will immediately suspect any rating holder to misuse it and to abuse the rights they are given. Well, if we pilots think like that, then what are we bitching about EASA's stance?

Apart, looking at the newly proposed ideas on what an airplane needs to be IFR certified (WAAS, dual 8.33 coms, no more "on conditon" e.t.c.) even if the new EIR will make it past the anti aircraft lobbies they just now again have won a decisive victory. Nobody will care for an IR if the airplanes involved are too expensive, or rather if the cost to upgrade them exceeds the airframe value.

[Pace]

AN2

We have the ability with the IMCR to make an instrument approach and in an emergency have the skills to be vectored onto an ILS anywhere and to fly it with reasonable accuracy to a landing.

What I feel uncomfortable with is the lack of a plan B in the EASA enroute IR I have been in this game long enough to know that with all the best intentions things do not work out as we envisage.

some poor sod dumping himself off the airway into Barcelona before the STAR over high ground trying to get visual doesn't bare thinking of even if Barcelona is giving CAVOK. i have seen totally different weather in the course of 25 miles on many occasions.
i have also see CAVOK at Barcelona and CAVOK on departure and en route airfields giving 700 meters cloud base 200 feet!

So any enroute part IR should involve the ability to fly an ILS and take vectors.
not to use in normal situations but like with the old tyro military call. There should be a call which identifies the en route IR pilot as being in difficulty and instigates an immediate vectoring to an airport with reasonable minima for an ILS.

Pace