Which is exactly why the UK CAA established the 4:1 rule in 1999 because 50 hours by sole reference to instruments was worth more than 200 hours in VMC on an IFR flight!

I have been trying to work out a plausible IMCR to EASA IR conversion route.

I wonder if there is a drafting error on page 790.

Indeed it looks as if many commenters identified the need for an oral exam instead of writtens (a "P.Holy" for example in comment 16) and for the reduction of the 100 hours to a more modest figure. I understand that it was broadly supported by FCL.008 group members.

What news on that BEagle? AOPAs (517), Europe Air Sports (1459) and PPL/IR Europe's (73) comments supporting the introduction of FCL.600(b) were 'noted', or 'not accepted'. What's the plan?

Whopity, the CAA are already concerned about the availability of sufficient IRIs, thanks to this excessive requirement - and the loss of the 4:1 rule...:\

Quite a few others made similar proposals, including the UK CAA (427). We will now work on a strategy to escalate the issue - but it's too early to advise what that's going to be.

The Agency has failed both to comply with the EASA management board’s call for greater rulemaking flexibility and to note the Commission’s flexible response in other areas of aviation legislation; the Agency has also failed to recognise that there is no safety case for the absence of the provisions of JAR-FCL 1.175(b) in FCL.600 IR – General.

How is the 200 hours IFR to be measured? If one has >= 200 hours in the 'sole reference to instruments' column is this sufficient? Or do you need to show time in class A airspace (and if so how would you go about that?).
I hold a current SP IR and instruct for IMC but I may well be looking at instructing for EIR at some future point.

For an FIAs there has never been any requirement to log time in accordance with IFR, for some, it will be difficult to prove. There is no requirement for any time to be by sole reference to instruments which makes a nonsense of the requirement!
However; their IN introducing the change contained even more ridiculous gold plated requirements. I note it has now disappeared!

Easa IR (restricted)
 

A member of our group is carrying out his IMC Rating training in our aircraft at a local aero club. The old ADF in the aircraft has developed an expensive fault. We wish to remove it as it weighs a ton, and will never be used in the real world.( We have an IFR radio fit with GPS)
The local flying instructor insists that ADF is still in the IMCR training sylabus.
As an ADF is now no longer legally required for IFR flight, presumably he is wrong, and a VOR or GPS approuch will fit the non precision requirement.
On the CAA website I can only find the revalidation requirements, that state the non precision approach can be ADF or GPS or VOR.
Can I get the definative answer before we repair the ADF set.

The ADF has never been a mandatory requirement in the IMC syllabus. The syllabus was designed to allow pilots to fly IFR in an aeroplane using the equipment fitted to that aircraft. The syllabus requires that a pilot is trained and tested to a level of proficiency in 2 approach types. Nowhere does it say that one must be ADF.

Whopity
 

Thanks, thats what I thought. I will get back to the instructor tomorrow who was insistant today, that we could not use our aircraft without a functioning ADF for the IMCR training.
That will save a bunch of training as the ADF requirement takes up a disproportionate amount of flight time.
It did seem odd that training was required for a radio aid no longer legally required for IFR.

Looking back at the original syllabus in CAP53 App H dated Sept 1991

Departure and En Route The candidate to be trained in the use of at least 2 from VOR, VDF or ADF

Approach and Let Downs Candidates are to be trained in at least 2 instrument approach procedures using VOR, ADF, ILS, radar or VDF one of which must be pilot interpreted.

The ADF is no longer a required carriage item for enroute IFR in CAS.

The "problem" is that many approaches involve an NDB as a locator, and if you fly procedurally (no radar) then you need to be able to deal with it there.

Of course nearly everybody uses a GPS to fly NDB (or VOR) approaches, but that is a different debate :)

To say that the IMCR does not need to teach NDBs is a tacit acceptance of not only universal GPS use but also of the US-style GPS substitution for the ADF which is not AFAIK formally available anywhere in Europe. I have no issue with that, because that is how I fly, but I do wish they became open about it instead of beating about the bush.

I am not an instructor but if I was teaching the IMCR I would make sure the student can fly every approach plate I stick under his nose :)

It is important to understand the origin of the IMC rating. It was introduced to compensate for changes in the law that prohibited pilots from flying in IMC outside controlled airspace, glider pilots retained that right. The IMC was variable in that it did not mandate equipment or approaches but allowed alternatives with the recommendation of additional training if different approaches are to be flown. In practical terms it is very difficult to complete IMC training without ADF even though it is not mandated especially as VDF has now largely disappeared.

I had to carry out NDB tracking and an ADF approach on my recent Instructor renewal. The last time I did that was on the previous renewal six years ago. It worked both times, which perhaps says something for the level of awareness that this spatially tricky exercise hammered into those of us old enough to have used it as a routine letdown. It's sadly true that there isn't sufficient time in the IMC syllabus to teach it to a satisfactory level, especially as the NDBs are being turned off in a lot of places. Heigh Ho, switch on the GPS.