EIR, IMC rating and Jim Thorpe

[Pace]

Its a good idea. When I used my IMCr all I wanted was the "right" to take the IR test and not to have to sweat through the exams which I didnt see as relevant given the amount of IFR flying I had already accomplished. As usual were it that simple - but yours is a good idea.

Fuji

I agree with you to be forced to wade through an expensive training programme is hard to take.

Frankly either you are good enough or your not and a test would soon weed out those who are not especially to IR standard.

If your not you need the training or part of, if you are then why can you not just sit the test after a mock test with a flight school to give you the green light for the real thing.

I always felt we should look at an achievable European PPL /IR rather than a European IMCR but one which allows approaches. For me this IFR on top is a nonsence and one which is courting disaster for a number of reasons.

If they could address the ground exams and make those far easier to get and more practically orientated and then to just give existing IMCR holders the option to bypass the flight training by doing a pre test flight test then that is all we should need, ask for or expect.

The end result a proper European PPL/IR with all the approach privalages and a few shortcuts competant IMCR holders can take.

Pace

[SkyCamMK]

So much for the global village!

Perhaps by the time the next recession arrives we will lobbying and really trying to rationalise and harmonise standards across the whole world given that we all use the same air and in many cases the same aircraft for the same purposes on the same or similar routes.

If there is one safe standard for IFR lets meet it and if ATPs need to go higher faster and more complicated then add to an IR qual with endorsemnets based on competency testing.

Whatever happens now it will eventually change - let's just hope it evolves in a useful way.

I know, pie in the sky....

[Justiciar]

What is interesting about the debate here is that almost every contributor has their individual ideas as to what any new EIR should allow and what its training requirements should be. It is not difficult to see how any European agency is having such a problem arriving at a consensus! That is besides those who think that it should be business as usual with no change to the IMCR.

Personally, I do not see why a national rating should be incompatible with the new EASA regime, but I get the feeling it is largely a done deal.

[IO540]

A status quo is not unattractive, because it would preserve the FAA / N-reg option on which so much IFR GA (including much high-end GA) runs.

Looking at the political options, a status quo is far from impossible, IMHO.

[Fuji Abound]

Hence my comment earlier that if you have something which works, which has a proven track record and an exceptional safety record you are on very dangerous ground fundamentally changing the parameters particularly when you have no safety case for doing so and, more importantly, not a single study whcih demonstrates the new proposals are better than those they replace.

In any other arena you would be wide open to some very substantial civil claims.

If anything comes of the EIR I shall be very interested to see the RIAs and how the changes are railroaded through unless UK IMCr holders are offered a very attractive carrot.

[Brendan Navigator]

Everyone has to stop thinking in UK terms and start thinking from the perspective of a European licence holder who has never held an IMC rating.

Some points to pick up on;

Dublin pilot - Engine failure in IMC enroute for someone with an EIR or an IR or an IMC rating present exactly the exact same issues. It is an emergency and thus the pilot can legally do whatever they think is necessary. However, should a PPL or an EIR or an IR or an IMC rated pilot be flying in VMC over an extensive fog bank and the single engine fails then they are all faced with having to complete a forced landing in IMC with insturments that are in the process of running down due to lack of suction and limited battery life for the turn coordinator and pitot heat etc

So do you think that a basic PPL flying VFR on top or an EIR holder who at the same place and the same level has the engine problem you describe - which will be better equipped to descend through cloud and track a VOR/NDB and/or follow ATC vectors?

I do not know how people have a problem with the requirement to "guarantee VMC" at the destination.

Perhaps it is a poor choice of words?

However every VFR pilot flies on the basis that they guarantee that they will fly and land in VMC. Is the UK somehow different in this basic safety issue?

People need to have a serious look at what the UK restricts and what is permitted outside the UK (as well as what is permitted both in and outside the UK) before they comment.

For example, someone asked how I would like to share the airspace with "Brevet de Base" pilots from France. Anyone in the UK has a good opportunity of sharing class D E F and G airspace with pilots who are the UK's version of the same i.e. 15 hours limited to a radius from departure etc etc. So different? how?

What about places where to fly IFR you have to hold an IR regardless of weather conditions? Or places where you have to fly IFR at night regardless of conditions?

People must not think of the proposed rating in isolation. Operating rules (Rules of the Air) and other related licensing rules have to be taken into account.

As for "permit to fly aircraft not being certified". That is not quite true. They are certified to a certain standard - CS-VLA, Section S etc but for various reasons are not eligible for the issue of an ICAO C of A. This is often simply down to paperwork, quality assurance and records standards.

That is why the disclaimer says "Not Certified to ICAO Standards" rather than "Not Certified".

Happy flying.

Brendan

[Cows getting bigger]

I must admit I don't have intimate knowledge of FCL.008. However, I have some reservations about part training pilots for IMC flight. If someone is trained to fly en-route IFR (ergo IMC) then there will be occasions where they will need an instrument approach having failed to 'guarantee' VFR (VMC) at destination. Assuming that is the case, I would speculate that any EIR would have to include an element of instrument approach training as part of the syllabus. Either that or there would have to be some pretty outrageous, public transport-type, destination and planned alternate airfield weather requirements defined in relevant legislation. I could not see any regulator signing-off a safety assessment on the understanding that pilots will never go IMC unless they can guarantee VMC at destination.

[IO540]

every VFR pilot flies on the basis that they guarantee that they will fly and land in VMC.

Not quite...

A VFR pilot flies without any clearance whatsoever - except a little bit he can pick up from the unit he happens to be talking to. (And if that piece of CAS joins onto another one, then he has a reasonable expectation that he will get a transit through that piece too - except maybe in Italy ).

If for whatever reason he cannot proceed (which could be due to weather, but ATC is also totally entitled to wash their hands of him) then he must divert, turn back, or (great stuff, this) do what they call a "precautionary landing".

An IFR pilot, flying a Eurocontrol route (and there is no other way, outside the UK), has an IFR clearance all the way to destination. The "system" cannot just drop him like a hot VFR potato ("remain outside controlled airspace") at any stage. Not in Europe, anyway.

This of course is what makes IFR flight so nice and stress free. ATC works with you (well most of the time ) and they have no option; that is their job.

Obviously the regs would specify destination forecasts to be above certain limits, but the ultimate backstop is a mayday followed by an instrument approach - because a landing is not optional.

The only debate I see possible around this area is how often the mayday would occur. In much of southern Europe, not very often.

[Pace]

I do not know how people have a problem with the requirement to "guarantee VMC" at the destination.

Brendon

I flew to France IFR in a twin. Beautiful weather and landed at Pontoise.
My owner businessman went off for a meeting then rang to say he had to fly to Le Havre.

The forecast was good with a front expected moving in from the southwest but later in the early evening.

Pontoise was bathed in glorious sunshine, deep blue sky and endless vis.
I filed VFR for the short hop over to Le havre.

All went well until halfway there when the vis dropped, upper cloud obscured the blue sky and bits of scud floated past beneith.

That soon changed to flying on top of solid with an actual at le Havre of overcast 400 vis 2 k in drizzle.

I requested a change to IFR and landed off an ILS approach.
It does happen take my word for it!

We should push for a European full PPL /IR.

We should push for a far more esely achievable ground exams designed for a PPL /IR and we should push for allowances towards the flight section with even the option to fly a pre flight test exam and if passed a Full IFR flight test.

Pace

[englishal]

If you had an "EIR" but with approaches, it would be a full IR in all but name.

Ah but you could limit it to "non public transport operations". This way the "full IR" skygods could be kept happy as they have done the full IR to fly people around - and rightly these fare paying passengers should have well qualified pilots up front.

You could also limit it to a single approach for example "limited to precision approaches or visual approaches only".

It would certainly give us mere mortals a chance at flying airways / "proper" IFR without the time and expense of a full IR, and achive an IR that many of us would use.

Even better, there could then be upgrade courses to the full IR, upgrade exams, previous instrument time taken into consideration etc.. It would boost UK and Euro flight training a heck of a lot I reckon.

[IO540]

Ah but you could limit it to "non public transport operations".

It's a fair proposal, but there is a very respected school of thought that one must not do anything which the "guardians of the professional IR" could use to push private IR holders into a ghetto.

Once you give them one excuse for saying that the private pilot's competence is any lower than the professional pilot's, the wedge is cast and it could lead to all kinds of undesirable outcomes.

So, the private IR pilot has a strong interest in not making the demonstrated competence any lower.

Which in turn leads to the perpetual difficulty in making the Euro IR more accessible...

[Fuji Abound]

Pace

You have it - I just cant help feeling some of those who contribute to these threads have little or no real word experience. Not long ago I flew from Oxford to the south coast - less than an hour. I "filed" VFR and both the TAFs and METARs indicated VFR would be possible the whole way. Now I am happy as it happens to run scud with the best of them but not only was my destination out of bounds VFR so was Oxford by the time I was half way into the flight. In fact by the time I arrived it was hard IFR and I only just got in. Moreover my climb was limited to remain below CAS because there was little hope of a pop up clearance so the rest of the route was IMC with the fluid running.

Coming back from Ireland last year tops were forecast at FL55 and with a base of broken 1,500 a VFR arrival seemed on the cards. Over the Bristol Channel I managed to just clear the tops at FL95 accumulating light ice in the last 1,000. On arrival the base proved to be overcast at around 850 feet.

I cant think of anything more dangerous than creating a rating that encourages pilots to get themselves stuck on top, or for that matter ever struggling to find the tops followed by a descent to a predicted VFR arrival but in fact having to divert or "bend the rules" in order to get home.

Like it or not much of Europe is dominated by Oceanic weather - it is not Australia and its not Spain, Italy or Germany.

For me those that propose ratings of this type have no real world experience or if they do it is long forgotten and that is one of the reasons I am so bitterly opposed to rule making to pander to those with a very different agenda form the safety of the pilots they serve.

For those reasons Brendan Europe might want to pretend that we should stop thinking about what happens when the weather changes en route from Ireland, and so might you for that matter, but I am far more comfortable in the real world and a great deal more comfortable knowing that when I set off I can safely make an approach without having to be concerned about a set of rules which are of no concern to Mother Nature.

For those that think otherwise talk to the guys that fly the milk run to the CIs for a living, ask them about the weather, and when you have done that come back and let us know whether you still hold to the same view - here is the problem, you can bet thats something none of the committee members have bothered to do.

[Pace]

So, the private IR pilot has a strong interest in not making the demonstrated competence any lower.

10540

I like the suggestion here of a modulated IR with a Basic PPL/IR which can then be upgraded to cover the whole CPL to ATPL.

the flight test would be No different the only difference would be in the ground exams. There would be a specific exam/ set of exams designed for the PPL who is not flying commercially, who will be using LAS and has no aspirations to be a heavy jet pilot flying at FL390.

The flight test and standards would be the same but with generous allowances given to PPL IMCR pilots. The litmus test is the test itself. Either you are good enough to handle all the IR test requirements or your not.

So the only quality difference between the two would in reality be the exams you have covered but even there you could always upgrade as and when you need to be a commercial /ATP pilot.

The powers that be may actually like the idea of the building block scenario of what they already have rather than a mickey mouse stand apart IR for private pilots.

Pace

[BackPacker]

The flight test and standards would be the same

Would that be absolutely necessary? The test standards for CPL are already more strict than for the PPL and we don't find that a problem do we?

I admit I do not possess an IR (otherwise I wouldn't bother mingling in this thread anyway) but if you allow slightly less strict standards for a PPL/IR than for a CPL/IR, and compensate for that by having, say, slightly higher departure/approach minima (published minima + 200' for instance), would that significantly impact the utility of a PPL/IR? Or maybe some system where you need to apply slightly higher minima for the first x "for real" IMC approaches?

PPL/IMC holders have long lived with the "advice" of the CAA to apply such a factor to their approach minima, haven't they? Was that an unreasonable advice, making things unworkable?

[englishal]

This is an interesting discussion.

Regarding level of training, the practical test standards should be the same.

So how does one make the EIR more achievable than the "full" IR for someone on a limited time/budget? Cost is going to be a big factor (main factor for most) in a private "sunday" pilots decision. For others it is time.

One way is the EIR with precision approach capability. This would mean that a) The ground exams could be a very cut down version, concentrating on IFR rules and procedures and weather only, b) The flight training could be cut down as one doesn't need to demonstrate NPA's and c) make allowances for previous time.

In theory then a current IMCr / ICAO IR holder could then self study for the exam, pay the exam fee (£100?) and take the test, do some brush up training with your local flying school and then take the test with an examiner - a relatively simple, time efficient and cost effective solution. Current IMCr holders wouldn't feel agrieved at losing a rating, as their rating counts towards the required time. IR holders shouldn't feel agreived because the practical test standards are the same as for them.

For new candidates, flying an ILS is the simplest procedure to learn and not particularly difficult. By cutting out NPA's the EIR could probably be condensed into 20-25 hours - which is realistically what the IMCr is now. The enroute stuff is easy, the ILS is easy. The hardest bit is the basic attitude instrument flying and partial panel.

Forget 170A's and JAA Class 1 Audiograms and keep it in the realm of the "private" pilot, not A380 captain.

If this was what the EIR evolved into, then I'd be quite happy, and I guess many of those who put their planes onto the N reg would also reconsider.

[IO540]

The JAA IR test is the same for the PPL as for the CPL.

In FAA land there is a tighter IR checkride incorporated in the ATPL checkride.

I agree with Pace, but there is some political obstacle to a straight modular IR.

[Pace]

BackPacker

I admit I do not possess an IR (otherwise I wouldn't bother mingling in this thread anyway) but if you allow slightly less strict standards for a PPL/IR than for a CPL/IR, and compensate for that by having, say, slightly higher departure/approach minima (published minima + 200' for instance), would that significantly impact the utility of a PPL/IR? Or maybe some system where you need to apply slightly higher minima for the first x "for real" IMC approaches?

You are realistically asking the Europeans to accept the IMCR? whats the difference?


The problem that concerns me is selling something acceptable to the Europeans. I agree with 10540 that if its seen as a lesser rating mixing in with the big boys the Europeans wont buy it.

If its seen as a stepping stone rating with the same flying standards they may?

The biggest hurdles are the cost of flight training which could be partially covered by IMCR allowances and the option if you think you are good enough to put yourself up for a pre flight exam exam and secondly the exams.

The exams can take months of hard dedicated graft learning a lot of stuff you dont really need to know.

The FAA exams can be done really quickly with no safety differences between the two. That beggers the question of are months of study really needed for a PPL/IR?

The business man /working man with a family often cannot find the time or level of commitment needed to study those blast+d exams.
So IMO keep the flying standards the same with allowances but make the study work a whole lot easier and more relevant.

They will never buy a European IMCR they may buy a stepping stone PPL/IR where the flying standards are the same but the study work can be added later as required.

Thats my opinion for what its worth.

One way is the EIR with precision approach capability. This would mean that a) The ground exams could be a very cut down version, concentrating on IFR rules and procedures and weather only, b) The flight training could be cut down as one doesn't need to demonstrate NPA's and c) make allowances for previous time.

Englishall

What you are asking for is for the Europeans to accept the British good old tried and tested IMCR. Trust me it will never happen go that route and we are dead meat.

Pace

[vanHorck]

It seems to me the horse is behind the cart here. We are looking at what can be made easier for the sake of being easier.


I see two issues:

the FAA IR is easier but then I understand their IFR flying is easier too because the FAA has been more dynamic than our European counterparts. The question is, are their lower standards also less safe? If not why not simply adopt the american FAA IR and/or allow it here for non commercial use on European aircraft?

The second issue is that PPL IR's will not encounter all the things ATPL's do. I am thinking of the coffin corner up very high, the risks in flying well above FL250, perhaps the pressures of having to fly in all conditions, surely things like auto land.

I would like to hear the opinions of IR rated PPL's here such as IO on these matters:
From a practical standpoint why would the FAA IR not suffice?
From a practical standpoint, what ATPL IR part of the syllabus should not be required for PPL IR's and how much time on theory and practical training would that save?

[Pace]

Van

The FAA IR Pilots have the same safety levels as the European IR pilots.
There was a massive study comparing both up to ATP level probably so EASA could use that study to force through changes on a safety angle.
No difference could be found.

In a sensible world yes an FAA IR CPL ATP should be easely changed for a European variety and visa versa, but its not a sensible world.

If it was a sensible world the Europeans would accept the UK IMCR as a an addition to VFR safety but they wont!

Its all about quangos, burocrats, protectionsism, politics, state control and above all NON SENSE. Thats what we are up against.

Pace

[IO540]

From a practical standpoint why would the FAA IR not suffice?

It would but European regulators just say "we are Europeans, not Americans, and we must have European solutions". End of debate.

From a practical standpoint, what ATPL IR part of the syllabus should not be required for PPL IR's and how much time on theory and practical training would that save?

Quite a lot, but a lot of it has already happened in the ground school. The PPL/IR has 7 exams, whereas the CPL/IR (in JAA-land the ATPL is a given once you reach the #hours etc) is 14 exams. Moreover, should you be doing the PPL/IR exams and encounter a question on 737 FMS etc, and you have just failed by 1 point, you can AIUI appeal the result. So, the early 2000s situation where a European PPL/IR had to do all the CPL crap (about the time I started on the US route) was fixed a few years ago.

What has not changed, and these differences are vital to getting US levels of IR penetration in the population, are

1 - the need to learn a lot of stuff (still)

2 - the need to do 50/55hrs (with zero credit for previous experience, regardless of competence)

3 - the need to do all flight training via a professional FTO (a blatent business protection measure, and most pilots don't have one at their local airfield, so are looking at a "residential" scenario to some degree)

4 - the Class 1 medical audiogram (affects some older pilots, though there are very roundabout solutions).

The EASA full IR, which is being worked on now, will address 1. to a degree (no idea how much), 2. to a large degree (I gather there would be a large element of "demonstrated competence"), but not 3. at all. 4. likewise; medical stuff is seemingly out of reach in Europe.

So things are happening, slowly. I think not solving 3. (if true) will be a major damper on progress. A large part of the success of the IMCR is that one can do it at one's local school.

The problem I see is more basic: EASA has tabled such aggressive FCL proposals on the foreign license side of things (undoubtedly, this was naively done to drag the FAA to the table, to get them to agree to a bilateral treaty on a pile of stuff which assumed that Europe is as relevant as the USA) that the resulting s**t is going to hit the fan in such quantity that all the wheels might come off in one go. In which case we will probably end up with a status quo...