EASA AND THE IMCR - NEWS
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My biggest gripe with the EIR right now is the ban on SIDs and STARs
Probably because they dont want some PA28 flying along the Star at 90 kts with half a million fast jets occupying the same airspace?
Your comment regarding weather is a big mistake by EASA. Legally and this is an EASA requirement! What is the point of getting destination weather if your descent point to VFR is 50 miles away?
Really makes you wonder at the knowledge some of these EASA guys really have.
" I followed EASA Requirements and got CAVOK at destination but lost the plot and declared an emergency when I tried to descend into VMC and VFR 50 miles out at my descent point and saw nothing with high terrain below?"
Pace
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Probably because they dont want some PA28 flying along the Star at 90 kts with half a million fast jets occupying the same airspace?
They will be vertically separated by at least 1000ft.
And most of the time, at most relevant airports, there will be hardly any traffic there anyway.
But the STAR ban is illogical because there is no obvious way to check for VFR wx at the STAR termination (entry) point.
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10540
We both know with any IFR/ IMC flying the safest way has to be in CAS from takeoff to touchdown.
Any IFR /IMC less than that has to be less safe.
Take away the approach and instrument landing or departures that the IMCR has and it all becomes less safe again! and with more room for error in transition from IFR to VFR and transition from IMC to VMC not following a procedure.
That cannot be disputed by anyone! especially with no weather at the point you make that transition.
EASA will have to build in a plan B in that eventuality?
IMO EASA will have to build in set procedures to follow if you do not become VMC and VFR in the descent from the descent point by MSA or they will have to strictly limit the airports you can use for these sort of EIR flights?
Pace
We both know with any IFR/ IMC flying the safest way has to be in CAS from takeoff to touchdown.
Any IFR /IMC less than that has to be less safe.
Take away the approach and instrument landing or departures that the IMCR has and it all becomes less safe again! and with more room for error in transition from IFR to VFR and transition from IMC to VMC not following a procedure.
That cannot be disputed by anyone! especially with no weather at the point you make that transition.
EASA will have to build in a plan B in that eventuality?
IMO EASA will have to build in set procedures to follow if you do not become VMC and VFR in the descent from the descent point by MSA or they will have to strictly limit the airports you can use for these sort of EIR flights?
Pace
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Pace,
I think you just confounded a bunch of things. Yes, the safest thing (whether VMC or IMC) is to be IFR in CAS all the way.
But very often that is not an option. The two obvious exceptions being VFR airfields and IFR airfields outside CAS.
I don't have any stats, but I would suggest that the proportion of flights that an EIR makes, which by definition are V/I/V, which never leave controlled airspace are very small. Most EIRs will be based in Cumbernauld, Popham, Blackbushe, Biggin and so on. There will, of course, be some at East Midlands and Teesside, but they will be the exception by, I suggest, an order of magnitude.
Once you accept that most EIR flights (and GA IR flights for that matter) will have an OCAS element, and a substantial proportion will have a VFR airfield at one end or the other, a lot of these theoretical objections begin to evaporate.
If I were to characterise the EIR flight, it will be from Blackbushe to Troyes. It will be executed exactly as such a flight would be executed today VFR, with the same eye to weather, except that it will be flown in comfort and safety at F090 for the bulk of the flight, and only the two ends will be scrabbling around uncontrolled, low level VFR, just as now.
I think you just confounded a bunch of things. Yes, the safest thing (whether VMC or IMC) is to be IFR in CAS all the way.
But very often that is not an option. The two obvious exceptions being VFR airfields and IFR airfields outside CAS.
I don't have any stats, but I would suggest that the proportion of flights that an EIR makes, which by definition are V/I/V, which never leave controlled airspace are very small. Most EIRs will be based in Cumbernauld, Popham, Blackbushe, Biggin and so on. There will, of course, be some at East Midlands and Teesside, but they will be the exception by, I suggest, an order of magnitude.
Once you accept that most EIR flights (and GA IR flights for that matter) will have an OCAS element, and a substantial proportion will have a VFR airfield at one end or the other, a lot of these theoretical objections begin to evaporate.
If I were to characterise the EIR flight, it will be from Blackbushe to Troyes. It will be executed exactly as such a flight would be executed today VFR, with the same eye to weather, except that it will be flown in comfort and safety at F090 for the bulk of the flight, and only the two ends will be scrabbling around uncontrolled, low level VFR, just as now.
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Timothy
I fully understand what you are saying. I have operated in airports OCAS for years in Senecas and other twin props some disused in a Cessna Crusader.
I am fully familiar with creative approaches, spatial awareness and flying on the edge.
Maybe why i am highlighting what I see as shortfalls in the proposed EIR.
Some are purely legalities such as getting weather which is irrelevant to your descent point! Asking what do EASA propose that you do if on leaving your descent point at MSA you are not visual?
Not such a big problem into a small IFR airport with good weather but a big problem in bigger airports.
The EIR who has a problem enroute with airports below giving RVR 700 overcast 300 ? What do EASA suggest the EIR does then.
These are real concerns through experience not made up in my mind!
It's a bit naive to think the EIR will take off in good weather sit happily at FL100 and plonk down VFR at the other end.
He might have that but life is never so simple.
Pace
I fully understand what you are saying. I have operated in airports OCAS for years in Senecas and other twin props some disused in a Cessna Crusader.
I am fully familiar with creative approaches, spatial awareness and flying on the edge.
Maybe why i am highlighting what I see as shortfalls in the proposed EIR.
Some are purely legalities such as getting weather which is irrelevant to your descent point! Asking what do EASA propose that you do if on leaving your descent point at MSA you are not visual?
Not such a big problem into a small IFR airport with good weather but a big problem in bigger airports.
The EIR who has a problem enroute with airports below giving RVR 700 overcast 300 ? What do EASA suggest the EIR does then.
These are real concerns through experience not made up in my mind!
It's a bit naive to think the EIR will take off in good weather sit happily at FL100 and plonk down VFR at the other end.
He might have that but life is never so simple.
Pace
Thread Starter
A quick update - the NPA workshop went extremely well on 30 Sep. Constructive suggestions were made regarding all 3 topics (EIR, 'new'IR and Sailplane Cloud Rating).
Of note is that the previously perceived 'dangerous' elements of the EIR, namely the IFR-to-VFR transition and the rather imprecise 'reasonable expectation' of VMC at destination have now been addressed satisfactorily, although further refinement will follow the NPA response. The EIR might complement, not replace the UK IMCR, so we now need to find a 'smart' way ahead for the future of the UK IMCR.
Capitalising on a comment made by a French conferee, I made a proposal which would effectively transfer an existing JAR-FCL regulation into part-FCL. Previously this might have been refused out of hand, but recent European Commission recognition of a need for greater flexibility for national needs now gives us the opportunity to exploit complementary flexibility for part-FCL matters. My proposal was strongly backed by the Europe Air Sports expert, so EAS and IAOPA will now work together to propose a formal amendment to the draft Rules which would provide a possible solution to the current problem regarding national qualifications such as the UK IMCR, the lack of regulations to facilitate non-English speakers flying IFR in their own airspace and the legal difficulties facing sailplane tug pilots at aerodromes with significant elevation. The intention is to take this further with some preliminary exploratory talks with the European Commission; however, EASA's chief rulemaker did NOT rule out such an option.
We also discussed the requirements for FAA IR holders 'converting' to the new part-FCL IR. Let's just say that there is considerable scope for relaxing the NPA proposals with regard to theoretical knowledge requirements, so any sensible responses made to the NPA will be considered.
When repsonding to the NPA:
And the Champignonrahmschnitzel mit Bratkartoffeln was very nice on Thursday - as were a couple of Weißbiers chased later with a couple of Jaegermeister!
Of note is that the previously perceived 'dangerous' elements of the EIR, namely the IFR-to-VFR transition and the rather imprecise 'reasonable expectation' of VMC at destination have now been addressed satisfactorily, although further refinement will follow the NPA response. The EIR might complement, not replace the UK IMCR, so we now need to find a 'smart' way ahead for the future of the UK IMCR.
Capitalising on a comment made by a French conferee, I made a proposal which would effectively transfer an existing JAR-FCL regulation into part-FCL. Previously this might have been refused out of hand, but recent European Commission recognition of a need for greater flexibility for national needs now gives us the opportunity to exploit complementary flexibility for part-FCL matters. My proposal was strongly backed by the Europe Air Sports expert, so EAS and IAOPA will now work together to propose a formal amendment to the draft Rules which would provide a possible solution to the current problem regarding national qualifications such as the UK IMCR, the lack of regulations to facilitate non-English speakers flying IFR in their own airspace and the legal difficulties facing sailplane tug pilots at aerodromes with significant elevation. The intention is to take this further with some preliminary exploratory talks with the European Commission; however, EASA's chief rulemaker did NOT rule out such an option.
We also discussed the requirements for FAA IR holders 'converting' to the new part-FCL IR. Let's just say that there is considerable scope for relaxing the NPA proposals with regard to theoretical knowledge requirements, so any sensible responses made to the NPA will be considered.
When repsonding to the NPA:
- Don't be silly or abusive
- State the reference upon which you wish to comment
- State your counter proposal
- State the justification for your counter proposal
- Compose your response off-line, then copy it into the CRT field!
- Do NOT leave everything until the eleventh hour. Start looking at the NPA as soon as you can and learn how to use the CRT.
And the Champignonrahmschnitzel mit Bratkartoffeln was very nice on Thursday - as were a couple of Weißbiers chased later with a couple of Jaegermeister!
Last edited by BEagle; 1st Oct 2011 at 16:37.
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The presentations will be on the EASA website Tuesday sometime.
There will not be any notes of the meeting issued by EASA, but they did take notes for their own follow-up.
All in all a very constructive 'workshop'.
More later perhaps, if time
There will not be any notes of the meeting issued by EASA, but they did take notes for their own follow-up.
All in all a very constructive 'workshop'.
More later perhaps, if time
Thread Starter
Is there any access to notes/minutes of the workshop?
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Of note is that the previously perceived 'dangerous' elements of the EIR, namely the IFR-to-VFR transition and the rather imprecise 'reasonable expectation' of VMC at destination have now been addressed satisfactorily, although further refinement will follow the NPA response.
Capitalising on a comment made by a French conferee, I made a proposal which would effectively transfer an existing JAR-FCL regulation into part-FCL.
I am a member of AOPA, but AOPA-Ireland, so may not see the forthcomming corrospondence you refer to if it comes from AOPA UK
Thread Starter
dublinpilot, if you take a look at the NPA, you'll find a good description of the destination and alternate aerodrome forecast requirements for the EIR. There are also much clearer statements concerning acceptance of IFR clearances than hitherto.
With regard to your second question, effectively it is to include the provisions of JAR-FCL 1.175(b) within FCL.600.
Any corrspondence will come from IAOPA, so your national AOPA should be able to advise you further.
With regard to your second question, effectively it is to include the provisions of JAR-FCL 1.175(b) within FCL.600.
Any corrspondence will come from IAOPA, so your national AOPA should be able to advise you further.
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Worthile comments might be:
The ban on sids and stars (especially stars) is unworkable. How are you going to make sure you are going to be VFR at the enroute sector terminating waypoint, say FL100, and with say 30nm to run to the airport for which you can get tafs and metars (and anyway cloud above 5000ft/MSA is not reported)?
The "demonstrate knowledge" should be an oral exam, for holders of ICAO (what EASA derisorily calls "thord country") IRs. (Best to not put in a URL to the recent Cathay Pacific scandal in this case
).
Also, ICAO IR holders have already demonstrated TK, so why do it again?
If you can find time, comment on totally silly TK items. There are not many for the FCL008 IR because the "X" does not appear against many items, but there are some like the "flight level 000" pointless/trick question. The existing JAA IR TK is mostly utter b000lox and a lot of it has been taken out but that is not a reason to suffer what is left, especially as IMHO the QB will take a long time to appear (due to simple lack of a commercial incentive at the ATO) so the study workload will be high for early adopters.
The ban on sids and stars (especially stars) is unworkable. How are you going to make sure you are going to be VFR at the enroute sector terminating waypoint, say FL100, and with say 30nm to run to the airport for which you can get tafs and metars (and anyway cloud above 5000ft/MSA is not reported)?
The "demonstrate knowledge" should be an oral exam, for holders of ICAO (what EASA derisorily calls "thord country") IRs. (Best to not put in a URL to the recent Cathay Pacific scandal in this case
).Also, ICAO IR holders have already demonstrated TK, so why do it again?
If you can find time, comment on totally silly TK items. There are not many for the FCL008 IR because the "X" does not appear against many items, but there are some like the "flight level 000" pointless/trick question. The existing JAA IR TK is mostly utter b000lox and a lot of it has been taken out but that is not a reason to suffer what is left, especially as IMHO the QB will take a long time to appear (due to simple lack of a commercial incentive at the ATO) so the study workload will be high for early adopters.
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dublinpilot, if you take a look at the NPA, you'll find a good description of the destination and alternate aerodrome forecast requirements for the EIR. There are also much clearer statements concerning acceptance of IFR clearances than hitherto.
How are you going to make sure you are going to be VFR at the enroute sector terminating waypoint, say FL100, and with say 30nm to run to the airport for which you can get tafs and metars (and anyway cloud above 5000ft/MSA is not reported)?
This was why I started the other thread about how the arrivals would work in practice. My own interpertitation is that EASA want an EIR pilot to desent to a lower altitude which will almost certainly be outside the airway system and quite probably outside controlled airspace, but no lower than 1000ft above the highest obstacle within 5nm. Presumably they'll use VFR charts for this. They'll need VFR charts anyway because they need to depart and arrive under VFR. My understanding is that the departure and arrival is VFR, not just VMC.
As Pace says, and yourself, it's not so easy to determine that the weather 50nm away from the airport will be VFR, as there might be no metar/taf there.
It's obvious to me that in all likelyhood using the EIR will require better weather conditions that VFR flight would. If you can't be sure of completing it under VFR, then you can't be sure of breaking out above 1000ft above any obstacles within 5nm.
It will of course allow you to build instrument time towards a full IR by flying under IFR when you would otherwise still have made the trip but under VFR, and it will allow you to fly on top of some local low cloud, but I don't really see it as providing a great deal towards safety, other than allowing an easier staged progression towards the full IR.
dp
Thread Starter
Ok, then I have misread your initial post. I thought some change had been agreed at the workshop, but now understand that no change has been made.
IO,
This was why I started the other thread about how the arrivals would work in practice. My own interpertitation is that EASA want an EIR pilot to desent to a lower altitude which will almost certainly be outside the airway system and quite probably outside controlled airspace, but no lower than 1000ft above the highest obstacle within 5nm. Presumably they'll use VFR charts for this. They'll need VFR charts anyway because they need to depart and arrive under VFR. My understanding is that the departure and arrival is VFR, not just VMC.
As Pace says, and yourself, it's not so easy to determine that the weather 50nm away from the airport will be VFR, as there might be no metar/taf there.
This was why I started the other thread about how the arrivals would work in practice. My own interpertitation is that EASA want an EIR pilot to desent to a lower altitude which will almost certainly be outside the airway system and quite probably outside controlled airspace, but no lower than 1000ft above the highest obstacle within 5nm. Presumably they'll use VFR charts for this. They'll need VFR charts anyway because they need to depart and arrive under VFR. My understanding is that the departure and arrival is VFR, not just VMC.
As Pace says, and yourself, it's not so easy to determine that the weather 50nm away from the airport will be VFR, as there might be no metar/taf there.
Prob the usual EASA tea and biscuits Meeting with emty promises ?
The "demonstrate knowledge" should be an oral exam, for holders of ICAO (what EASA derisorily calls "thord country") IRs.
If you can find time, comment on totally silly TK items. There are not many for the FCL008 IR because the "X" does not appear against many items, but there are some like the "flight level 000" pointless/trick question.
1. State the reference upon which you wish to comment
2. State your counter proposal
3. State the justification for your counter proposal
Jim has already done a good job of de-bolleaux-ing the LOs, but any further constructive suggestions will of course be followed up.
Last edited by BEagle; 2nd Oct 2011 at 12:43.
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It's obvious to me that in all likelyhood using the EIR will require better weather conditions that VFR flight would. If you can't be sure of completing it under VFR, then you can't be sure of breaking out above 1000ft above any obstacles within 5nm.
If I look at any of my long VFR (pre-IR) trips, which were up to maybe 800nm in one leg, all of them involved flying above (often high above) some low cloud. In N Europe, it is pretty normal to have cloud between say 2000ft and 5000ft.
UK PPLs fly almost totally below such cloud, and cannot go above it even if one can find the proverbial hole because of Class A.
With the EIR, you will be able to cross this stuff, high above it, on an IFR clearance.
It is very hard (if not impossible, though I have never tried it) to fly hundreds of miles under whatever cloud one encounters. Actually I did try it once, coming back from Biarritz, in 2003, and busted one of the French power station TRAs as a result (they were not shown on the charts back then, or in notams)
But as I said I am pretty concerned about the STAR ban, because there is no easy (and certainly no "official" i.e. might be trained at an ATO) way of checking the wx at some point 30nm before the destination, at FL100-180.
The SID ban would, if nothing else, be a huge irritation to ATC at airports, because the pilot would have to depart VFR, and mess around, looking for a hole in the cloud (which is possible only OCAS) and then rejoin CAS to join up the start of the filed route.
1. State the reference upon which you wish to comment
2. State your counter proposal
3. State the justification for your counter proposal
2. State your counter proposal
3. State the justification for your counter proposal
If they stripped out TK items which are not bollox, they would not be left with much. BUT it's hard to say how much, because the FCL008 document lists learning objectives (i.e. the TK syllabus) and not the questions which will appear in the multiple choice exams. You could have reasonable LOs (e.g. "state the conditions for airframe icing") and then some idiot drafting the QB might generate loads of utter bollox questions based on that. My generous estimate of non-bollox in the current JAA IR TK is under 10%, but obviously that is the QB, not the LOs. I haven't got a clue what the LOs are, and most of them probably don't sound all that unreasonable.
The only thing which has kept a lid on the bollox in the QB has been the UK CAA weeding out the worst ones. As a result I saw very few in the actual IR exams I sat. But the EIR/FCL008-IR is meant to be pan-EU and a pilot sitting this in say France is likely to get the whole lot.
It is a direct consequence of nearly everybody involved in the TK not having ever been a pilot.
Not a lot one can do about that, except maybe draw attention to it.
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In order to comply with FCL.825 (a)(2), the holder of an EIR should not commence or continue a flight during which it is intended to exercise the privileges of the rating unless the forecast for the destination or alternate aerodrome one hour before and one hour after the planned time of arrival indicates VMC.
Firstly my reading says to me that an EIR holder can plan to an airport with marginal conditions and see what it's like when they get there, if they have an alternate which is in forecast VMC +/-1 hour.
Secondly it calls for the airport to be in VMC. I take this to mean that it's capable of accepting landing/departing traffic under VFR. It's quite possible to have an airport in VMC, but which still have an OVC which is below 1000ft above the highest obstacle within 5nm. It seems to me that if an EIR holder was stupid enough to try it, they could plan to an airport that they had no chance of landing at.
Should they not have said that the destination should have forecast conditions which would allow the flight to arrive under VFR rather than state that the airport itself if VMC?
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Obviously, yes.
"VMC" is meaningless. Most airports in CAS will have VFR minima c. 1200-1500ft cloudbase. Any lower, and you are grounded if already there, and you cannot arrive VFR except as a mayday.
"VMC" is meaningless. Most airports in CAS will have VFR minima c. 1200-1500ft cloudbase. Any lower, and you are grounded if already there, and you cannot arrive VFR except as a mayday.
Thread Starter
Bollox is self evidently bollox. How do I dig out a reference for it being bollox?
Firstly my reading says to me that an EIR holder can plan to an airport with marginal conditions and see what it's like when they get there, if they have an alternate which is in forecast VMC +/-1 hour.
SVFR adds further confusion as it has different meanings in different nations. So perhaps best just to leave it out of EIR discussions?