EASA AND THE IMCR - NEWS
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Also, in any conditions, in CAS even, there could be traffic there which isn't supposed to be there - as some have found out.
One is more likely to encounter it if the actual conditions are VMC, obviously, for that is the profile of the GA population, but one could be going down an ILS where from the FAF down to the DA one passes through 2 or 3 cloud layers, and somebody flying "VFR", or even just busting CAS, could be perfectly happy with themselves flying between the layers.
If you are head down all the way, and single pilot, and absolutely obeying the company rulebook and not even lifting the eyebrows to see if you are visual until the altimeter reads the DA (which I completely believe Timothy was doing, but it beggars belief that it would really be standard practice because it goes so much against human nature and self preservation) you are denying yourself the opportunity to spot some joker.
In VMC conditions you are chucking away the chance of spotting a runway incursion nice and early, or a helicopter doing something at 100ft AAL, etc.
But hey company policy is company policy no matter how weird. I once asked an instructor if when he was flying an NDB approach, and the ADF was indicating OK but a GPS was telling him he was about to die, his reply was he would trust the ADF.
One is more likely to encounter it if the actual conditions are VMC, obviously, for that is the profile of the GA population, but one could be going down an ILS where from the FAF down to the DA one passes through 2 or 3 cloud layers, and somebody flying "VFR", or even just busting CAS, could be perfectly happy with themselves flying between the layers.
If you are head down all the way, and single pilot, and absolutely obeying the company rulebook and not even lifting the eyebrows to see if you are visual until the altimeter reads the DA (which I completely believe Timothy was doing, but it beggars belief that it would really be standard practice because it goes so much against human nature and self preservation) you are denying yourself the opportunity to spot some joker.
In VMC conditions you are chucking away the chance of spotting a runway incursion nice and early, or a helicopter doing something at 100ft AAL, etc.
But hey company policy is company policy no matter how weird. I once asked an instructor if when he was flying an NDB approach, and the ADF was indicating OK but a GPS was telling him he was about to die, his reply was he would trust the ADF.
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Beagle, I beg to differ. All the criteria were exactly the same with the 'advantage' of having a safety pilot doing the lookout. Somehow all concerned still managed to engineer a collision.
The point is quite obvious. Flying an instrument approach reduces effective lookout, irrespective of the flight rules/conditions. That reduction in lookout needs to be mitigated somehow, whether that is with a safety pilot, enhanced ATC procedures etc. FWIW, I think we all agree on that fact.
The point is quite obvious. Flying an instrument approach reduces effective lookout, irrespective of the flight rules/conditions. That reduction in lookout needs to be mitigated somehow, whether that is with a safety pilot, enhanced ATC procedures etc. FWIW, I think we all agree on that fact.
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What a wonderful argument against the proposed EIR!
Thread Starter
What a wonderful argument against the proposed EIR!
Since the privileges of the EIR are only to be exercised in the en-route phase of flight, the holder of an EIR should:
1. at no time accept an IFR clearance to fly a departure, arrival or approach procedure;
2. declare an emergency to ATC if unable to complete a flight within the limitations of their rating.
1. at no time accept an IFR clearance to fly a departure, arrival or approach procedure;
2. declare an emergency to ATC if unable to complete a flight within the limitations of their rating.
Hence an EIR holder intending to fly IFR en-route will be required to depart under VFR until reaching his pre-planned VFR-to-IFR transition point, then fly the en-route element under IFR before reaching the IFR-to-VFR transition point and completing an entirely VFR arrival. Which is going to be rather more demanding in terms of flight planning than simply planning end-to-end IFR - and which may confuse the heck out of an air trafficker unused to such things.
If there's no STAR and the EIR holder is following radar vectors, he must fly VFR before reaching the approach fix:
If an IFR approach procedure is established at the destination airfield, this IFR/VFR transition point should be passed before reaching the Initial Approach Fix (IAF).
N.B. My quotes are from NPA 2011-16. The use of 'should' has already been pointed out to EASA to be incorrect; however, it seems that their own rules don't allow 'shall' in an AMC....
So they've said that they will find a way of ensuring that these will become mandatory requirements in the final Opinion.
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and which may confuse the heck out of an air trafficker unused to such things.
- An aircraft reaches an airways point, requests to leave controlled airspace by descent and then, a few minutes later turns up at a VRP asking for VFR entry (both completely normal, recognised aviation practice) or
- Aircraft flies a STAR, arrives at the IAF and says "sorry guys, here I am in the middle of an IFR procedure but I'm VFR and can go no further IFR; what are you going to do about it?"
A thought on a dilema that seems to be appearing from this debate. Take me for an example - I fly a moderate 90ish hours per year - so pretty current in general terms, am IMC qualified and current, but by most standards am a very inexperienced instrument pilot.
So, I turn up at an airfield with a couple of available IAPs; in adequate or good visual conditions. This happens reasonably regularly. Indeed, I tend to try and avoid flying when the weather is particularly poor, because it's less fun and usually I don't need to.
So, if every time I can, I fly a visual approach, the result is that I fly a genuine IAP 2-3 times per year.
On the other hand, fly an IAP when I can - which perhaps means I fly an average of 1-2 a month. Perhaps degrade my instrument flying performance a bit by maintaining a good lookout, or if I have a passenger give them a lookout role. This is certainly the approach I'm taking with my flying at the moment (although many airports do not seem to see why I want an IAP if the conditions are good for a visual approach, as others have mentioned).
Now, take the day I'm on a long trip into somewhere, the weather has deteriorated, and my route back is around my IMC minima - say 600ft cloudbase with an available ILS, and 2000m RVR. This is the day I really need my instrument flying skills.
If I've been flying an IAP a couple of times per year, I'm rusty, working extremely hard, and the potential for me to screw up is on the high side.
If I've been flying a couple per month, I'm sharper, more current, working less hard, and more likely to get the IAP right.
This to me makes a strong case for taking an IAP when one is available, to stay sharp, for the day you really require it. It is also an argument against the philosophy of the EIR where the "emergency instrument procedure" allowed for in the EASA philosophy will seldom if ever be practiced (and if it's in the annual IRT, will cause EIR holders to end up spending lots of money on training every year to get themselves back to test standard for their practice emergency IAP since they've had no ability to practice it otherwise).
Allow at-least an EIR to accept SIDs and IAPs when they can do so whilst remaining VMC below MSA, that way when they really need to make an IAP, there's a fighting chance they'll remember how to do it!
You may of-course get stung for approach fees - but I'm willing to bet that those approach fees will add up to less than the remedial training to get through the IRT/IMCRT renewal if the pilot hasn't been practicing.
G
So, I turn up at an airfield with a couple of available IAPs; in adequate or good visual conditions. This happens reasonably regularly. Indeed, I tend to try and avoid flying when the weather is particularly poor, because it's less fun and usually I don't need to.
So, if every time I can, I fly a visual approach, the result is that I fly a genuine IAP 2-3 times per year.
On the other hand, fly an IAP when I can - which perhaps means I fly an average of 1-2 a month. Perhaps degrade my instrument flying performance a bit by maintaining a good lookout, or if I have a passenger give them a lookout role. This is certainly the approach I'm taking with my flying at the moment (although many airports do not seem to see why I want an IAP if the conditions are good for a visual approach, as others have mentioned).
Now, take the day I'm on a long trip into somewhere, the weather has deteriorated, and my route back is around my IMC minima - say 600ft cloudbase with an available ILS, and 2000m RVR. This is the day I really need my instrument flying skills.
If I've been flying an IAP a couple of times per year, I'm rusty, working extremely hard, and the potential for me to screw up is on the high side.
If I've been flying a couple per month, I'm sharper, more current, working less hard, and more likely to get the IAP right.
This to me makes a strong case for taking an IAP when one is available, to stay sharp, for the day you really require it. It is also an argument against the philosophy of the EIR where the "emergency instrument procedure" allowed for in the EASA philosophy will seldom if ever be practiced (and if it's in the annual IRT, will cause EIR holders to end up spending lots of money on training every year to get themselves back to test standard for their practice emergency IAP since they've had no ability to practice it otherwise).
Allow at-least an EIR to accept SIDs and IAPs when they can do so whilst remaining VMC below MSA, that way when they really need to make an IAP, there's a fighting chance they'll remember how to do it!
You may of-course get stung for approach fees - but I'm willing to bet that those approach fees will add up to less than the remedial training to get through the IRT/IMCRT renewal if the pilot hasn't been practicing.
G
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This to me makes a strong case for taking an IAP when one is available,
Allow at-least an EIR to accept STARs and IAPs when they can do so whilst remaining VMC
My main beef with the otherwise useful EIR proposal is that it bans SIDs and STARs. Specifically, it means you gave to cancel IFR at or before the last enroute waypoint, which means that your legal preflight planning has to include a verification of VFR conditions at that waypoint, for which there is no obvious process, internet or no internet. I also think it will confuse the hell out of ATC, not least because that last waypoint is prob99 going to be in CAS, and at an altitude at which VFR traffic would not be desired in many/most countries in Europe.
As a side point, flying conventional-navaid IAPs is a whole lot easier if you have a moving map GPS
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Allow at-least an EIR to accept STARs and IAPs when they can do so whilst remaining VMC, that way when they really need to make an IAP, there's a fighting chance they'll remember how to do it!
I am writing an article as we speak (actually, writing this posting is just another procrastination tactic not to get back to it) about zero-zero landings.
I was taught (by one example) how to do a zero-zero landing in June 1986. I needed to do one in April 2008, 22 years later. I did so quite effectively.
The requirement to do a zero-zero landing by an experienced IR who has got caught out cannot be much different from the requirement for an EIR to fly an instrument approach, or SRA, to, say, 800' because he has got caught out. (let's not think that an EIR has got so caught out that the weather has gone from above the MSA to below minima, that's daft.)
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A question from a slightly different stance for those who have scrutinised the NPA: if an IMCR holder were to add an EIR to their repertoire, would the combined privileges equal those of a full IR holder flying solely in the UK (notwithstanding visibility and descent minima)? It seems possible to depart Southern Europe in VFR, fly IFR en-route, then complete an IAP in the UK.
It's a dangerous thing is thinking
It's a dangerous thing is thinking
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a question from a slightly different stance for those who have scrutinised the NPA: if an IMCR holder were to add an EIR to their repertoire, would the combined privileges equal those of a full IR holder flying solely in the UK? It seems possible to depart Southern Europe in VFR, fly IFR en-route, then complete an IAP in the UK.
For a UK pilot, having an IMCR and an EIR would be a great combination, because, as well as being IAP legal in the UK, when the weather was bad in Germany or France, he would still have the skills to perform an instrument approach, albeit illegally.
However, some thought has to be given to the pilots of 26 other countries! maybe they should all pile over here and get a UK IMCR before April
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A question from a slightly different stance for those who have scrutinised the NPA: if an IMCR holder were to add an EIR to their repertoire, would the combined privileges equal those of a full IR holder flying solely in the UK (notwithstanding visibility and descent minima)? It seems possible to depart Southern Europe in VFR, fly IFR en-route, then complete an IAP in the UK.
You will have to file a route which terminates in Class D, or OCAS, basically.
The ability to do this depends on how strictly Eurocontrol enforce the last waypoint of the enroute section connecting to the first waypoint of the STAR. In the UK, this seems pretty loose, and a DCT to a waypoint further down the STAR ought to work provided it is shorter than 50nm (100nm if below FL100).
If landing at an OCAS airport, there isn't going to be a formal STAR anyway, so the route can just end with a DCT or two as desired.
I have just had a quick look at Bournemouth (Class D) and e.g. the arrivals from the south east are no problem either, as no explicit enroute terminator waypoint is given; you can seemingly just pick any of SAM, GWC, CAMRA, WAFFU, etc. Cardiff appears similar.
Flight Plan Pro is the tool I use for Eurocontrol routings. It's free, so grab a copy and have a play. The lowest airway level worth trying is FL070 and FL100 generally works a lot better. I always go for min FL090, desired FL140, max FL190.
If you want a web-only facility (which can run on a smartphone, etc) then Rocketroute gives you the same routing features as FPP. RR uses the same routing software as FPP (written by the same person - a poster here
).For those who develop their routings using a separate tool (such as FPP) there is EuroFPL which is what I use. They offer the Eurocontrol "route suggest" facility which is usually OK, but the FPP routes tend to be better optimised.
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For those who develop their routings using a separate tool (such as FPP) there is EuroFPL which is what I use. They offer the Eurocontrol "route suggest" facility which is usually OK, but the FPP routes tend to be better optimised.
I must say that I tried FPP and didn't find that it worked (it was very buggy, that might have improved since) whereas EuroFPL usually gets me around 105% - 115% GC with no difficulty.
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Quote:
As you were flying multi crew jets (HS125) your co-pilot would have been looking out the whole time, which makes this rather different to doing it single-pilot.
As you were flying multi crew jets (HS125) your co-pilot would have been looking out the whole time, which makes this rather different to doing it single-pilot.
Peter,
No-one has a higher opinion of your knowledge and experience than you do. Does it not occur to you that I know more about my biography than you do? I flew single crew piston twin air taxis for many years. I am not an idiot, even compared to you.
No-one has a higher opinion of your knowledge and experience than you do. Does it not occur to you that I know more about my biography than you do? I flew single crew piston twin air taxis for many years. I am not an idiot, even compared to you.
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Just a thought...
I fly an N reg. I hold an FAA IR. I hold a JAA PPL with IMCr.
What I understand is the EIR will be given in exchange for an FAA IR. I hold and IMC which will be grandfathered.
So I see the problem with private N reg and IFR ops has now gone away - I can fly the N reg using the FAA certificate (required), I can fly IFR IAPs in the UK using my IMC (required due to stupid rules), I can fly IFR IN CLASS A AIRSPACE in Euroland due to the EIR (and FAA IR), I can fly IFR anywhere in the world due to FAA IR.
Suddenly there seems very few restrictions, other than perhaps I can't fly an ILS in France.....But actually I would do that anyway due to my Mexican visa which says "this person is a temporary resident of Mexico" on the back....so all of the above is irrelevant?
Am I correct?!
I fly an N reg. I hold an FAA IR. I hold a JAA PPL with IMCr.
What I understand is the EIR will be given in exchange for an FAA IR. I hold and IMC which will be grandfathered.
So I see the problem with private N reg and IFR ops has now gone away - I can fly the N reg using the FAA certificate (required), I can fly IFR IAPs in the UK using my IMC (required due to stupid rules), I can fly IFR IN CLASS A AIRSPACE in Euroland due to the EIR (and FAA IR), I can fly IFR anywhere in the world due to FAA IR.
Suddenly there seems very few restrictions, other than perhaps I can't fly an ILS in France.....But actually I would do that anyway due to my Mexican visa which says "this person is a temporary resident of Mexico" on the back....so all of the above is irrelevant?
Am I correct?!
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Cheers guys, it was something I've been pondering over for a few weeks but with the sensitivity of IR vs IMCR/EIR I didn't want to upset anyone. Took a deep breath and cringed before reading your replies in fact!
To be honest it'll be at least another year before I fly anything that has a service ceiling above 13-14000ft without thinking about cruising at FL140. That said, I'm beginning to see the usefulness of the EIR if it would be possible to fly through or cross the low-alt airways flying an East/West track in DTY or TNT areas for example. Perhaps a solid cloud base base of 3-4000ft on a day when 'ginners' VMC on top at 6-8000ft would be more useful? It would only take 20-30nm max in a straight line, and hopefully my 'spamcan' wouldn't cause any problems with the AT ships.
As for filing a FPL, I like to think I'm a dab hand with ERCs, AFPEX and FPL addressing. Its astonishing how many PPLs I hear having trouble with AFPEX FPLs to hop across the Channel because they are trying to put VRPs in the route field rather than as RMK in F18. OK OK a bright spark will turn up here shortly to spout something about the full FPL not being visible to all. Which is true for Centre and Information agencies as their electronic flight strip system automatically displays the route with essential details. The full FPL has to be requested by exception which is also available. The full plan is also read by Dep, Dest, Altns, and Originator by default too.
IO540, I'll definitely investigate FPP and Rocketroute see how they compare. Although in case of cerebral flatulence I have contacts at Brussels as a last resort (also 'IFPS route changes accepted' in F18 usually works if the FPL can't be auto ACK'd and goes manual)
Thanks again!
To be honest it'll be at least another year before I fly anything that has a service ceiling above 13-14000ft without thinking about cruising at FL140. That said, I'm beginning to see the usefulness of the EIR if it would be possible to fly through or cross the low-alt airways flying an East/West track in DTY or TNT areas for example. Perhaps a solid cloud base base of 3-4000ft on a day when 'ginners' VMC on top at 6-8000ft would be more useful? It would only take 20-30nm max in a straight line, and hopefully my 'spamcan' wouldn't cause any problems with the AT ships.
As for filing a FPL, I like to think I'm a dab hand with ERCs, AFPEX and FPL addressing. Its astonishing how many PPLs I hear having trouble with AFPEX FPLs to hop across the Channel because they are trying to put VRPs in the route field rather than as RMK in F18. OK OK a bright spark will turn up here shortly to spout something about the full FPL not being visible to all. Which is true for Centre and Information agencies as their electronic flight strip system automatically displays the route with essential details. The full FPL has to be requested by exception which is also available. The full plan is also read by Dep, Dest, Altns, and Originator by default too.
IO540, I'll definitely investigate FPP and Rocketroute see how they compare. Although in case of cerebral flatulence I have contacts at Brussels as a last resort (also 'IFPS route changes accepted' in F18 usually works if the FPL can't be auto ACK'd and goes manual)
Thanks again!
Last edited by GeeWhizz; 8th Nov 2011 at 18:12. Reason: usual rubbish typos, extra info, blar blar blar!
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What I understand is the EIR will be given in exchange for an FAA IR
AFAIK the above is true for both the EIR and the CBM IR.
All in all, the proposed conversion is not all that different to the present 15hr IR conversion route, once you consider that the present 7 exams are supported by a reasonably complete question bank and, if you do it all via CATS, you can just hammer the QB and never have to open the almost totally irrelevant study material. The present 15hrs minimum dual flying time is probably what most existing IFR pilots will need to pass the flight test with the traditional IR examiner (VOR, NDB, etc stuff), anyway. That is basically why I am doing the IR conversion now, rather than waiting.
Plus you will need the CAA Class 1 medical, or the Class 2 with the Class 1 audiogram.
To be honest it'll be at least another year before I fly anything that has a service ceiling above 13-14000ft without thinking about cruising at FL140
As for filing a FPL, I like to think I'm a dab hand with ERCs, AFPEX and FPL addressing
also 'IFPS route changes accepted' in F18 usually works if the FPL can't be auto ACK'd and goes manual
The new route will be communicated to you from the filing agency, usually to your phone, so you have to pick it out of there, convert it to waypoints to load into the GPS, etc.
And if you file the FP traditionally (handing it in at the tower) the new route will never be communicated to you so you have to wonder where ATC will send you next.
Admittedly a lot of pilots, especially those totally baffled by the Eurocontrol tech-boffin system, use the 'reroute accepted' and get away with it well enough on the day, but if you can generate a valid route yourself then you will be much better prepared when you get airborne.
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I posted on this subject previously but perhaps my thoughts are worth repeating.
I dont understand the magic of the FAF. The CAA took the view that IMCr holders might struggle to fly to the required tolerances close to the ground. In consequence they recommended IMCr holders adopt a higher DH that IR holders. In that there is sense. The pilot has been restricted by a parameter which is directly related to the skiils he is required to excercise. On the other hand the FAF is not asscoiated with any parameter of which I am aware in the same way. It could be overhead the airfield at 1,600 feet or it could be ten miles from the airfield at 4,000 feet.
I assume that it was felt because the FAF defines the point at which the pilot enters the "arrival process" this is also the point at which the pilot starts to fly a more complicated procedure with the propensity to "screw" up.
In reality few arrivals will be procedural these days, and for most of us wanting an easy life we will routinely accept vectors. It also seems to be worrying that a pilot is aqualified to fly airways cant be trusted to accurately fly vectors in IMC to a reasonable tolerance.
For these reasons using the FAF as the point of defining where the pilot's skills dont correspond with the task in hand doesnt make a great deal of sense.
If the pilot is to be restricted, he should be restricted by his actual skill set.
My experience is that many pilots struggle to fly a complicated procedural approach. It is also my experience that many pilots struggle to fly the final part of an ILS accurately. However, pilots are pretty good at accepting vectors.
For all of these reasons it seems to me than an EIR holder should be allowed to accept vectors to the top of the glide slope. Whether he should be allowed to continue some way down the glide slop is debatable and would depend upon how much ILS training was included in the syllabus. If it was felt that he should not continue down the G/S unless visual at the top of the G/S I dont see this an issue. The pilot would fly the missed and AT would be well accustomed to pilots going missed albeit usually from a lower level.
It could be argued that if the pilot went missed at the top of the G/S he would now have to fly the missed procedure for which his skill set was lacking. Well that is where an approach ban could be useful. In other words if the METAR wasnt giving a cloudbase above the top of the G/S the pilot would be required to divert - simple and clear, and reliant on an accurate and current definition of the conditions, unlike deciding what the cloudbase might be at an FAF ten miles from the airports based on the airport METAR or the area forecast.
In short I think an EIR holder should be allowed to accept vectors to the top of the G/S unless the cloudbase was below the top of the G/S. If vectors are not available then the pilot should be allowed to descend to the top of the procedure within the ATZ, once again if the cloudbase is reported as being above, or else be required to divert.
I dont understand the magic of the FAF. The CAA took the view that IMCr holders might struggle to fly to the required tolerances close to the ground. In consequence they recommended IMCr holders adopt a higher DH that IR holders. In that there is sense. The pilot has been restricted by a parameter which is directly related to the skiils he is required to excercise. On the other hand the FAF is not asscoiated with any parameter of which I am aware in the same way. It could be overhead the airfield at 1,600 feet or it could be ten miles from the airfield at 4,000 feet.
I assume that it was felt because the FAF defines the point at which the pilot enters the "arrival process" this is also the point at which the pilot starts to fly a more complicated procedure with the propensity to "screw" up.
In reality few arrivals will be procedural these days, and for most of us wanting an easy life we will routinely accept vectors. It also seems to be worrying that a pilot is aqualified to fly airways cant be trusted to accurately fly vectors in IMC to a reasonable tolerance.
For these reasons using the FAF as the point of defining where the pilot's skills dont correspond with the task in hand doesnt make a great deal of sense.
If the pilot is to be restricted, he should be restricted by his actual skill set.
My experience is that many pilots struggle to fly a complicated procedural approach. It is also my experience that many pilots struggle to fly the final part of an ILS accurately. However, pilots are pretty good at accepting vectors.
For all of these reasons it seems to me than an EIR holder should be allowed to accept vectors to the top of the glide slope. Whether he should be allowed to continue some way down the glide slop is debatable and would depend upon how much ILS training was included in the syllabus. If it was felt that he should not continue down the G/S unless visual at the top of the G/S I dont see this an issue. The pilot would fly the missed and AT would be well accustomed to pilots going missed albeit usually from a lower level.
It could be argued that if the pilot went missed at the top of the G/S he would now have to fly the missed procedure for which his skill set was lacking. Well that is where an approach ban could be useful. In other words if the METAR wasnt giving a cloudbase above the top of the G/S the pilot would be required to divert - simple and clear, and reliant on an accurate and current definition of the conditions, unlike deciding what the cloudbase might be at an FAF ten miles from the airports based on the airport METAR or the area forecast.
In short I think an EIR holder should be allowed to accept vectors to the top of the G/S unless the cloudbase was below the top of the G/S. If vectors are not available then the pilot should be allowed to descend to the top of the procedure within the ATZ, once again if the cloudbase is reported as being above, or else be required to divert.
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I assume that it was felt because the FAF defines the point at which the pilot enters the "arrival process" this is also the point at which the pilot starts to fly a more complicated procedure with the propensity to "screw" up.
In short I think an EIR holder should be allowed to accept vectors to the top of the G/S unless the cloudbase was below the top of the G/S. If vectors are not available then the pilot should be allowed to descend to the top of the procedure within the ATZ, once again if the cloudbase is reported as being above, or else be required to divert.