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EASA AND THE IMCR - NEWS

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Old 8th Nov 2011, 21:10
  #341 (permalink)  

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I'll repeat my earlier point. What is ATC supposed to do with someone who reaches the IAF (or FAF) expecting to be VMC who isn't? Presumably push them into the Missed Approach? That means that most traffic will be descending to 200' to a successful landing and a few will be clogging the system by flying from the FAF to MAP, at 2,500' then starting a missed approach already 2,300' too high...it's horrible to contemplate.

If you dump them out of airways just far enough from the zone boundary to descend outside controlled airspace such that they can call visual for a visual approach it makes much more sense.

If they reach MSA while still in IMC they then have to assess their options, just like someone going to a VFR field today does. They might decide to push it, because they are certain of their position, or they might fly out to sea to descend, or they might declare an emergency and get shepherded down an approach.

These are all things we do at the moment and require no new regulation, familiarisation or training for ATCOs.

You know it makes sense!
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Old 8th Nov 2011, 21:51
  #342 (permalink)  
 
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Timothy

I cant agree. Dumping a pilot out of the airways is never a good idea. He finds himself with a fragmented service at best ocas and possibly no service at all scrambling around low level with potentially no way of getting back into the system and working out a diversion on the fly. If the belief is eir pilots are some way short of the ir skill set this is a recipe for disaster.

No the pilot needs a reliable point to which they can descend pretty much assured of a further visual descent thereafter. Some point, any point, in the procedure to which they can be vectored would work as long as that point is within reason with the cone of the airport metar. In that much 9 times out of ten the pilot knows whether or not he can complete the procedure in vmc. If he cant before being dumped he can continue within the system to a suitable alternative.

I dont agree this would cause a problem. It is not that unusual for a pilot to request a visual approach once in vmc at a point in the procedure. I suspect most atc would be able to handle some traffic doing so. Moreover in reality i dont think any of use believe there will be droves of pilots going to the busy commercial airports as a result of the eir. Most pilots stay away because of the cost and hassle as it is - that will not change. The mid sized regional airports are hardly pushed it seems to me and have the flexibility to deal with the odd eir requesting vectors to descend and brk for a visual approach.
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Old 8th Nov 2011, 22:12
  #343 (permalink)  

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We are not talking about "dumping". We are talking about the perfectly normal procedure of an aircraft leaving controlled airspace either laterally or, more commonly, by descent. It is what every aircraft bound for an airfield in Class G does at the moment. It is SOP.
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Old 9th Nov 2011, 06:19
  #344 (permalink)  
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Timothy - I'm not defending the EIR approach, which I disagree with, but presumably the pilot, just as he/she would when descending to DH and finding themselves still in IMC, will divert to their alternate? The difference is that they no longer have to fly the missed approach procedure.

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Old 9th Nov 2011, 06:57
  #345 (permalink)  

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I'm not defending the EIR approach, which I disagree with, but presumably the pilot, just as he/she would when descending to DH and finding themselves still in IMC, will divert to their alternate? The difference is that they no longer have to fly the missed approach procedure
But if they don't fly the MA what do they fly? That is my point.
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Old 9th Nov 2011, 07:43
  #346 (permalink)  
 
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Timothy to be fair it was you who introduced the dumping concept.

This implies returning from france at fl65 to be told by london to continue with london info because you are too low for an airways clearance. Descending ocas for a class g arrival is a diiferent matter. You have not exactly be dumped but have elected to leave the system for reasons of necessity.

Never the less i dont follow your concern about the pilot flying the ma. As matters stand if the pilot is not visual by the faf he is going elsewhere. At that point he is some way away from the final approach track so the ma is hardly appropriate. As he is ocas he would presumably inform at that he was not visual at the faf and would continue on heading x with a request to climb to y and depart own navigation on a heading of z for his diversion.

In my opinion i come back to the point i made earlier it is just daft that a pilot would be persuaded to leave cas on the strength of a metar for a descent to a point that might be miles away from the airfield. If on the other hand he knew the metar coincided with weather at the point at which he was descending he would make a sensible judgement call as to whether or not he expected to be visual by that point and if he didnt before leaving the comfort of cas would go elsewhere.

Unless you know differently it seems to me most airports with an iap in class g have almost no traffic when the weather is poor and i doubt if it is that poor the eir holder will have much chance of being visual by the faf. Never the less if he elects to prove the metar wrong i doubt he will cause at too many problems.
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Old 9th Nov 2011, 07:58
  #347 (permalink)  
 
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I'll repeat my earlier point. What is ATC supposed to do with someone who reaches the IAF (or FAF) expecting to be VMC who isn't? Presumably push them into the Missed Approach?
The way I understand the EIR concept is that an arrival is to be made VFR in VMC. Is it not logical to expect that if a pilot is permitted to get into and fly within IMC, that he/she cannot, at a suitable time, organise a descent to return to VMC? It suggests a little extra planning would be required, which realistically isn't too far from what IMCR or VFR only pilots are doing already. Should the met forecast not agree with the limitations of our ratings we don't fly the route or flight, or we do something else.

If the weather is different from the met office fairy tale then of course a diversion to an aerodrome maintaining VMC would be sensible. I agree that allowing an EIR to descend to 2500' or whatever to 'go missed' is silly, pointless and dangerous. The EIR NPA caveat of having an alternate field planned that is VMC should be mandatory (it probably already is banter away!) in this sense. Perhaps even to the extent that the weather minima must be VMC for the hour prior to landing +1. I was going to suggest CAVOK but enforcing this would render the EIR useless in general.

I'm sure there are very few of us actually supporting it, but the EIR seems inevitable; recent debates are on how this rating could work rather than fighting against it.
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Old 9th Nov 2011, 08:06
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I think the eir will exist and i hope it will evolve into something better, assuming it is found to have shortcomings.
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Old 9th Nov 2011, 09:15
  #349 (permalink)  
 
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We are not talking about "dumping". We are talking about the perfectly normal procedure of an aircraft leaving controlled airspace either laterally or, more commonly, by descent. It is what every aircraft bound for an airfield in Class G does at the moment. It is SOP.
Timothy, that may well be SOP in the UK, where there are large swaths of class G, extending well above the MSA. But that's not true of large portions of the rest of Europe, where you may find large swaths of class E, with the bottom well below the MSA.

So how is this going to work then, assuming the cloudbase is at or below the MSA? There is no written IFR procedure for a descent to VMC below the MSA, with the sole exception of the current approach procedures themselves. Or are you going to assume that ATC is going to let you descend in IMC and in controlled airspace, below the MSA, somewhere randomly off-airport (possibly in a non-radar environment)? Or are you going to assume that specific off-airport descent procedures will be designed for the benefit of EIR holders?

I agree with Fuji. The EIR holder has to be able to work in the current system of airways, MSA and instrument approaches. If the EIR holder is not deemed sufficiently proficient to fly an instrument approach to published minima, then higher minima need to be establised (either expressed as an AAL, or the IAF, or the FAF, or the top of the glideslope, whatever) but laterally the only location where the EIR holder can fly below the MSA is on the instrument approach. And if they don't reach VMC by the time they reach whatever minima are established for them, they fly the missed approach procedure to get back above the MSA.

Particularly in a non-radar environment there is no way that ATC can handle anything other than that. Except in situations where airspace is structured like the UK, where ATC can let you descend above the MSA to some place outside controlled airspace, and then take their hands off you. But you can hardly call that "handling".

Last edited by BackPacker; 9th Nov 2011 at 11:03.
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Old 9th Nov 2011, 09:38
  #350 (permalink)  
 
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This is assuming that the EIR is going to be using the same approaches as the IR traffic.

It would be relatively simple to design a cloud break procedure to comply with the EIR rules which then delivers the aircraft to some point which is away from IR traffic and will allow the EIR to then come in VFR without getting in the way.

It would only take one procedure and as it will be above MSa it wouldn't require expensive surveying etc to design.
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Old 9th Nov 2011, 10:12
  #351 (permalink)  
 
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It would only take one procedure and as it will be above MSa it wouldn't require expensive surveying etc to design.
I may be daft but why would you need a separate procedure to descend to the MSA? You can just descend on track to the MSA, can you?

Anyway, adding an EIR cloud-break procedure for each of the thousands of airports in Europe is still going to be a lot of money. And I don't think it's far from trivial as there has to be some sort of STAR towards that procedure from all directions, and some sort of missed-approach procedure that brings you back into the airways (like a SID).

And obviously those STARs, the cloud-break procedure itself and the missed approach procedure all need to either tie-in neatly, or remain totally separate from the current full-IR procedures, so that they can be executed in parallel or sequential, without causing conflicts, even in non-radar situations.
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Old 9th Nov 2011, 10:25
  #352 (permalink)  
 
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Nobody is going to be designing special procedures for GA. It's simply not going to happen in Europe, in much of which GA is all but nonexistent anyway.

This has been done many times here but the main issues in the "IFR department" are not aviation related but political.

Being political does not make them any less real or problematic, of course.

There is also a lot of emotion around the whole subject of IFR, nearly all of which is not based on any safety data and is propagated by old prejudices. Nearly all commercial aviation runs in the IFR system, and the amount of work one has to do to become an ATP makes everybody involved very guarded about any newcomers into the system who appear to have done less to get in than the present incumbents.

For European IFR, as approved by the European axe grinders, there are certain things which are absolutely not negotiable:

1) Whatever you do, a "Euro IR" must not be like the FAA IR. "FAA", "USA" etc are dirty words in European aviation regulation, and in most of the training system for both commercial pilots and ATCOs. So any new IR has to differ in key respects. But EASA has ostensibly nailed its flag to the "ICAO" mast and while this is the key factor here which is enabling progress, one can push this only so far.

2) One is not allowed to state the truth that the UK IMCR is a full IR in all but name, and only the UK's extensive Class A separates the "amateurs" from the "pros". An IMCR holder who has been trained by a real IFR-flying instructor will be able to fly any published approach plate for any airport in the world. SIDs and STARs are not covered but are relative trivia. Nearly the entire difference between the IMCR and the IR is the currency of the holder and his aircraft capability and equipment, but that is nothing to do with the bits of paper. But the only other Euro country with lots of Class A is Italy, so the IMCR concept is not transportable to the rest of Europe because it would be a full IR in most of it. The 1800m vis is a non-issue most of the time (it is practically fog). I know the JAA IR flight test is harder than the IMCR flight test, but the JAA IR flight test is also a lot easier in say Spain or Greece than it is in the UK...

3) Speaking of the EIR, if you got too close to allowing approaches, it would be a full IR, but you can't do that

I have no inside track on what is going to happen, but I suspect that the EIR may get tossed into the melting pot at the end, as a quid pro quo to get the CBM IR accepted. One does the same thing in Planning applications In that respect, the EIR is vitally important, otherwise any difficulties on the CBM IR will result in its termination, and in the continuation of the present ridiculous 50/55hr JAA IR route which very very few private pilots have been doing since JAA came along in 1999 (most went N-reg).

There is a long way to go on this stuff. The CBM IR is going to become a political hot potato for some other reasons.

Last edited by IO540; 9th Nov 2011 at 10:38.
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Old 9th Nov 2011, 11:20
  #353 (permalink)  
 
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Yes you could but that would then get in the way of the other procedures/ vectoring.

Just bung a line off from the end point of a star to some place that they arn't going to get in the way and thats your procedure designed. It won't cost a fortune.

I agree its political as most airports and airlines don't want slow IFR traffic getting in the way of the commercial inbounds. They will suffer it enroute because the levels being used in general aren't the ones they want. I think most will put up with getting you to the end of a star or getting somewhere visual then hopefully you will dissappear of to some other airport without any approach aids. If not you are stuck orbiting until they have a hole to get you in.
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Old 9th Nov 2011, 13:30
  #354 (permalink)  
 
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It's not even political in any operational sense.

IFR GA has never been an operational issue in Europe, because

- ATC nearly always give jets traffic total priority on getting airborne, even if it means keeping light GA at the hold for an hour

- the lower airways in Europe are practically devoid of traffic (easy to do a 700nm leg without getting visual with another plane, of any kind, within a few k feet in altitude)

- the Eurocontrol routings keep lower airways traffic well away from terminal areas

- ATC keep it well away from other traffic in terminal areas, which is not hard because the climb and descent performance of the two is very different

- it goes mostly to different airports, because the big ones have set up "mandatory handling" cartels with silly pricing

- there is very little of it, due to poor utility value of GA in Europe

The politics are to do with professional pilot status (tied to the IR, instead of being tied to the ATPL like it is in the USA), FTO profits (or lack of them, presently), and stuff like that.

Last edited by IO540; 9th Nov 2011 at 14:04.
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Old 9th Nov 2011, 14:20
  #355 (permalink)  
 
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even if it means keeping light GA at the hold for an hour
I think my record is about 40 minutes. Can anyone improve on that?
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Old 9th Nov 2011, 14:44
  #356 (permalink)  
 
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You could try Valencia... it's fun to hear the Ryanair pilots say to each other "welcome to the 3rd world of Europe"
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Old 9th Nov 2011, 14:59
  #357 (permalink)  
 
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I think my record is about 40 minutes. Can anyone improve on that?
I once spent 20 minutes waiting just to cross the runway. Because ATC was in the habit of giving landing clearances 4 nm out. Does that count too?
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Old 9th Nov 2011, 15:30
  #358 (permalink)  
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35 minutes, so not quite at the lead. March 2006, Coventry, whilst they reconfigured the runway for arrival of whatever budget airline they had operating there at the time. (BMI?)

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Old 9th Nov 2011, 18:48
  #359 (permalink)  
 
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Only been held twice. The first was 30 mins along a very thin taxiway where a CPL/ME student was doing run ups; you could have defined the concept of 'Air Rage' by my vocalisations!

The second was only 20 mins at the hold due to a large jet flying an 'ILS against the stream to circle to land' manoeuvre. Interesting to watch so no grumbles.
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Old 10th Nov 2011, 07:56
  #360 (permalink)  

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My worst was being on minimum fuel and being told by LHR that the hold would be at least 40 minutes, so shutting down, and then being asked "are you ready immediate?"

The answer was yes, of course. The last call in the flight deck on the ground was "Take-off checks complete - rotate!"
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