EASA AND THE IMCR - NEWS

[Justiciar]

do things the ICAO way

This is a bit like "Health & Safety" and "Data protection" which is wheeled out by jobsworths and bureaucrats whenever they want to justify some crass rule or rules, without actually understanding what they are talking about. EASA have not worried too much about ICAO in their plan to require EASA paperwork to fly "N" reg in the EU, which is not provided for in the Convention in that form, i.e basing it on place of establishment as opposed to nationality.

Why? What's the hardest aspect of flying IFR? Is it sitting on an airway staying within 5 miles of the centreline for hours at a fixed altitude? Surely not. Rather, it's flying the approaches. So if you're going to permit pilots to have privileges before they've done the full training to fly IFR in the form of the IR, doesn't it make sense to allow them to do the easy part (enroute) but not the hard part (approaches)?

I am sure you are right, which makes the proposal even more difficult to understand. Allowing a pilot to fly when he is trained just for the easy bits seems to me to be a recipe for disaster. To my mind a rating should be focussing on that most difficult aspect, ie getting down safely in IMC using an instrument approach. The holder of an EIR will not be able to practice his skills by doing instrument approaches (other than with a safety pilot under VFR); he will only be able to do one in a real emergency, when his currency will be almost non existent. That seems to me to be the height of stupidity.

You may say, if you want that do the IR, but that brings us back full circle to the arguments and issues why so few pilots in Europe have an IR.

The IMCR has the right balance in my view, with extensive privileges outside class A and the option of letting down safely and of practising those skill regularly. That suits the flying pattern of many pilots in the UK. With the EIR the safety of any flight will now be determined by the accuracy of the met forecast at the other end!

[soaringhigh650]

With the EIR the safety of any flight will now be determined by the accuracy of the met forecast at the other end!

Just like any other PPL.

But the IMCR and EIR both achieve different objectives.

and the option of letting down safely and of practising those skill regularly

With the IMCR, I hear you don't have to fly any instrument approach or be checked by anyone for almost two years. Then you can legally take off, hack through cloud, and fly an approach to a 300ft cloud base?

Sounds like a death rating to me.

[thing]

With the IMCR, I hear you don't have to fly an instrument approach for two years. Then you can legally take off, hack through cloud, and fly an approach to a 300ft cloud base.

Sounds like a death rating to me.

Well if you're dumb enough to actually do that then I suppose it is. As with all 'legally defined' aspects of flying you have to exercise your wisdom. I'm a new PPL, my legal limit for vis is 5k. There's no way I'd even drive to the airfield if it was only 5k, likewise unless you want to appear in the Darwin awards you wouldn't shoot an ILS to 300 ft if you hadn't done one for two years, legal or not.

[KeyPilot]

Reading now.

I agree with others that say the idea of allowing en route IMC flight but not intended approaches is wrong. Indeed in my view it is utterly preposterous.

The preamble to the report states that the EIR will allow PPLs "to cope with unforeseen deteriorating weather conditions". This is exactly what it will not do. The principle area of risk is for weather at destination to be below expectation; and this rating does not help with that in prohibiting IMC approaches (unlike the UK IMCR). The idea of allowing "emergency" approaches is a nonsense - in an emergency, a Commander may take any decision he sees fit in the safety of himself, his aircraft and those on board. For a rating to be useful, it must contain priviledges which may be regularly exercised and practised - otherwise (especially with IF) they will be rusty and dangerous.

I am shocked at this glaring shortcoming in a proposal from EASA. Or maybe I shoudln't be. The EIR is retrograde step, and we should ensure that EASA gets as many responses from the UK GA communty as possible pointing this out.

Back to reading.

[soaringhigh650]

Well if you're dumb enough to actually do that then I suppose it is.

Same idea with the EIR then. Are you dumb enough to arrive at an airport when the conditions ain't VFR?

Many have complained about over-regulation from the regulators over the years.
Are some guys complaining about under-regulation this time?

[flybymike]

I'm a new PPL, my legal limit for vis is 5k.

Only inside controlled airspace.
Otherwise 3k

[thing]

Slip of the finger there. 3K, but I mean, what low hour PPL would take off in 3k vis?

[oldspool]

I think the proposals are a hugely positive step and I hope that the NPA receives strong support.

Existing IR = 55 hours + a load of theory.

New Modular IR = 40 hours + reduced, targeted theory. Plus credit for previous experience (competence based). In addition, signs that IMCr privileges transfered and credited towards both E-IR and full IR.

Lots of whinging about no instrument approaches for the E-IR. If you want those privileges, do the full modular IR - its now a realistic prospect.

You do 15 hours instruction for the E-IR, excercise the privileges of the E-IR for 15 hours PIC (IFR), then you only need [potentially] 10 hours instruction at an ATO for the full IR. That's 25 hours instruction total (which is where the cost is)!!!

Even better, do your IMC now and theres a good chance that initial 15 hours for the E-IR will be reduced.

It's certainly a lot better for those who want a full IR.

[Justiciar]

Just like any other PPL.

No. With a PPL you are not able to fly IFR in IMC with the presumption (hope?) that you destination will be VMC, but without the skill to get yourself down if it is not. Yes a PPL can get caught out but the chance must be greater with an EIR where you can legally take the decision to fly a substantial part of the route IMC.

With the IMCR, I hear you don't have to fly any instrument approach or be checked by anyone for almost two years. Then you can legally take off, hack through cloud, and fly an approach to a 300ft cloud base?

... and you can legally get into an aircraft once a year with no checkride. But most don't and most serios IMCR pilots practice their skills. They can shoot as many ILS or non precision approaches as they wish in IMC. The EIR pilot cannot do this other than in VMC/VFR, so he is unable to practice an essential skill which sits with enroute IFR flying. His chance of practising his "emergency" approach procedure will be limited to his annual revalidation.

[dublinpilot]

Same idea with the EIR then. Are you dumb enough to arrive at an airport when the conditions ain't VFR?

How would you know? You will have sat above the cloud, or in it practicing your IMC skills, for the past three hours, fat dumb and happy, knowing that the forecast for your destination was good VFR, and blissfully unaware that the airport is now covered in fog or low cloud.

If you were flying VFR you would have seen the changes happen, but because with your EIR you were on top or in the cloud, you wouldn't have seen what was happening below.

I think there is a lot of good in these proposals. I can understand why they wouldn't want full approach priviliges in the EIR (to distinguish it from the full IR) but I agree with justiciar that the lack of any approach priviliges will feature in the statistics in the future.

In terms of drawing a distinction from the full IR they could easily have left out all IFR departure proceedures, and all IFR arrivals apart from one type. The one type that needs to be tought could be specified in the leglisation or left up to the canidate to choose. Having to learn only one type of approach shouldn't increase the time requirement too much. Once they needed more than one approach type they'd need to full IR.

This would ensure that the EIR holder always would have one way out if the forecast turned out to be wrong.

[dublinpilot]

As I understand it the purpose of the EIR is to allow those wishing to do an IR to cut down the dual training. They can do the EIR course, and then do much IFR time by themselves as PIC and then only a few hours more for the IR course.

Is this dual time which will be replaced by PIC time really going to work like that? As I understand it the EIR will only be allowed to fly enroute IFR, and all the IR pilots here seem to be saying that that's the easy part.

So will the reduction in dual time requirement really result in a reduction in actual dual time required to pass or will it simply mean that compulsory dual time will be replaced by voluntary dual time?

[bookworm]

Allowing a pilot to fly when he is trained just for the easy bits seems to me to be a recipe for disaster. To my mind a rating should be focussing on that most difficult aspect,

By that argument, why would any pilot ever be allowed to fly without a full instrument rating? Isn't what the IR trains you for more difficult than bimbling around VFR? But what we do, is give pilots privileges to match the activities they have been trained for.

[bookworm]

Is this dual time which will be replaced by PIC time really going to work like that? As I understand it the EIR will only be allowed to fly enroute IFR, and all the IR pilots here seem to be saying that that's the easy part.

Well the IMC-rated pilots here seem to be saying that you can train pilots to fly both enroute and approaches in 15 hours for the IMC rating. If that's the case, why not do so, and allow the remaining hours to be a form of hour-building towards the ICAO minimum of 40 hours IF for the IR? Just as you have to build 70 hours PiC for a CPL and 1500 hours for an ATPL.

I don't have a problem with the concept of issuing a pilot with 15 hours of IF training with an IR if they can pass the skill test. But unfortunately, arguing that we should simply ignore the ICAO requirement for 40 hours is not going to fly in Cologne.

[bookworm]

For a rating to be useful, it must contain priviledges which may be regularly exercised and practised - otherwise (especially with IF) they will be rusty and dangerous.

By the same token, would you advocate giving PPLs with no instrument qualification the privilege of flying solo into IMC so they can practise an inadvertent encounter with cloud? We do, after all, spend a few hours training them to keep it the right way up in cloud in the basic PPL syllabus.

[bookworm]

How would you know? You will have sat above the cloud, or in it practicing your IMC skills, for the past three hours, fat dumb and happy, knowing that the forecast for your destination was good VFR, and blissfully unaware that the airport is now covered in fog or low cloud.

And with an IR you can have sat above the cloud, or in it practicing your IMC skills, for the past three hours, fat dumb and happy, knowing that the forecast for your destination was above aerodrome operating minima, blissfully unaware that the airport is now covered in fog or low cloud that takes it below Cat 1 minima. If that is such a likely occurrence, where are all the bodies?

Having to learn only one type of approach shouldn't increase the time requirement too much. Once they needed more than one approach type they'd need to full IR.

Interesting idea, but I think you exaggerate the difference between "approach types". Today, there is admittedly some minor difference in flight technique between precision and non-precision approaches. But in a few years time, there will be little practical difference between approaches. There will, in effect, be only one sort of approach to fly, the one where you keep the crossed bars in the middle all the way down. The differences will be in ground school, not flight procedures.

[AN2 Driver]

Folks,

there is plenty to gain from an EIR. Plenty. I am appalled at the shortsightedness expressed in some commentaries here, please take a moment to check what this means and try to see it also outside the UK focus only. Airspace in other countries are very different. While I myself would rather go for the full IR once it becomes this accessible (and it remains to be seen if it will), I'd take an EIR anytime and with enthusiasm as it will allow me to do most of th enroute portion of the flight legally in IFR.

THAT means a couple of things and only few of them are related to real IMC.

Any of you ever flown VFR in Italy? Bloody pain in the neck with several A airspaces all over the place, Milano, Rome. Coming from the alps one needs to descend to 2000 ft AGL in the turbulence of the heat of the area there, in the murk and dust with maybe 5 km vis whereas in FL90 there is bright sunshine. Or Rome, where you need to fly 1500 ft above WATER. Hell, I'll take the privilege to fly these things legally with an EIR ANYTIME to finally be able to route along airways and forget about all the special use airspace which make flying VFR often enough a question of a great circle index in the 150ties. Not only Italy, there are other places like this where controlled airspace is all over the place but with nice straight airways going right through them. I'd love to use those rather than constantly having to circumnavigate huge areas.

Think. This is a huge chance, especcially with the proposed modular system where you can get the EIR first, get comfortable with it and then progress to a full IR, which in any event is superior to both the IMCR and the EIR.

I think if the JAR and before the national IR had ever been this accessible to the PPL pilots, there would not really have been a need for an IMCR in the first place. For us outside the UK, there never was an IMCR. So this proposal would be a mighty breath of fresh air.

Folks, let's not spoil this by hanging onto things which will not be there anymore in any case. Rather let's use the chance to expand our privileges and, for those who can live with the EIR do this and for the others go for the full IR. I fully intend to.

I used to have a national IR but it's expired (more than 7 years) so I need to do the theoretical part this way or the other. But I will wait now until we see what happens with this proposal, which I believe is a lot easier to fulfill than the JAR doctorate IR.

Best regards
AN2 driver.

[mm_flynn]

Originally Posted by dublinpilot

How would you know? You will have sat above the cloud, or in it practicing your IMC skills, for the past three hours, fat dumb and happy, knowing that the forecast for your destination was good VFR, and blissfully unaware that the airport is now covered in fog or low cloud.

???
With an EIR (or IR for that matter), Sitting up on top you can see if the forecast BKN/SCT is there from 100 miles out. If there is an overcast you get the local weather 70 miles out and can contemplate which diversion options to choose at leisure and safely thousands of feet above the MSA.

On the other hand a PPL (UK style needing to be under the clouds) discovering the weather close in on them can get pushed closer and closer to the ground and then find themselves with limited options, limited time, close to the ground. The stats clearly show this is a bad place to be.

[Pace]

How would you know? You will have sat above the cloud, or in it practicing your IMC skills, for the past three hours, fat dumb and happy, knowing that the forecast for your destination was good VFR, and blissfully unaware that the airport is now covered in fog or low cloud.

And with an IR you can have sat above the cloud, or in it practicing your IMC skills, for the past three hours, fat dumb and happy, knowing that the forecast for your destination was above aerodrome operating minima, blissfully unaware that the airport is now covered in fog or low cloud that takes it below Cat 1 minima. If that is such a likely occurrence, where are all the bodies?

Bookworm

And here lies the problem. The guy flying along on top will NOT be able to get accurate weather for his cloudbreak as getting actuals for his destination will not give him the cloud cover or vis for his descent 20 or 30 miles out.
Infact getting weather for his destination where they give overcast at 3000 feet and 10k plus vis could be 1000 overcast and 3000 metres in rain 30 miles out where he is descending so I ask with the EIR whats the point of getting destination weather when you cannot use that airspace in anger?
Destination weather is meaningless for your cloudbreak point!

What is the point of getting Barcelona actuals if your home made instrument approach/cloudbreak isnt at Barcelona but 30 miles away over hefty mountains?

Infact it makes a legal mockery of stating that you can only fly on top if your detination is forecast as good because your destination is not your destination as far as weather goes if you get my jist?

The only safe way is to descend on a procedure or with radar into an area with accurate weather reports and preferably down an ILS not with some half baked home made cloudbreak into an area you have no clue on what lies below weather or otherwise?

The other blatant problem is the PPL who gets his weather at destination happily climbs on top smelling the roses knowing Barcelona is Cavok when half way enroute over france his engine coughs or he has some other mechanical, electrical, or fuel problem? Oh dear the area he is over and all the airfields below are all giving 300 to 500 foot overcast with 700 to 1500 metre vis? what does the said EIR do then?

Pace

[mrmum]

With the IMCR, I hear you don't have to fly any instrument approach or be checked by anyone for almost two years. Then you can legally take off, hack through cloud, and fly an approach to a 300ft cloud base?

Sounds like a death rating to me.

Perhaps, if you choose to act stupidly. It's actually just over two years, up to 25 months to be exact. However, that's not much different to a JAA-PPL with SEP(L) class rating, you could choose not to fly for a year and 51 weeks, then jump into your sole-owned aircraft in 3km vis. All perfectly legal, but not sensible or safe.

[flybymike]

The other blatant problem is the PPL who gets his weather at destination happily climbs on top smelling the roses knowing Barcelona is Cavok when half way enroute over france his engine coughs or he has some other mechanical, electrical, or fuel problem? Oh dear the area he is over and all the airfields below are all giving 300 to 500 foot overcast with 700 to 1500 metre vis? what does the said EIR do then?

What would a vanilla PPL flying perfectly legally VFR on top (outside the UK) do?