EASA AND THE IMCR - NEWS

[BEagle]

A few k and upwards is a fair estimate.

Unlikely to be quite that costly, but will depend upon agreed 'conversion report' terms. Conversion theoretical knowledge requirements would also need to be agreed.

One dark cloud on the horizon. Mutterings reaching me are that objections to the EIR have been lodged by a certain €uropean NAA - which clearly doesn't understand the old aircrew maxim "No stick = no vote!".

[peterh337]

Unlikely to be quite that costly

Not one to usually disagree with you Beagle but I cannot see that.

Look at my costs posted above for the IR conversion. I did that at 1400hrs TT, on my own aircraft.

The marginal cost of flying my TB20 is less than the rental cost of a C150 from a school (RF) never mind an FTO/ATO.

Virtually nobody will reach the standard for a UK IRT (as it currently stands) in less than about (very roughly) 30hrs - unless of course they have previous experience/training, or they do some unusual kind of focused training.

The only way to do it in less time is to drop the NDB stuff (leaving GPS and VOR and ILS) but nobody seriously thinks NDBs will be removed in Europe anytime soon. There are far too many around. But even then you are looking at a few k.

The IMCR could be done at the low end of "few k" but only because it tends to be trained minimally (usually in planes which are barely airworthy for VFR never mind IFR) and examined minimally. It does the job but only if people take care afterwards to get good on their own.

The EIR will not be much cheaper than the CBM IR, too. The difference in the syllabus is too small.

Ultimately the costs of doing these things are not significant on the scale of flying something IFR capable afterwards, and the biggest burden for most people doing them is not the cost but the exams and the various other hassles resulting from the "FTO" restrictive practices. The "IR business" is not really set up for private pilots and while I have seen really worthwhile positive changes when doing mine, including a very modern kind of IRT, changing the underlying culture will take more time.

[thing]

The "IR business" is not really set up for private pilots

Is that just a cultural thing or isn't it cost effective for FTO's?

[chrisbl]

The time to convert all depends. assuming on is confortable with flying the aircraft, its then down to being able to use the instruments and manage the mental agility required to keep situation awareness.

Flying with the autopilot following the magenta line is not always the best experience in preparation for the IR.

The flying required for the test is predicated on IFR in IMC (hence the screens) and as long as NDBs feature in the IAPs the it would be reckless for prospective IR pilots not to be able to fly them.

I recall when I did my FAA IR I specifically asked the examiner about flying an NDB procedure as that was what I was likely to find in the UK. I have to say he was surprised but agreed with the rationale and incorporated it in the test.

After that I always practiced NDB approaches as part of retaining currency.

[thing]

Speaking from my own very limited experience I found ILS and PAR approaches easy and NDB's a damn sight harder so I suppose it makes sense to keep up to speed on them. What's an autopilot?....

[peterh337]

and as long as NDBs feature in the IAPs the it would be reckless for prospective IR pilots not to be able to fly them.

I would partly agree, but OTOH everybody knows that NDBs are not tested if the JAA IR is done at certain southern European locations.

I say "partly" because nobody in their right mind will fly an NDB procedure using the ADF, when they have an IFR GPS with the OBS mode, which they must have to be legal in the first place in enroute CAS anyway.

[BEagle]

I say "partly" because nobody in their right mind will fly an NDB procedure using the ADF, when they have an IFR GPS with the OBS mode, which they must have to be legal in the first place in enroute CAS anyway.

No they don't have to have an 'IFR GPS'. See: EUROCONTROL - Requirements for civil aircraft

The first aircraft in which I had to fly NDB approaches without DME using just an RMI and stopwatch was the VC10. The only information you were allowed to be given by the navigator was drift and an estimated time from overhead the beacon to the start of the inbound turn. Hand flown NDB approaches aren't really that difficult if you have a decent gyro compass and RMI - but are the very devil if using a fixed-card RBI and DI.

[VMC-on-top]

I'm playing devils advocate but for those who currently have FAA IR's only, if there was no cost (or at least minimal cost a la JAR to FAA route), would you all (a) readily do the JAR / EASA IR without issue and (b) convert registration to G from N? If the answer is yes, is the biggest hassle factor in this the cost of converting, the time or the ground school / exams? I suppose what I'm asking in a round about sort of way is, do the benefits of having an aircraft on an N reg with the added hassle and hardship of constantly thinking what are EASA going to do to get rid of us next, outweigh the negatives of having the aircraft on a G reg and paying for annual IR renewals etc. - and more to the point, what are the comparable costs?

Finally, does anyone think there is any realistic chance that EASA may entertain the idea of a more staggered approach to these changes and propose genuine grandfathering of FAA IR's with a new line in the sand from say, 2014 / 2015 for their new proposals?

I've sat on the fence with which route to an IR for the last year and this issue just seems to get no nearer a certain conclusion - Europe in turmoil, huge backlash at Eurocrats etc. etc. - so I'm still no nearer knowing which way to jump and quite frankly, this looks like it could run on and on for years and years?

[wsmempson]

"Quote:
I say "partly" because nobody in their right mind will fly an NDB procedure using the ADF, when they have an IFR GPS with the OBS mode, which they must have to be legal in the first place in enroute CAS anyway.
No they don't have to have an 'IFR GPS'. See: EUROCONTROL - Requirements for civil aircraft

The first aircraft in which I had to fly NDB approaches without DME using just an RMI and stopwatch was the VC10. The only information you were allowed to be given by the navigator was drift and an estimated time from overhead the beacon to the start of the inbound turn. Hand flown NDB approaches aren't really that difficult if you have a decent gyro compass and RMI - but are the very devil if using a fixed-card RBI and DI."

Thanks for the link; in the navigation section of the requirements, there is a requirement for BRNAV compliance for flights within controlled airspace. I don't believe that an ADF and a stopwatch constitutes BRNAV compliance, regardless of whether you have a navigator feeding you drift and ETA calculations whilst you fly your VC10.

[peterh337]

I've sat on the fence with which route to an IR for the last year and this issue just seems to get no nearer a certain conclusion - Europe in turmoil, huge backlash at Eurocrats etc. etc. - so I'm still no nearer knowing which way to jump and quite frankly, this looks like it could run on and on for years and years?

There are two separate issues there:

- having to get the EASA papers
- moving N to G

The first has been done to death here and elsewhere... I've done mine as an insurance policy, just in case, even though it spread itself over much of the past year. It is possible (though IMHO unlikely) that EASA will give an EASA IR to every FAA IR holder, in 2014 or whatever. The French are proposing to do exactly that, after all. But if you look at the political history of the "JAA/Euro IR", I cannot see it happening without at least a flight test, which in turn means X hours training to pass that, etc, etc... and the general approach around the world to accepting another ICAO license is to sit the local air law exam also, so you have exams, so you have to study for those too..... you get the idea. Once you believe that a flight test will be required, and I do, it directly follows from that that a whole lot of stuff (basically some form of the present 15hr conversion route) will be required. And if there isn't a flight test on the day of conversion, there will be one at each anniversary because there is no way that politically EASA will accept the FAA 6/6 rolling currency. It's 100% politics and 0% safety - the FAA system is as safe or safer.

The second is something which EASA has fortunately backed away from, presumably because they are smart enough to realise that long term parking limits are unenforceable. I guess that the growth of the N-reg community will decrease greatly once the FAA IR route is undermined by the duplicate EASA papers requirement.

Like I always say: if you want a specific capability today then you need to get off your backside and get it now I started my PPL in 2000 and an "easier IR" has been just "around the corner" every day since then. The CAA IRT has been significantly modernised over the past year or two but the FTOs are still stuck firmly back in the olde days.

Re BRNAV, yes, in the days when Beagle was flying VC10s there was no BRNAV requirement Today, an IFR GPS is de facto mandatory for enroute IFR in CAS.

[BEagle]

Sorry, Saul but I fail to understand your comment about NDB approaches as having any relevance to en route BRNAV requirements. Anway, we actually had a PRNAV FMS system with Y-code GPS-augmented LINS plus a secondary INS also available. Which meant when flying NDB approaches in the -K variant you could 'cheat' by using the inbound NDB course set in the FMS, then select the compass 'source' to INS and use the CDI bar to give azimuth error whilst the RMI still showed the raw ADF value. Of course this GPS overlay was only a 'back up' and no-one really used it, did they...... The 'raw NDB' with only a stopwatch was something we only practised for operating into out of the way, austerely equipped aerodromes; some instructors also required it to be flown at night with no VASIs/PAPIs or approach lighting, just runway edge lighting, in order to practise for 'worst case' scenarios. Even more fun was a 3-engine NDB to go-around at night as this took you right over the station commander's house, so if you timed the go-around just right he would be treated to the 'sound of freedom' of 3 Conways at max thrust....

Ah - a de facto requirement for an IFR GPS now, is it? Whilst I would certainly agree that for any serious long-distance IFR cruising an IFR GPS system would be very highly desirable and people would be daft not to have one or two systems fitted, there still isn't any actual mandate to have an IFR GPS for en-route navigation. There are probably a few folk coping quite happily with a KNS80 or similar.

Use of the proposed EIR for serious 'airways touring' will certainly depend upon the availability of suitably equipped aircraft, so may well become the province of the private owner. How much of the rental wreckage available for hire these days actually has reasonable IFR kit or a reliable autopilot?

Finally, does anyone think there is any realistic chance that EASA may entertain the idea of a more staggered approach to these changes and propose genuine grandfathering of FAA IR's with a new line in the sand from say, 2014 / 2015 for their new proposals?

There is a considerable swell of opinion regarding conversion of third country IRs to require far less than the current requirements. IAOPA(EU) has proposed:

IAOPA(EU) considers that the demonstration of acquisition of knowledge can be satisfactorily assessed by the Examiner during the pre-flight preparation and conduct of the C-B IR Skill Test, supplemented if necessary by oral questions. It should be noted that the requirement for the holder of an IR issued in compliance with the requirements of Annex 1 to the Chicago Convention to sit further written theoretical knowledge examinations when converting to a EU IR is widely regarded as an expensive waste of time, which serves very little practical purpose. An Examiner will be able to make a much more pertinent assessment of the applicant’s relevant knowledge; we strongly recommend that oral assessment in the manner described should satisfy the requirements.

IAOPA(EU) considers that the requirement for 100hrs of instrument flight time as PIC is excessive. Pilots with considerable flight time under IFR would be disadvantaged; there would be safety implications for a pilot to fly deliberately in IMC, with the attendant risks of turbulence and icing, merely to reach the 100hrs requirement. We therefore recommend that sub-paragraph 8(d) is reworded as follows:

8 (d) have a minimum of at least 50 hrs of flight time under IFR as PIC on aeroplanes.

We remind the Agency that the C-B IR is ‘competency based’ by definition and that, although some relevant experience is clearly needed, the Skill Test will provide entirely sufficient assessment of the applicant’s suitability to be issued with the C-B IR.

[soaringhigh650]

Saul but I fail to understand your comment about NDB approaches as having any relevance to en route BRNAV requirements

I think Saul is saying that en-route BRNAV requirements requires much more than just one NDB. Therefore IFR aircraft will be equipped to meet those requirements.

It therefore sounds strange that you get aircraft equipped with only an NDB to fly the approach. (as how can you fly the approach without flying en-route?)

[wsmempson]

What I believe we are talking about, Nick, is "EASA and the IMCR - News" as opposed to what you might have been doing 30 years ago in a military VC10, with or without the assistance of a navigator.

Today, the expectation is rightly that there is other equipment that is available (and indeed required) for the safe execution of civilian GA flights other than and NDB and a stopwatch. The BRNAV compliance point was made because
a. It was made in the link that you posted

and

b. In order to arrive at the place where you are going to make an instrument approach (and if you choose to do that with only a stopwatch and an NDB, be my guest) the likelihood is that you will need to be BRNAV compliant to arrive there. An NDB and stop-watch alone will not fulfill that function.

[peterh337]

Ah - a de facto requirement for an IFR GPS now, is it?

There are only two ways to comply with BRNAV:

1. INS (which is how airliners do it)

2. IFR GPS (the only relevant means for GA including most light jets)

Well, you can get the old KNS80 BRNAV certified but it will be useless as soon as ATC give you a DCT to a waypoint which is 200nm away (which they do all the time; ATC all over Europe treat all waypoints as RNAV regardless of whether it is a navaid e.g. SFD or a virtual one like ORTAC).

IAOPA(EU) considers that the requirement for 100hrs of instrument flight time as PIC is excessive

Yes that proposal is ludicrous, but it's obvious why it was put in: to pacify the FTOs which are going berserk because if you make conversion too easy, it will make sense for airline pilot wannabees to get a CPL/IR in the USA first and then come back to convert here. This would all but wipe out the FTO business.

So various GA groups are trying to go for something smaller e.g. 50hrs instrument time, which would make conversion viable for an FAA PPL/IR holder who actually flies, while maintaining a reasonable barrier to the "21 year olds" who want to be airline pilots. Whether EASA will listen I have no idea.

On average, to reach 100hrs instrument time you will be looking at someone with 1000hrs total time, and even that is assuming that he has done a lot of dual time e.g. IMCR, FAA IR, and done a lot of IFR trips in bad weather. That would make the conversion route worthless for most private pilots. I have ~150hrs myself, 1400hrs TT so I would be OK but I don't think this is fair.

That's the trouble with aviation. No matter which way you turn, you bump into the same old axe grinders. You go to some aviation show and queue up for a sandwich and the people in the queue before and after you are the same ones as the year before And MONEY always talks.

[soaringhigh650]

There are only two ways to comply with BRNAV:

1. INS (which is how airliners do it)
2. IFR GPS (the only relevant means for GA including most light jets)

Ain't there three more:

3. VOR/DME,
4. DME/DME, and
5. Loran C

?

[BEagle]

In order to arrive at the place where you are going to make an instrument approach (and if you choose to do that with only a stopwatch and an NDB, be my guest) the likelihood is that you will need to be BRNAV compliant to arrive there. An NDB and stop-watch alone will not fulfill that function.

Of course I wouldn't ever wish to fly an NDB approach if there was any other option available! But we had a training requirement to do so.

It will be interesting to see whether the IAOPA(EU) proposal is given a fair hearing by the Comment Response Team - or whether we'll end up involved in some souk-haggling nonsense.

[peterh337]

Ain't there three more:

3. VOR/DME,
4. DME/DME, and
5. Loran C

Not in Europe.

[soaringhigh650]

Really? Hmmm...

For ECAC airspace the primary sources of navigation information are VOR/DME, DME/DME and GPS.

[peterh337]

I'd love to answer but it would be another long one so I will leave it to somebody else while I get onto the VAT return

[BackPacker]

Okay, I'll try. Soaring, the list you referred to is the INPUT into a navigation system that provides BRNAV capabilities. Using that input the system is then able to compute its position, and uses that position to navigate you somewhere else.

Unless your mathematical abilities are so good that you are as quick and accurate as the average microchip that does this calculation, and thus you are able to calculate your exact position from raw VOR/DME input, just having two VORs, a single DME and a single ADF does NOT provide you with BRNAV capability.

As Peter said, there are only two systems (GPS and INS) that have the ability to continuously calculate an accurate position, and supply you with a heading, distance and ETA to an arbitary point in space. Of these two, only GPS is feasible in a light aircraft.