EASA AND THE IMCR - NEWS
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>>What would a vanilla PPL flying perfectly legally VFR on top (outside the UK) do?
The same others do when riding on a 'normal' IFR flight plan? Or at night or over open water?
If he has a chut, it' a perfect moment for pulling. If he doesn't, minimum airspeed, control the airplane, after coming clear look for options.
My instructor in the US told me once: in case of an emergency at night, turn on your landing lights. And if you don't like what you see, turn them off again.
The same others do when riding on a 'normal' IFR flight plan? Or at night or over open water?
If he has a chut, it' a perfect moment for pulling. If he doesn't, minimum airspeed, control the airplane, after coming clear look for options.
My instructor in the US told me once: in case of an emergency at night, turn on your landing lights. And if you don't like what you see, turn them off again.
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Fuji
Where is your source for that? So you are saying that a PPL with the EIR will be allowed to fly the STAR onto an instrument approach and descend to SSA on that approach?
What happens then? He breaks off and causes chaos to all the inbound RyanAirs and EasyJets flying into Alicanted, Bilbao, Malaga etc.
Say said pilot is flying the procedure into Bilbao where there is a step down approach over very high ground he descends to SSA and nothing or even worse gets partially visual with scattered broken cloud below.
Doesnt sound very safe or practical to me.
There are 67000 FAA pilots in Europe! a lot with full FAA IRs flying perfectly safely in a safe invironment from take off to touchdown.
They are using a rating which is statistically equal to the JAA IR.
EASA the so called safety body could quite easely copy the FAA IR as are the french but they wont!!! Why? matters of safety?
To expect a PPL to be good enough to climb up through cloud navigate on Top and then to be abandoned to his own devices on a home made cloudbreak with NO possibility of getting accurate weather for that cloudbreak is lunacy.
IMO this is all a complete and ridiculous NON SENSE.
Pace
Where is your source for that? So you are saying that a PPL with the EIR will be allowed to fly the STAR onto an instrument approach and descend to SSA on that approach?
What happens then? He breaks off and causes chaos to all the inbound RyanAirs and EasyJets flying into Alicanted, Bilbao, Malaga etc.
Say said pilot is flying the procedure into Bilbao where there is a step down approach over very high ground he descends to SSA and nothing or even worse gets partially visual with scattered broken cloud below.
Doesnt sound very safe or practical to me.
There are 67000 FAA pilots in Europe! a lot with full FAA IRs flying perfectly safely in a safe invironment from take off to touchdown.
They are using a rating which is statistically equal to the JAA IR.
EASA the so called safety body could quite easely copy the FAA IR as are the french but they wont!!! Why? matters of safety?
To expect a PPL to be good enough to climb up through cloud navigate on Top and then to be abandoned to his own devices on a home made cloudbreak with NO possibility of getting accurate weather for that cloudbreak is lunacy.
IMO this is all a complete and ridiculous NON SENSE.
Pace
Last edited by Pace; 23rd Sep 2011 at 11:32.
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Pace
Having now read the document for myself it says the EIR holder should plan to be VMC by the initial approach fix. I take this to mean that there would be no reason why the pilot could not ask for radar vectors to the IAF with a descent in IMC until cloud break as long as the cloud break comes before the IAF. That would mean a controlled descent probably, but not necessarily, in a terminal control area with other traffic and with "known" weather conditions based on the TAF and METAR.
It will be interesting to consider how this might work. Take Southampton for example the IAF is overhead SAM which in turn is almost overhead the airport. Accordingly the METAR for Sothampton should be reliable in "predicting" whether a cloud break will be achieved as should the TAF in terms of forecasting an achievable cloud break.
If the pilot were flying the procedure he would be positioned on the IAF at 3,000 feet, descending to 1,800 to turn inbound on the ILS, but the plate says the procedure can be started from the hold down to 2,000 feet. Presumably the EIR holder could request vectors to the IAF with descent to 2,000 feet followed by a visual approach to RWY 20. I dont see that this would be necessarily disruptive to CAT although if the pilot did not become visual it would be interesting to conject how ATC will deal with the aircraft which is presumably not entitled to continue with the procedure at 2,000 feet and fly the missed but would be required to receive vectors and a climb away from Southampton towards the planned diversion or would require to be repositioned for another descent to the IAF.
In the case of Southampton it seems to me that really the only additional burden for ATC over and beyond handling the lower speeds of any light aircraft would be pilots pitching up requesting vectors to the IAF at the minimium altitude from which the procedure could be commenced and dealing with that traffic going "missed" when they are not VMC by the IAF or the traffic having established VMC breaking off and potentially flying their own made up visual approach - on which point it seems to be far more sensible that the EIR holder should be expected to continue with the published procedure, but to maintain VMC.
I am guessing that at the largest airports with a stream of inbound CAT on a day when conditions are on the EIR holders minimium this could cause a certain amount of quick thinking by both pilot and more especially the controller but on the whole airports of this sort are not the home of GA. I am not convinved any where else would it cause the controller or anyone else for that matter too many issues.
FWIW personally I think it would have been far more sensible that the EIR holder should be visual by the top of the G/S. This would ensure all the traffic is following the same routine, with the only difference being some traffic might break off the approach at the top of the G/S and go missed either to be put back in the hold, be vectored to the IAF for another go, or to b***er off some where else. By going missed at the top of the G/S it seems to me everyone would be following the same procedure the only difference being that while the IR holder might break off at 250 feet the EIR holder would be breaking off at 1,800 feet. In so doing the EIR holder would be provided with the same protection that much higher minimium would give and yet would fit with the needs of all the other traffic.
I think expecting pilots to make up their own descent some way away from the IAF is nuts and is really unlikely to helpful to either controller or the pilot, but we shall see what the true intention is.
I do think however that in terms of the EIR holder these are pretty substantial approach tolerances and something has gone very wrong at the planning stage if the pilot cannot establish visual beneath an undercast.
As a final thought mind you I do find hard minimium at these heights a more interesting real world concept. In my experience at least, except in the case of fog, when ever conditions are on the deck in the vast majority of cases the pilot is "really" visual by the DH (or not). By that I mean the DH is "so low" that it is rare to have anything other than visual condtions until wheels touch. However with the much higher minimium proposed with the EIR I can think of numerous approaches where the pilot is visual at say 2,000 feet but with all sorts of broken, scattered and other "cr**" below, however you want to define it. In the real world the EIR holder is now presented with an interesting scenario. He knows he is required to maintain VMC bit does he ignore the odd bit of scattered and go on through, or does he weave and dodge. From a practical point of view in poor visibility, and with gusty wind as we all know the key to a good approach is a well establsihed and controlled descent from the FAF with the aircraft correctly configured and on the speeds. The last thing the pilots wants to be doing is dodging around the various bits of scattered.
I raise the last point in particular because I do find myself wondering when reading some of the commentary whether the posts are from those who actually fly in the variety of weather conditions we see because it sometimes comes across that they believe the weather follows the rule book with a 2,000 or whatever foot base, sharply defined, and with only woderful VMC below. We can only wish.
Ah well as we all know the weather has a nastly habit of certainly not following the wishes of the bureacrats in Brussels whether it be the with respect to the financial, political or any other climate you may like to pick
Having now read the document for myself it says the EIR holder should plan to be VMC by the initial approach fix. I take this to mean that there would be no reason why the pilot could not ask for radar vectors to the IAF with a descent in IMC until cloud break as long as the cloud break comes before the IAF. That would mean a controlled descent probably, but not necessarily, in a terminal control area with other traffic and with "known" weather conditions based on the TAF and METAR.
It will be interesting to consider how this might work. Take Southampton for example the IAF is overhead SAM which in turn is almost overhead the airport. Accordingly the METAR for Sothampton should be reliable in "predicting" whether a cloud break will be achieved as should the TAF in terms of forecasting an achievable cloud break.
If the pilot were flying the procedure he would be positioned on the IAF at 3,000 feet, descending to 1,800 to turn inbound on the ILS, but the plate says the procedure can be started from the hold down to 2,000 feet. Presumably the EIR holder could request vectors to the IAF with descent to 2,000 feet followed by a visual approach to RWY 20. I dont see that this would be necessarily disruptive to CAT although if the pilot did not become visual it would be interesting to conject how ATC will deal with the aircraft which is presumably not entitled to continue with the procedure at 2,000 feet and fly the missed but would be required to receive vectors and a climb away from Southampton towards the planned diversion or would require to be repositioned for another descent to the IAF.
In the case of Southampton it seems to me that really the only additional burden for ATC over and beyond handling the lower speeds of any light aircraft would be pilots pitching up requesting vectors to the IAF at the minimium altitude from which the procedure could be commenced and dealing with that traffic going "missed" when they are not VMC by the IAF or the traffic having established VMC breaking off and potentially flying their own made up visual approach - on which point it seems to be far more sensible that the EIR holder should be expected to continue with the published procedure, but to maintain VMC.
I am guessing that at the largest airports with a stream of inbound CAT on a day when conditions are on the EIR holders minimium this could cause a certain amount of quick thinking by both pilot and more especially the controller but on the whole airports of this sort are not the home of GA. I am not convinved any where else would it cause the controller or anyone else for that matter too many issues.
FWIW personally I think it would have been far more sensible that the EIR holder should be visual by the top of the G/S. This would ensure all the traffic is following the same routine, with the only difference being some traffic might break off the approach at the top of the G/S and go missed either to be put back in the hold, be vectored to the IAF for another go, or to b***er off some where else. By going missed at the top of the G/S it seems to me everyone would be following the same procedure the only difference being that while the IR holder might break off at 250 feet the EIR holder would be breaking off at 1,800 feet. In so doing the EIR holder would be provided with the same protection that much higher minimium would give and yet would fit with the needs of all the other traffic.
I think expecting pilots to make up their own descent some way away from the IAF is nuts and is really unlikely to helpful to either controller or the pilot, but we shall see what the true intention is.
I do think however that in terms of the EIR holder these are pretty substantial approach tolerances and something has gone very wrong at the planning stage if the pilot cannot establish visual beneath an undercast.
As a final thought mind you I do find hard minimium at these heights a more interesting real world concept. In my experience at least, except in the case of fog, when ever conditions are on the deck in the vast majority of cases the pilot is "really" visual by the DH (or not). By that I mean the DH is "so low" that it is rare to have anything other than visual condtions until wheels touch. However with the much higher minimium proposed with the EIR I can think of numerous approaches where the pilot is visual at say 2,000 feet but with all sorts of broken, scattered and other "cr**" below, however you want to define it. In the real world the EIR holder is now presented with an interesting scenario. He knows he is required to maintain VMC bit does he ignore the odd bit of scattered and go on through, or does he weave and dodge. From a practical point of view in poor visibility, and with gusty wind as we all know the key to a good approach is a well establsihed and controlled descent from the FAF with the aircraft correctly configured and on the speeds. The last thing the pilots wants to be doing is dodging around the various bits of scattered.
I raise the last point in particular because I do find myself wondering when reading some of the commentary whether the posts are from those who actually fly in the variety of weather conditions we see because it sometimes comes across that they believe the weather follows the rule book with a 2,000 or whatever foot base, sharply defined, and with only woderful VMC below. We can only wish.
Ah well as we all know the weather has a nastly habit of certainly not following the wishes of the bureacrats in Brussels whether it be the with respect to the financial, political or any other climate you may like to pick
Last edited by Fuji Abound; 23rd Sep 2011 at 11:36.
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There seems to be a point which Bookworm has made, perhaps too quietly, and has not been heard.
An EIR is an IR with higher minima.
All the same decisions have to be made by an EIR holder as an IR holder, except that he has to consider minima around, say, 1400' rather than 200'. He can follow procedures (STARs and the Initial Descent) but must be VMC at IAF. That happens nearly all the time anyway...how often do we really fly to minima?
(Why it is necessary to descend below MSA at 30nm is lost on me.)
I was originally taught the IR by the great Dai Heather Hayes. He made me do a completely blind ILS, right down to tracking the localiser on the runway after landing. That was way more than the syllabus required, but, he told me, one day I would thank him. Well, 25 years later, I wrote him that thank you letter because I had had to land completely blind at Resolute Bay in the deep Canadian Arctic, when the weather went to complete sh1t and the windscreen was covered in the very ice that all the books say cannot form at -25C.
Having the knowledge from Dai that I could land way, way below minima was what saved me and my aircraft that day.
Well, I would expect any sensible EIR and any sensible EIR instructor to do the same as Dai did for me. Just check that even if things go completely to sh1t you can still make an arrival.
But for 25 years I never needed that skill, even at hundreds of hours a year. It took the wilds of the far North of Canada, where alternates are 600nm apart, to force me into a position where I had to accept completely unexpected conditions.
It will be very rare for EIR holders, and when it happens they will survive.
The "Death Rating" wallahs are doing no good to GA at all. They should be ashamed that they trying to kill off the best thing to happen to GA for a generation.
An EIR is an IR with higher minima.
All the same decisions have to be made by an EIR holder as an IR holder, except that he has to consider minima around, say, 1400' rather than 200'. He can follow procedures (STARs and the Initial Descent) but must be VMC at IAF. That happens nearly all the time anyway...how often do we really fly to minima?
(Why it is necessary to descend below MSA at 30nm is lost on me.)
I was originally taught the IR by the great Dai Heather Hayes. He made me do a completely blind ILS, right down to tracking the localiser on the runway after landing. That was way more than the syllabus required, but, he told me, one day I would thank him. Well, 25 years later, I wrote him that thank you letter because I had had to land completely blind at Resolute Bay in the deep Canadian Arctic, when the weather went to complete sh1t and the windscreen was covered in the very ice that all the books say cannot form at -25C.
Having the knowledge from Dai that I could land way, way below minima was what saved me and my aircraft that day.
Well, I would expect any sensible EIR and any sensible EIR instructor to do the same as Dai did for me. Just check that even if things go completely to sh1t you can still make an arrival.
But for 25 years I never needed that skill, even at hundreds of hours a year. It took the wilds of the far North of Canada, where alternates are 600nm apart, to force me into a position where I had to accept completely unexpected conditions.
It will be very rare for EIR holders, and when it happens they will survive.
The "Death Rating" wallahs are doing no good to GA at all. They should be ashamed that they trying to kill off the best thing to happen to GA for a generation.
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Fuji
There was another major collapse on the stock markets yesterday main concerns being the USA and the imminent demise of Europe.
Why is Europe and the Euro in such a bad state because for a successful Europe the only way it would have worked is as a copycat of the USA! Ie a united states with one currency, a central government and tax raising abilities.
Anything half baked aint going to work.
The same with this fangled EIR.
The only safe way is for the aircraft to fly IFR takeoff to touchdown. real world I agree with you the weather doesnt follow EASA DIRECTIVES.
I would advice anyone in such a predicament to use their Captaincy legal overide on grounds of safety, inform ATC that you will stick with the ILS thank you and let our Safety body (EASA) fight you in the courts.
A complete and utter NON SENSE and I split the word on purpose.
Pace
There was another major collapse on the stock markets yesterday main concerns being the USA and the imminent demise of Europe.
Why is Europe and the Euro in such a bad state because for a successful Europe the only way it would have worked is as a copycat of the USA! Ie a united states with one currency, a central government and tax raising abilities.
Anything half baked aint going to work.
The same with this fangled EIR.
The only safe way is for the aircraft to fly IFR takeoff to touchdown. real world I agree with you the weather doesnt follow EASA DIRECTIVES.
I would advice anyone in such a predicament to use their Captaincy legal overide on grounds of safety, inform ATC that you will stick with the ILS thank you and let our Safety body (EASA) fight you in the courts.
A complete and utter NON SENSE and I split the word on purpose.
Pace
Early in this thread someone said, and I cannot see it corrected, that a UK IMCR holder can leagally fly an ILS down to 300'. Surely (and I only had to learn this a few months ago) the height minima for a UK IMCR pilot are 500' for precision approach and 600' for non-precision. Usually when I do the MDH or DH calculations for me as an IMCR pilot, the result is rather higher than that anyway.
I love having an IMCR and use its privilieges on most flights but it's probably best not to frighten foreigners and regulators by exagerating what it allows.
I love having an IMCR and use its privilieges on most flights but it's probably best not to frighten foreigners and regulators by exagerating what it allows.
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It was me who said that the 600 feet and 500 feet minima are recommendations only. The 1800 metres vis is statutory, otherwise IR minima apply. Bookworm did in fact confirm this later in the thread.
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Pace (and others),
I think you are making an unproductive issue of the EIR. The EIR is clearly not relevant to IMCr holders or to third country IR holders. It has the same amount of flight training as the IMCr and more knowledge requirement - so characterising it as a 'death rating' just feeds ammunition to the people opposed to the IMCr concept (I know the detail is in the level of approach training - but even the pro IMCr argument is mixed between the 'get out of jail' and 'plan to fly IMC within slightly higher limits' camps).
The EIR includes training in approaches for emergencies, so it is not like having a VFR PPL on top of a layer with no way back through it. It is an incremental step to address the perception that a full IR is too hard. I suspect with the competency based approach to the IR, most people who get an EIR will then go on to get a full IR within a year or so. Allowing people to incrementally move through the IR process is a fantastic thing.
The complaints about the EIR are highlighting the downside of some low probability events while ignoring the upside for the vast majority of circumstances.
I don't fly as much as others, but I can't think of a case EVER where I set out expecting a 2000+ cloud base and then was faced with sub 1400 feet over such a wide geographic and temporal area that I could not have held or diverted to any number of VFR destinations.
widespread low clouds/fog (as compared to local weather) is virtually always well forecast.
I think you are making an unproductive issue of the EIR. The EIR is clearly not relevant to IMCr holders or to third country IR holders. It has the same amount of flight training as the IMCr and more knowledge requirement - so characterising it as a 'death rating' just feeds ammunition to the people opposed to the IMCr concept (I know the detail is in the level of approach training - but even the pro IMCr argument is mixed between the 'get out of jail' and 'plan to fly IMC within slightly higher limits' camps).
The EIR includes training in approaches for emergencies, so it is not like having a VFR PPL on top of a layer with no way back through it. It is an incremental step to address the perception that a full IR is too hard. I suspect with the competency based approach to the IR, most people who get an EIR will then go on to get a full IR within a year or so. Allowing people to incrementally move through the IR process is a fantastic thing.
The complaints about the EIR are highlighting the downside of some low probability events while ignoring the upside for the vast majority of circumstances.
I don't fly as much as others, but I can't think of a case EVER where I set out expecting a 2000+ cloud base and then was faced with sub 1400 feet over such a wide geographic and temporal area that I could not have held or diverted to any number of VFR destinations.
widespread low clouds/fog (as compared to local weather) is virtually always well forecast.
There would seem to be a suggestion that with an EIR the pilot can fly the IAP down to the EIR minimium so establishing VMC (hopefully).
He can follow procedures (STARs and the Initial Descent) but must be VMC at IAF.
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They should be ashamed that they trying to kill off the best thing to happen to GA for a generation.
I don't think anyone is arguing to kill it. Our concerns seem to be that about the lack of approches included in the EIR. Most seem to be concerned for the safety of someone who is given the tools to get themselves into a dangerous situation, but no tool to help them get back out legally and safely.
My comments will be that an EIR should include one type of approach privlidges. I won't be arguing against the rating itself. I might even do it in the future. It would be tempting.
Last edited by dublinpilot; 23rd Sep 2011 at 14:07.
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I am confused .... how does a E-IR pilot safely descend to VMC perhaps outside of controlled airspace, or even in controlled airpsace for that matter and quite probably without the aid of radar vectoring
VMC could well be below MSA
It is never advisable to descend below MSA unless on an approach or in the hold ... in other words in a protected zone
He could fly to the IAF, and descend in the hold - however this requires a resonable level of skill that many IR pilots in their 50 odd hours training struggle with
VMC could well be below MSA
It is never advisable to descend below MSA unless on an approach or in the hold ... in other words in a protected zone
He could fly to the IAF, and descend in the hold - however this requires a resonable level of skill that many IR pilots in their 50 odd hours training struggle with
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The same with this fangled EIR.
The only safe way is for the aircraft to fly IFR takeoff to touchdown. real world I agree with you the weather doesnt follow EASA DIRECTIVES.
........A complete and utter NON SENSE and I split the word on purpose.
The only safe way is for the aircraft to fly IFR takeoff to touchdown. real world I agree with you the weather doesnt follow EASA DIRECTIVES.
........A complete and utter NON SENSE and I split the word on purpose.
You are not exactly plagued by self-doubt in your opinions!
So tell me, what do you think people should do who are IFR-capable but based at VFR airports? This is very prevalent in the GA community, eg. around London and airports such as Blackbushe, Denham, White Waltham - frankly over much of the UK where the costs of IFR airports are high? Is there death and destruction as a result of people using, in effect, EIR privileges? Are their vast numbers of diversions to Farnborough or Northolt or even Heathrow? Should they be rebasing themselves at Farnborough at vast cost to avoid a VFR arrival phase on an IFR flight? Of course not, it would be NON SENSE, to use your terminology. So where exactly is the problem?
If the real world weather doesn't follow EASA directives, what is anyone with a plain PPL meant to do - since they can never guarantee VMC? Or with an IR but only Cat 1 capability?
The problem here I think is that people are arguing from "personal conviction on first principles" and ignoring the practical experience of pilots, uncertain weather and sensible decision-making. Let me give you an example. Imagine a universe in which there was no GA IFR but only GA VFR and airliners with zero-zero Cat IIIC capability. Someone invents a GA airplane like the ones we have today. What would you be writing:
"the IR is a DEATH rating because of the 200' limit. No-one can predict the weather. Fog can easily cover a region unexpectedly, putting all the regional airports below minima. It is a recipe for death and disaster blah blah blah".....I hope the analogy is clear.
I would advice anyone in such a predicament to use their Captaincy legal overide on grounds of safety, inform ATC that you will stick with the ILS thank you and let our Safety body (EASA) fight you in the courts.
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I am confused .... how does a E-IR pilot safely descend to VMC perhaps outside of controlled airspace, or even in controlled airpsace for that matter and quite probably without the aid of radar vectoring
He does it in exactly the same way an existing IR or IMCr holder arrives today at a VFR-only airport. For that matter, during the first 20 years or so of the IMCR, before the UK started using the ICAO airspace classification system in the 90s, there were many of the present IFR Class D airports "notified under Schedule 8" in which IMCr holders could not fly IFR. In effect, the IMCr was an EIR in those days, in many circumstances where a diversion would have been an incredible hassle.
Let's be clear on one thing. There is no "mystery" as to how a flight which is IFR in IMC enroute (in airways or non-) establishes VFR for the approach and landing. It happens all day every day at VFR airports with IFR-capable GA traffic.
brgds
421C
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421C
Firstly If it is the case that the EIR will allow an aircraft to fly a STAR and part of the approach in CAS to safely become visual then I dont have a problem with that.
I have thousands of hours hard IFR in piston twins all over Europe. One was going into a VFR airfield very near Barcelona. Barcelona were giving CAVOK with sunloungers on the apron.
Inland from the coast I was on top of solid cloud and attempted to descend to get visual for the little VFR airfield with high ground all around.
Not breaking out and half scaring myself I climbed and asked for IFR to land at Barcelona.
Getting your weather at destination can be meaningless unless you are landing at that airport. 300 overcast and the correct RVR and you are pretty sure thats what you will get. If not you miss and fly a missed app procedure for another go or divert.
If it is true that the EIR pilot can follow a set arrival like a STAR and fly an instrument approach in IMC albeit to much higher minima then I am not complaining but that is not how I interpreted what was to be allowed.
Maybe someone can clarify?
If it is the case that the pilot will have to cloud break without accurate weather 20 plus miles out then that is dangerous. Not so much in the low lying south UK But dangerous in many parts of Europe.
Yes more experienced pilots like yourself do fly cloudbreaks into places like Fairoaks, Elstree etc. Sometimes to cloudbases we would not admit.
But that is a bit different to doing the same at somewhere like Bilbao without a lot of experience.
But the EIR doesnt apply to you or I with bags of experience but pilots with far less experience.
I strongly hold that the safest way is in CAS takeoff to touchdown if this allows that to nearly touchdown where an aircraft could continue on the ILS if all was not as expected then I have no problems with it.
The other point is that this is a European rating. Flying around the south of England means your unlikely to hit anything nasty. That is not the case in many parts of Europe where the mounatins often reach several thousand feet or more.
Finally WHY WHY WHY not take the french FAA copycat proper IR based on European regs? There is no safety difference between the FAA IR and JAA IR only one is a lot more accessable to the working man PPL?
421C i can be provocative in my writing on certain subjects but that more to generate passion and discussion both ways than to dictate my view
Maybe someone would kindly clarify what will or will not be allowed with the EIR?
Pace
Firstly If it is the case that the EIR will allow an aircraft to fly a STAR and part of the approach in CAS to safely become visual then I dont have a problem with that.
I have thousands of hours hard IFR in piston twins all over Europe. One was going into a VFR airfield very near Barcelona. Barcelona were giving CAVOK with sunloungers on the apron.
Inland from the coast I was on top of solid cloud and attempted to descend to get visual for the little VFR airfield with high ground all around.
Not breaking out and half scaring myself I climbed and asked for IFR to land at Barcelona.
Getting your weather at destination can be meaningless unless you are landing at that airport. 300 overcast and the correct RVR and you are pretty sure thats what you will get. If not you miss and fly a missed app procedure for another go or divert.
If it is true that the EIR pilot can follow a set arrival like a STAR and fly an instrument approach in IMC albeit to much higher minima then I am not complaining but that is not how I interpreted what was to be allowed.
Maybe someone can clarify?
If it is the case that the pilot will have to cloud break without accurate weather 20 plus miles out then that is dangerous. Not so much in the low lying south UK But dangerous in many parts of Europe.
Yes more experienced pilots like yourself do fly cloudbreaks into places like Fairoaks, Elstree etc. Sometimes to cloudbases we would not admit.
But that is a bit different to doing the same at somewhere like Bilbao without a lot of experience.
But the EIR doesnt apply to you or I with bags of experience but pilots with far less experience.
I strongly hold that the safest way is in CAS takeoff to touchdown if this allows that to nearly touchdown where an aircraft could continue on the ILS if all was not as expected then I have no problems with it.
The other point is that this is a European rating. Flying around the south of England means your unlikely to hit anything nasty. That is not the case in many parts of Europe where the mounatins often reach several thousand feet or more.
Finally WHY WHY WHY not take the french FAA copycat proper IR based on European regs? There is no safety difference between the FAA IR and JAA IR only one is a lot more accessable to the working man PPL?
421C i can be provocative in my writing on certain subjects but that more to generate passion and discussion both ways than to dictate my view
Maybe someone would kindly clarify what will or will not be allowed with the EIR?
Pace
Last edited by Pace; 23rd Sep 2011 at 14:19.
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Pace,
The French copy cat IR and the competency based IR as proposed seem very very similar. There are a number of issues I have with the NPA modular IR in detail (like why 3 and 1/2 hours of testing, why Europe seems unable to implement efficient, economical, readily accessible computer based testing, etc. ) but these are all petty irritations and IMHO just a fact of life in many aspects of life in Europe. We should be focusing on all of the upsides on the NPA not providing ammunition for the axe grinders.
I think there are a number of comments one can make productively such as
With regard to your example in Spain, I don't see where the problem is, the EIR descends to MSA/MVA is not visual, climbs back up and goes to the sun on the coast. The example just makes the point that unexpected bad weather tends to be localised and the EIR holder proceeds IFR enroute (as trained and practiced) to his alternate.
The cloud breaks we fly into Fairoaks, Denham etc are flown by people with the same number of hours of training as proposed for the EIR (I.e. and IMCr) and substantially less required knowledge, so I am struggling to see why the EIR pilot is going to be so much less competent in this particular activity (which after all is decision making and flying an IMC descent to an altitude - a task which I recall doing once or twice in the enroute phase of an IFR flight)
The French copy cat IR and the competency based IR as proposed seem very very similar. There are a number of issues I have with the NPA modular IR in detail (like why 3 and 1/2 hours of testing, why Europe seems unable to implement efficient, economical, readily accessible computer based testing, etc. ) but these are all petty irritations and IMHO just a fact of life in many aspects of life in Europe. We should be focusing on all of the upsides on the NPA not providing ammunition for the axe grinders.
I think there are a number of comments one can make productively such as
- The EIR syllabus should include the use of an ILS or SRA as an emergency procedure, execution of which in the flight test
- The EIR holder should be allowed to be descended to minimum RVA and hence a visual approach (as in a typical arrival to Fairoaks etc)
- Others?
With regard to your example in Spain, I don't see where the problem is, the EIR descends to MSA/MVA is not visual, climbs back up and goes to the sun on the coast. The example just makes the point that unexpected bad weather tends to be localised and the EIR holder proceeds IFR enroute (as trained and practiced) to his alternate.
The cloud breaks we fly into Fairoaks, Denham etc are flown by people with the same number of hours of training as proposed for the EIR (I.e. and IMCr) and substantially less required knowledge, so I am struggling to see why the EIR pilot is going to be so much less competent in this particular activity (which after all is decision making and flying an IMC descent to an altitude - a task which I recall doing once or twice in the enroute phase of an IFR flight)
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Pace
I think it is clear that the EIR holder will be able to fly to the IAF by whatever means and that at the IAF he must be in VMC. in order to proceed with a visual approach.
Will the pilot continue with the procedure (flown visually) or will he self position for a visual approach I dont know (see my earleir post).
In other words presumably the higher of his rating privilige and the minimium descent altitude at the IAF is his DH as to whether or not he can continue with a visual approach.
That seems to me reasonably clear.
The whole point seems to me the pilot is trained to fly to a much DH and if not visual does the safest thing (for that pilot given his level of training) which is to go else where or to declare an emergency so that ATC can keep a very close eye on what he is up to. In your example it seems to me the EIR would do a very good job of protecting the pilot from a further descent that might even test the skills of an experienced IR holder.
I think it is clear that the EIR holder will be able to fly to the IAF by whatever means and that at the IAF he must be in VMC. in order to proceed with a visual approach.
Will the pilot continue with the procedure (flown visually) or will he self position for a visual approach I dont know (see my earleir post).
In other words presumably the higher of his rating privilige and the minimium descent altitude at the IAF is his DH as to whether or not he can continue with a visual approach.
That seems to me reasonably clear.
The whole point seems to me the pilot is trained to fly to a much DH and if not visual does the safest thing (for that pilot given his level of training) which is to go else where or to declare an emergency so that ATC can keep a very close eye on what he is up to. In your example it seems to me the EIR would do a very good job of protecting the pilot from a further descent that might even test the skills of an experienced IR holder.
Maybe someone would kindly clarify what will or will not be allowed with the EIR?
Firstly If it is the case that the EIR will allow an aircraft to fly a STAR and part of the approach in CAS to safely become visual then I dont have a problem with that.
My comments will be that an EIR should include one type of approach privilege. I won't be arguing against the rating itself.