EASA AND THE IMCR - NEWS

[mm_flynn]

Originally Posted by Genghis the Engineer

For private flying, is there an equivalent document that I didn't find?

G

Part 91 is for non-commercial ops.

Part 135 and 121 are the rules for what you would call AOC operators.

I don't believe Europe offers an IFR clearance comparable to the FAA 'VFR-On Top' clearance. The description of this clearance sometimes confuses people. For the avoidance of doubt, the FAA allows PPLs to fly VFR over an undercast with no more formality than flying on a clear day.

[flybymike]

compared to 600ft DH for an NPA with an IMC or 500ft on a PA,

AIUI these are recommended minima. Full IR minima may be used with an IMCR if wished, subject to 1800m vis for take off and landing.

[IO540]

although I do agree that concept of the EIR is quite ridiculous - it effectively gives the EIR holder the same privileges as the PPL holder throughout most of the world! -

You get mega new privileges: access to all airspace, and ability to fly in IMC.

I used to do long VFR trips across Europe, on a PPL/IMC, but one has to ask for each CAS transit. On the EIR, you just file a Z flight plan (VFR-IFR-VFR) and during the IFR portion you are treated as an IFR enroute flight, and you just go, with CAS being irrelevant.

What's the cost/hassle factor in renewing a JAA IR annually?

That's a very good question. My totally informal research around where I fly from is about £150. This is "not a lot" but is another £150 of pointless cost inflation. It is possible for a "mate" who can do it to do it for nothing, of course. N-reg owners will need the DfT permission for the test in their plane if they are paying the instructor and they are doing it in UK airspace; this permission is currently free.

(I cannot get the pprune quotation feature to work unless I access the internet via a VPN terminating in the UK - quite odd ).

[Genghis the Engineer]

Flybymike - negative, those are hard limits shown in the ANO, as is the 1800m viz. But yes, most of the other stuff in the IMC syllabus about higher limits is only advisory.

G

[huv]

Denmark - VFR on top

VFR on top is permitted according to national Danish legislation on the following condititions:

VMC forecasted on the planned route/altitude; destination forecast with min vis 5 km and no cloud layer denser than 4/8 (ETA +/÷ 1 hr). Fuel reserve requirements similar to IFR: alternate + 45 min.
This minimises the risk of ending up flying in IMC.

The pilot is required to have logged at least 150 hrs, and the aircraft has to be IFR equipped.
This ensures some probability of succes should IMC be encountered accidentally. But there is no specific training or skill requirements for the pilot to exercise the right to fly VFR on top.

[bookworm]

Flybymike - negative, those are hard limits shown in the ANO, as is the 1800m viz. But yes, most of the other stuff in the IMC syllabus about higher limits is only advisory.

The 1800 m vis is a "hard limit" in the ANO. The 600 ft MDH and 500 ft DH are recommended by the AIP.

[bookworm]

For private flying, is there an equivalent document that I didn't find?

There are no corresponding restrictions in Part 91 about flying VFR over the top, if that's what you mean. For Part 91, VFR is VFR I think.

[Genghis the Engineer]

Originally Posted by bookworm

There are no corresponding restrictions in Part 91 about flying VFR over the top, if that's what you mean. For Part 91, VFR is VFR I think.

Thanks, consider us educated!

For anybody who wants to double check, Electronic Code of Federal Regulations: but Bookwork seems to be correct.

G

[BillieBob]

So you won't be able to fly the ILS at L2k...well, you can fly it down to 1000' cloud base I would imagine

How will you be able to do that when you may not accept an IFR clearance to fly an arrival or approach procedure?

[IO540]

The exact way the EIR would work in these situations remains unclear at the moment.

In the simplest scenario, the pilot will be unable to fly an IAP even under total VMC.

But one can also look at it from the Z flight plan POV where the VFR to IFR to VFR transitions are specified (as waypoints) in the flight plan, and during the VFR sections the behaviour expected of the pilot is very clear - VFR. I suspect this is the intended way of working it.

[Justiciar]

This seems like the curate's egg: good in parts.

I am not clear why they have so explicity excluded instrument approaches from the EIR. They recognise that there will be situations when such an approach is necessary, hence the emergency training requirement. Why not go the rest of the way and allow add on training to permit legal instrument approaches?

Arguably though this is not as significant as it appears as many wanting to use the EIR will not being going into an airfield which has an instrument approach, so the end phase of the flight becomes all the more critical in the planning, from a Wx perspective.

These proposals seem to indicate no grandfathering of IMCR privileges to the EIR but strangely up to 30 hous instrument time (from the IMCR training or otherwise) will count towards the Competency based IR! Interesting that classroom time may be combined with the practical flight training. I am not clear what that means. Does a briefing count?

[Contacttower]

I haven't had a chance to read the entire thing in detail but from the brief skim read of it I can't see anywhere an explanation how many written exams there will be and how exactly they are administered? I got the bit about 100hrs of theoretical study though and some more 'high performance' stuff being deleted from the written syllabus.

There is nothing to indicate how EASA will deliver on the promises made by the EC to the European Parliament regarding taking the UK IMCR into European legislation.

I guess someone must know at what point this will be addressed...?

I think overall the sentiment expressed in this NPA is broadly in the right direction.

[bookworm]

I am not clear why they have so explicitly excluded instrument approaches from the EIR. They recognise that there will be situations when such an approach is necessary, hence the emergency training requirement. Why not go the rest of the way and allow add on training to permit legal instrument approaches?

As I mentioned earlier in the thread, I think there's a clear analogy with the instrument training given to PPLs. We make them do a few hours under the hood, even though there is no intention to permit instrument flight as a privilege of the basic PPL. It's for emergencies, not for regular use.

[Pace]

Arguably though this is not as significant as it appears as many wanting to use the EIR will not being going into an airfield which has an instrument approach, so the end phase of the flight becomes all the more critical in the planning, from a Wx perspective

That is the danger that being precluded from making safe instrument approaches pilots will be making home made cloud breaks into hilly or mountainous regions to try and go VFR below.
Not a clever or safe scenario. People are People and the accident stats will go up with what EASA are suggesting which is contrary to what the safety aspect of the IMCR was all about.

Pace

[Justiciar]

I think there's a clear analogy with the instrument training given to PPLs

Maybe they are making an analogy, but there is still no rational argument as to why. I have only skimmed the EASA document, but they have advanced no rational explanation for this and I can only assume that it is to placate the airline mob who do not want anyone flying full IFR without the full IR.

It seems to make no sense to me to allow a pilot to legally fly IFR for hundreds of miles and then for him to have to rely on limited emergency training to get down when he finds unexpected IMC at his destination. This seems a bit like training a pilot to fly but not to land!

Of course if you add approaches to the EIR you have a full IR. I suspect that EASA could not bring themselves to accept the IMCR and have ended up with something which though undoubtedly useful to many is also possibly fatally deficient in the key area of approaches.

[bookworm]

Maybe they are making an analogy, but there is still no rational argument as to why.

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)?

Once again, I just don't understand why you'd pick on the EIR as "possibly fatally deficient". A PPL without any instrument qualification can find "unexpected IMC" at the destination, and an instrument rated pilot can find conditions below Cat I minima. They survive by going to their alternate where conditions are better.

[Pace]

Of course if you add approaches to the EIR you have a full IR. I suspect that EASA could not bring themselves to accept the IMCR and have ended up with something which though undoubtedly useful to many is also possibly fatally deficient in the key area of approaches

.

Justiclar

You have hit it right on the nail. EASA are not motivated by their mandate as a safety organisation but have their own mandate of regulating, protectionism and control.
They will only budge from that if up against a brick wall.
What they are offering is fatally flawed and I dont use the word lightly!

Pace

[bookworm]

You have hit it right on the nail. EASA are not motivated by their mandate as a safety organisation but have their own mandate of regulating, protectionism and control.

Right sentiment, wrong target. EASA has been told by the European Commission that they have to do things the ICAO way. The ICAO way is to require 40 hours of instrument time before you get an IR. So do the FAA for that matter.

[Pace]

Bookworm

But allowing a pilot to fly on top is instrument flying. The tops can an do rise I can well remember getting into such a situation many moons back in a single Saratoga. The clouds rose and before I knew it I was not just IMC but icing up.
It was a front moving west to east and I was flying north to south.
I ended up just on top at 12K with the cloud in the hills below.
This on top thing is fine if the pilots are ENCOURAGED to declare and take an assisted instrument approach if their is any doubt about their descent at the other end.
The IMCR is a safety rating as proved in the stats! Some use it with anger others use it as a just incase but pilots do get into a mess of their own making and thou shall not do this is not enough.
I dont agree on EASAs safety priority in their rule making
I am one who doesnt agree with holding onto the IMCR. I have always pushed for the easely achievable PPL IR based on the FAA system.
Statistically as safe as the JAA IR and equally as good but achievable by all and a proper instrument rating.
If EASA are so safety mandated why dont they offer the same albeit with European study material instead of USA.


Pace

[KeyPilot]

Oh dear. I had hoped to come on here and get the lowdown on the NPA without having to read the whole thing. Sadly despite reading many posts I don't know if it's a good or bad thing!

Time to stop being so lazy. Will read tonight.

One thing does strike me, though. 239 pages seems an awful lot to cover "Qualifications for flying in IMC", and especially so since the NPA does not specify in any meaningful detail the transition route from one such existing European qualification (namely the UK IMCR) to the proposed new regime!

Only in Europe?!