New EASA IR(A) and the solo NQ requirement

[Grumman77]

The solo is done with an instructor next to you who will not touch the controls while you complete your 5 t/g's. This time is counted as PIC time.

That is indeed interesting. But can I legally be PIC on a night time flight in the Netherlands if I have the restriction "Valid by day only" on my medical? Have you heard of someone in my position doing the NQ that way (or maybe you have this restriction yourself)?

[belowradar]

As someone who has broken through the CVD barrier myself I would advise as follows


Do not ask too many questions up front as you will get an array of different answers SO.....keep control yourself by flying the dual hours of night training as normal and then "solo" hours with fellow night q pilot or instructor as P1supervised.

This will allow you to fill in the required form accurately, tick the right boxes and then get some non pilot office bod to issue the new qualification JOB DONE

This is based on "don't ask don't tell"

So what if office bod says but you are day vfr only ?
Then argue that you have filled the requirements in a safe and logical way and that there is no logical reason not to issue qualification.

From my experience do not let them decide up front as most do not have a clue about what is sensible and fair.

The CAA are not that joined up anyway

[pmh1234]

Danish CAA, or UK CAA?

UK CAA. I have a UK license PPL/IMC

[pmh1234]

Belowradar ->
That would seem to be a way out and it may actually work.
I would though not enter into costly and time consuming IFR training if there is a risk I will be told later that the I can't get the rating.
Perhaps a way could be to get the EIR and then try this approach for the full IR - since that is not going to be alot of extra study and flying as I undertand it.

[belowradar]

The night qualification is not a great big investment only 5 hrs and once you have the NQ then you will meet entry requirements for IMC/ EIR so no prblems after that.

[PrivatePilotDA40NG]

Hello ,

As i almost have my PPL(A) and even if i won't go for the ATPL , i will certainly get an Instrument Rating , I have read the complete EASA document regarding the possible changes to the instrument rating IR(A). The EASA confirmed that they will not work out any changes for helicopter pilots yet.

In their proposals , there are 3 possible options. Briefly said:
1. Introduction of an EIR , meaning Enroute Instrument Rating. This means that the enroute segment of the flight can be completed under IFR , in IMC. However , no SIDs or STARs may be flown with this rating. Takeoff and landing must be completed under VFR. On departure , this means that the overcast cloud deck should be above 1000ft (i guess AGL). So overcast at 1500 means u can just climb out above.

2. Introduction of a more accesible IR(A). It is mentioned that this IR will be more competency based, meaning that the theoretic knowledge required to get this rating , will be severely lowered. A lot of knowledge that is required for the current IR(A) , makes no sense for just flying a cessna 172... That means that the parts regarding flight of High Powered Airplanes , like jets , will be deleted from this more simplified IR.
The main goal of the changes is to make it more attractive to get the rating.

3. The third and most probable option is the combination of option 1 & option 2. Regarding the EASA's calculation of the amount private pilots that will get an IR after this, option 3 would encourage the most pilots to get either the IR or an EIR, greatly reducing the change of accidents following continued VFR flight into IMC.

I am eager to get a full IR. So i hope that either the second or the third option will come soon.

Greetings,
De Smet Sébastien

[Immortal]

That is indeed interesting. But can I legally be PIC on a night time flight in the Netherlands if I have the restriction "Valid by day only" on my medical? Have you heard of someone in my position doing the NQ that way (or maybe you have this restriction yourself)?

I don't have the restriction myself.

In your logbook you will enter the time flown as PIC. In the little remarks column at the end the instructor will put his signature and a little remark, SPIC. This is according to the dutch regulations that the 5 t/g's solo are to be flown in an SPIC situation.

So you comply with the rules. You have 4 hours of Dual night time and 1 hour of PIC. That there is a S at the beginning of PIC doesn't mean it isn't PIC anymore does it?

[mad_jock]

The only problem you have is that PICS is a intergrated course "thing". Unless you on one of those courses you can't log it.

I would imagine that this thread has been noted and there are a few emails flying around between various national authorities.

BTW Personally I don't think they should be a night requirment for a PPL IR so don't take my comment as putting anyone down. I just cant see how they can justify/allow it to work.

[Whopity]

All IRs are Competency based, if you are not Competent, you don't pass the test! This statement in the NPA makes it quite clear there is only one standard irrespective of what you call the IR

A high uniform level of safety is ensured by requiring the applicants to pass exactly the same skill test as established already for the IR in Part-FCL.

There was a perfectly good ICAO IR in the UK before the JAA increased it by 26%. Initial CAA statistics showed that fewer candidates obtained a first time pass than on the shorter IR! Option 3 in the NPA looks very similar to the pre JAA course. A step back to reality perhaps.

The Exams are of dubious relevance however; what makes you assume that any new shorter exams will be of any more relevant or quality? The people producing these papers, who remain anonymous, have minimal knowledge on the subject, and there is little evidence to suggest they know anything about how to formulate an examination question. At 50 Euros a question are they even bothered?

and there are a few emails flying around between various national authorities.

I doubt it! There is very little internal communication, let alone cross Authority.

[Immortal]

The only problem you have is that PICS is a intergrated course "thing". Unless you on one of those courses you can't log it.

I would imagine that this thread has been noted and there are a few emails flying around between various national authorities.

BTW Personally I don't think they should be a night requirment for a PPL IR so don't take my comment as putting anyone down. I just cant see how they can justify/allow it to work.

It is approved by the Dutch authorities, ask an FTO in Holland for his syllabus for the NQ, it will have some kind of approvement letter from the Dutch CAA.

I agree that this is not the normal way of doing your NQ, but here in the Netherlands it is not possible to do Night VFR, so we do things on a IFR flight plan. Ridiculous I know, but this is why they came up with a workaround for the the touch and go's for the NQ, SPIC.

[BillieBob]

It is approved by the Dutch authorities

The fact that national authorities could grant exemptions from the JARs made a mockery of the whole JAA concept and was one of the prime drivers behind the development of EU legislation. Once the implementing rules are adopted, it will not be possible for national authorities lawfully to grant exemptions and I wonder how this problem will be dealt with in the future.

One may, as belowradar suggests, choose to falsify your logbook and one may even get away with it. On the other hand, one may not and it's a risk that many would not choose to take.

[BackPacker]

That there is a S at the beginning of PIC doesn't mean it isn't PIC anymore does it?

The problem is that JAR-FCL 1.something doesn't require five full-stop landings and take-offs as PIC. They require them to be done SOLO. (BTW in LASORS the word PIC is used, but JAR-FCL talks about SOLO. -1 for LASORS.)

The Dutch authorities have made an exception to JAR-FCL in this respect so if you fly them as SPIC / P1/S or whatever it's called, it's accepted for the Dutch authorities to issue the NQ, and use them as the entry requirements for the IR course.

But the rest of the JAA world doesn't recognize this Dutch exception so if you have a license that's issued anywhere else, you're stuck. I have pointed the Dutch exception out to the UK CAA, but they simply pointed back to JAR-FCL, as that's their guidance document.

The fact that national authorities could grant exemptions from the JARs

It doesn't quite work that way, although in practice, I can imagine someone thinks so.

The JAA is a volunteer organization, founded by the National CAAs of the various countries. As such, the JAA itself has no legal basis whatsoever. They can come up with binders full of paperwork, but the individual countries have to use their own internal process to embed this into law. Sometimes the law simply points to the JAR-FCL text (which then becomes binding in that particular country), sometimes JAR-FCL is 1-on-1 transposed into law (with a possible translation in the local language), and sometimes it is made into law slightly differently from what JAR-FCL wrote down and/or intended.

As long as the difference between what ends up in the laws, and the original JAR-FCL text, is minor, nobody really cares. The result is that anything that happens under the guise of "JAR-FCL compliant" is implicitly recognized/accepted by the other JAA countries. But every now and then there are little corners of this framework where things don't quite work as advertised.

The Dutch way of doing the NQ is an example. Another was the fact that certain medicals (the German ones come to mind) were not accepted by the UK to fly on a UK-issued JAR-FCL PPL, even though they were OK in combination with a German-issued JAR-FCL PPL.

The idea behind EASA is that all of these national twists are going to disappear, as EASA is part of the EU and can pass directives which become law immediately. But that, of course, highlights these and a whole bunch of other issues that were swept under the rug in JAR-FCL, and now need to be sorted properly.

[belowradar]

One may, as belowradar suggests, choose to falsify your logbook and one may even get away with it. On the other hand, one may not and it's a risk that many would not choose to take

I never suggested that logbooks be falsified, I suggested that you log P1(S) and fly with instructor for solo hours, this is to sensibly, safely and legally fulfil the requirements for NQ.

At the end of the day you are proving that you can safely fly at night

[BillieBob]

I never suggested that logbooks be falsified, I suggested that you log P1(S) and fly with instructor for solo hours

The definition of 'solo flight time' in JAR-FCL 1.001 is "Flight time during which a student pilot is the sole occupant of an aircraft." If a student pilot records as solo flight time during which an instructor is also in the aircraft (i.e. he is not the sole occupant), how is this not falsification?

It doesn't quite work that way

It works exactly that way! Individual member states currently pick and choose the elements of the JARs that suit their national interests and either ignore or grant exemptions from those that do not. Once the new EU Regulation comes into effect, however, the option to grant exemptions will be removed and member states will be left only with the option to ignore the requirements and, no doubt, the usual suspects will do so.

[peterh337]

There is no fundamental difference between the proposed route, and doing what Ireland was doing until not long ago which was converting an FAA ATPL into a JAR-FCL ATPL

I gather the UK CAA used to do the same, until about 20 years ago.

Not to mention various other routes that have appeared over the years. Some still exist but usually involve some hassle, like actually working for an operator of an aircraft of the desired registry.

The aviation business has always been full of this stuff. Nobody in their right mind is going to sit 14 exams and spend £30k+ doing the logbook stuffing if they can get a straight paper swap, which according to ICAO principles should have been offered in the first place

It is only blatent in-your-face Euro job creation / job protection which has given rise to the JAR-FCL restrictive practices.

Of course, nobody actually working for an airline, especially a flag carrier, would have done any of this, when a harder route was available to them

One thing which makes me smile a little is that whenever one bumps into a bunch of private UK IR holders, it turns out that nearly all of them did it pre-1999 i.e. under the old 700hr route. Of course I never question this because I automatically assume that when JAR-FCL came in, they all went to an FTO and re-did the whole 50/55hr course and re-sat the exams

So, if you can find a route through this maze, go for it, but make sure you are a good and current-on-type pilot notwithstanding, by flying often, and practicing instrument procedures often, using checklists, etc.

[belowradar]

Billibob if the regs are illogical it does not prevent us from being logical so as there is no safety issue in flying at night with observing Fi and as the regs require night flight experience then how else can it really be done? Surely some common sense must prevail so they either permit or get rid of night requirement for cvs pilots but if public are not at risk then what is the problem?

[BackPacker]

fly with instructor for solo hours

What part of "solo" do you not understand? JAR-FCL is 100% clear on this. You have to be the only person on board if your flight is to be classified as "solo". And the take-offs and landings for the NQ have to be done solo.

We can discuss whether this is sensible, safe and reasonable but at the end of the day that is what is written in JAR-FCL, and made into law in most countries.

grant exemptions from those that do not.

Okay, I guess I should have made my point clearer. You cannot "grant exemption" from something that's not a regulation. So a country cannot grant an exemption from JAR-FCL. They can only choose not to implement bits of JAR-FCL into law, or implement something slightly different (or even wildly different) into law. And only once it's in the law books they can grant an exemption. From the law, not from JAR-FCL.

But I agree that it's all semantics.

[Whopity]

there is no safety issue in flying at night with observing Fi

Probably not, but once qualified, the pilot can then exercise the privileges at Night solo, even if his visual acuity is such that he can't see a thing. The medical restriction that causes this problem is surely there for Safety.

The old UK system of permitting an IR with a No Night safety restriction got around the problem without compromising the medical safety issue. The Dutch approach fudges the whole thing and could leave the Authority negligent.

[mad_jock]

Why is it even in that they require a NQ anyway?

I always thought it was strange that the night currency wasn't required if you had an IR. There is nothing in particular that sets you up for dropping an aircraft into a black hole landing in the IR course.

[peterh337]

The problem is that the colour vision requirements are to a large degree not relevant to aviation. See this. The chance of a pilot who fails his NQ medical requirements due to CV and having problems is quite small because most CV deficient pilots can actually see all the required colours.