EIR - maybe not such a bad thing after all?

[peterh337]

There is little evidence that EASA takes any notice of any responses - unless it is on something totally neutral.

[421C]

It's an interesting question. Certainly my stab at 20% is on the high side.
I just looked at an electronic logbook for my time on 2 specific aircraft (a G-reg Seneca and an N-reg C421). The numbers were 14% of logged time as actual instrument and 2% as simulated instrument. I think 5% is too low in Europe unless you simply avoid flying in IMC and don't stay current in the aircraft.

[421C]

I actually wonder what the point of this conversion option is at all. If one
pretends one doesn't have any ICAO IR and just does the CBM IR as ab initio (which one is obviously entitled to do) then the min dual training is 10hrs (which I am 99.9% certain will be required by 99.9% of candidates no matter how experienced), with 40hrs instrument time (which can include non-PIC time), so the extra cost is whatever the TK comes out to relative to the "1 exam". Is that correct?

No. Ab initio the minimum time for the CB IR is 40hrs training of which 10 must be in an FTO. The concession for holders of another instrument qualification is that they can credit time spent as PIC in instrument flight to a max of 15hrs, so that the minimum dual time is 25hrs of which 10 is at an ATO. For example, an ab initio guy with zero instrument time can do an EIR (15hrs dual) then get 15hrs instrument experience then do 10hrs ATO for the CB IR.

The "conversion option" does 2 things
- drops the full IR exam requirement
- drops the 10hrs ATO but not the IRT
Surely you see the value in the latter. Yes, most people do need training. The advantage of the conversion is that you can get to the standard however you want. You don't have to go to an ATO. You aren't the greatest fan of ATOs so surely you see the benefit!
brgds
421C

Sorry, to be clear on the "1 exam", the NPA says "demonstrate that he/she has acquired knowledge of air law, meteorology, flight planning and performance, and human performance;". Worst case is 4 exams. AOPA and PPL/IR argued for an oral exam given by the IRT examiner. The compromise could be 1 exam, we'll have to see.

[421C]

crucially whether there will be a QB. Absence of a QB dramaticallyjacks up the workload.

There is no reason at all to think there won't be a QB for the CB IR TK. It's simple - the Learning Objectives (LOs) for the present syllabus are published in the NPA in excruciating detail. It also publishes the LOs deleted under the FCL008 proposal. All a QB provider has to do is delete the corresponding questions. For example, the CATS QB has about 2600 questions for the IR exams. So someone has to spend a few days going through the questions and x-referencing against the LOs, if that isn't automated in some database.

Quite seperately, EASA have published a study about multiple-choice exams that you've referenced and which includes all sorts of potential options for making the QB more obscure or having many many more questions. In the short-medium term I doubt anything will happen. EASA have enough on their plate and there is no sign of a formal rulemaking task or working group or anything to pursue this.

[peterh337]

Ab initio the minimum time for the CB IR is 40hrs training of which 10 must be in an FTO

Fair enough, but I think most UK candidates doing the CBM IR will have ~20hrs IMCR training in their logbook so they will be able to use that, whereas none of that is usable towards the present IR.

Which is a whole lot better than logging a "genuine" 100hrs instrument time as PIC which will take years. I may have that now, after 10 years of doing ~150hrs/year.

air law, meteorology, ..... and human performance

Those happen to be 3 of the hardest exams for swatting up, so it's not much of a concession for the conversion candidate

As always in flight training, it is stitched up so there are no really attractive options. 6 of one....