EIR - maybe not such a bad thing after all?
Thread Starter
Join Date: Sep 2006
Location: Los Angeles, USA
Age: 52
Posts: 1,631
Likes: 0
Received 0 Likes
on
0 Posts
EIR - maybe not such a bad thing after all?
Just recently back from a 3000nm return trip from LA to New Orleans (surprisingly without a single squawk - a first, bless her). Although I had to scud run in Texas and Louisiana to get under some nasty weather for 2 days, it was still VFR or marginal VFR.
The last days leg went from Lubbock, TX, to LA. Took off early, silky smooth air, beautiful trip all the way until I hit the LA basin - socked in uncharacteristically. An incongruous bunch of pilots took turns in getting through at Banning Pass (the only low level entrance into the LA basin) and the airport there, but all failed (myself included). Almost all of LA was reporting ceilings at 2000ft if one could just get past the pass. We were hearing joyous position reports from people at uncontrolled airports just on the other side of that bl**dy wet curtain of mist and clouds blocking the entrance. Taunting us. Surrounded by mountains and sea, no way around - can't come from the top, can't drop down over the ocean. I gave it a go twice, before I scared myself from trying again.
It was so frustrating to have to fail after 3000 miles only 30 miles from my home airport. Ended up having to leave the old gal at another remote airport and arrange all sorts of complicated and expensive means to get home/pick her up later.
The EIR would have gotten me in that day. And one wouldn't have needed more than an AI, a turn coordinator and a radio - instruments that exist in almost all aircraft. A GPS and a VOR would have made it even better, of course, but strictly not necessary. I'm thinking the EIR might be a good idea for those who just want a bit more utility, without planning on doing approaches to minimums. I will certainly expedite my IR training after this, but would gladly go halfway for an EIR in the meantime, if such a thing existed.
BTW, what is the latest on that?
In better weather.
The last days leg went from Lubbock, TX, to LA. Took off early, silky smooth air, beautiful trip all the way until I hit the LA basin - socked in uncharacteristically. An incongruous bunch of pilots took turns in getting through at Banning Pass (the only low level entrance into the LA basin) and the airport there, but all failed (myself included). Almost all of LA was reporting ceilings at 2000ft if one could just get past the pass. We were hearing joyous position reports from people at uncontrolled airports just on the other side of that bl**dy wet curtain of mist and clouds blocking the entrance. Taunting us. Surrounded by mountains and sea, no way around - can't come from the top, can't drop down over the ocean. I gave it a go twice, before I scared myself from trying again.
It was so frustrating to have to fail after 3000 miles only 30 miles from my home airport. Ended up having to leave the old gal at another remote airport and arrange all sorts of complicated and expensive means to get home/pick her up later.
The EIR would have gotten me in that day. And one wouldn't have needed more than an AI, a turn coordinator and a radio - instruments that exist in almost all aircraft. A GPS and a VOR would have made it even better, of course, but strictly not necessary. I'm thinking the EIR might be a good idea for those who just want a bit more utility, without planning on doing approaches to minimums. I will certainly expedite my IR training after this, but would gladly go halfway for an EIR in the meantime, if such a thing existed.
BTW, what is the latest on that?
In better weather.
Last edited by AdamFrisch; 25th Apr 2012 at 03:37.
Join Date: Dec 2011
Posts: 2,460
Likes: 0
Received 0 Likes
on
0 Posts
The EIR is indeed a useful thing simply because it is an additional privilege which doesn't currently exist.
It will be useful to pilots who are currently "clever" VFR pilots and who know how to play the game and are flying suitable aircraft, but who cannot currently climb above weather because ATC will not allow them into CAS because the particular ATC unit (or country) refuses to operate ICAO airspace classification (VFR is OK in all airspace except Class A). In fact the EIR will allow access to Class A as well - just like the full IR.
I can see the objections to the EIR but really it is no different to the present ability to fly VFR above an overcast which is already allowed in nearly all of Europe.
My main gripe is the ban on flying a SID or a STAR.
Where is it? Nobody knows. Probably wrapped up in the same fate as the CBM IR.
It will be useful to pilots who are currently "clever" VFR pilots and who know how to play the game and are flying suitable aircraft, but who cannot currently climb above weather because ATC will not allow them into CAS because the particular ATC unit (or country) refuses to operate ICAO airspace classification (VFR is OK in all airspace except Class A). In fact the EIR will allow access to Class A as well - just like the full IR.
I can see the objections to the EIR but really it is no different to the present ability to fly VFR above an overcast which is already allowed in nearly all of Europe.
My main gripe is the ban on flying a SID or a STAR.
Where is it? Nobody knows. Probably wrapped up in the same fate as the CBM IR.
Awaiting the Comment Response Document from EASA.
Mind you, with 1556 responses and only 1 Review Team meeting (none other planned, it seems), glib responses such as 'noted' will be unacceptable.
Yes, the EIR would add en-route IFR privileges, but that's about all. Incidentally, the ANO PPL restrictions applicable to JAR-FCL PPLs without IMCRs ceased to apply after 8 Apr 2012 when such licences were 'deemed' part-FCL licences by the UK CAA. So you may fly out of sight of the surface without the need for an IMCR / IR if you wish - assuming you can get up and down again in VMC. This does NOT apply to non-JAR-FCL PPLs such as the UK PPL.
Join Date: Feb 2007
Location: Amsterdam
Posts: 4,598
Likes: 0
Received 0 Likes
on
0 Posts
Incidentally, the ANO PPL restrictions applicable to JAR-FCL PPLs without IMCRs ceased to apply after 8 Apr 2012 when such licences were 'deemed' part-FCL licences by the UK CAA. So you may fly out of sight of the surface without the need for an IMCR / IR if you wish - assuming you can get up and down again in VMC.
Any other hidden gotchas like that? For instance, is there stuff which was previously deemed "aerial work" which can now be done by a PPL, or the other way around? (The two main traditional exceptions obviously were glider tugging and parachute dropping, which could be done by a PPL "for free", instead of having to cost share.)
Join Date: Dec 2011
Posts: 2,460
Likes: 0
Received 0 Likes
on
0 Posts
The UK sight-of-surface for VFR was never in the slightest enforceable or even verifiable and I have never come across anybody who actually bothered to comply with it and who was able to radio-navigate. (one could say the same for VFR in IMC actually 
).
It merely generated gigabytes of discussion on pilot forums
The way it was worded, seeing a mountain peak 100nm away sticking up from the cloud met with the requirement.
This would have met the requirement many times over...
).It merely generated gigabytes of discussion on pilot forums
The way it was worded, seeing a mountain peak 100nm away sticking up from the cloud met with the requirement.
This would have met the requirement many times over...
Join Date: Dec 2011
Posts: 2,460
Likes: 0
Received 0 Likes
on
0 Posts
The EIR will be sub-ICAO, as will be the LAPL.
Not sure how this will be handled. The EU could force member states to file differences to ICAO on this, or they could do it individually. If this were done, then these papers could be valid worldwide unless specifically objected to by the airspace owner. But I suspect nothing will be done because, in general, Europe is big enough to fly around and flying outside Europe is a big logistical hassle (avgas, etc).
Not sure how this will be handled. The EU could force member states to file differences to ICAO on this, or they could do it individually. If this were done, then these papers could be valid worldwide unless specifically objected to by the airspace owner. But I suspect nothing will be done because, in general, Europe is big enough to fly around and flying outside Europe is a big logistical hassle (avgas, etc).
Thread Starter
Join Date: Sep 2006
Location: Los Angeles, USA
Age: 52
Posts: 1,631
Likes: 0
Received 0 Likes
on
0 Posts
If the EIR becomes a reality, I wouldn't be surprised if the FAA followed suite at some point. They are very keen on harmonisation and EASA commonality these days. Last years "line up and wait" etc, etc.
I'm doing my IR as we speak, but the pace has been admittedly rather slow. This trip has certainly re-inforced the idea to ramp it up. With a bit of luck I could be done by late summer, maybe..
I'm doing my IR as we speak, but the pace has been admittedly rather slow. This trip has certainly re-inforced the idea to ramp it up. With a bit of luck I could be done by late summer, maybe..
Join Date: Jul 2005
Location: SoCal
Posts: 1,929
Likes: 0
Received 0 Likes
on
0 Posts
Well, Adam, first off, glad to hear the old gal is holding up well! 
Given where you are, the full IR is definitely the better option. That said, something like the proposed EIR would certainly help in many, if not most, cases, especially for those of us flying non-deiced SEP spamcans. Quite often you can / could depart VFR but then need to punch through a cloud layer to get on your way. It may not be the perfect solution (that would be an FAA-style IR), but the EIR would definitely increase the dispatch rate - if one can use that term in an SEP flying context - greatly.
Given where you are, the full IR is definitely the better option. That said, something like the proposed EIR would certainly help in many, if not most, cases, especially for those of us flying non-deiced SEP spamcans. Quite often you can / could depart VFR but then need to punch through a cloud layer to get on your way. It may not be the perfect solution (that would be an FAA-style IR), but the EIR would definitely increase the dispatch rate - if one can use that term in an SEP flying context - greatly.
Join Date: Aug 2003
Location: Surrey
Posts: 1,217
Likes: 0
Received 0 Likes
on
0 Posts
The EIR makes sense in the strange IR world of EASA/JAA where the overhead assoicated with achieving the rating is grossly excessive. A halfway house between a PPL and IR in a world where you can get all the way to the PPL/IR destination in one economical (in comparison to Europe) step would seem like T!ts on a Bull.
Join Date: Jun 2010
Location: Wiltshire, UK
Posts: 67
Likes: 0
Received 0 Likes
on
0 Posts
If the EIR becomes a reality, I wouldn't be surprised if the FAA followed suite at some point. They are very keen on harmonisation and EASA commonality these days. Last years "line up and wait" etc, etc.
The EIR may make some sense in some cases in Europe, particularly for IMC holders, but a more achievable CBM IR would be a better option.
Join Date: Aug 2009
Location: Copenhagen
Posts: 150
Likes: 0
Received 0 Likes
on
0 Posts
Note that the suggestion is not ONLY an EIR rating. It's a complete review of the IR rating. That means (if it is accepted) that the theory for getting a full IR will be significantly reduced!!.
I think most people with an IR can agree that there is nothing wrong with the practical part of the IR course, but the theory part is WAY overkill.
What the current document describes is both a reduction in the theory (and it will be the same for IR and EIR), and the possibility to first go for an EIR, and then later take the additional 25 hours and get the full IR.
I think most people with an IR can agree that there is nothing wrong with the practical part of the IR course, but the theory part is WAY overkill.
What the current document describes is both a reduction in the theory (and it will be the same for IR and EIR), and the possibility to first go for an EIR, and then later take the additional 25 hours and get the full IR.
Last edited by lasseb; 26th Apr 2012 at 16:14. Reason: spllnnninngg
Join Date: Dec 2011
Posts: 2,460
Likes: 0
Received 0 Likes
on
0 Posts
I think most people with an IR can agree that there is nothing wrong with the practical part of the IR course
The current 50/55hrs is way over the top. While the average ab initio pilot probably needs 40+hrs to pass the northern European IR flight test (IRT) what about those with previous experience? They are just burning money to get the logbook entries, which all have to be done under an FTO, which is expensive.
The CBM IR will retain the present IRT, which in turn means that very few people will be able to take advantage of the proposed zero-training IR conversion option.
Join Date: Oct 2006
Location: London
Posts: 423
Likes: 0
Received 0 Likes
on
0 Posts
The CBM IR will retain the present IRT, which in turn means that very few
people will be able to take advantage of the proposed zero-training IR
conversion option
I think the proposed FAA to EASA IR conversion is actually pretty good (one exam and an IRT, no mandatory training), the problem is the silly requirement for 100hrs PIC Instrument Flight Time. Which unless studying the inside of clouds is your hobby takes 500hrs of IFR...
Join Date: Mar 2011
Location: South East Asia
Posts: 68
Likes: 0
Received 0 Likes
on
0 Posts
the problem is the silly requirement for 100hrs PIC Instrument Flight Time.
Join Date: Dec 2011
Posts: 2,460
Likes: 0
Received 0 Likes
on
0 Posts
I think the proposed FAA to EASA IR conversion is actually pretty good (one exam and an IRT, no mandatory training),
Nobody will pass the IRT - not even a 20k hour airline pilot, and probably especially not a 20k hr airline pilot, without a good number of hours with an instructor familiar with the requirements.
That's why I think the "no mandatory training" part is essentially worthless, while being politically highly provocative (to the FTO industry) and this probably led to:
the problem is the silly requirement for 100hrs PIC Instrument Flight Time. Which unless studying the inside of clouds is your hobby takes 500hrs of IFR...
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?
If so, I cannot see what benefit the FTO industry is going to get by killing off the conversion route by demanding the ludicrous 100hrs PIC instrument time. The only extra workload for the student will be the extra TK and the FTOs don't make any extra money from that; the UK ones will still charge ~£1000 to take some homework off you and sign you off for the exams.
Hodja - the gotcha here is not that it is not IFR time (which is easy to log) but that the 100hrs instrument time has to be as PIC i.e. not under training. Most pilots flying normally accumulate very little instrument time because nobody deliberately sits in cloud, turbulence, icing, etc.
Actually I wonder about what "PIC" exactly means. For example if you do an IR in the FAA system, you log the lot as PIC because the actual flying is VFR, under the hood. Only the 250nm x/c flight is traditionally flown on an IFR FP, and only flights above 18000ft will have to be IFR in which case you cannot be PIC. It is only in the JAA system that training is implicitly PU/T. So I reckon an FAA IR holders' training will count towards the 100hrs. Not that that helps much...
Join Date: Mar 2011
Location: South East Asia
Posts: 68
Likes: 0
Received 0 Likes
on
0 Posts
A lot more than 500hrs IFR. More like 1000-2000hrs IFR
I actually enjoy flying non-turbulent, non-icing IMC. The problem is, around these part of the woods IMC equals TCUs & CBs...
No decision has yet been made concerning the 'demonstration of knowledge' requirement for converting an FAA IR to an EASA CB-IR. Several other recommendations have been made in the NPA 2011-16 response, for example IAOPA (Europe) commented:
Similarly, the '100 hrs IFR as PIC' proposal is unacceptable. So IAOPA(Europe) commented:
We now await the CRD to discover whether the €urocrats have accepted our recommendations.
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.
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 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.
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.