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Old 1st Mar 2013, 17:54
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IR(R) -

Hola,

I have a JAA PPL w/ IMCr due for renewal (the licence that is) in May 2014. I also have FAA CPL/IR, and fly an N reg in Euroland. I have just been reading some of the stuff regarding the IMCr and IR(R) and have a couple of Q's.

The CAA statement here http://www.caa.co.uk/docs/2330/Revis...2012%20_v3.pdf says that the holder of an IR(R) will have the same privileges as a IMCR holder in UK airspace - so shoot approaches, flying an Airspace class D and below IFR.

My question is two fold....first, it seems to me that I am better to swap my licence to a part FCL licence sooner rather than later, as I understand that if done after April 2014, then I would be limited to Non EASA aircraft (whatever they are)? Is this correct?

Secondly the way I understood an IR(R) is that it allowed IFR enroute, but no approach capability. With an IMCR issued IR(R), does this hold true in Europe? So in UK airspace, I would be limited to IFR in Class D and below, but can shoot approaches, but in EASA airspace, I would have no airspace limit, but cannot shoot approaches? Or is this IR only valid in the UK airspace?

Seems kind of confusing to have two IR(R)'s labeled the same, but with differing privileges?

If the second point is true, is there any way to convert my FAA IR to an EASA IR(R) but not restricted to UK only airspace?

TIA....
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Old 1st Mar 2013, 18:26
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E

As far as I read it you can fly approaches in the UK as you can with your IMCR and with the EASA IR(R) Fly enroute in CAS.
Hence in the UK it can be used like an IR albeit with IMCR minimas.

Out of UK airspace you can only use the EASA IR(R) for enroute IFR in CAS NO Stars or Sids NO instrument approaches.
I can see loads of pitfalls and serious problems with the European part

Happy to be corrected

Pace

Last edited by Pace; 1st Mar 2013 at 18:28.
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Old 1st Mar 2013, 18:29
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I have a JAA PPL w/ IMCr due for renewal (the licence that is)
JAA (5 year) Licences are no longer issued. You need to apply
for a (non-expiring) Part-FCL PPL.

As you already have an IMCr you will be given an IR(R).
This is effectively an IMC in another name. Same privileges as
an IMC and still restricted to UK airspace only.

Secondly the way I understood an IR(R) is that it allowed IFR enroute
No
You are thinking of the En-Route IR (ERIR) which does not currently
exist, but has been proposed.
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Old 1st Mar 2013, 18:53
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You are thinking of the En-Route IR (ERIR) which does not currently
exist, but has been proposed.
LA

That is pretty obvious! and what he is referring too. I personally think there are huge pitfalls in an enroute IR without approach and instrument landing abilities either end and in the middle

Pace
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Old 1st Mar 2013, 19:37
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I would be limited to IFR in Class D and below, but can shoot approaches, but in EASA airspace, I would have no airspace limit, but cannot shoot approaches? Or is this IR only valid in the UK airspace?
We dont know of course but I dont think that can be so.

It seems certain the EIR will allow en route IFR in all classes of airspace and since it is an EASA rating will include the UK. In the UK the IMCR (now the IRR) will permit any approach with the same minima as an IR other than in respect of runway visibility in which event it is slightly more restrictive although unlikely to be relevant for GA.

In Europe the IRR will have no validity BUT we dont know how the IRR will deal with the off airways segment.

We also dont know whether their will be a conversion route from the IRR to the EIR.

It is still a mess but at least those years ago when we campaigned for the IMCR to be retained has rightly paid the most wonderful dividends in spite of the nay sayers; and thank you Englishal for the part you played.
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Old 1st Mar 2013, 20:14
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1. The EIR is an 'enroute only' EASA IFR rating which is still only a proposal.

2. The IR(R) is exactly the same as the UK IMCR - same privileges, restrictions, revalidation and renewal requirements. For boring technical reasons, an IMC Rating cannot be included in a Part-FCL licence, so it has been termed the Instrument Rating (Restricted) at my suggestion.

3. Currently, or at least until some sense is knocked into the blinkered, stubborn €urocrats in Köln, only those pilots whose licences included IMCR privileges prior to 8 Apr 2014 will be able to exercise them on EASA aeroplanes (and if you don't know what those are, you need to find out!) after that date. To do so, such IMC privileges must have been converted (paperwork exercise) to an 'IR(R)' - if they haven't been, pilots will only be able to exercise such privileges on non-EASA aeroplanes until their licence does include an IR(R).

4. Pilots who don't already have one will still be able to obtain IMCRs after 8 Apr 2014, but only for use on non-EASA aeroplanes.

The fight for new issues of the IR(R) after Apr 2014 is still being fought - at pretty high level.

It is by no means certain that the EIR will be adopted; at least one NAA is firmly against it on safety grounds.

Last edited by BEagle; 1st Mar 2013 at 20:18.
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Old 1st Mar 2013, 21:22
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Thanks. So I'll renew my jaa ppl early to get an IRr added to use in easa aeroplanes in the hope of getting an ERIR by default, seeing as my faa ir wont be good enough one day. Bit of a stupid name that, easa aeroplane, my easa Rockwell Commander is actually an FAA aeroplane and was built in america too ...
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Old 1st Mar 2013, 21:47
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Not many easa aerocraft built in europe, diamond is about the only current generation that springs to mind and they build the other side of the pond as well.

It may say something in itself about easas attempts to strangle ga
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Old 1st Mar 2013, 22:22
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The IR(R) does not exist in reality, it is merely a device to allow the UK IMCr to prolong its existence in the EASA environment. Whilst it exists for the moment, there is no certainty that it will survive into the future, although BEagle will, no doubt, be strident in its defence. The EIR, on the other hand, is a perfect example of a 'committee' solution - it neither satisfies nor offends anyone and is, as a result, totally useless in practice. Whoever dreamed up the idea (and I know who it was) should be smeared in honey and strapped over an anthill!

Considering that it is now approaching a year since the Aircrew Regulation became law, there is a worrying lack of understanding of the definition of an EASA aeroplane. Only slightly less worrying is the confusion that is apparently being caused by the ersatz IR(R).
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Old 1st Mar 2013, 22:30
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Quote:
You are thinking of the En-Route IR (ERIR) which does not currently
exist, but has been proposed. LA

That is pretty obvious! and what he is referring too.
I don't think so since he originaly said:
Secondly the way I understood an IR(R) is that it allowed IFR enroute, but no approach capability.........

Seems kind of confusing to have two IR(R)'s labeled the same, but with differing privileges?
and I think he is still confused:
I'll renew my jaa ppl early to get an IRr added to use in easa aeroplanes in the hope of getting an ERIR by default
englishal

You will get an EASA Part-FCL PPL and, yes, you will get an IR(R).

You will not get an EIR by default.
1) Because it does not yet exist (and may never)
2) You will have to do the Training Course, and pass the
Test like anyone else (though you may be credited with
some elements due to having an FAA IR).

There is no need to rush - Your JAA PPL + IMC will remain good for EASA
aircraft until the Licence expires (May 2014).

Last edited by Level Attitude; 1st Mar 2013 at 22:56.
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Old 1st Mar 2013, 22:53
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The IR(R) does not exist in reality, it is merely a device to allow the UK IMCr to prolong its existence in the EASA environment
Billie Bob

EASA have a real problem! They are supposed to be safety regulators! The french have a very poor safety record under VFR the UK has a good safety record in comparison with the IMCR.

EASA cannot ignore the safety argument for allowing a certain level of instrument flight below a full IR on safety grounds for VFR pilots.

Frankly they have not got a clue about what they are doing and are desperate to put something in place which does not water down their own IR plans but which improves the poor safety record of VFR only in France

Pace
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Old 1st Mar 2013, 22:56
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BEagle, thanks for the bullet points, although I have a doubt now.

If I had a plain JAR-PPL right now, I could add an IMCR to it (no later than 8 Apr 2014) and then convert the lot to an EASA PPL(A) + IR(R). Fine.

What if I had already a Part-FCL licence right now (plain vanilla EASA PPL - Aeroplanes): would it still be possible, up to 8 Apr 2014, to add an IR(R) rating to it (not an IMCR, since you said that it's not possible due to a technicality)? Or is the former the only route to an EASA PPL(A) + IR(R)?
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Old 1st Mar 2013, 22:58
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If the second point is true, is there any way to convert my FAA IR to an EASA IR(R) but not restricted to UK only airspace?
While everyone seems to rush to condemn the EIR, I'm surprised that nobody has mentioned to englishal the other part of the FCL.008 group's work, which was captured in the CRD as:

8. Applicants for the competency-based modular IR(A) holding a Part-FCL PPL or CPL and a valid IR(A) issued in compliance with [ICAO] requirements may be credited in full towards the training course [for the IR]. In order to be issued the IR(A), the applicant shall:
(a) successfully complete the skill test for the IR(A) ...;
(b) demonstrate to the examiner during the skill test that he/she has acquired an adequate level of theoretical knowledge of air law, meteorology and flight planning and performance (IR);
(c) [have English Language Proficiency];
(d) have a minimum experience of at least 50 hours of instrument flight time as PIC on aeroplanes.


(d) is likely to be changed to "50 hours of flight time under IFR" when the Opinion is published.

Whether that part of the amendments to Part-FCL becomes law before April 2014 may be too close to call, but either way, as long as you have a valid FAA IR, you should eventually be able to get yourself a Part-FCL IR (no 'E', no 'R') with minimum hassle -- effectively just a check ride.
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Old 2nd Mar 2013, 07:22
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Implementation is likely to be delayed to 2016 anyway as nothing is sorted or set in concrete still and there would be chaos trying to Implement in 2014.
That was readily but unofficially accepted by EASA at the last big meeting.

Pace
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Old 2nd Mar 2013, 07:34
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What if I had already a Part-FCL licence right now (plain vanilla EASA PPL - Aeroplanes): would it still be possible, up to 8 Apr 2014, to add an IR(R) rating to it (not an IMCR, since you said that it's not possible due to a technicality)?
Yes. No matter whether you have JAR-FCL PPL or a Part-FCL PPL, you will do the same IMCR course and send off your licence for inclusion of the Rating. When it comes back, it will be a Part-FCL PPL(A) with IR(R). It is impossible for the CAA to add anything to a JAR-FCL licence now - even something as simple as a change of address.

(d) have a minimum experience of at least 50 hours of instrument flight time as PIC on aeroplanes.
is an error - they have assured me that this was supposed to read '50 hours flight time under IFR as PIC on aeroplanes' and have apologised (as far as Germans know how....) for their sloppy proof reading.

The NPA2011-16 CRD reads:

Accepted

Thank you for providing this comment.

The Agency and the Review Group experts agree with IAOPA (Europe) and have amended 8(b) to allow an applicant to demonstrate adequate theoretical knowledge to an examiner during the skills test.

The Agency and the group also agreed to amend 8(d) by reducing the minimum experience required to 50 hours flight time under IFR as PIC on aeroplanes.

Last edited by BEagle; 2nd Mar 2013 at 07:52.
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Old 2nd Mar 2013, 09:42
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But if I renew after April doesn't that mean it will be restricted to non easa aeroplanes? Ie I have to change to part FCL before my license expires?
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Old 2nd Mar 2013, 11:01
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Bookworm

Not maybe so much for this forum but there is still a long silence on the dual licencing requirements and conversion route for FAA ATP conversion for working European pilots flying N reg in Europe?

There is supposed to be another big meeting this summer EASA FAA where things should be clearer and I cannot see pilots waving new bits of paper till 2016 which was unofficially accepted by EASA as a likely implementation date at the last meeting.


Pace

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Old 2nd Mar 2013, 12:04
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But if I renew after April doesn't that mean it will be restricted to non easa aeroplanes? Ie I have to change to part FCL before my license expires?
From April 2014, you will need a Part-FCL licence to fly "EASA aircraft" (i.e. those that don't fall under Annex II of the Basic Regulation). Your JAR-FCL licence is deemed to be a Part-FCL licence. When you convert (or "replace", long story) your JAR-FCL licence to a new Part-FCL licence (which you must do before the JAR-FCL one expires in May 2014), the new one will have an IR(R) attached to it, which will allow you to continue with the privileges you currently have. After April 2014, you may not exercise the privileges of an IMC rating attached to a JAR-FCL licence on an EASA aircraft until it is converted to a Part-FCL licence with an IR(R) attached.

Implementation is likely to be delayed to 2016 anyway as nothing is sorted or set in concrete still and there would be chaos trying to Implement in 2014.
That was readily but unofficially accepted by EASA at the last big meeting.
...
Not maybe so much for this forum but there is still a long silence on the dual licencing requirements and conversion route for FAA ATP conversion for working European pilots flying N reg in Europe?

There is supposed to be another big meeting this summer EASA FAA where things should be clearer and I cannot see pilots waving new bits of paper till 2016 which was unofficially accepted by EASA as a likely implementation date at the last meeting.
Big meeting of what, Pace? And implementation of what?
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Old 2nd Mar 2013, 13:34
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Regarding requiring dual licences to fly N reg aircraft in Europe! If you remember EASA had a bilateral agreement with the FAA already in place to which they hoped to attach FCL.
Last summer there was a joint meeting between the FAA and EASA to look at ways of bringing a bi lateral about dual licences being declared by EASA as not being their route of choice as well as being legally riddled with potholes for them regarding working pilots in Europe.

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Old 2nd Mar 2013, 14:07
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IMCR

I have a JAA PPL issued in Feb 2012 when my ATPL expired,this PPL expires 2017.
I have a valid UK IR which I will let lapse this year due cost. I recently sent to CAA the application and cheque for the inclusion of an IMCR on the basis of my current full IR.
It took two months for them to reply refusing to add an IMCR/ IR/R to my PPL as it is not an EASA license,and I would have to apply for issue of new EASA PPL as they now only issue EASA licences, with associated costs. Two new licenses in less than a year!

I thought after 4/2012 all licenses would be deemed an EASA license and then a proper EASA license would be issued on renewal in 2017?

Last edited by cessnapete; 2nd Mar 2013 at 14:10.
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