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EASA publishes draft IMC flight 'Opinion'

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EASA publishes draft IMC flight 'Opinion'

Old 29th Apr 2013, 10:26
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I don't know where I said the EIR forced you to fly airways??

The EIR is being promoted as offering access to airways. EASA refer to flights being IFR in the en-route phase but ending VFR at an airfield without any nav aids. Is UK not unusual in having so much off-airways IFR anyway??
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Old 29th Apr 2013, 17:35
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Can the CAA not say that National Licences will allow pilot
privileges on EASA aircraft in UK Airspace only?
No. An EASA aircraft (i.e. non-Annex-II) requires an EASA Part-FCL licence.

It is a question of politics and no-one in EASA will admit the best solution for light GA is an FAA style IR. Even your CB IR will be more expensive to obtain and maintain.
Why will the CBM-IR will be more expensive to obtain and maintain than an "FAA style IR"?

There are probably four factors:

1) The higher cost of aircraft operation in the EU
2) The requirement for ATOs to be approved, hence passing on the fixed costs
3) The requirement for an annual proficiency check
4) The greater theoretical knowledge content, even though it's 50% of what it was for the JAR-FCL IR

Factor 1 is just a fact of European life. It's never going to be as cheap to fly in the EU as in the UA. Enjoy the free/cheap healthcare though.

Factor 2 is a consequence of the EASA system, which appears to equate "approval" and "certification" with safety. It will affect all training, including, if it were retained, training for a future IMC rating if is to be applicable on EASA aircraft. For the CBM-IR, only 10 of the 40 hours need to be at an ATO, which should help with costs.

Factor 3 makes the IR a bit more expensive. I don't see much difference between a prof check and a BFR which the FAA pilot is going to be doing anyway. The IMC rating has a biennial renewal, which isn't much different.

The cost and convenience difference of factor 4 is probably more dependent on the mechanism by which the theoretical knowledge training and testing is delivered than the amount of stuff in the syllabus. The FAA IR has a single exam and the preparation is a single book, but covers much of the same ground.

The UK solution to the original gold-plated IR was to create a rating for PPLs (and included in the CPL) requiring 15 instead of 40 hours, slashing the ICAO standard for IFR privileges. The safety record of the IMC rating speaks volumes about the appropriateness of that hours requirement, but I fear that another one of EASA's flawed assumptions is that ICAO's word is sacrosanct, even if activities are confined to the EU. I'd like to see the IMC rating be offered (for use in UK airspace) alongside the CBM-IR and EIR.

So the key factors to attack are the requirement for ATO approval and the ICAO Annex 1 hours requirements (which might be replaced by something a bit more competence-based). The requirements affect a lot more than just the IR. PPL/IR Europe, IAOPA-EUR and Europe Air Sports are working hard to address those and other issues with EASA and the Commission.
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Old 30th Apr 2013, 05:44
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5) The lack of FTOs willing to handle private pilots (non ATP)
6) The huge lack of FTOs willing to handle pilots with their own plane

The above two factors inflate the IR process with a big disruption to one's life and extra costs and hassle (hotels, travelling, etc).

Whereas in the USA you can do the IR in the same school where you did your PPL.

I could also add the FTO moneymaking scam called the "170A flight test" but that may go away...
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Old 30th Apr 2013, 05:55
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7) A 170A which could cost another £1000 all in with aeroplane hire etc....
8) the CAA test fee which will no doubt set you back another grand

All these extra Grands add up, plus with over inflated sim prices (£200 per hour is not uncommon - the SAME sim in the USA would cost you $100 per hour).

Is it Greed in EU land? That flying should be limited to the very few privileged people? That is what it seems like sometime.....
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Old 30th Apr 2013, 06:29
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Most of the cost difference is the instructor pay.

And the instructor cost will only get higher as there is no easy way for ppl instructors to get the IRI with having to build hours which most won't be able to afford without going to fly commercially first. Once they have stepped out of the instructing side of things most never return.
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Old 30th Apr 2013, 06:34
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All these extra Grands add up, plus with over inflated sim prices (£200 per hour is not uncommon - the SAME sim in the USA would cost you $100 per hour).

Is it Greed in EU land? That flying should be limited to the very few privileged people? That is what it seems like sometime.....
The core problem is a restrictive GA regulatory environment which is generally getting worse under EASA, but I still believe that is more to do with CAA interpretation of rules than direct EASA issues. The second problem is that most of the kit is USA made and pricing tends to be done on the basis of just changing the sign in front from $ to £ an issue that has been a problem in IT and comms for aeons.
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Old 30th Apr 2013, 06:55
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..... guys, can you please read yourselves back.... you are starting to moan like a bunch of old women who have been married for 50 years and have not have had sex since the first day of marriage.

If this is the way we go about when progres is made .... ???


regarding

1. go and live in the usa
2. true but some real competition is coming up. you will find a good ATO willing to accomodate you more than you will expect at a very reasonable price .. otherwise come to Rotterdam and I will gladly sort this or you.
3. the US way is much better but 1x per year is doable.
4. agreed, but it is still a quantum leap forward.. If you push it, you can do this really quick.
5. Hey, it is one Europe, just make a deal elsewhere and you will see ATO's waking up to the new reality. You will find plenty good and willing ones .. else see 2.
6. Ditto .. just a matter of finding a willing ATO. I know my ATO iN Rotterdam will gladly do it and be of service.

7. a170a? I presume you mean the checkride? I know in Holland they will charge you £ 300-350 for an ir checkride. And this is perfectly allowed while he would be accredited by your CAA .. so you are rid of these CAA employed examiners.

8. see 7.

...

Europe means a very strange way of finding a compromise solution whichs outcome is in many cases not the wanted endresult as there are allways a few countries who will hold you back regardless of logic or reason. It however also means that you have to look from a much broader perspective and find and see the oppertunities which arise from this.

I know that french ATO's are very willing as well. You will even find ATO's with dual Faa/easa fi .. making for an interesting combination. (for example if you would like to add a twin rating). Allthough I did hear some strange things about the cost of insurance when under a French ATO but that might be a purely french thing.

Last edited by Ellemeet; 30th Apr 2013 at 06:57.
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Old 30th Apr 2013, 07:19
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A 170a is a UK thing which dates back to when all IR's and a lot of CPL's were tested by CAA employed examiner.

There was a set of examiners who weren't employed by the CAA who were authorised to pre test the candidate which they had to pass before getting sent on to the CAA ones. It was I think a way of only making likely passes going for the full thing.

Unfortunately it was perverted by some schools as a method of extracting more money from the student.

There was never a requirement for a flight test for the CPL only a paperwork check but many schools still demand a flight test outside the CPL course.

For the IR there is a bit of a grey area now as its not compulsory for you to use a CAA examiner. The test is normally done but there have been some who have managed to by pass the test and go straight to test because under EASA and JAR I believe there is no requirement for it. Obviously the schools don't like this as its 2.5 hours in the aircraft and also the local examiner also gets a fee for the test. In a twin including approach fees this can cost over £1000 per test.

At the beginning of JAR there was a bit of confusion about how it was all applied. And quite a few of us managed to get the 170a included in the course and also that the full time in the aircraft from taxing to stop was included in the course hours. Which personally saved me about 5 hours on the course of 55hours and a 2.5 hour test and approach fees. So about 2.5k at the prices at the time. The UK CAA won't allow this now.
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Old 30th Apr 2013, 07:35
  #49 (permalink)  
 
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tx

Did not know this but it is apparantly another typical UK thing ...

Hurray again .. you do not need this what so ever..

Last edited by Ellemeet; 30th Apr 2013 at 07:36.
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Old 30th Apr 2013, 07:59
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The pre JAR set up was in some ways a lot better.

You could count IMC rating training and could also do training as required with certain experience requirements. That all went to the wind in 2002ish.
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Old 30th Apr 2013, 08:33
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mmm

interesting.. The imc rating training ... can you or can you not count this towards the full CBM IR? It would make sense that you can?
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Old 30th Apr 2013, 08:54
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I don't have a clue about that side of things.

I could never justify the cost of getting the no instrument applied restriction when I was a full time instructor. So would now need to get an IRI unless I went through regaining my FI and upgrading.

And now I have loads of hours flying IFR but in a twin turbo prop and my FI lapsed recently.

So to become a FI capable of teaching on twins and single I would need.

FI revalidated which is a two day course and skills test £1000
MEP rating back which apparently is a full course now to learn how to use cowl flaps and mixture levers. £4000

30 hours PIC in a MEP £7500 (the 3000 IFR hours as PIC of a twin TP don't count)

MEP added to FI £3000

IR added to FI £1500

So as you can see from those costs there isn't going to be many Commercial pilots going to go near becoming able to teach IR. And the current PPL instructors don't have anywhere near the IFR experience levels to be able to teach it.

So in some ways it really doesn't matter what the rules are about gaining a flavour of IR there is going to be no bugger to teach it. And the few that do will be able to charge a fortune so will price most out of the market.
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Old 30th Apr 2013, 09:24
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(the 3000 IFR hours as PIC of a twin TP don't count)
This is bloody madness isn't it! And why the FAA have it right when it comes to revalidations etc.....Catagory / Class and all that.
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Old 30th Apr 2013, 09:28
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Mad Jock

I am lost. The question was wether you can or can not count the trainings hours for the imc rating towards the CBM ir, not what it takes for you to get current. This with respect to your remark about the pre jar era.

getting a sep rating back should be nothing more than a proficiency check.
mep you should still be?

For FI I have no idea but I think your assumption is wrong as your experience will count or may be used on special request to waive certain requirements.
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Old 30th Apr 2013, 09:37
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Sorry I don't think you can, but my slight rant was to say that I am not really current to be able to say yes or no.

MEP is covered by the currency rules and basically after 3 years you have to do the whole thing. I am way way past the 3 years.

Then you have to send it back to the CAA to get the rating re-issued. SEP is slightly different as there is no defined course for a SEP class rating. I presume though you would still have to send the license off to get the class rating re-issued. Any way that's still current for me. I just go up with a tame examiner when ever its due and get my IMC and SEP signed off at the same time for aircraft time and loads of beer.

And they won't give any credit I have asked and been told NO you will have all the boxes ticked. Even guys who have been flying single crew in F406's have been knocked back.
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Old 30th Apr 2013, 09:43
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are you talking about MEP rating or ME FI ?

As you fly twins you have your ME rating??
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Old 30th Apr 2013, 09:51
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BEagle, you're so focused on preserving this sub-ICAO 'IMC Rating' that you've completely forgotten all the positives of the CBM-IR and EIR where the very "€urocrats" you mention have actually listened to the plight of many pilots across Europe who all want more accessible qualifications for instrument flying.
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Old 30th Apr 2013, 10:04
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MEP rating is a class of aircraft, ME is a subset of the IR rating.

You can be a IR instructor on the F406 which is ME but you would need to be a CRI on that type as well. But unless you were a CRE on MEP you couldn't teach IR's on it.

It all gets a bit involved but to teach IR on piston aircraft single engine.

You need.

SEP class rating
SPA-SE-IR.

IRI-SE.
or in the UK FI with applied instruments removed.

For MEP

MEP class rating
CRI MEP
SPA-ME-IR

IRI-ME
CRI on the class or type your teaching on
or UK FI with MEP and applied instrument restriction removed.

Pre-Course Entry Requirements

An applicant for an IRI(A) certificate shall:

(a) hold at least the licence and the rating for which flight instruction is to be given

(b) be entitled to act as PIC on the aircraft during flight instruction

(c) have completed at least 800 hours of flight time under IFR, of which at least 400 hours shall be in aeroplanes
That's what the current pre course experience levels required. There is no way in hell that any single engine PPL instructor will be able to get 800 hours IFR time.

plight of many pilots across Europe who all want more accessible qualifications for instrument flying
Even if you get the qualification there isn't going to be anyone to teach it. The teaching IMC was within the grasp of most PPL instructors and in fact before 2000 it was a requirement to become unrestricted. Which was why the IMC rating had such a huge uptake as people very easily could go PPL, night then IMC.

Last edited by mad_jock; 30th Apr 2013 at 10:06.
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Old 30th Apr 2013, 10:28
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BEagle, you're so focused on preserving this sub-ICAO 'IMC Rating' that you've completely forgotten all the positives of the CBM-IR and EIR where the very "€urocrats" you mention have actually listened to the plight of many pilots across Europe who all want more accessible qualifications for instrument flying.
Well said.
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Old 30th Apr 2013, 12:12
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I hereby appoint soaringhigh650 as my sexual advisor....

As for
the plight of many pilots across Europe who all want more accessible qualifications for instrument flying
you'll find that it was only the French who actually bothered to propose a national IR before the leaden hand of FCL.008 descended. None of the other Member States did....

As has been said, try and find anyone with the right qualifications to teach the EIR and/or C-bM IR, at least in the short-to-near term, and you'll be looking long and hard.

The UK fully supports the EIR, C-bM IR and SCFR. But unless the Draft Opinion is amended to include the flexibility of JAR-FCL 1.175(b), it will NOT be possible for the UK to vote honestly for the Draft Opinion at comitology. For which Goudou and his gang of €urocrats can rightly be held to blame.

Last edited by BEagle; 30th Apr 2013 at 12:13.
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