The future of EASA Instrument Qualifications

[englishal]

No, you have read that wrong. There are no credits towards the EIR for the IMC rating -- you have to do the full 15 hours. There are credits towards the CBM route to the IR, to the extent that an IMC-rated pilot may require as little as 10 hours.

What about conversion to the EIR from ICAO IR?

I have the FAA IR and on top of that IR(R) due to the FAA IR. Obviously flying airways is a piece of cake and I have done hundreds of hours of IFR flights.

For most of my flying, if I had the EIR, IR(R) and FAA IR then I would be more than happy. Most of my flying time is spent in the UK (or USA), rather than Europe and for Europe the biggest advantage would to be able to get back home again - where approaches would be legal. I don't plan to fly approaches at LHR, but even that will become class D one day, so effectively this Combo would give me a full IR in the UK.

The biggest benefit of the EIR is "airspace avoidance". You file your FP and all airspace disappears......it is great stuff. It also means I can get up high in the UK, where out TC'd aircraft really comes into its own.

Of course this is nothing new and nothing that we don't already have by virtue of a N reg and FAA IR, but I would be quite happy with this combo. I am presuming the IR(R) and EIR could be re-validated in one flight?

[BEagle]

Are the IMC recommended minima now hard minima if using the rating?

AOPA proposed this to the CAA several months ago; however, no response has yet been received.

[Genghis the Engineer]

Originally Posted by BEagle

AOPA proposed this to the CAA several months ago; however, no response has yet been received.

AOPA proposed creation of an additional restriction where there wasn't a safety problem? At-least, I'm not aware of any safety problems being caused by IR(R)/IMCR holders flying occasionally to somewhere between IMCR recommended minima, and IR hard minima?

G

[Cathar]

If the EIR is accepted by the European Parliament

It is the Regulation as a whole that is subject to scrutiny by the European Parliament and the Council. They cannot reject the EIR and keep the rest of the Regulation. They can only vote to oppose the adoption of the Regulation in it entirety on certain legal and procedural grounds. If that happens the CBM IR, Article 4(8) and the extension of the derogation for third country licence holders would also be lost. Given that there does not appear to be anyone lobbying against the Regulation it is hard to imagine that it will be rejected.

So far as I am aware, EP scrutiny has lead to only one motion to oppose the adoption of a Commission Regulation giving effect to EASA implementing rules. That was on flight time limitations. The motion was defeated in the vote.

[Pace]

Sorry if some of these IRs are confusing ; ) if we are talking about the enroute IR where you have to drop out of CAS before the STAR and cannot fly an instrument approach then there are a number of safety issues
1 where do you get your destination weather? Fly to Barcelona surrounded by big mountains and the coastal weather given for Barcelona can be very different to your departure from CAS point maybe 25 miles away over heavy terrain!

2 with no instrument landing ability what happens to Joe Bloggs sitting in the sun at 10k who has a problem which means he had to land?
Using the Bsrcelona example I have departed UK in CAVOK Barcelona CAVOK and had the airfields enroute reporting 800 meters overcast 200 what does our intrepid enroute pilot do when forced to land enroute ?

We discussed this before there has to be inbuilt safeguards for those eventualities

Pace

[bookworm]

So far as I am aware, EP scrutiny has lead to only one motion to oppose the adoption of a Commission Regulation giving effect to EASA implementing rules. That was on flight time limitations. The motion was defeated in the vote.

For those interested: motion, vote, rule of procedure.

And, as Cathar says, I think that's the only such motion on EASA Committee output.

[BEagle]

Genghis the Engineer, the idea is to add credibility to the IR(R), so that it cannot be thought of as an IR-by-stealth by those who would discredit it.

IMCr holders are NOT assessed to IR minima, which require a faster scan and corrections to be applied more promptly closer to the RW for obvious reasons.

Why the UK AIP lists the IMCr minima as 'advisory' is beyond me. In 40+ years of holding IMC approach qualifications, I'd never come across 'advisory' minima before. Fortunately most, if not all, IMCr pilots are not so stupid as to press on below these limits though.

[BackPacker]

Sorry if some of these IRs are confusing ; ) if we are talking about the enroute IR where you have to drop out of CAS before the STAR and cannot fly an instrument approach then there are a number of safety issues

First, I don't think you have to "drop out of CAS". I don't see an inherent restriction or rule that prevents you from cancelling IFR while still inside CAS - unless that CAS happens to be class A. The only real issue is that you have to (be able to) descend into VMC and cancel IFR, before dropping below the MSA/MVA (or whatever it's called). Whether that happens inside or outside CAS is largely irrelevant as far as I can see.

As far as the rest is concerned, yes, I see and share the concern but shouldn't that be solved by normal planning: Making sure the flight can be executed within the privileges of your licence?

You should not commence a VFR-only flight if the forecasted weather is below VMC anywhere on your route, or have a solid plan B.
You should not commence a Y or Z flight if the VFR portion of your flight is below VMC anywhere on that part of your route, or have a solid plan B.
You should not commence an IFR flight if your origin or destination is below IFR minima, or have a solid plan B (which, admittedly, is easier to create and execute than the previous examples).

And with the EIR, the additional consideration is:
You should not commence an EIR flight (a VFR-IFR-VFR flight executed with EIR privileges) if your origin or destination is below VMC, or have a solid plan B.

In all cases you've got to keep up to date with the en-route and destination weather during the flight, to avoid being suckered into a situation where there is no easy or legal way out.

And as for trouble en-route: The exact same would be true for VFR-on-top flights, or for instance SEP flights over water: It becomes a risk management issue. In those cases, I'd prefer doing an EIR flight (high, in the airways, with constant ATC oversight), than doing the equivalent flight as a VFR or VFR-on-top flight. After all, in large parts of Europe, VFR or VFR-on-top means at a significantly lower altitude and with less ATC support compared to an IFR flight. Up high it's all class A (or class C with additional restrictions that for all practical purposes it's class A anyway) so if you want to have safety in altitude, you need an IR or EIR.

I can well imagine that from the point of view of a full-IR rated pilot, the EIR seems to be a step down in a lot of things. But from the point of view of a VFR-only pilot it's a very welcome step up. A step up that can bring additional safety, as long as you use it responsibly.

[englishal]

They may not be assessed to IR minima, but I bet you after 40 years of holding an IMCr a person could fly a stabilised ILS down to minima! Actually flying an ILS to minima, is, should I be so bold as to say, easy in calm non convective conditions, if the approach is stabilised early on - which it should be anyway. This means knowing your aeroplane, the power settings etc..

Still interested to know if ICAO IR holders will be given credit towards the EIR?

[mad_jock]

Fortunately most, if not all, IMCr pilots are not so stupid as to press on below these limits though.

All the ones I know wouldn't think twice about going down to mins. In fact most if not all IMC examiners that I know tested down to IR minimums.

On the bias that if they need it they better know how to do it. There is one that teaches down to 50ft, for when the poo hits the fan and sod the mins.

[IRpilot2006]

AOPA proposed this to the CAA several months ago; however, no response has yet been received.

Not suprising as the cloudbase is pilot interpreted and is unenforceable!

Can't believe AOPA is doing this kind of proposition to the CAA.

[bookworm]

Not suprising as the cloudbase is pilot interpreted and is unenforceable!

BEagle didn't say anything about cloudbase being involved. Just a mandatory higher DH/MDH.

[bookworm]

Still interested to know if ICAO IR holders will be given credit towards the EIR?

FCL.825 (i) Applicants for the EIR, holding a Part-FCL PPL or CPL and a valid IR(A) issued in accordance with the requirements of Annex 1 to the Chicago Convention by a third country, may be credited in full towards the training course requirements mentioned in point (c) . In order to be issued the EIR, the applicant shall:
(1) successfully complete the skill test for the EIR;
(2) by way of derogation from point (d) , demonstrate during the skill test towards the examiner that he/she has acquired an adequate level of theoretical knowledge of air law, meteorology and flight planning and performance (IR);
(3) have a minimum experience of at least 25 hours of flight time under IFR as PIC on aeroplanes.’

But bear in mind:

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 the requirements of Annex 1 to the Chicago Convention by a third country may be credited in full towards the training course mentioned in paragraph 4. In order to be issued the IR(A), the applicant shall:
(a) successfully complete the skill test for the IR(A) in accordance with Appendix 7;
(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); and
(c) have a minimum experience of at least 50 hours of flight time under IFR as PIC on aeroplanes

So if you have 50 hours IFR, you might as well convert to the IR.

[Barcli]

Understood - so that's all for someone having an IR(A) then Englishal, not an IR(R) - so give Timmy a ring and do the training and test !!

[BEagle]

Can't believe AOPA is doing this kind of proposition to the CAA.

Why? 'Advisory' limits are utterly meaningless and merely give ammunition to IMCr / IR(R) detractors who like to suggest that it is a rating for amateurs who are quite happy to ignore limits.

Or have I flushed out a couple of scud runners?

All the ones I know wouldn't think twice about going down to mins. In fact most if not all IMC examiners that I know tested down to IR minimums.

On the bias that if they need it they better know how to do it. There is one that teaches down to 50ft, for when the poo hits the fan and sod the mins.

Little wonder that the IMCr has such a poor reputation in some quarters...

[englishal]

Roger that. Might as well do the full IR(A) in that case

[Pace]

Backpacker

It's just my personal opinion flying 3000 hrs in various piston twins around Europe!
I cannot see a halfway house in instrument flying you either can do it properly or not at all! Too many times I have seen weather go down and IMO you have to have the Skills to fly instrument approaches to minima!
It is so easy to fly on top of broken cloud only to find that the holes close up, the tops rise and the bottoms descend!
There are IMCR pilots who fly out of CAS who are very skillful at what they do but it's usually with years of experience but they can fly instrument approaches often down to IFR minima.
This idea of having a half way house pilot flying on top without the ability to fly a full set of IFR procedures worries me!
Too many times I have seen the weather go pear shaped!
One trip was forecast good VFR from Paris to the coast!
I filed VFR for the short trip to suddenly being on top of scud cloud which went solid! I filed IFR in the air to land at my destination on minima for the airfield!
Ok if a pilot is very self disciplined he won't go but many do!

The IMCR is the minimum proper IFR rating which allows an instrument approach if need be!
The enroute restricted IR is a halfway house which is asking for trouble

Pace

[mad_jock]

Don't know the accident stats for up North aren't to shabby on that front.

And if you decide to go around at Wick because you can't see the ground you really don't have many options about especially if the wind is up from the wrong direction.

And for those of us with a MPA-IR its not really saving us from anything we don't do day in and day out at work.

[BEagle]

Don't know the accident stats for up North aren't to shabby on that front.

In English, please....

[mad_jock]

We don't have many if any IMC holders crashing off instrument approaches.

The TAF's up North are not the best either as the metoffice computer doesn't seem to know about Sea Haar or the tide. And whatever sorts the predicted cloud base out doesn't always get it right.

And if east coast starts going out its a long way to Glasgow/Prestwick.