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EASA Enroute-IR minimum ceiling?

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Old 28th Feb 2014, 11:55
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EASA Enroute-IR minimum ceiling?

Hello everybody,

I have followed the new EASA suggestions for the Enroute IR flight with great enthusiasm.

However I cannot find anywhere the rules for the minima. I know that the departure and landing must be under VFR, but what are the criteria for the ceiling?

Let me have some examples:

Dep. and Ldg. Airport: Broken/OVC in 1500 ft. both in airspace G. Here I could fly in e.g. 1300 ft VFR, but can I go to e.g. FL100 ang go enroute IFR?

How low can the ceiling be in controlled/non-controlled airports before I cannot go VFR in the landing circuit?

I hope you can help me finding these rules!
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Old 28th Feb 2014, 12:40
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As far as I read it and i am sure someone else can clarify. the Idea of the enroute IFR is that you take off VFR/VMC fly on top to detonation where your approach and landing is VFR/VMC.

The problem with that as an example is you cannot fly a STAR and as such would have to leave CAS before the start of the Star.

Somewhere like Barcelona you may well indeed get CAVOK but 30 miles inland there could be heavy build ups over the mountains at start of STAR where you have to leave and are on your own.

The other problem I have is enroute in a single you may be over airports below where the cloud base is 200 feet what happens if you need to divert!
As I read it you can with a UK IMCR Leave the UK in IMC and return in IMC but only in UK airspace.

Pace
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Old 28th Feb 2014, 14:48
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Just my tuppence.... in Germany, VFR flights are forbidden when the clouds are under 500 feet so in uncontrolled airspace, I would take that as my minimum to be able to start and land VFR - whether I would want to, is another topic. When viewing controlled airspace, Delta CTRs have minimum cloud bases of 1500 feet for VFR flight so there's your answer for that.

When departing you would likely also have to remain VFR until you exceed the Minimum Radar Vectoring Altitude which AFAIK is 1000 feet above the highest object within 8km plus a 500 feet puffer for uncontrolled airspace so if the MRVA is (e.g.) 3000 feet, you wouldn't be allowed to do your trip....

On cancelling IFR, you'd probably be in Echo airspace which means you would need vertical separation of at least 1000 feet from clouds so again, you wouldn't be able to drop down to land...

On top of this, I shouldn't forget the minimum VFR altitude clearances - means 500 feet above the highest obstacle within 2000 feet radius when over clear ground or open water, 1000 feet above built up areas, except when coming in to land; however, I seriously doubt that a 10 mile final would qualify as a reason to be at 800 feet over a major city.....
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Old 28th Feb 2014, 14:48
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...fly on top to detonation...
Was that intentional, or a Freudian slip?


MJ

Last edited by Mach Jump; 28th Feb 2014 at 15:00. Reason: Housekeeping
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Old 28th Feb 2014, 14:56
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auto speller but with the enroute IFR rating could read detonation if it all goes pear shaped on you forget freudian slip ups there are a number of potential slip ups I can see in the enroute IFR rating

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Old 28th Feb 2014, 15:23
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As I read it you can with a UK IMCR Leave the UK in IMC and return in IMC but only in UK airspace.
True. You know it's amazing how many people fly back fom the continent to UK and meet a perfectly legal wall of IMC right at the IFR boundary...
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Old 1st Mar 2014, 08:27
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The rules as we currently understand they will be are as follows:

FCL.825 En route instrument rating (EIR)
(1) The privileges of the holder of an en route instrument rating (EIR) are to conduct flights by day under IFR in the en route phase of flight, with an aeroplane for which a class or type rating is held. The privilege may be extended to conduct flights by night under IFR in the en route phase of flight if the pilot holds a night rating in accordance with FCL.810.
(2) The holder of the EIR shall only commence or continue a flight on which he/she intends to exercise the privileges of his/her rating if the latest available meteorological information indicates that:
(i) the weather conditions on departure are such as to enable the segment of the flight from take-off to a planned VFR-to-IFR transition to be conducted in compliance with VFR; and
(ii) at the estimated time of arrival at the planned destination aerodrome, the weather conditions will be such as to enable the segment of the flight from an IFR-to-VFR transition to landing to be conducted in compliance with VFR

AMC1 FCL.825 En-Route Instrument Rating
CONDITIONS FOR THE EXERCISE OF THE PRIVILEGES OF AN EN-ROUTE INSTRUMENT RATING (EIR)
In order to comply with FCL.825 (a)(2), the holder of an EIR should not commence or continue a flight during which it is intended to exercise the privileges of the rating unless the forecast for the destination or alternate aerodrome one hour before and one hour after the planned time of arrival indicates VMC. If the required meteorological data are not available for the destination aerodrome, the flight should be planned to a nearby aerodrome for which such meteorological information is available. An IFR/VFR transition point should be used in order to enable the pilot to conclude the flight under VFR to the intended destination. For this purpose, when filing a flight plan in accordance with operational rules, the holder of an EIR should include IFR/VFR transition points.

GM1 FCL.825 En-Route Instrument Rating
GENERAL
Since the privileges of the EIR are only to be exercised in the en-route phase of flight, the holder of an EIR should:
1. at no time accept an IFR clearance to fly a departure, arrival or approach procedure;
2. declare an emergency to ATC if unable to complete a flight within the limitations of their rating.


I think it's clear that at the VFR/IFR and IFR/VFR transition points and levels, flight should be possible under both VFR and IFR. Thus if they are outside controlled airspace, the ceiling at the transition point should be at least at or above the minimum IFR altitude (usually 1 000 ft above the highest obstacle within 8 km), and if they are inside controlled airspace, the ceiling at the transition point should be at least 1000 ft above the minimum IFR altitude (i.e. 2 000 ft above the highest obstacle within 8 km).

The wording is also such that if the destination or alternate is in controlled airspace, the ceiling there should be forecast to be at least 1500 ft and the visibility at least 5 km. It does not appear to have taken into account the possibility of a transition from IFR to VFR outside controlled airspace and a SVFR arrival.

Last edited by bookworm; 1st Mar 2014 at 19:43.
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Old 1st Mar 2014, 10:04
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Bookworm

Reading this it would be illegal and against these rules using an EIR to take off in IMC in the UK using an IMCR.
in no place does it add that UK IMCR pilots may exercise the privileges within UK airspace and hence make compliance with these regulations.
As this stands to take off in IMC would void the legality of the flight and not comply with the privileges of the EIR

Pace
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Old 1st Mar 2014, 15:07
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Reading this it would be illegal and against these rules using an EIR to take off in IMC in the UK using an IMCR. in no place does it add that UK IMCR pilots may exercise the privileges within UK airspace and hence make compliance with these regulations.
As this stands to take off in IMC would void the legality of the flight and not comply with the privileges of the EIR
For those of us who haven't been on the Perverse Interpretation of EASA Regulation course, you might need to unpack that a little, Pace.
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Old 1st Mar 2014, 15:14
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I think it's clear that at the VFR/IFR and IFR/VFR transition points and levels, flight should be possible under both VFR and IFR. Thus if they are outside controlled airspace, the ceiling at the transition point should be at least 1000 ft above the minimum IFR altitude (usually 1 000 ft above the highest obstacle within 8 km), and if they are inside controlled airspace, the ceiling at the transition point should be at least 2000 ft above the minimum IFR altitude.
Where do you get the 2000 ft figure? The cloud clearance requirements for VMC are 1000 ft vertically in controlled airspace.
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Old 1st Mar 2014, 17:50
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For those of us who haven't been on the Perverse Interpretation of EASA Regulation course, you might need to unpack that a little, Pace.
Bookworm

If you read the regulations there are very detailed conditions laid out to comply with legal EIR flight!
Under the usual interpretation of legal flight if a flight starts illegal it remains illegal!
To fly legally IFR under these regulations certain conditions must be met which are VFR / VMC departures and arrivals
Even thought iMC departures are allowed within the UK with an IMCR to do so would contravene the requirements for enroute IFR as laid out in these regulations and hence the rest of the flight would be illegal !
The above regulations need to have added " unless the departure is within UK airspace where the pilot has a current IMCR! In that situation he may depart and join an enroute airway in IMC"
As the regulation is stipulated there is no such allowance made!
As such a pilot departing the UK in IMC would contravene the requirements laid out in the regulation for enroute IFR flight with an EIR once they leave uk airspace, the requirements for EIR flight in the regulations would not have been met
Hence as it reads by departing the UK in IMC under IFR with an IMCR you are contravening the stipulations required for legal EIR flight regardless of what you can or cannot do in UK airspace

To put it in simple terms you fly two flights in the Uk
The first you depart IFR in IMC using your IMCR you fly OCAS to destination and again fly IFR in IMC for the approach and landing
All legal with your IMCR rating
Next flight you do the same but fly higher into CAS for the enroute section!
Illegal in the UK with an IMCR
So for that portion enroute in CAS you revert to your EIR to be legal!
Sadly you have not met the requirements in these regulations with your departure and arrival hence the flight is illegal

Pace

Last edited by Pace; 1st Mar 2014 at 18:28.
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Old 1st Mar 2014, 18:52
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I'm sorry AirborneAgain. What I meant to write was this:

I think it's clear that at the VFR/IFR and IFR/VFR transition points and levels, flight should be possible under both VFR and IFR. Thus if they are outside controlled airspace, the ceiling at the transition point should be at least at or above the minimum IFR altitude (usually 1 000 ft above the highest obstacle within 8 km), and if they are inside controlled airspace, the ceiling at the transition point should be at least 1000 ft above the minimum IFR altitude (i.e. 2 000 ft above the highest obstacle within 8 km). [corrected above]

To fly legally IFR under these regulations certain conditions must be met which are VFR / VMC departures and arrivals
Yeah I see what you mean. I'm a bit torn, as I've pointed out on a number of occasions that this obsession with the EIR + IMCR is daft: if you have an EIR and have been trained to fly IAPs because you have an IMCR, just get an IR rather than faffing about with some weird combination of rules. However, since the entire IMCR depends on either a conversion report or an authorisation issued under the new Art 4(8) of the Aircrew Regulation, both of which are in UK hands, then the UK CAA can craft words accordingly.

Last edited by bookworm; 1st Mar 2014 at 19:43.
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Old 2nd Mar 2014, 08:58
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Bookworm

As those regulations stand it would be illegal to depart France in CAVOK use the EIR to a destination in the UK where it was IMC with an IFR approach required even if you have an IMCR
There is no accommodation in the regulations for the IMCR and UK airspace
That accommodation needs to be made
Will the CAA want that ?
Effectively such an accommodation would in UK airspace give the holder of an IMCR and EIR IR privalages
Ie IMCR for IFR departure arrivals and EIR for enroute airways!
A UK airspace only pilot would not need to get an IR as in reality he would have one!
My guess the CAA will say one or the other
Use the EIR as per regulations or the IMCR as per regulations but not BOTH

Pace
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Old 2nd Mar 2014, 09:51
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Pace, I know who you are now. You're that tutor from the Perverse Interpretation of EASA Regulation course...

I shall crawl back into my book for a while and work out how we should play this...
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Old 2nd Mar 2014, 10:27
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Pace, how on earth do you come to your ridiculous conclusion? Even the most perverse 'a rule is a rule' €urocrat shows more commonsense.

Of course a pilot with an IR(R) and an EIR can get airborne using the privileges of the IR(R) in UK airspace, then use the EIR privileges when he/she needs to; for example, to join airways to fly to a European destination.

Similarly, if on your return the aerodrome is outside EIR limits - or even if it was before you left €uroland - you can use the IR(R) to fly an instrument approach at your UK destination if necessary.

How you can make such and absurdly tortuous interpretation is frankly beyond comprehension.....

Last edited by BEagle; 2nd Mar 2014 at 10:55.
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Old 2nd Mar 2014, 10:40
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The passage that Pace refers to is not an EU regulation but an AMC (Acceptable Means of Compliance). An AMC is basically a way to comply with the rule in practise which EASA thinks is ok. That doesn't say that it can't be done in other ways but in that case it's up to you to convince the relevant authority (the UK CAA in this case).

Has someone in the UK asked the CAA for their position?

Last edited by AirborneAgain; 2nd Mar 2014 at 11:48.
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Old 2nd Mar 2014, 11:02
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Beagle

All due respect its not absurd at all and does require clarification from the CAA.
As stated a mix of the EIR and IMCR would in practical sense give the IMCR the majority of privalages of a full IR in UK airspace.
If you cannot see that then who is being absurd myself or you?

Pace
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Old 2nd Mar 2014, 11:20
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Have the AMC and GM for the Article 4(8) amendment now been released? EASA stated that they were due in Feb 2014, but I haven't seen them yet.

Mind you, we're still waiting for the FCL.002 NPA........

Pace, the UK CAA doesn't need to clarify anything - because there's nothing at all to clarify.

So please stop inventing problems where none exist... !!

Last edited by BEagle; 2nd Mar 2014 at 12:36.
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Old 2nd Mar 2014, 15:08
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I wouldn't expect AMC for Art 4(8). It's unusual to have AMC for an article of the cover regulation and it's very much up to the NAAs as to what they do with it.

Pace does have a point that FCL.825(2) does have some unintended consequences.
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Old 2nd Mar 2014, 16:56
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Sorry Beagle, but if the rules are as shown by Bookworm in Post No.7, then it's hard to see how they can be interpreted in any way, other than as stated by Pace.


MJ
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