Blagger,

There are a couple of countries in EASA without access to the IMCR, I believe.

Timothy - sorry, I don't understand what you are getting at??

What about all the PPLs of France, Germany, Italy, Spain and all the rest who cannot get an IMCR and now, suddenly, have a real prospect of IFR/IMC flight?

Timothy

too true :E I fly into Bezier on the south coast of france and met a French PPL who flies from Paris to his villa VFR
Such a rating would I am sure appeal to someone like him

Pace

I'm still making the same point - I think the IMCR is accessible and achieveable, but uptake is still relatively low. As written the new EIR and IR, still with a reasonable TK requirement and annual renewals with an IRE to IR standards, I can't see a great percentage of private pilots taking it up anywhere (regardless of whether they have IMCR now or not).

An alternative theory is that IFR will no longer be seen as unattainable and elite and become much more part of the mainstream, as it is in the US.

I think that has a chance of becoming true outside the UK, where they never had anything lesser than the full JAA IR.

But there are other factors at work there too... why touring is so obviously rarely done by certain European nationalities. I think the reason is obvious: they can't speak English; the totally universal language of European IFR. That is one reason why an IR uptake in Europe as a whole will never reach the US levels. They have no Customs, a common language, no PPR, etc.

No matter where I go, where I meet pilots who have come from a long way away, they are mostly from countries where English is spoken well.

Also the IMCR exists in the UK and no matter how one wraps it up, the IMCR is a helluva lot less work in getting and keeping than any IR proposal now on the table.

Much will depend on the detail i.e. the IMCR -> FCL008 IR upgrade route.

Blagger

Do you think anyone should be flying IFR airways if they cannot fly to IR standards? I dont!!!!

I have never had a problem with any flight test( If you cannot fly the tolerances and deal with all the rest maybe you should not be there) only in ATP terms 14 exams, 6 months full time study or 2 years distance learning and a big portion of that learning totally irrelevant!!!

Pace

I think you'll find a significant proportion of people in Europe do speak English better than the average English speaker speaking any other language in Europe!

That's why there are different procedures for the different categories of aircraft. You bunch the ones with similar speeds/characteristics together.

That is not to do with seperation!

I used to fly a Seneca into Dublin main every week and we were slotted inbetween large jets with the request to maintain 160kts until 4 dme.

To hold 160 kts was a lot easier keeping the Seneca clean down the ILS and at 4 dme putting in first stage flap (140 Kts and gear at 128) It was then easy to fly at 128 till almost short finals bring speed back with land flap at 100kts and back to 80 kts over the threshold.

High speed approaches should be practiced even in the club PA28 if not for slotting in with fast traffic but also for strong wind shear conditions to the local airfield.
Its all about speed management and confidence in the aircraft you fly!

Speed is your saviour not your enemy as some consider and high speed approaches and management are not taught enough.

Pace

No they should not. The aircraft should be flown in accordance with the POH. Flying at excessive speed on the approach often leads to a poor landing. Failure to trim correctly, overcontrol and ballooning are the result - or a damaged nose undercarriage if the aircraft is flown onto the runway at high speed.

This 'adding 5 knots' for weight / shear or whatever is wholly unnecessary. Pilots should use the POH figure and nothing else.

I'm intrigued to know how a 'freelance' FI / IRI would work in €uroland - I can find no reference to such a creature in FCL.001 and the part-OR requirements indicate that all flight instruction will be conducted at an ATO... Doubtless someone will enlighten me in a few hours' time.....:hmm:

Beagle

Ii hope you never fly into a major airport iin a PA28 at 75 kts from 8 miles out! Or on a very heavy windshear day as I woulnt want to be in the aircraft.
Have I suggested that you land at above the normal landing speed in the POH No. All the stuff you mention like ballooning or landing too fast are indicative of poor pilot technique and not flying a fast approach.

In the Citation I maybe asked to maintain 200 kts (Flaps app speed) I may come back to 160 with gear down and then bleed in full flap which on the Citation is like a speed brake in the drag it creates.

Vref maybe 105 so a speed range of 100 kts

Ok the PA28 is a little aeroplane but there is no reason in the sky why you cannot fly down the approach at 100 kts coming back to 80 and then 70.

Pace

They won't; the FCL008 IR flight test is just like the full IR flight test.

The other side of the argument is that IFR is by far the easiest way of flying.
That's very true, but not relevant.

Not really; you don't see a CatA flying an IAP concurrently with CatD. The different tracks shown on the approach plate are not for traffic separation; they are for the different speeds.

I don't thinkt his is an issue. In "proper" IFR one needs to be able to fly at the landing gear limiting speed (Vlo) all the way to glideslope intercept, but that's not a problem.

In general, ATC will slot you in.

Sorry I wasn't clear when I used the expression "TMA", but I was not referring to the speed of a PA28 on finals. That is annoying but not insuperable.

I was referring to the previous 60 miles in the TMA, which is mainly occupied by aircraft streaming in at 220-250 kts. Getting them past a Seneca doing 175, let alone a C150 doing 75, is a real pain.

I was only saying this wrt the comments about airways at F100. There there really isn't a problem, because the airspace is empty and anyway we already "own" it (in the gangsta sense).

The problem is in the TMA, which is already occupied, in some cases, like Heathrow and Schipol, fully occupied, by fast CAT.

However, it is the job of Air Traffic Service Providers to provide a service to all users, so, if there is a massive upsurge in GA IFR, which I doubt, they will have to find a way.

Let's hope it's not "dumped at Detling".

But, to be clear, I expect it to be a relatively small and manageable problem in reality.

That is what I mean when I mentioned different procedures earlier on. Some STARs at airports near mine are for prop and turboprops and others are for medium and large jets.

When you depart you are kept low until a space is found in the relevant airway - then you are slotted in and asked to climb.

If the airport has multiple runways you'll find some are mainly used for light/small movements while others are used for medium/heavies to maximize efficiency.

And if there is just one runway, you need to keep your speed up.

Timothy

Frankly I am a little surprised about these issues of fitting in with CAT.

I do a fair amount of touring and often go to some of our regional airports (in the UK and Europe). In the vast majority of cases unless you happen to pitch up at an unusually busy time the traffic density is pretty low and I have seldom had any issues.

Personally, unless I really have a good reason for going to the largest airports, I try and avoid these and then I would certainly try to avoid peak times. Even at Gatwick you only have to look at the arrival and departure boards to realise outside peak time the traffic density is not that high.

It is a bit like lower airspace, I think all these claims that the traffic is stacking up are vastly over done, and where and when it really is, it is doubtful whether light GA wants to be there anyway either because the weather is so bad or the prices so high.

I think we may be looking for a solution to a problem that does not exist.

EIR - IT COULD BE SO SIMPLE
 

Only EASA could have concocted the nonsense proposed in the NPA, but in fairness it was fuelled by some of the input from various UK interest groups. The UK IMC has evolved into something close to a full IR, and if taught properly it is unlikely that less than about 25 flying hbours will have been expended in order to not only to make a candidate ready for a test, but more importantly make him/her competent and safe. Why on earth the whole IR issue is not addressed with a view to making it more akin to the US model is beyond me. Regretably, there is very little coming out of EASA that is not overly complicated and expensive, and is far too readily embraced by our CAA. (I will not even mention AOPA). Whilst the NPA can be responded to, do they really listen?

I think Timothy's comments are more directed at operations into Dublin, Geneva, Prague, Barcelona, etc. rather than Southampton, New Castle ....

I certainly have never had a speed issue into the regional airports, but have almost never not had a request to maintain high speed into the major airports.

justmaybe,

The competency based IR in the NPA is not that far away from the FAA model. certainly from the context of where it started it is a massive positive move in the right direction - Yes the TK Learning Objectives remain suspect (but this NPA was not scoped to address that issue), yes it is a PITA that Europe doesn't seem able to do CBT, but the TK test can now be done in a day (even if it is twice as many questions as the FAA it is still way way smaller in scope than the current monster), yes it is a bit of a pain it is 40 hours dual rather than 40 hours time (but most people in FAA land due the 40 hours dual any how as it does take some effort to learn IF)

We had this discussion a while back on the FLYER forum. I believe it is a misconception that EASA regs require all flight instruction to be at an ATO.

Part OR simply describes what is required to qualify as an ATO.
Part FCL does in most instances specifically state that the flight training required for a particular qualification must be at an ATO, but where it doesn't, then the training can be outside of an ATO.

Let me illustrate the contrast (with my underlines): on Class and Type Ratings, FCL.725 says
But for Variants, FCL710 says

It's simple - the absence of the requirement for a course at an ATO makes it clear the training can be done with an independent instructor.

I believe some of the misunderstanding comes from the wording of the CAA's "Expected Effects on Pilot Licensing" paper, which, for example, emphasises that all training must be at an ATO (in the sense that it can not be done in an RTF). But it would be a mistake to interpret that as all training in all circumstances. Pretty much all training needs to be done at an ATO, because the major cases of new licence and rating issue, revalidation and renewal are "pretty much all training". That does not mean there isn't some training that can be done outside an ATO. The variant/differences training is an example. Any elective (non-required) recurrent training can be.

I think it's pretty obvious and non-problematic. I find it odd that you write "how a 'freelance' FI / IRI would work in €uroland - I can find no reference to such a creature in FCL.001 ". The references to instructors are rather extensive and obvious in SubPart J of FCL001!

It would be like saying that you can't find a reference to independent commercial pilots in FCL001, because you expect all commercial pilots to be employed by AOCs. But that isn't how the regs are structured. FCL defines pilot, instructor and examiner regulations. By default, these are "independent" people. Part OPS defines where flights need to be conducted by AOC holders, just as Part FCL defines where training needs to be done by an ATO. The Organisational requirements for AOCs and ATOs are in Part OR.

Let's also remember that the IMCr can be taught by independent instructors - there is no requirement for an RTF, only that an approved syllabus be used. Of course, most of the western world's flight training is conducted under the American 14 CFR Part 61, which is legally, in effect, by independent instructors.

brgds
421C

The wording is not crystal clear, but it is 40hrs time of which 25hrs must be dual and of that, 10 must be at an ATO. The difference with the FAA system is that the 15hrs which could be solo must be instrument time "as PIC on aeroplanes, under a rating giving the privileges to fly under IFR or in IMC" - this could be an ICAO IR, and IMCr or an EIR. (The ICAO IR case would apply to someone who didn't have the 100hrs instrument time needed for the conversion). It means that solo time "under the hood" with a safety pilot, but no IFR qualification, can not be counted, unlike in the USA.

See para 6 on page 21 of the NPA.

I think it makes sense because it gives someone the option to do
- 15hrs EIR training
- 10hrs (minimum) experience in IMC as PIC using EIR privileges, in practice this might mean considerably more hours as PIC under IFR
- ...then 10hrs at an ATO to get the IR

Of course, these are all minimum times, and most people should expect to need some more time - exactly as per the FAA system, where few qualify in 15hrs training, as mm flyn points out. But that's the whole point of competence-based training!