Pace

I take your Barcelona example as a good one. But with your experience you are going to plan a VFR arrival (was it Sabadell I guess?) less cautiously than an EIR holder should. But Barcelona was VMC you said, so in an emergency an EIR holder would have had no trouble getting a VMC arrival.

I disagree that enroute descent from IMC to VMC is for the experienced only. I think the majority of IFR-capable users at the VFR airports in the UK are likely to be relatively inexperienced IMCr holders, not guys with your kind of experience (or my more modest experience). It's a simple fact that these kind of pilots have safely operated IFR enroute and VFR arrival for decades.

I take your point that in the parts of Europe with terrain, it does become a more serious issue. I've flown to Bilbao and Barcelona and I know what you mean. But the people the EIR is aimed at today will be VFR only pilots - what about the risks they take in marginal weather scud-running into Bilbao? I think it would be better that they fly enroute IFR with the right training (remember the 15hr EIR training minima is the same as the entire full-blown FAA IR training minima!) and then establish VMC in descent. If they can't, they go out to sea and try there, or they declare an emergency and fly the approach - remember that the "weather worse than forecast" can be a lot worse than that required for a 1000'/5nm enroute descent but still make it a pretty benign emergency approach.
Err, because, as I read it, the new full IR proposed in FCL008 is a long way towards the FAA model (compared to the present) and goes further than the French model.

brgds
421C

Simply put, you will be able to fly under the instrument flight rules above MSA (as defined in SERA A) but you will not be able to accept an IFR clearance to fly any departure, arrival or approach procedure. A VFR/IFR transition point on departure and an IFR/VFR transition point on arrival should be included in the flight plan, the latter point should be passed prior to reaching the IAF. Consequently, you should not commence or continue a flight unless the forecast conditions at the destination or alternate aerodrome will, for one hour before and and one hour after your ETA, allow flight at and below MSA in VMC (as defined in SERA A) on or before reaching the declared IFR/VFR transition point.

Well, you live and learn. Thank you to FBM for putting me right, I was wrong about the minima for IMCR holders. Thanks to another PPrune thread, I have found the reference:

UK AIP AD 1-1-7 section 8

All in all I am very happy with the proposals.

I would like to see:

1. The EIR holder being entitled to fly a vectored approach to the top of the G/S,
2. The theory to be further reduced and more specific to the EIR,
3. Instructos and Examiners currently entitled to teach the IMCr to be grandfathered into the EIR training camp,
4. The EIR holder to be entitled to depart with a lower cloudbase where not required to fly a SID.

Well, a full IR/ME allows your (for private ops, depends on the country regulations) to fly a Seneca I 364 days after your proficiency check to takeoff in 150m visibility, and let's say you have an engine failure upon rotation and the runway remaining (if you even see any of it at all) isn't enough to abort the takeoff. So you then do a one-engined approach down to 200ft DH with RVR 550m, probably on some airport 50NM away. You can use the same scenario (obviously without an engine failiure) for an owner-pilot, which flies his/her own Jetprop/TBM 364 days after his/her proficiency check down to the same minima as stated before. Not the safest place to be.

Rules are for the obiendce of fools and the guidance of wise men. - Douglas Bader

Every licence is a death-attracting one, if you take all the regulations blindly serious. Sadly, the aviation is going British/France way, overdoing everything, writing rules/guidance/schedule/orders/whatever you call it for everything. Soon you will require an STC'd pens, mobile phones, paper, etc. for use in cockpit. I bet that with the current rate of law development, there will become a day when you'll have to check that the air in the engine intake complies with the standards and will have to be checked by a trained professional. Everybody who's ever flown IFR in piston single knows that there is great difference between what is legal to do and what is actually smart/safe to do in certain situations.

Back on topic. Any IR rating as such, being EIR, IMCr is useless without approach capability. I agree with IO540, IR and ability to file and fly on IFR flightplan has its advantages in routing (e.g. you don't need to request transit through every little piece of CAS), but in reality I don't think one actually needs the right to fly in IMC in en-route phase. Many times, if weather is getting worse (from VMC into IMC, probably with raising tops, developing Cu and TCu), one can safely expect the weather won't be that good at destination (unless you do really long trips, passing through different weather systems), so there is no point in being able to fly en-route IMC, if you then can't shoot an approach to a certain safe DA/MDA at destination. But still, there need to be some limits in approach capability, since EIR/IMCr/whatever you call it will/is mostly used by pilots who don't fly that much and use it only as an exit strategy. I think it would be smart to include the type of approach and number of attempted approach in regulation. For example, you arrive at the airfield and you elect to do a VOR/DME approach, which you either don't fly good enough or you have no visual references at minima. I believe this (and all other less-precise approaches) should be forbidden for you from then, so if you choose to make another approach, you would be left with ILS or LOC approach. So basically, each consecutive approach you make at the same airfield should be the one with greater precision - I believe it would increase the safety quite significantly.

I don't agree with a MDA/DA recommendation that is currently the case with IMCr. An ILS approach, probably to a field with supports Cat II/III operations with radar vectors even with half-scale deflection throughout to DH of 200ft is MUCH safer than a dodgy plain non-DME NDB approach with the beacon at the airfield and no (or procedural-only) ATC to let's say recommended MDH of 600ft, especially if regular MDH is close to 600ft. However I do agree that visibility should be required for an approach, but the same minimums as for circling minima currently in EU OPS should do just fine (1500m for Cat A, 1600m for Cat B).

But that's just my opinion.

Does anybody know when this could come in to force?

So this means you cannot fly any of the approach but have to leave CAS by decent into VFR.
That brings back the concern that what relevance does weather at your destination/alternative have to the transition point and the cloudbase for your VFR descent? both could be wildly different.
9/10 such a descent will be fine but there has to be a plan B option which includes an option for some sort of approach and maybe a restriction on some airports for the EIR???

Pace

There are already airports which don't accept VFR (ironically, Barcelona being one such) so I would not be surprised if some will not accept EIR pilots, as they will be VFR at the point of arrival.

But my feeling is that the airports which won't accept EIRs will be the very ones that EIRs won't want to go to.

I also think that the 9/10 ratio is wildly pessimistic, probably by more than two orders of magnitude. We are talking only about people who have been caught out by seriously misforecast weather.

That will happen, just as it happens to VFR, IMCR and IR pilots today. When it happens we mostly find a way of sorting them out but, very occasionally, one comes to grief.

But just as VFR, IMCR and IR pilots come to grief from time to time now, VFR, IMCR, EIR and IR will all occasionally come to grief in the future. You cannot, and should not, legislate that possibility away.

If you try to, you will kill all aviation.

Timothy

Doubtless it will, but I think you give the wrong impression.

I would hope that every EIR holder that uses the rating in earnest will keep their approach skills alive with an instructor or by flying approaches in VMC.

If the weather really misbehaves and no alternative is available I see no reason why an EIR holder should not be capable of flying an approach down to 500 feet, which would mean the weather would be seriously in the naughty corner.

After all even if he doesnt fancy the ILS a talkdown is hardly the most challenging approach to fly.

FA,

I completely agree that any sensible EIR will take out his own insurance by doing some practice.

Having said that, I have flown with some IMCRs who would, IMO, probably kill themselves and their pax if they tried to fly an ILS to minima for real, because they have not been sensible enough to develop and retain the skills, and I guess that there is an analogy with some EIRs.

But I think that the reality of all this is that most EIR pilots will be very conservative and only fly on days when they would have gone VFR, but now have the ability to fly, in VMC, on airways, under the protection of IFR, without having to scrabble around for Class D crossing clearances and worrying about parachute drops.

That will be the real premium.

It has just occurred to me that there is an analogy here.

For years we have managed with an IMCR, which is great, but has faults. One such fault is that the weather can fall below the minima an IMCR holder can cope with. But it hasn't been a real problem, life has gone on and we have coped.

Now the EIR is coming along and some people are upset that an unforecast change in the weather could engender embarrassment, difficulty or even danger for the holder, forgetting the similar shortcomings of the IMCR.

Is this not just the same as the GPS replacing the NDB/ADF for approaches?

For decades we have been using unreliable and error prone technology to get us down to 400' on the approach, with the needle bobbing around, pointing at thunderstorms, being bent at night or near coasts, but we have managed.

Then along comes the GPS and the CAA gets all worked up about possible obscure failure modes, not giving a thought to the fact that it is a million % better than what came before.

Is that a useful analogy, I wonder?

???
While it is true weather varies around the piece, it is going to be an exceptionally unlucky pilot who has CAVOK at both the reporting stations he is using for his alternate and destination weather and has no point in the IFR system within his fuel range that he can make a descent to VMC at the MSA ... AND who then chooses to descend below MSA in the clag and hit something, rather than declare an emergency and proceed along a STAR to a VFR arrival (not something that is going to be a real challenge).

There EIR is not going to guarantee you make it into your destination, but I just don't see the purported risk being of any significance.

Mm

That's not my experience the weather can be very different in the course of 20 mi!es my Barcelona example as one.
Not a problem if your flying into a sleepy IFR airport where a request to fly to the overhead at MSA would get an approval so you can get a descent in VMC but a bigger problem into a busy airport.
With the IMCR you could take approaches albeit with higher minims with this it appears you cannot.
Most of the time it will work out fine but there has to be a plan B option just incase?
Enroute say Southampton to S France you may indeed have glorious weather in the south but may transit over the top of airports in mid and north France who are all giving 300 overcast ( yes that happens too) not a problem unless
you have a problem requiring you to land enroute ?Again not a problem if the EIR pilot is extra vigilant with enroute actuals and TAFS or is prepared to take
the risk.
Timothy
I flew on an IMCR for years in the Uk. The IMCR did allow approaches to higher minima and that for me is a safer way than being dumped to your own devices at some way point in unknown weather with the knowledge that you will have to declare an emergency! The IMCR was a safer option IMO than what's proposed in the EIR

Pace

That IS my point. Having only EIR capability might be a PITA on occasion, but not a safety issue. In your example you destination was not accessible, however there were plenty of CAVU destinations near by - hence no safety issue.

With regard to long distances on top, this is no worse and probably better than a VFR only pilot undertaking the same flight (as he is currently allowed).

Personally I would get an IR rather than an EIR (but I made that choice a long time ago)!

I think this, combined with the grandfathering of IMCr holders, the modular IR, reduced TK and sensible Foreign conversion as a package is fantastic. I don't see any reduction in safety or utility from what we have today AND a sensible path for a big fraction of European GA pilots to take a range of positive steps to increase utility and safety. Some may only go for the EIR, some all the way to a full IR (sadly I don't think Europe is any where near authorising single pilot piston Cat II approaches as can be done in FAA land ;) - so we will just have to live with that 'risk').

Probably the one missing item is a CAA decision to contnue issuing the restricted IR AKA IMCr after 2014. But we can hardly expect or lobby that decision until this one is landed.

Am all for probing and discussing , but believe it is good policy and imperative that GA stands up and endorsed the key thrusts of this NPA while not feeding ammunition to those who would water down the proposals.

M

MM

Ok I will shut up now :E

Pace

A VFR only pilot might be allowed to do it, but in my experience none actually do it, unless they have an IMCR or lappsed IR.

dp

How many of those considering the EIR actually have access to aircraft which actually meet the legal requirements for flight in CAS, I wonder? 'Airways equipped' being the historical term.

What I find interesting is that the FCL people in that Tower of €urobabble are working to a different timetable than the SERA / SES people. So that the FCL people are trying to sort out the rules for a game, the shape of whose playing field is as yet uncertain.

Far better for the FCL people to sit on their hands and let JAR-FCL 1.175(b) continue until such time as the airspace requirements for which they're trying to invent their ponderous licensing rules is actually known.

Last week was the 40th anniversary of the first instrument qualification I ever held - a PIFG on the Chipmunk. That required 11:05 of IF time - and of course it included IF approaches as did every single other instrument qualification, miltary or civil, which I held since. On my test from RAF White Waltham I had to fly an ACR7 approach into RAF Andover; the whole test taking 1:15 of which all bar 5 minutes was on instruments. The emphasis was on safe flight in IMC, not playing airliners in spam cans.

Never in the past 40 years have things been so ridiculously confused as they are today - or rather as they will be when those lunatic €urocrats start meddling when, as they have been told on countless occasions by the Commission, there isn't actually any need for them to do so.

I'm afraid "airways equipped" is a thing of the past, BEagle. EASA NCO OPS only differentiates equipment for IFR flight from equipment for VFR flight. It makes no distinction based on the flavour of air you happen to be passing through.

....and you are representing AOPA's position to EASA? Not a great start.

Change is inevitable. Do you wonder if perhaps you may be getting so long in the tooth you are loosing objectivity?

40 years ago a Chipmunk may have been fine for IFR, these days it's a summers evening plaything. The aviation world has moved on albeit slowly but we should approach it with an open mind......