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-   -   EASA Enroute-IR minimum ceiling? (https://www.pprune.org/private-flying/535014-easa-enroute-ir-minimum-ceiling.html)

BEagle 2nd Mar 2014 17:31

From the last TAG/SSCC/FCL MoM:


AMC/GM to FCL.008
****** asked when AMC/GM related to FCL.008 would be published. Matthias Borgmeier explained that EASA can only publish the AMC/GM when the rule amendment package is published in the official journal of the EU.

The Agency is currently preparing the AMC/GM to be ready by February 2014 and then wait for the publication of the associated rules.
The CAA is also awaiting these AMC&GM.....

Pace 3rd Mar 2014 10:36

Beagle

You have always been a big supporter of the IMCR! Me too with a caveat!
It is a Micky Mouse instrument rating and I always as you know supported the idea of a FAA style instrument rating valid across Europe!
The IMCR has safety benefits which are as a get out if jail card for the VFR pilot not as an instrument rating to be used in anger!
That is not to say that very experienced pilots do not use it effectively but that is their experience levels not the rating!
As things stand as you say an IMCR holder will get a restricted EASA rating which allows limited use of airways!
The IMCR allows approaches in IFR in the UK
A pilot operating in England Scotland and Northern Ireland would effectively have a full IR on the back of a Mickey Mouse rating!
Apart from being rude to me explain how I am wrong or whether that would be advisable ?

Pace

Genghis the Engineer 3rd Mar 2014 11:21


The IMCR has safety benefits which are as a get out if jail card for the VFR pilot not as an instrument rating to be used in anger!
A common argument, but a wrong one essentially used by full IR holders to maintain their perception of their own superiority.

An IMCR / IR(R) is a rating like any other, and like any other required recency and maintained skill levels to use it safely. With that, it's perfectly useable as a mini-IR. Without that, it's not useful as a "get out of gaol card", as almost certainly unexpected flight in IMC requires a greater level of currency and skill as it's dealing with an unplanned situation, not lower. The only way to maintain that level of currency and skill is to have used the rating with planning. As the "mini-IR" you disapprove of.

It's only "Mickey Mouse" if instructors and especially examiners are not ensuring an adequate skill level. I've never heard this being seriously suggested.

Yes the full IR is a higher standard - because it is primarily used for public transport, and also a very high degree of precision is needed for flying in airways, and thus poor flying has a substantial impact upon other public transport users. That again doesn't make the IMCR "Mickey Mouse", just appropriate to flying small aeroplanes outside of airways.

G

Pace 3rd Mar 2014 11:58


Yes the full IR is a higher standard - because it is primarily used for public transport, and also a very high degree of precision is needed for flying in airways, and thus poor flying has a substantial impact upon other public transport users. That again doesn't make the IMCR "Mickey Mouse", just appropriate to flying small aeroplanes outside of airways.
I would quote the higher degree of proficiency but also note your comments on currency!
There are PPLs who are just as good and in some cases better than IR holders I know in my own case I used the IMCR in extreme anger in multis and twins OCAS.
But it still comes down to experience. Having flown both ways On an ATP airways and on an IMCR Multi and single OCAS it is far more demanding and requires a lot more pilot interpretation flying with an IMCR OCAS than taking off in CAS cruising in CAS and landing under radar control in CAS.
But that is hard earned experience and surviving that experience rather than the rating which does not prepare a pilot for the precision you quote above.
Hence why I personally promoted the idea of an FAA style IR which is good to go all over Europe.
The worst scenario is neither fully IFR or fully VFR and dumping someone out of the system on their own is the highest risk of all.

A common argument, but a wrong
I cannot agree with that as if the case what level below the full IR would you classify as right? Anything less than the full IR has to be less

Pace

Genghis the Engineer 3rd Mar 2014 12:07

And presumably the CBM IR will be roughly what you're promoting? (And I'll be one of the first people queued up to do it when it's available).

Yes, an IMCR is a lower standard qualification than an IR. A PPL is a lower standard qualification than a CPL. Would you ban PPLs from flying as they don't have as high a qualification as CPLs. Or would you accept that a PPL is "fit for purpose"?

G

Pace 3rd Mar 2014 12:14


Or would you accept that a PPL is "fit for purpose"?
G

There is a massive variation in PPLs some are down right dangerous some are brilliant. Some I would not send the hated neighbours dog up with never mind a loved member of my family and I mean that :E That is what worries me with the IMCR
While you can get bad CPLs!CPLs tend to be much more of a unform standard rather than PPLs where there can be a massive variation (sadly)
Hence why the training should be up to IR standard!


Pace

IRpilot2006 3rd Mar 2014 13:57


It is a Micky Mouse instrument rating and I always as you know supported the idea of a FAA style instrument rating valid across Europe!
The IMCR has safety benefits which are as a get out if jail card for the VFR pilot not as an instrument rating to be used in anger!
What complete nonsense.

There is almost nothing in the full IR (US or EU) which exceeds the IMC-R and which is relevant to flying.

Just a load of old codgers feeling smug about something they achieved 30 years ago. And most of them did it using shortcuts which closed with JAA.

Genghis the Engineer 3rd Mar 2014 14:18

Also incidentally an IMCR holder has to pass a 25 month retest, which a standard PPL holder does not. (Nor of course does a CPL/VFR holder...)

G

soaringhigh650 3rd Mar 2014 14:37

A private pilot typically has to do a biennial review though.
The instructor will not sign off if they are not satisfied.

IRpilot2006 3rd Mar 2014 14:55

A UK instructor will sign off on that flight provided he lives after the landing and can still walk and write with his right hand.

How else do you think we have so many pilots saying "over" on VHF?

The FAA BFR is different.

Genghis the Engineer 3rd Mar 2014 14:55

Not in Europe - the BFR is a wholesome aspect of the FAA system. In Europe, a pilot has to fly with an instructor for an hour every other year, but there's no requirement to actually display any minimum standard of competence, nor to do anything particular in that flight. We tend to borrow the USian shorthand and call it a BFR, but it's not actually a review.

G

Pace 4th Mar 2014 14:10


There is almost nothing in the full IR (US or EU) which exceeds the IMC-R and which is relevant to flying.
IRPilot

Amazing I never knew that they were almost the same?
You really need to come to Pprune for accurate information ;)
Oh well that makes all the difference! My argument has gone up in smoke ;)

Pace

Red Chilli 4th Mar 2014 17:59

Pace - the new restricted EASA IR(R) which equates to the IMC exactly, does not give access to Airways (as per your earlier post), that requires the addition of the new EIR rating.

thing 4th Mar 2014 18:22

Pace- on the one hand you say that the problem with the IMC is that holders don't stay in practise then you say that when you had one you used it all the time. Why do you assume that no one else does? I use mine when I can as I enjoy flying on instruments (I know, a little sad probably).

It's not a get out of jail card, it's something I use regularly and wouldn't consider being without. I don't know anyone else who only uses it in an emergency either.

maxred 4th Mar 2014 18:50


It is a Micky Mouse instrument rating and I always as you know supported the idea of a FAA style instrument rating valid across Europe
Pace, I sometimes wonder why you post on the Private Flying columns, because you post, most of the time, some of he most condescending bull**** I have ever heard from another pilot. You fly a Citation, commercially, so why not hang out on the Bizjet forum. But no, you come here, spouting all you appear to know, about everything. Some guys have worked damned hard to get their Mickey Mouse rating, which you think, they should not blacken the sky's in case they hit you. It's the same with the nonsense regarding flying an SEP over water. Heaven forbid one of the underlings should do it IMC, with an Imcr rating:ooh:

Look,


You really need to come to Pprune for accurate information
Sorry not where you are concerned.

The CAA has deemed the Imcr, a credible rating, allowing pilots to fly in IMC conditions, with restriction. Not anywhere on their website does it state, Get out of Jail Card, a phrase which you use with monotonous regularity.

Pace, grow up please, you may just gain a bit more respect...

Pace 4th Mar 2014 19:24

Maxred

If you knew me real world I dont think you would see me as condescending as I dont know anyone who would describe me as condescending.
Here I have my own style of posting which can be challenging for a purpose.
Private Jets are still GA and some are flown by lucky private owners.
Many moons ago when I got my IMCR a lot never used it in anger some did but as I posted earlier usually the more current and experienced PPLs.
A lot of my flying life has been in SEP and MEP and that is still where my heart is hence why I post here.
But apologies if I have come over that way and overstepped the mark

Pace

maxred 4th Mar 2014 19:41

No requirement for an apology, but I think you need to take an appreciation that pilots at all levels, PPL, Imcr, IR, and ATPL, all have varying levels of competency, hence the reason that 18000 hr ATPL pilots drive perfectly serviceable and flyable aeroplanes into the ground. It happens at all levels, and I know by reading your many posts, you are highly experienced. Hence, it gets me going when you refer to ratings as , Mickey Mouse. You should appreciate that individuals have taken it upon themselves to go and get additional training, and ratings. most Imcr pilots, certainly that I know, go on and respect the rating, by taking recurrent training, and are sensible enough to understand their limitations.

The accident rate in the US, where most have instrument ratings, contain a lot of loss of control in IMC, not a huge amount here in the UK, so someting in the Imcr must be working, or, pilots do not fly as much IFR, as the States.

From my Imcr, I went on to do the FAA IR, because I wanted to, and also realised some of the IMC limitations. But it was a very valid rating, and helped me in a lot of scenarios simply because I had done it.

Pace 4th Mar 2014 20:35

MaxRed

If you read back through my posts I actually state that flying OCAS in IMC with an IMCR is more demanding and requires a lot more "creative" thinking than flying depature in CAS enroute in CAS and arrival and landing in CAS most under the watchful eye and control by radar.
I have also stated that current PPLs with experience and currency do a lot better of a job than many IR pilots but that is their experience levels gained probably since the IMCR rather than because of it.
Most fly within their limits and currency. I also stated that there is a much larger variation between PPLs than say CPLs.
I am sure there are many PPLs you would not send your kids up with with just them as the pilot?
There are Brilliant PPLs and very poor PPLs (do you agree?)
What stirred this conversation was the fact that the IMCR gave you an enroute instrument rating in EASA land which with the existing IMCR IN THE UK would realistically give the holder of an IMCR almost FULL IR privalages.
The question with that is whether this was envisaged by the regulators or advisable considering that a low time IMCR pilot could theoretically take off from say Bournemouth into a 200 foot cloudbase fly airways to Aberdeen and land with a 200 foot cloudbase all the while relying on his autopilot to hold up!
I felt the subject warranted discussion and lively discussion at that so again I apologise for stirring too much but not for anything I have said above :ok:

Pace

Red Chilli 4th Mar 2014 22:49

Hi Pace - I still think you are a little confused about the new EASA land (aren't we all). The IMCR replacement is in name only and does NOT give you any new en route privileges outside the UK or inside the UK - this is the purpose of the new additional en-route EIR rating. This is an entirely separate rating which covers airways flying etc.

If you bolt the EIR onto your existing IMC (now known as an IR(R)), then with BOTH ratings you do indeed have fairly reasonable privileges, which will include airways and certain approaches, in the UK only.

If you don't take the new EIR then nothing has changed from where we are today.

Cheers

Pace 5th Mar 2014 08:02

RC

Thanks for correcting me ;) YES I Totally agree on the confusion with the stuff that comes out from EASA even the CAA get confused with it or rather how to interpret it
We were discussing EASA years ago and the IMCR! I was opposed to retaining it because I saw it as a diversion from a Europe wide FAA style IR! I agree the JAA exams were a major stumbling block for the working / family man in achieving a sensible, achievable IR!
IMO if you fly IFR and airways you have to be able to fly instruments with the precision and tolerances required in the JAA and FAA instrument ratings! Do that and you are fit to fly IFR /airways whether you are a PPL or CPL but there has to be a challenging flight test which will load you to make sure you can handle the worst / I never had the impression that the IMCR quite made that standard ?
Yes trim the exams to FAA style but the flying and tolerances and loading required no as IMC IFR airways is not a place to burn out and not cope with! Hence my referral to Micky mouse rating which I apologise for


Pace


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