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!

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

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.....

Was that intentional, or a Freudian slip?


MJ:ok:

auto speller :E 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 :E

Pace

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...:)

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.

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

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.

Where do you get the 2000 ft figure? The cloud clearance requirements for VMC are 1000 ft vertically in controlled airspace.

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

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]

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.

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

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...

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.....:(

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?

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

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...:ugh: !!

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.

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:ok:

From the last TAG/SSCC/FCL MoM:

The CAA is also awaiting these AMC&GM.....

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

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

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.
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

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

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

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.

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

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

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.

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

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

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.

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.

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,

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...

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

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.

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

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

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