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FAA IR holders - make sure you log your "IFR time"

I've just read that there has been yet another wording change in the CB IR stuff, and "instrument time" is now "IFR time" in

  • the 30hrs experience required for the ab initio CB IR
  • the 50hrs experience required for the ICAO IR to CB IR conversion

The 10hrs dual time for the ab initio CB IR remains "instrument time", fairly obviously.

Pilots will be keenly aware that there is a huge difference between instrument time and IFR time.

Anybody flying on the FAA IR and who cannot arrange a "non EU operator" is going to have to get the EASA IR and they should diligently log IFR time. The simplest (hardest to challenge) assumption is that this is time on a Eurocontrol flight.

But UK pilots will also be well aware that flight in VMC, on simple PPL privileges, in Class G, in accordance with IFR rules, can be logged as IFR time. There isn't going to be any evidence in your logbook of such a flight, unfortunately, unless you make a special effort to log it thus. I can't believe EASA intended this but equally I can't believe they were not aware of it.

Administrator
Shoreham EGKA, United Kingdom

I think this has been the case for quite a while now. There has been extensive discussion on other forums, and I believe it has been pointed out that this IFR time has to be whilst exercising the privileges of a rating, i.e. an ICAO IR or IMC rating, or under instruction.

I am sure what is written is exactly what the working group intended.

Darley Moor, Gamston (UK)

I log IFR generously, and typically the sum of a) I was above cloud in VMC b) I was in cloud - so not in sight of the surface for the last two, c) when it was somethign like 3k visibility and although I could see the ground, I was relying on instruments for safety d) when crossing the channel in poor horizon situations. In almost all cases I would likely be IFR 1000 ft above nearest obstacle, but not likely to be following the quadrantal rule, and OCAS.

I know the jury is out on this, but as a relatively low time IMC flyer, if I only logged time IFR in IMC, it would be very low. If and when I want to do a EIR or a CB IR, then hopefully there isnt too much over analysis of IFR time. But then if they were going to do that, there would have to be some clear rules on logging IFR time, and it seems to me there isnt? Right?

But then if they were going to do that, there would have to be some clear rules on logging IFR time, and it seems to me there isnt? Right?

As Neil says, one can speculate on what the WG intended, but if the rule says "IFR time" it says "IFR time".

Clearly the second most valuable thing in the universe is "instrument time" and the first valuable thing in the universe is "instrument time as PIC", so make sure you log your IMCR instrument time extremely diligently, every few minutes. It accumulates awfully slowly... on a 20hr trip to Greece I am lucky to log 20 mins of it.

Administrator
Shoreham EGKA, United Kingdom

I’ve just read somewhere an opinion by someone close to the matter that the whole “IFR time” business is actually going to become “instrument time”.

It seems to have been a drafting error all along.

I have always been surprised about “IFR time” because a UK PPL can log IFR time just by flying around in VMC, on basic PPL privileges, in accordance with instrument flight rules.

The important thing is that it will be the FTO, at which you turn up for either your ab initio CB IR or for the conversion CB IR, who will make a decision on whether they like your logbook or not.

Administrator
Shoreham EGKA, United Kingdom

I would be surprised if “someone close to the matter” had said that, Peter. :)

The important thing is that it will be the FTO, at which you turn up for either your ab initio CB IR or for the conversion CB IR, who will make a decision on whether they like your logbook or not.

That is important, though what is more important is their interpretation of ‘instrument time’. I could log instrument time for a flight that was originally intended to be VFR, but I halve flown over broken clouds or a inversion of haze layer, and following IFR rules, and am relying on instruments (and I include in that a GPS track on a VOR display) for navigation rather looking out the window and checking ground features. But that is different to being in situations where using instruments is absolutely needed to maintain straight and level or sensible turns (typically in cloud where there is no horizon at all). As people often say, a long IFR trip might well be done in VMC probably with sight of the ground – that must count for instrument time.

What do you make of it, bookworm? You ought to be far better informed than I am. I just pick up snippets around the place. I know the FTOs I have spoken to don’t know what it is supposed to mean and they don’t believe “IFR time” will be allowed in any eventual means of compliance.

That is apart from the obvious fact that logged “instrument time” while flying solo is completely unverifiable and could be logged wholly as “parker pen time”, to use one of the industry names for it

what is more important is their interpretation of ‘instrument time’.

I think a fairly wise approach to this would be to visit the prospective FTO with your logbook and get them to agree the entries before you proceed. For example when I went to the USA to do the FAA IR, and later when I did the FAA CPL (in the UK), the very first thing one does is to sit down with the DPE and go right through the logbook and look at every entry and make sure they add up to the required total. The US system has more individual discretion (vested in the DPE) but here in Europe an FTO could gold-plate the requirements as they wish and what exactly are you going to do? Sue them? Yeah right…. If you are doing the ab initio thingy, you probably have a considerable investment with that one FTO by the time this stuff gets looked at, so they have you over a barrel. Been there, done that, got the T-shirt, as they say

Last Edited by Peter at 27 Mar 09:27
Administrator
Shoreham EGKA, United Kingdom

I was involved in proposing a change from the original drafting of ‘IMC time’ to ‘IFR time’ in ICAO IR – EASA IR.
I produced examples of commercial pilots who flew 500 hours last year of which only 8 minutes was in IMC!
If they change it back to ‘IMC time’ the bulk of IR pilots in the world would fail to qualify!

Rochester, UK, United Kingdom

the bulk of IR pilots in the world would fail to qualify!

But surely that was the whole point of using “instrument time” otherwise every ATPL cadet with enough IQ to do some due diligence (i.e. google) is going to do their CPL/IR in Arizona (or perhaps elsewhere in the USA where the food is edible) and will come back to €uroland and do the conversion, and trash the €uropean FTO industry

That prospect would have never been permitted.

50hrs instrument time, especially instrument time as PIC, is a tall barrier, which only private pilots over say 1000hrs TT will be able to meet.

Can you summarise where the CB IR requirements currently stand, Peter G?

  • for ab initio pilots doing the CB IR
  • for IMC Rated pilots doing the CB IR
  • for ICAO IR pilots doing the CB IR

I mean as a likely actual implementation by the FTO industry.

Last Edited by Peter at 27 Mar 11:47
Administrator
Shoreham EGKA, United Kingdom
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