991 pages.
Who will be the first to writeup an executive summary? 
I got to this bit, page 13, which will interest N-reg pilots:
Crediting for third-country licence holders The Agency introduced a few changes in order to simplify the criteria for Part-FCL licence holders also holding a third-country IR, to obtain their IR converted into a Part-FCL IR. Firstly, the demonstration of theoretical knowledge was clarified by allowing the applicant to demonstrate an adequate level of knowledge to the examiner during the skill test. The number of subjects was also reduced to three and cover air law, meteorology, and flight planning & performance. Secondly, several comments proposed to further review the requirement of 100 hours prior instrument flight time as PIC. As this requirement stems from criteria already established for the acceptance of licences and ratings, the Agency came to the conclusion that this could be reduced to 50 hours of minimum experience (instrument flight time) as PIC. The Agency also made provisions for those pilots with less than the 50 hours of minimum experience by allowing them to credit PIC hours towards the EIR and competency-based IR(A) courses. Please see paragraph ‘crediting of prior experience’ in this section and items 13 and 31 for further details. Finally, several comments requested the deletion of the skill test and English language requirements. The Agency strongly believes that to ensure a minimum standard and consistency both requirements should be kept and therefore decided to keep the skill test and the FCL.055 English language proficiency requirements as proposed by the NPA. The method of assessment shall be established by the competent authority.
So, if you have 50hrs "instrument flight time" in your logbook, you sit 3 exams, get an EASA PPL and an EASA medical, and do the JAA/EASA IR skills test.
The original proposal was 100hrs which was outrageous, given that most IR holders fly mostly VMC on top and log almost no instrument time...
I found a comment of mine on page 224, about allowing oral exams, which unfortunately they took (perhaps intentionally) as meaning oral+written, and reply as follows
In addition, the holder of a Part-FCL PPL or CPL and a valid IR(A) issued in compliance with the requirement of Annex 1 to the Chicago Convention by a third country may be credited in full towards the IR(A) training course requirement.
which suggests that if you already have an FAA IR, and an EASA PPL or CPL, you don't need to sit any exams at all. Or maybe they are referring to flight training?
I found a comment of mine on page 224, about allowing oral exams, which unfortunately they took (perhaps intentionally) as meaning oral+written, and reply as follows
No, they understood it correctly, I think:
Page 791
(a) successfully complete the skill test for the IR(A) in accordance with Appendix 7;
(b) demonstrate to the examiner during the skill test that he/she has acquired an adequate level of theoretical knowledge of air law, meteorology and flight planning and performance (IR);
(c) demonstrate that he/she has acquired knowledge of English in accordance with FCL.055;
(d) have a minimum experience of at least 50 hours of instrument flight time as PIC on aeroplanes.
Looks interesting. Am I right in deducing that the discussion points in this document are for the 2012 agenda, and it mentioned April 2012 is the date when things will be finalised? Or have I got that completely wrong when skim reading it?
On one hand it seems quite open, on the other hand it's very specific, but I suppose for me if I wanted to try and qualify for a CBM/IR I am still intersted to know what books I need to buy, when they come out, who can do the training, and how many hours are needed. It looks like the CBM/IR suggests 80 hours of theoretical training.
I shall have a fuller read a bit later.
So if I understand this right, the best proposal thus far for FAA IR holder to get an EASA IR is by
The above is for a PPL/IR.
FAA CPL/IR holders who want an EASA CPL/IR (and who don't have the ICAO ATPL plus 2000hrs in Part 25 aeroplanes which is the easy way to do it) will need to do whatever the CPL conversion is, plus the above.
Is that correct?
If so, and if this gets through the legislative process and comitology, it will be a very good result!
Not wishing to sidetrack this right now, but as I have often written before, step 5 above has a lot of stuff hidden behind it. Almost nobody will achieve this in less than 15-20hrs of flight training, not least because there are NDB holds and NDB approaches in the syllabus. I know people who have done it in 15hrs but they mostly did it at a specific FTO in Spain where NDB procedures are known to not feature in the skills test.
Under the current 15hr conversion route you have to spend at least 15hrs at an FTO, plus odds and ends.
So here is a good concession for those who can get informal training (with someone familiar with the IR skills test protocol) because the mandatory FTO time has been eliminated.
It's also useful to non-UK-based N-reg pilots who are currently unable to train in their aircraft in their home country, who will be able to train unofficially (no need to record the flight time as "training") anywhere they like, and who will be able to come to the UK for the skills test.
Perhaps the biggest thing is the apparent elimination of all 7 written exams which, while not hard because they could be done wholly by hammering the question bank, were depressing in their irrelevance to any form of flying, and were a considerable hassle due to the fixed timetable at CAA Gatwick.
I am trying to work out the latest proposed requirements for going from an IMC Rating to the IR.
It is around page 790.
For the SE IR you need 40 hrs of "instrument time under instruction".
There is a concession
prior experience of instrument flight time as PIC on aeroplanes, under a rating giving the privileges to fly under IFR and in IMC
(which to me clearly describes the IMC Rating)
these hours may be credited towards the 40 hours above up to a maximum of 30 hours.
but that appears contradictory because "flight time as PIC" is not "instrument time under instruction" so how can the former be allowable towards the latter?
Under ICAO, you need 40hrs instrument time for the IR, so I wonder if the "40 hrs of instrument time under instruction" (45 for the ME IR) is a drafting error?
Certainly, when the CBM IR proposals were aired in the past, they were clearly set out as 40hrs total instrument time, of which at least 10 was instruction and those 10 had to be done at an ATO. That is also the ICAO position. The FAA IR, for example, is 40hrs total IT of which 15 has to be instruction.
Assuming it is a drafting error, an IMCR holder with 30hrs instrument time in his logbook needs to do 3 exams (Air Law, Met, A/C Performance), 10hrs at an ATO, and pass the IR skills test. Plus of course the Class 1 audiogram!
Thank you Peter for decrypting the document for us. I am one who is in the above situation ( FAA Commercial/IR and about 450h under an IFR flight plan) and I could benefit hugely from that. let's see:
should be OK
have no idea how to prepare for that, yet.
what I would do is fly maybe 5-10 on my own aircraft, practising the fine points of holds and approach procedures, and then maybe do 3-4 hours with an instructor in the airplane I would use for the test, including NDB stuff. Might also get a couple of hours in a simulator in.
Would all be too good to be true. As Peter points out, often the devil is in the detail. One of these details tends to be how you can apply for a test. Can you just go to an examiner yourself, or do you require the endorsement from an ATO's CFI for that. while the regs don't specifically say so, the german aviation authorities tend to just conclude the latter, thus effectively putting the pilots into the hands of flight schools..
Anyway, what I am much more keen to know is: with this document punlished, what could be realistic timeframe for these regs to be actually fully in force? April 2013 is looming and just around the corner...
The instrument time as PIC is not "IFR time". It is time when flying on instruments, which IMHO is either time under the hood with an instructor, or you flying alone in IMC.
Here in the UK, the derogation is till April 2014. Has Germany/Italy gone for April 2013? I have a list of derogations here.
My loooooooong writeup on the IR conversion is here. With luck, a fair bit of that is going to be obsolete, but not the generalities. For example I see no indication that the skills test content is changing - except maybe possibly to include a GPS/RNAV approach under the "nonprecision approach" heading.
Stuff like examiner booking is going to vary between countries. Here in the UK, under the current system, once you have completed the approved IR course (50/55hrs) or (as an IR conversion candidate) have completed the abbreviated approved IR course (15hrs), the FTO is obliged to give you a "170A course completion certificate" and you can apply to the CAA directly and book the skills test.
But very very few people know about this. The FTOs normally impose a "170A flight test" and you have to "pass" that before they give you the 170A certificate. This means that if you need additional training (common for conversions, because the 15hrs is not a lot) then you are stuck at the FTO, whereas if you knew your options you could do the extra stuff with any freelance instructor.
Re timescales, I don't know but they always seem to slip April 2013 is totally unrealistic for this stuff to be in operation. It still has to go through comitology (a committee behind closed doors, where anything can happen) and then through lawmaking (where things can change too).
Clearly there are some very good people in there trying to generate sensible proposals to mitigate EASA's full frontal political attack on the bulk of IFR GA but the CBM IR is politically very vulnerable... time will tell.
Quick question, I've downloaded the CRD to my ipad but haven't had time to wade through it yet. Is this a 'normal' IR but just with a different route to getting it? i.e. once you've got it it doesn't look any different on the licence / doesn't work any different, and more importantly I can use it to keep my ATPL exam credit live? Cheers
Is this a 'normal' IR but just with a different route to getting it?
Yes.
The CBM IR is a fully ICAO compliant IR.
Just like the JAA IR, the FAA IR, etc.
This is where the political vulnerability lies: it is not limited to a PPL, and is sure to become the default route for the CPL/IR too.
can use it to keep my ATPL exam credit live?
No idea.
