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FCL.008 CRD published

This is looking very promising, and is probably all the encouragement I need to do nothing at the moment! The alternative was bashing the CATS question bank and doing the TK exams. A right royal pain.

Whatever happens I will have to pass a test, but I like flying so I will enjoy the training and put up with the test. I'll probably go away somewhere on a full time course for a few days and get it done when the proposal eventually passes into regulations.

On timing surely it will come into effect before 2014 or else how can the massed throngs who fly 3rd country aircraft get their EASA licences in order? I would also expect an FAA conversion industry to spring up once the situation is absolutely clear.

An interesting byproduct for me will be that I will probably be able to drop my FAA type rating renewals. I fly an M reg aircraft and they will accept my validation based on either FAA or EASA licences and ratings, and I would have to renew the EASA ones anyway to be legal.

Darley Moor, Gamston (UK)

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?

I don't think it's a drafting error, though it's inelegant. I can't speak for the author or FCL.008 group, but I believe the intention is that the 40 hours can be comprised of any combination of:

A) instrument time under instruction, either on the course or otherwise given by an instructor qualified to teach for the IR

and/or

B) prior experience of instrument flight time as PIC on aeroplanes, under a rating giving the privileges to fly under IFR and in IMC

What it cannot be is instrument time with a safety pilot, who is not an instructor qualified to teach for the IR, practising instrument flying under the hood.

Many thanks bookworm

I do have to ask however why didn't they just say that?

The effect of this in-elegancy is pretty dramatic, for the thousands of IMCR holders who are wondering which way to go.

Not being able to use time with a safety pilot is IMHO totally irrelevant. I have never heard of anybody logging such time. But maybe it is time to start a thread on whether one can log taxi time without flying?

Also requiring 40hrs of training demolishes the concept of "demonstrated competence". We are almost back to the ab initio JAA IR but with fewer exams.

As it happens I believe that few people will reach the JAA IR skills test standard in less than 40hrs anyway, or the FAA IR one for that matter, but both the FAA IR and the proposed CBM IR carry the huge concession that one can use freelance instructors for the bulk of the training.

What is the currently proposed situation with CBM IR instruction? Can it be a freelance IRI for example? Or has that concept been terminated? I know it does remain for the IR revalidation, but most of those IREs are AFAIK having to "do a deal" with an FTO so they can carry on doing the bread and butter stuff.

Administrator
Shoreham EGKA, United Kingdom

I have just read somewhere that EASA have now said, informally, that the 50hrs of instrument time is actually meant to mean

"minimum experience of at least 50 hours of flight time under IFR as PIC on aeroplanes"

which is of course completely different, and far easier to achieve. Practically everybody who has been flying on the FAA IR will already have this.

Administrator
Shoreham EGKA, United Kingdom

This raises the question for those of us currently flying on a UK IMCr - how should we log IFR time as opposed to IMC time? My average IMC time per IFR flight is about 15 minutes ... my average flight time in accordance with IFR more like 1.5 hours.

Does anyone know of any official guidance on this?

EGEO

Peter, I hope your interpretation is right about the IMC to IR route - that would be a right royal result! I wait with baited breath!

Roll on 2013 (or perhaps beyond!)

While "IFR time" is a lot easier than "instrument time", this stuff has been badly thought through.

Very few people log "IFR time" in Europe. Apart from some requirement for IR instructors (?) it doesn't carry any value.

IMHO, the easiest evidence for "IFR time" would be flight on an IFR flight plan, but IMCR holders will rarely have filed an IFR flight plan because such flight plans are all but meaningless in UK Class D/G).

And in the UK you can fly, as PIC, on a plain JAA PPL, under "IFR", provided the actual conditions are VMC. Non-radio, too. So, in theory, one could fly at 4000ft/FL060 etc, in sunshine, for an hour, and nominate that as 1hr of IFR.

I can see some authority sticking in its own clarification of this stuff... what it might be I have no idea.

Administrator
Shoreham EGKA, United Kingdom

I have an IMCr and generally I log any time in very low viz, or vfr on top as 'instrument time'. Part of the reason for that is that I fly on average 5 hours a month, and want to keep logging some instrument time so it might count towards a CBM/IR or something else.

Maybe the definition of 'instruments' is blurry nowadays. In my type of flying I consider 'instruments' to be the six-pack type. So if I was vfr on top and only using the six-pack for situational awareness, then I dont see it being a problem logging it as instrument time. The fact that I have and use a GPS (which I just consider just to be a GPS, and not an 'instrument' (though that is debatable)) as my main navigational aid doesnt have to change how I log the time. Thats my opinion...

Maybe the definition of 'instruments' is blurry nowadays.

I was taught to log instrument time for time spent in real or simulated IMC. Where IMC is defined as any conditions not meeting VMC minima. Simulated IMC being time spent in VMC wearing foggles or a hood with a safety pilot.

I am going to start logging flight in accordance with IFR in the other column in my logbook, and annotating it as such in the comments for each flight.

IMO instrument (and IFR) time should be independent of the means used for navigation - it is quite possible to navigate visually while flying in accordance with IFR, and quite normal to use radio navigation when VFR.

I will be happy if we can credit 30 hours of IMC time towards the minimum for the CBM IR. Most people will graduate from the IMCr with about 15 hours instrument time. Gaining another 15 in the real world isn't such a bad thing - even if it does take a couple of years. Another 10 hours of instruction to improve the standard of approaches, learn a little about airways IFR, SIDs and STARs, improve the standard of radio work (IMO a weak point among the IMCr community) and other small items commensurate with the increased privileges seems quite reasonable.

EGEO

Peter: You write:> 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.>
As you know - because you have hinted about it in the past! - it has been possible to find a 'friendly' examiner (in Spain?) who has 'tested' one without NDB's etc. Am I right that an EASA license is a European one?
On that basis - provided one can overcome the language barrier - would it not, in the future, be perfectly legal - and in certain circumstances more convenient (and cheaper?) - to do one's test anywhere in Europe?

Rochester, UK, United Kingdom
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