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En Route IR / CB IR / IMC

The politics of aviation regulation development are just bizzare…

Earlier this year AOPA UK became aware of the proposal for a five-year concession but was asked to refrain from publicising it because it could hamper negotiations. This month, the news leaked out via those who had spoken against the IMC rating at FCL.008.

Who might be speaking out against the IMCR in FCL008??

I have just read elsewhere a statement by a prominent UK AOPA rep (retired ex RAF, not a serious GA pilot AFAIK) saying AOPA asked the CAA to make mandatory the presently advisory minima for IMCR holders, but the CAA doesn’t appear to be interested. Ostensibly the reason for the request was

the idea is to add credibility to the IR(R), so that it cannot be thought of as an IR-by-stealth by those who would discredit it

I think GA spends so much of its time shooting itself in the foot…

Administrator
Shoreham EGKA, United Kingdom

>Who might be speaking out against the IMCR in FCL008??

The same guys who would like to shoot the whole proposal down because they don’t like the idea of a non doctoral thesis IR. The same guys who would love to have no small GA IR at all. The same guys who feel they had to do the whole EASA / JAR IR before and feel because THEY had to “suffer” why should newbies not?

>I think GA spends so much of its time shooting itself in the foot…

Hell yes!

And this passage

>In 40 years the IMC rating has been achieved by some 25,000 British pilots, only one of whom was subsequently killed in IMC. Fatal accidents in GA in Britain are believed to be three to four times lower than elsewhere in Europe.

should really tell those who STILL oppose and shoot against a new achievable and realistic IR that they WILL have blood on their hands if they prevail and shoot down FCL.008.

LSZH(work) LSZF (GA base), Switzerland

I’m a bit confused what to do.

I have a UK IMCr (and UK license), but live in the Netherlands. So I can’t use the privileges of an IMCr. Therefore it would be very interesting for me to “convert/train” for an EASA (E)IR.

I read the [document](http://www.pplir.org/images/stories/pplir_files/GA_IR_v1.4.pdf) of the PPL/IR organisation. I quote:
> For experienced holders of an EIR and IMC Rating, the full EASA IR will require no additional TK exams and only an ATO course with a minimum of 10 hours.

What is meant by an “experienced holder”?
Should I go to the UK to get some extra hours IFR before the legislation is a fact?
Or can I also build hours after the legislation gets in place?

Any advise would be welcome.

jkv
EHEH

I think they mean you already have the 30 hours IFR time in your logbook.

Then the required ATO time is 10hrs (min).

Whether you need to go to the UK to build “IFR time” is a very good question.

My understanding is that the holder of a JAR-FCL (now EASA) PPL can log IFR time just by flying in VMC, in accordance with IFR rules. Has this been stopped, or does the CB IR proposal contain wording excluding such time? If it says e.g. the IFR time must be time while flying in conditions which require compliance with IFR (that form of words has been used in some other contexts I recall) that needs one of these two

  • the IMCR, which implies doing it in UK airspace, or
  • a full IR, OK anywhere, but if you have the full ICAO IR then you don’t need any ATO training time anyway (the conversion route is an oral exam with the examiner and a flight test)

Any views?

Administrator
Shoreham EGKA, United Kingdom

I think I would wait and see what organisations will allow you train for either the EIR or CB IR, and what the training is like, and whether either of them is do-able. I have said on here before that I have been generous in logging hours in the ‘instrument time’ column in my logbook, where most was VMC on top out of sight of the surface, complying with IFR rules OCAS. I have more than 50 hours logged on instruments, but I wont kid myself that I am going to need minimum hours to do either the EIR or CB IR. If you have an IMCr, you probably have at least 15 hours logged on instruments, so I’d wait and see what becomes. I don’t think I’d go to the expense of coming to the UK just to notch up more hours, when the money is probably best spent on training as when it is available getting you up to the required proficiency. Spending time brushing up NDB and VOR holds on flight sim, in cloud, doing some approaches is possibly more useful. Just my view…

Recently, I spoke to one of the editors of the UK issued PPL material, who is very much up there with the echelons of the training elite, and he says he really isn’t sure what’s happening with either potential qualification at the moment. I asked him if he was aware of any material being written in preparation, and he said he was aware of nothing official, but for the organisations he is associated with, they are writing their own. I didn’t really qualify whether that was based on guidelines of some kind, or if it was a stab in the dark as to what might be required, or maybe he was being coy to protect his or another organisations interests, or something else.

Thanks for the quick reply. Another question pops up in regard to the EIR.

> The EIR training course is a minimum of 15 hours dual instrument instruction, 10 hours of which must be a formal course at an ATO (Approved Training Organisation) and 5 hours which may be conducted
independently by an IRI

Can I use my IMCr training hours towards the EIR or does that not count as “a formal course”. I need to do the theory exams in that case of course.

A lot of questions remain, but in general its great if this legislation gets in place…

jkv
EHEH

>Can I use my IMCr training hours towards the EIR or does that not count as “a formal course”. I need to do the theory exams in that case of course.

I would suspect that it counts as a formal course, especially as it has a stay of execution and is recognised by EASA. Other than an IR(R), which I think is only recognised in the UK anyhow, both the EIR and CB IR (definitely the CB IR) will have additional material and I am sure both will require separate ground school hours and tests. What that will entail has yet to be seen.

Can anyone clarify what the legal and jar / easa definition(s) of instrument flight time are? I too, have been generous about logging instrument flight time whilst being vmc on top but I recall being shot down in flames on another forum when I said I’d been logging as such. The explanation at the time was that instrument flight time is time which is by"sole reference to the instruments" ie the aircraft is controlled only by reference to instruments? Clearly flying on top is done primarily by reference to the horizon?

EASA defines this as time under instrument flight rules. Flying VFR and VMC on top of clouds does certainly not count. It doesn’t matter what technique was used to fly straight and level or to maneuver the aircraft. Flight rules (instrument or visual) is what counts.

I am aware that in contries like the UK, when OCAS, only the pilot decides which “set of rules” to follow at a given moment.

Mainz (EDFZ) & Egelsbach (EDFE), Germany

Yes but… here in the UK a PPL holder can fly in accordance with IFR, in VMC, by meeting the IF rules (FL060/070 etc).

That is what my Q was about. I am not sure if this was recently terminated.

I should also add that nobody is going to make the CB IR in the 10hrs min time. In fact almost nobody ever made the supposedly much easier IMCR in its 15hrs min time. The CB IR will have the CAA appointed IR examiner “doing you” – just like the JAA IR.

Actually you could do the CB IR in the 10hrs – by flying with a freelance examiner who knows the exact protocol, including the way the particular FTO instructor (the one you will have for the 10hrs) works. But that will take some work, and contacts.

Administrator
Shoreham EGKA, United Kingdom
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