It all boils down to three things
– you need to learn to fly IFR at an ATO
– you need to pass a theory exam
– you need to pass a check.
Working backwards
– the check is reasonable (except maybe the – diminishing – obsession with ADF holds in the UK)
– with the “competency based route”, the minimum hours are no longer an issue, so you fly the tame it takes to reach the standard
– but the need for an ATO reduces supply, decreases convenience, and increases cost
– and the theory is still way out of proportion compared to what is needed.
So addressing the theory requirement should be next on the list, and after that, get rid of the need for an ATO.
Plus the annual revalidation flight, which (like has happened to the twin rating, with the high cost of renting a twin for an annual test) more or less kills the IR for anybody but an aircraft owner, or a well funded and dedicated renter.
What always strikes me with these regulations is how poorly constructed they are – having just gone through the theory bit of the CBIR – you are still being asked questions about IR’s and ADR’s and FMS’s in Boeing 737 airplanes (got a question on my exam) which is entirely ridiculous as you will never be flying that type of plane with an IR.
However, practically you can leave an airfield with just the minima for take off (say 250M visibility) – vertical visibility isn’t required to be above minima for an ILS approach with only 1 alternate and weather conditions below minima at your arrival field as long as your alternate is forecasted to be above minima. As a professional pilot you would need 2 alternates and comply with a whole host of other regulations. So actually they are imposing stricter rules for (arguably) better prepared and trained pilots with more engines than our SEP planes…
Cobalt wrote:
So addressing the theory requirement should be next on the list, and after that, get rid of the need for an ATO.
Yes, as I said in post#4….but as I also said, why create a new sub-ICAO rating? Just fix the CBIR requirements…
What always strikes me with these regulations is how poorly constructed they are – having just gone through the theory bit of the CBIR – you are still being asked questions about IR’s and ADR’s and FMS’s in Boeing 737 airplanes (got a question on my exam) which is entirely ridiculous as you will never be flying that type of plane with an IR.
There is a lot of history to this exam stuff – one cockup after another.
When I was first looking at the (then JAA) IR, c. 2002, there was no theory just for the IR. The only option was the then new JAA ATPL QB, which as everybody knows was (and mostly still is) packed with irrelevant bullsh1t and generally poor quality questions (multiple correct answers, etc). It was a tour de force in political correctness in that e.g. Air Law was done by a Portugese ATCO!
I had a look at the theory – about 10 huge ring binders, each 10cm thick – and gave up on it.
Over the following years the UK CAA, and possibly some other N European CAAs, weeded (cleaned up) the ATPL QB and removed the worst of the questions.
Then a year or two later a route opened up for PPL/IR students which used about 7-9 of the 14 exams. This stuff still had loads of jet performance stuff in it.
Then, later, a “private IR” exam set of 7 exams was developed by the UK CAA which was a subset of the ATPL exams, except HP&L which was directly out of the ATPL stuff. I sat these in 2011 as detailed here. They did contain some jet stuff but you were allowed to appeal any such questions (in practice only people who failed by a small margin bothered to do that). These exams however contained a dead-end gotcha in that if you got the IR with them, and then did a CPL (which was 9 exams at the time), you got a CPL/IR but that CPL/IR could never be upgraded to an ATPL unless you sat most of the 14 ATPL exams! But obviously most private pilots didn’t care about that. Around 10-20 PPLs per year did their IRs via this route in the UK… a tiny number.
Then came the CB IR which is a good achievement on the training and test but the theory got screwed up, in that it reverted to taking questions out of the original JAA QB to pack out the LOs (learning objectives i.e. the syllabus) so the benefit of the CAA weeding was lost.
In the meantime the online QBs, which started by being packed will bullsh1t out of the (originally leaked and later released under an FOIA request in Denmark) 14-exam ATPL QB, remained more or less the same because the weeded versions of the QB were never published. And the online QBs got your £10/month or whatever, regardless of the quality. The actual exams were always easier than the QBs – because the QBs contained a lot of rubbish and still do.
Also the CB IR route ignored any medical issues such as the two-ear Class 1 audiogram which prevents many older pilots from ever doing the Euro IR.
LFHNflightstudent wrote:
However, practically you can leave an airfield with just the minima for take off (say 250M visibility) – vertical visibility isn’t required to be above minima for an ILS approach with only 1 alternate and weather conditions below minima at your arrival field as long as your alternate is forecasted to be above minima. As a professional pilot you would need 2 alternates and comply with a whole host of other regulations. So actually they are imposing stricter rules for (arguably) better prepared and trained pilots with more engines than our SEP planes…
The professional pilot is only required to comply with that and “a whole host of other regulations” if operating a commercial air transport flight. Such flights are operated to a higher target level of safety, which is why the rules are more restrictive.
That should not detract from your first paragraph, which is, of course, spot on.
EASA has published what they call “Easier access for general aviation pilots to instrument flight rules flying” here under NPA 2016-14
Lots of interesting snippets in there.
One of them is:
The respondents to the previous stuff make an interesting list too:
We had two threads here on the same thing so I merged them.
respondents, those who speak the best English 
It makes perfect sense to ditch the EIR if BIR becomes reality. I think I wrote as much here in some discussion about this. That’s because the BIR concept has an equivalent of EIR (what you could call an en-route module – I’m sure they have some name for it, I haven’t read the NPA yet).
The NPA seems slightly less chaotic than the first draft.
Now we are discussing 5 different instrument flight ratings in EU, and I am not even counting the sailplane cloud rating. We have the IR, the CB-IR (admittedly almost the same thing), the IR[ R] in the UK, the EIR, and now it seems we need one more, the BIR. In the US everyone seems to be happy with the one they have.
I know this has been discussed and turned down, but it would have been more elegant to twist the UK IR into something acceptable for both UK and the rest of EASA, and forget about EIR and BIR. As that is not going to happen, the question is which one to kill: the EIR or the BIR?
As the EIR is gaining momentum (or is it?), the flight schools are probably not enthusiastic about the prospect of continuing the bureaucracy of relearning everything, revising the lesson plans and SOPs, and getting new ATO approvals.
With a BIR the pilot is restricted to a MDH/DH of 500 ft instead of 200 ft. Those 300 ft difference seem to be the sole justification for a reduced training program totally without any specific number of required flying training, as opposed to 40 hours for the IR and CB-IR. Also while the Skill Test for the IR/CB-IR is mandated by hard law, it seems the test for the BIR is in the AMC, subject to national preferences. Is there really a rationale in those differences?
