N reg pilots who in Europe must fly using the most penalizing regs between the FAA regs and EASA regs… At least I think that’s how I remember the conversation with the examiner before my last check ride.
If that is how your examiner has presented §91.703(3) to you, I suggest that he is either mistaken or deliberately peddling FUD.
If the FAA’s and an EASA Member State’s rules governing a particular operation differ in substance or effect, those rules are, by definition, inconsistent with each other.
I have not read the BIR syllabus but for the privileges it cannot be much different to the full IR in terms of hours of flight training.
Especially if the pilot is hoping to actually go somewhere in the European IFR system.
Oh, whoops, I forgot! The full IR doesn’t teach you to even plan a flight successfully, let alone teaches you how to fly in the European IFR system 
MikeWhiskey wrote:
Is there a real-life simplification of the practical training towards BIR instead of CBIR? In a nutshell, the key difference seems the higher decision altitude, will the training be much lighter/easier then? Maybe in light of VMC-requirements for the approach?
Also with regard to the BIR-theory training, I guess it basically is the CBIR-theory broken into three separate exams?
AFAIK it is more simplifed, split in three parts – basic, AD and enroute, just like theory. If you have IR(R) then you should get basic and aerodrome part (semi-)automatically. And for those module where you don’t have the qualification, there should be no minimum hours – fully competency-based.
Theory is supposed to be simplified compared to CBIR as BIR is sub-ICAO rating and CBIR is full ICAO.
And BIR requires an audiogram unlike IR(R).
I can’t see the typical European IR examiner cutting any much more slack on BIR test applicants.
Also, as often said already, flying an ILS und GPS approach down to 200 feet instead of 500 feet is totally trivial. What is demanding in IFR flying is other things: properly managing the aircraft, briefings approaches, interacting with ATC, planning descents, setting up the avionics, etc. All this in an often very limited bracket of time. Also, holds will still be the same.
So no, in practice, BIR pilots will likely nees substantially less hours to get ready for the test.
I agree 100%.
It’s the same with the PPL v. LAPL, etc.
Perhaps one attraction is the 3 exams instead of 7, but how can that be achieved? Well, they could have made the content practically useful (the JAA/EASA IR basically wasn’t)
AIUI the audiogram for the IR now has a concession route, via demonstrated ability. Previously, the only way in was the back door UK CAA / ICAO CPL/ATPL route… or “some other way” of getting the initial Class 1 medical done.
boscomantico wrote:
So no, in practice, BIR pilots will likely nees substantially less hours to get ready for the test.
That’s probably true, but a key difference is that there is no flight time requirement for the BIR. That means that the pilot can benefit from any kind of training or preparation that isn’t loggable. Particularly uncertified simulators can be used. I believe this will have a major effect on cost.
Ture, but proper sim training also costs money. And of course time.
And “playing” on a home sim, alone, will sometimes likely not be beneficial, but rather detrimental to getting up to test standard. Again, there will be no proper, realistic ATC interaction, no pressure, no unforeseen events, etc.
@Jacko I am afraid my examiner was neither mistaken or spreading FUD. In another thread I gave an example of an N reg and an EASA reg flying into Le Touquet. On certain elements the approach and landing was more favourable to the N reg pilot whilst on others it was more favourable to the EASA reg.pilot.
91.703(3) cannot deal with this situation because under ICAO and EASA a pilot must obey the regulations of the country in which his licence is held, the country of registration and the country/state in which s/he is flying.
The only way to do that is to fly to the most penalizing of the regulations.
Eg If the FAA state that a pilot holding an FAA licence cannot begin an approach if the ceiling is below the DA/MDA given on the IAC plates and the EASA regs state you can begin the approach if the visibility is equal to or higher than that given on the IAC no matter what the given ceiling is, then the pilot of a N reg aircraft must take the ceiling into account before starting an approach.
@Peter I do not know what the full IR training in the UK encompasses but in France you certainly do learn to plan, brief and file a flight successfully in the European system, including in my case flights to the Channel Islands and the UK mainland as well as to different parts of France.
boscomantico wrote:
And “playing” on a home sim, alone, will sometimes likely not be beneficial, but rather detrimental to getting up to test standard. Again, there will be no proper, realistic ATC interaction, no pressure, no unforeseen events, etc.
Nothing says you can’t use a “home sim” with an instructor. (I do feel a slightly condescending tone in “playing with a home sim”. X-plane, just to mention one, is also used in approved simulators.)
Airborne_Again wrote:
Nothing says you can’t use a “home sim” with an instructor. (I do feel a slightly condescending tone in “playing with a home sim”. X-plane, just to mention one, is also used in approved simulators.)
Flying the MS FS X at home helped me significantly in my preparation for IR(R) course and test. Saved some time as well.
