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How to embark on the IMCR such that the lessons count towards the CBIR [was: if the IMCR is killed off?]

Numerous UK pilots are asking this Q, because the IMCR (a.k.a. the IR(R) ) is supposed to be killed off under Brussels orders in April 2019.

I don’t believe for a moment the UK CAA will kill it off, because it would be a huge scandal (reducing safety, etc) but in line with their standard practice they won’t announce anything until the day before.

Administrator
Shoreham EGKA, United Kingdom

Well, assuming the IMCR lessons are “instrument flight time”, they should be:

  1. creditable up to 30h if the instructor was an EASA (UK?) IRI(A) or a FI holding the privilege to provide training for the IR (Aircrew Regulation 1178/2011, Appendix 6, section Aa, paragraph 6.(a)(i)(A)).
  2. creditable up to 15h otherwise (Aircrew Regulation 1178/2011, Appendix 6, section Aa, paragraph 6.(a)(ii)).

My understanding is that IFR time flown under the IMCR (as PIC) is also creditable up to 30h, under Aircrew Regulation 1178/2011, Appendix 6, section Aa, paragraph 6.(a)(i)(B))):

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

Last Edited by lionel at 20 Nov 16:50
ELLX

I guess there are two things to clarify,
- Grandfathering time with IMCr instructors only
- Training time done outside ATO

Given how the CAA did it for many other stuff (e.g. NPPL), it will be the flexible approach or just kick it forward in the last minutes

I got TMG rating from my NPPL granthfathered on my EASA PPL in the last weeks before Apr18, the key words from an email I received was : “the sensible thing to do while we are in transition…”, even those who did not convert, now have until Apr20 to do so !

Training is different as you have nothing to grafather but still who has a nice list of FIs with IMCr vs IR? UK FIs? RTFs vs ATOs?

You still need to find a CBIR school that take you up with some IMC training hours but I don’t it will make much difference on the totals unless you pass on min hours?

You can say the same on counting FAA IR training hours for CBIR or counting IMCr trainjng hours for FAA IR, there is no black and white from the rules, just interpretation from whom you speak to

Last Edited by Ibra at 20 Nov 21:18
Paris/Essex, France/UK, United Kingdom

As said before, if you have the IMC/IR(R), 15 hours count towards the CBIR. If you want more than that, simply approach your training as if you’re doing the IR. So get an IR instructor, make sure the paperwork (including training records) is done to IR standard and whatnot. Then, when you have enough experience, do the IMC written and practical exam and forget about the rest of your IR training. Then you can be sure that all training hours, even if more than 15, count towards the CBIR in the future.

One small correction. Brussels cannot kill off the IMCR, only the IR(R).

I have heard rumoured in the corridors of power that, in the event that it is lost, the IR(R) will be grandfathered into a BIR with as little fuss as possible. That has yet to be determined, but seems another reason for getting an IR(R) now, it may even be an easier route to the BIR.

Incidentally, there will be a lot of pilots for whom a BIR will be enough. There are quite a lot of IRs who never go below BIR minima anyway, some because they don’t trust their skills and recency, some because they think that singles should not be flown in worse conditions and some because they just don’t like it.

EGKB Biggin Hill

Yes; though one can argue this various ways.

One line of argument and perhaps the worst-case scenario is that if, post-brexit, the UK wants to remain in EASA, and bearing in mind the blindingly obvious i.e. Brussels has zero incentive to make it pleasant (and has issued various statements generally saying UK licenses etc etc will be invalid in the EU then, etc, etc) then Brussels has the UK over a barrel because it can say “if you implement any concessions even if valid only in UK airspace which are better than what the rest of the EU has, then we will block or constrain your EASA membership”.

The EU has a long history of wanting precisely this (witness Eric Sivel’s renowned position on the IMCR “you can keep it but only if the rest of the EU wants it too – because the EU is all about standardisation” on the IMCR … I still have my conference notes somewhere).

Against this “shaft the UK” attitude we have the more practical reality that a large % of airline flights within the EU are on UK issued pilot licenses and with UK-145-certified aircraft and aircraft components

And also against this argument runs the very much longer (since 1969) history of the IMCR being a very safe privilege, which I am very certain the CAA will find some way to keep – even if the announcement will not be made until literally the day before, which is how they do everything these days… Also the UK is not the only country to have national concessions; witness France requiring no medicals for ULs for example. BUT this last one is tricky because it opens the trap of the IMCR being limited to non EASA (basically uncertified) aircraft, which actually happened with the NPPL (and its preceless-for-many medical self declaration) earlier this year, which would be wonderful news for anyone wanting to sell their RV I don’t think there are many (any?) concessions left elsewhere in Europe which are usable on certified aircraft?? This landscape gets complicated… there is this.

And if the EU was to totally shaft the UK then the UK could safely implement whatever it wants

So it depends on which way the politics pans out i.e. how big balls the CAA has got. As I said I am certain the IMCR will remain (it will prob99.9 remain for non EASA aircraft; it is the “other bit” which is perhaps debatable) and the ability to use the training (if structured right) towards the full IR makes embarking on it a win-win scenario.

Administrator
Shoreham EGKA, United Kingdom

As the BIR has to be taught at an ATO it’s no use to me.

The nearest ATO to me is a 62 Mile round trip and I wouldn’t use them in a million years. The nearest one after that is 104 Mile round trip.

Meanwhile my local rtf which has three IRI’s on staff. One IRR. One IRE. A FIC and an FIE. Won’t be allowed to teach for the BIR.

Great. Just great.

Bathman, there is a decent amount of training going outside of physical ATO locations, so it might be worth looking into (if you can get past the sadness of the illogical situation you are in). I did my Multi stuff at North Weald, with an ATO based about 2h away. The instructor (who wasn’t himself based at the ATO) would come to “my” airfield and we would train / exame in “my” plane.

Dunno about BIR, but for a CB-IR, you can train all you want with your local IRIs. Do it until (nearly) ready for the test. Then you only have to do 10h in an airplane in an ATO. It would be … a pity if a BIR were harder to get than a CB-IR.

That’s what I did for my (CB)IR… Depending on the type of training you do, 10h can fit into not-many days. Don’t shoot approaches and holds for 5h straight per day, that’s not reasonable, but it won’t be necessary since you will already master these well from your previous “out of ATO” training. Both the instructor and the ATO should be happy / willing to make it something more typical of a “real” IFR flight. Go in the morning (by plane VFR/VMC?) to the ATO, and your lesson is to travel somewhere, have lunch / visit the sights (or only a drink and debrief), travel back. You can easily pack 4-5h of flying in a day over two flights. You’ll be rested between the two flights, and that flying is not very tiring, assuming the travel is an “airways / eurocontrol” IFR flight on a plane with autopilot.

ELLX

Peter wrote:

One line of argument and perhaps the worst-case scenario is that if, post-brexit, the UK wants to remain in EASA

It is a UK-only rating, it will be very easy to wrap and sell with or without Brexit…

Would have been easier if the rating comes on a different set of papers, so it does not have to be fudged in Part-FCL until something better comes in

Bathman wrote:

As the BIR has to be taught at an ATO it’s no use to me.
The nearest ATO to me is a 62 Mile

As Noe said the physical location is a bit wired, you will also have to fly to another airfield away to shoot an ILS if you are doing BIR in a place with “no ATO”, that costs more money, time and hassle, so at least why not do that bit alone and count it as cheap+PIC time?

I think the problem for low intakes of EASA IR was the heavy TK requirements and less to do with ATOs, lot were prepared to go to the US to avoid this…still having to do all of it in ATO may make it less appealing than CBIR for some

Last Edited by Ibra at 21 Nov 12:10
Paris/Essex, France/UK, United Kingdom
22 Posts
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