Surprising because you can log IFR time on a plain PPL, in CAVOK, just by flying in accordance with instrument flight rules i.e. whole-number flight level, etc.
Not according to Part-FCL.
FCL.600 IR — General
Except as provided in FCL.825 [EIR], operations under IFR on an aeroplane, helicopter, airship or powered lift
aircraft shall only be conducted by holders of:
(a) a PPL, CPL, MPL and ATPL, and
(b) except when undergoing skill tests, proficiency checks or when receiving dual instruction, an IR
with privileges appropriate to the applicable airspace requirements and to the category of aircraft.
Yes, the bit about plain-vanilla PPL (without any sort of IR) being allowed to fly IFR is wrong. But still, in the UK, with an IR, one can fly IFR, without a flightplan, without a clearance and even without radio contact with anybody. So, an UK IMC rating holder (or FAA IR holder) can indeed very easily and quickly accumulate the required 50 hours PIC under IFR required for the EASA CB-IR.
That thing about being allowed to fly IFR without having any sort of IR used to be an old UK CAA concession, valid only in very specific curcumstances, but it is long gone.
Interesting – thanks.
I have never met anyone use used that concession to log “IFR time” – especially as no logbook I have ever seen has such a column. The issue was raised initially when the “50hrs IFR time” for the ICAO IR to CB IR conversion came out. What else could IFR time be used towards? Was it an IRI or some such? I believe @timothy might know; I recall some discussion somewhere, years ago.
For sure an IMCR/IR holder can log IFR time and he can do it while flying non-radio in Class G 
Basically every flight an IMCR/IR holder does can be thus logged. One remaining Q is whether you can log “IFR time” brakes-off to brakes-on, in the way you log everything else in your pilot logbook. I know of one prominent personality on the GA scene (not on here AFAIK) who is viciously against that; presumably logging airborne time would be unquestionable
nickflyer wrote:
1. As far as I understand, you can do 30 hours of your CBIR training outside an ATO with an FI. Could I fly those hours in the US or Canada with a local instrument-rated FI or does he need to be EASA-rated?
With a non-EASA rated instructor, you can credit up to 15h.
Part-FCL Appendix 6
Aa. IR — Competency-based modular flying training course
FLYING TRAINING
6 (a) (ii) When the applicant has prior instrument flight time under instruction other than specified in point (a)(i), these hours may be credited towards the required 40 hours up to a maximum of 15 hours.
In my understanding, you can credit 30h dual flown with an EASA rated IRI(A) on a non-EASA plane (e.g. N-reg or C-reg) in any airspace (EASA, FAA, TCCA, …).
on a non-EASA plane (e.g. N-reg or C-reg)
Not being able to log time on a plane which is not on an EASA registry would be a very curious restriction…
A limitation for “non EASA planes” (basically meaning planes without an EASA CofA, which basically means planes without an ICAO compliant CofA) is much more likely. There is a long history of not being able to log qualifying time in homebuilts or UL, for example.
I haven’t read the whole thread, I’m just here because Peter said the magic words and turned thrice widdershins, but I agree that the phrasing of the EASA law give a huge, ridiculous and presumably unintended advantage to the UK pilot, in that in the UK being IFR is only a state of mind.
You can fly the length of the country in beautiful sunshine, outside controlled airspace, in radio silence, upside down if you wish, and, provided you are 1000’ above any obstacle within five miles and obeying the semicircular rule, decide, in your own head, that you are IFR and log it as such.
I log IFR in my log book in a column on the right that I relabel. I also log instructional hours.
The only time I remember being asked was, IIRCC, when converting my JAA ATPL to EASA ATPL.
I log the same hours as block time, as IFR duties definitely start at (actually well before) brakes off. The act of copying your clearance, putting it into the FMS, checking it, briefing it, checking your navaids and all the other stuff you do before takeoff is much more experience of IFR procedures than ten minutes in the air watching GPSS flying a straight line.
I reckon that whoever says that it should be takeoff to landing must be making the schoolboy confusion between IFR and IMC.
Finally, there is always less written in the law than the keyboard warriors think, hope or expect. People argue for hours on fora such as this about exactly what the law says and means, when the law only has seven words on the subject.
Normally these anomalies are sorted out by case law, but thankfully they very rarely come to court and even then only to lower courts, where no precedent is set, so the answer is never truly found.
Sometimes we have the benefit of someone like @bookworm telling us exactly what was discussed in committee before the law was made, so we have some insight into intention, but even that has no weight in law.
I apologise if these points have been made, but I am typing without knowing what has gone before; I have a hugely busy time at the moment. You just don’t want to know the multitasking I just achieved while typing :-D
Normally these anomalies are sorted out by case law, but thankfully they very rarely come to court and even then only to lower courts, where no precedent is set, so the answer is never truly found.
There is this claim
" A famous former German ATO, which did this systematically, comes to mind – ending in license revocations years later, hefty fines and other things…"
posted above, so I wonder what it was?
There is (and I know this for a fact) a history of the FAA not recognising checkrides done by a specific DPE(s) (for reasons which aren’t clear – about 10 years ago, and I don’t want open discussion here because he readily threatens litigation) but where the pilot(s) challenged this via legal channels, he/they got the certificate granted. Obviously most won’t bother; they will just re-do the checkride…
In general, you are entitled to assume the examiner is legal, so this is not surprising. So IMHO for a license etc to be revoked there is likely to have been collusion between the ATO and the student(s) e.g. fake exam passes.
Hence I do not believe this has happened because somebody’s 50hrs of IFR time was retrospectively un-recognised and his CB IR revoked.
What exactly does Germany need “IFR time” for?
As so often, someone has taken a court case applying to one thing and tried to stretch it as precedent over another.
I am sure that training organisations have been taken for task for systematically falsifying records, probably in every jurisdiction the world at some time or other.
That speaks nothing to the issue of what counts as IFR time
Timothy wrote:
I haven’t read the whole thread, I’m just here because Peter said the magic words and turned thrice widdershins, but I agree that the phrasing of the EASA law give a huge, ridiculous and presumably unintended advantage to the UK pilot, in that in the UK being IFR is only a state of mind.Not only in the UK. You can do this in Sweden as well as long as you stay below 5000’ (or 3000’ AGL if higher) — above that you need an IFR flight plan and radio contact with ATS.You can fly the length of the country in beautiful sunshine, outside controlled airspace, in radio silence, upside down if you wish, and, provided you are 1000’ above any obstacle within five miles and obeying the semicircular rule, decide, in your own head, that you are IFR and log it as such.
Personally I log IFR time when I’m either on an IFR flight plan (regardless of weather conditions) or in IMC (actual or simulated).
There is this claim „A famous former German ATO, which did this systematically, comes to mind – ending in license revocations years later, hefty fines and other things…"
posted above, so I wonder what it was?
You may Google „IKON Flugschule Nürnberg“, but most of the results will be in German, unfortunately: 5 hrs SIM time had been recorded as 32 hrs, a FI candidate had only received a fraction of the required training on an airplane and an applicant for a Jet-TR had claimed to have been trained (including several approaches and airwork) on a pax flight from Moscow to Nice, when according to radar data this had definitely not happened and all evidence showed that the candidate wasn’t even on board on that flight (!).
I do not believe this has happened because somebody’s 50hrs of IFR time was retrospectively un-recognised and his CB IR revoked.
I do not either – I just wanted to point out that if the authorities have a reason to suspect your claims, there are ways to get after you.
What exactly does Germany need “IFR time” for?
This is not a German thing, but defined in FCL.010:
Flight time under Instrument Flight Rules’ (IFR) means all flight time during which the aircraft is being operated under the Instrument Flight Rules.
And this is what’s required if you want to get a CB-IR based on another ICAO-IR according to Appendix 6 Part-FCL:
Applicants for the competency-based modular IR holding a Part-FCL PPL or CPL and a valid IR issued in compliance with the requirements of Annex 1 to the Chicago Convention by a third country may be credited in full towards the training course mentioned in paragraph 4. In order to be issued the IR, the applicant shall:
(a) successfully complete the skill test for the IR in accordance with Appendix 7;
(b) demonstrate to the examiner during the skill test that he/she has acquired an adequate level of theoretical knowledge of air law, meteorology and flight planning and performance (IR); and
(c) have a minimum experience of at least 50 hours of flight time under IFR as PIC on aeroplanes
