My apologies for opening a new topic on this, but it is taking me out of seriousness.
For those not familiar with the Portuguese Aviation Authority, it is the most annoying entity that works against GA in EASA. Whatever you went through with your respective CAA, ANAC can multiply it for dozens of times.
I did finish my BIR 2 months ago in CR. After going through the theoretical exams, I did found time to fly to CR, do my training, the exam and finally see myself as a proud IR pilot, right? WRONG.
The school sent the process to ANAC, and to CR CAA. From ANAC I first receive an email to fulfill a form requesting the BIR to be registered on my license.
Week later another email requesting me the last 6 pages of my pilot logbook and the evidence that I did the theoretical exams. Because I am in Sudan, my wife scanned the last 6 pages of the logbook and the competent CR CAA had gave me the certificate of finalizing of the 3 exams and another document with the grades.
Another email to attest that I did had classes to which I reply that for sure the ATO had to attest to the CR CAA that I was deem competent to be submitted to examination and the presence on the examination room was sufficient for it.
Another email that ATO has to certified that the theoretical classes were effectively done.
So my ATO sent me the document sent to CR CAA proposing me to the exams, stating that I have completed 80 hours of online training and passed the internal evaluations.
Another email that regulation requires 150 h of theoretical classes and I only had 80. Attached the send a Regulation (EU) No 1178/2011 Appendices to Annex I. Appendix 6 – Modular training courses for the IR which on theoretical knowledge paragraph:
“An approved modular IR course shall comprise at least 150 hours of theoretical knowledge instruction”
My comments:
1. First the mentioned regulation date from 2011 when the BIR was regulated if I am not mistaken in March 2020
2. In essence, the BIR provides a more accessible pathway for general aviation pilots to gain IFR proficiency within the EASA framework, while acknowledging some limitations compared to a full IR.
3. CB-IR equivalent to IR requires 7 exams over a bank of 4,000 questions while the BIR only requires 3 over 1,400 questions.
Can someone please guide me on a specific EASA policy that identifies the theoretical hours required for the BIR?
Thank you in advance for the support.
Luis
The minimum theory course length of 80 hours is probably correct based on EASA recycling much of the CBIR framework. Strictly speaking, the implementing rules set no minimum hours for the BIR theory course. The Explanatory Note to Decision 2020/018/R, para 2.3.2 (key principles for the BIR), states: “Training that is entirely competency-based. There will be no minimum hours requirement set for the BIR.”
There’s a drafting error in FCL.835(c) which requires “Applicants for the BIR [to] have completed at an ATO … theoretical knowledge instruction in accordance with point FCL.615(a)…” The latter starts with “Applicants for an IR shall have completed …,” yet FCL.600 and FCL.605 make it clear that the BIR is not an IR. Taken literally, this broken rule chain would mean the BIR has no TK syllabus, contrary to EASA’s stated intention, so FCL.615(a) should be taken to mean “… IR or BIR…”
EASA’s NPA 2016-14 and its CRD, together with AMC1 to FCL.835, confirm that the BIR was crafted in the style of the CBIR. Hence, if any of the minimum theory course lengths in appendix 6 must be referenced, the CBIR figure in section Aa 5 is appropriate at 80 hours.
Edited to add URLs and to strike an erroneous inclusion of “FCL”.
Thank you Qaluplik
After a long night reading through regulations:
FCL.615 IR – Theoretical knowledge and flight instruction
FCL.165 (pagina 760)
(a) Course
Applicants for an IR shall have completed a course of theoretical knowledge and flight instruction at an ATO. The course shall be:
(1) an integrated training course which includes training for the IR, in accordance with Appendix 3 to this Annex (Part-FCL); or
(2) a modular course in accordance with Appendix 6 to this Annex (Part-FCL).
(b) Examination
Applicants shall demonstrate a level of theoretical knowledge appropriate to the privileges granted in the following subjects:
(1) air law;
(2) aircraft general knowledge — instrumentation;
(3) flight planning and monitoring;
(4) human performance;
(5) meteorology;
(6) radio navigation; and
(7) communications.;
Aa. IR — Competency-based modular flying training course
THEORETICAL KNOWLEDGE
5. An approved competency-based modular IR course shall comprise at least 80 hours of theoretical knowledge instruction. The theoretical knowledge course may contain computer-based training and e- learning elements. A minimum amount of classroom teaching as required by ORA.ATO.305 has to be provided.
According to Aviation Safety Agency Explanatory Note to Decision 2020/018/R
In 2.3.2 “Key principles for the BIR”
The key principles for the BIR are as follows:
— Training that is entirely competency-based. There will be no minimum hours requirement set for the BIR. Instead, the required competencies that a GA pilot needs for an IFR flight are grouped into three modules of training, with an optional fourth module. Candidates will progress to the next module or skill test when ready to do so.
— Training that is flexible. The core module of instrument flying skills must always be completed first, and after having done so, the candidate may choose which further module to tackle next, within a timescale that suits them. This takes into account the fact that GA pilots may often not have the time or financial resources to commit to a more conventional continuous course of training towards the IR.
2.3.3 Training structure
The competency-based training is conducted through a modular training system. There are four modules: Module 1 is completed first, but the order in which Modules 2 and 3, and — if applicable — Module 4, are completed is up to the applicant (see point FCL.835).
(…)
Each module contains the required individual competencies. It will be up to the training organisation or instructor to determine whether the competencies have been assimilated to the required standard before allowing the candidate to progress to the next module or skill test. This will allow that the difference in learning speed of candidates can be taken into account for their progress.
2.3.4 Theoretical knowledge (TK) and examination procedures
To ensure a better fit to the BIR course structure (compared to the CB-IR), training Modules 1 to 3 are supported by theoretical knowledge examinations incorporating the relevant learning objectives (LOs), resulting in a total of three focused theoretical knowledge (TK) examinations. Each TK examination consists of a ‘paper’ addressing parts of three or more TK subjects, so the exams cut across the traditional seven subjects required to be covered for this rating.
Moreover, and outside of the subject of my post, 2.3.4. for me it is implicit that the TK for BIR cover the 7 subjects of the CB-IR, hence the transition between both is resumed to addressing the training skills differences.
Portuguese CAA (ANAC) not knowing regulations is pretty serious, when they clearly point to outdated regulation and they don’t even bother to look for the regulation behind the BIR. For them it is easier to deny a certification then to look for the adequate regulation.
Bur I am also of the opinion that BIR does not require a minimum hours o theoretical classes, the same way they clearly stated for skill practical lessons. While it is clear on the second, it leaves room for interpretations on the first, but no room for interpretations for modalities over 80 hours.
Luis, I don’t have much to add except that ANAC is a whole pile of s***. They have killed GA in Portugal.
In your position, I’d jump ship and transfer the medical and licence records to another EASA state. The new SOLI should add the BIR to the licence. There’s generally a six month time limit from passing a skill test until applying for a licence or rating. I’d recommend Trafikstyrelsen/Denmark or Austrocontrol/Austria.
After a long night reading through regulations:
As Qualu already explained, the hour requirements from the appendix aren’t applicable to the BIR. They are applicable for an IR.
I am pretty sure the national CAA will cave in. You are probably the first BIR holder and they simply don’t know the law.
Thank you all for the support.
Indeed, I am probably the first one but that is not an excuse for the continuous requests, one after each other. For me the worst is the disrespect shown towards a fellow CAA distrusting that they followed the right procedures accepting me for the theoretical exams. The devil is on the details, and end of all they are the ones not knowing the regulations.
But there is even worse. ANAC hates GA. If you go the their exams page, you can only find ATPL, CPL, PPL, LAPL, IR but not CBIR and not even close the BIR. The schools were never incentivized to create CBIR or BIR, here you have 2 types of schools: the big ones for the ATPL and the small aeroclubs that hardly survive with the PPL.
As Fernando well mentioned, for ANAC, GA is a burden that they happily would get ride of it.
Another small example. A good friend of mine had for many years a LAPL license. He bought a nice PA28 and started with the PPL. According to regulations, having a current LAPL, you can reduce 10 hours of practice and go for exam. That’s what he did. After a successful exam, he presented all docs to ANAC, to be informed that he was missing 10 hours on the practical instruction. Didn’t matter how much he claimed, he had to undergo for the remaining 10 hours and do another examination. That is ANAC.
When it comes to aircraft registrations, that is another nightmare. They can find ‘irregularities’ everywhere, turning that into an endless process. Result: less and less Portuguese registrations, and the few that exist, are moving to D or PH.
At the end, not to expire my exam, I might have to change my license to CR.
Since Portugal is EASA, why don’t you move your licence elsewhere ? Austria is handy here, but other countries work as well. Maybe even neighboring Spain.
Before trying to change the system, transfer the licence and go flying ;-)
And yes, you can fly during the process – the old licence is only handed in after completion.
(And you help the buerocrats ;-) )
lmsl1967 wrote:
When it comes to aircraft registrations, that is another nightmare. They can find ‘irregularities’ everywhere, turning that into an endless process. Result: less and less Portuguese registrations, and the few that exist, are moving to D or PH.
That explains why an aircraft my club sold some four years ago which is now in Portugal is still on SE-reg!
As expected and I am not surprised
“Good afternoon, Mr. Luis Leal.
Your text has received our full attention.
Regarding the matter at hand, Commission Implementing Regulation (EU) 2020/359 of March 4 essentially mentions the phasing out of the “En-Route Instruments” rating and its replacement by the “BIR” rating. It does not mention minimum theoretical requirements for the BIR course.
The BIR rating is mentioned in paragraph 2 of Chapter A of Appendix 6. The Competency-based IR Course (in the Annex), although also a Modular course, is – as explained in its preamble – aimed at pilots who already have prior experience in Instrument Flight (i.e., they hold this rating in an ICAO license).
What was your experience in VPI Flight Under Instruments (under “IFR”) before starting the BIR course?
If you read Chapter Aa. In Appendix 6, you will see that it does not mention practical instruction by modules (like the BIR).
Therefore, we do not agree with associating a BIR course with a CB course. They are two different courses.
But, as before, your email below will be forwarded to your superiors.
Best regards,"
Frustration
