Unless EASA changed it when the CB IR was introduced, there are seven subjects/exams: Air Law, Meteorology, Human performance and limitations, Flight planning and monitoring, Communications, Radio navigation, Instrumentation.
Interpretation of EIR rules
The German magazine Pilot und Flugzeug recently had an article about the practical use of the enroute IR-rating. Most of what the author writes concurs with both my understanding and what seems to be the general view on the web. But there is an important exception.
A crucial part of the AMC to part-FCL relating to the EIR states:
To comply with FCL.825(a)(2), the holder of an EIR should not commence or continue a flight during which it is intended to exercise the privileges of the rating unless the appropriate weather reports or forecasts for the destination and alternate aerodrome for the period from one hour before until one hour after the planned time of arrival indicates VMC. The flight may be planned only to aerodromes for which such meteorological information is available. When filing a flight plan, the holder of an EIR should include suitable VFR to IFR and IFR to VFR transitions. In any case, the pilot needs to apply the relevant operational rules, which ever are more limiting.
The author interprets this to mean that the destination airport has to have a TAF – which in practise means an open instrument airport! So if you want to fly to an airport without a TAF, you have to make the flight in two segments – one IFR segment to an airport with a TAF and a second VFR segment to your destination.
He then goes on to give an example of an EIR flight from one VFR airport to another. Although he doesn’t show an ATS flight plan for the example, it is implied that it is a Z flight plan with an IFR arrival to a filed destination airport (with a TAF) which is not his intended destination. In the example he is told by ATC to expect an ILS to the filed destination, but declines and instead cancels IFR and diverts to his intended destination. He comments “Der Lotse wundert sich” and “Aus Sicht des Lotsen in Dijon war unser Verhalten komplett unsinnig” – indeed!
I believe that this interpretation not only appears “unsinnig” (senseless) to ATC but that it is. For one thing, I don’t see why the “meteorological information” has to be a TAF – any cloud base and visibility forecast for the destination area should do. Also, surely the planned IFR to VFR transition should be in the filed flight plan and the flight planned destination should be the intended destination!
I agree that that interpretation is too limiting. Sure, you have to plan your flight as a VFR-IFR-VFR flight, and the transition points VFR-IFR and IFR-VFR need to be both in VMC and above the MSA/MVA (“operational rules, whichever are more limiting”) but those transitions do not necessarily have to be an airport. They can also be an IFR intersection near an airport, or a VOR on the airport. As long as you have a transition point for which you have a reasonably reliable weather forecast, including cloud base and visibility, and is connected to the IFR airway system somehow (if necessary via a legal DCT).
The main issue highlighted here is that there are very little weather forecasts available to the general public or aviation consumers, which include information such as cloud base and visibility. The most obvious is a TAF and that indeed implies that your transition point needs to be very near a major airport. In some countries you could use a GAFOR or something like the UK 215/216 metforms, but since these cover a fairly large area, they have to be used with quite a safety margin. And otherwise you’d have to rely on Skew-T forecasts, which require quite a bit more knowledge to interpret and are not as readily available as TAFs. Not an ideal situation.
In any case, flight planning your flight so that the IFR-VFR transition at the end of your EIR flight happens above the MSA and happens in VMC, is probably going to be one of the bigger challenges of the EIR. I certainly hope that any EIR training includes at least some experience with flying IFR approaches. Even though they may be illegal on an EIR, they can save your life if the forecast happens to be wrong.
I have said from the very start (a few years ago) that ATC will need some training to be able to work with this, because it really breaks the existing system.
It is the ban on sids and stars which is the biggest issue because it forces “VFR” flight a long way away from the terminal aerodrome. Obviously, what pilots will do is what non IR holders do the world over: fly “VFR” in IMC. Hence my frequent comment: the EIR will be a brilliant privilege for “clever” VFR pilots, who know how to play the game.
Re TAFs, I don’t think this makes legal sense because unless the law actually uses that word you cannot make an interpretation based on a specific weather service. It’s like saying you have to fly with a particular brand of printed or electronic chart.
The UK F215 is almost completely useless.
That is an interesting point.
Obviously, the phrase
The flight may be planned only to aerodromes for which such meteorological information is available
does not specify the format of the meteorological information that shall be available. It does not prescribe a TAF and that’s not how I would interpret it.
OTOH, what is
any cloud base and visibility forecast for the destination area
I think this should need to be judged on a case-by-case basis.
Let’s assume a wider area around my destination is CAVOK the entire day (GAFOR all open, in Germany e.g.). Though obviously I might have exptected some IMC enroute, otherwise this would be a VFR flight to begin with (how realistic or not this is has been debated elsewhere). In that case, I would think a TAF for the destination aerodrome is not required to make a sound judgement that my destination is in VMC at my planned time of arrival and one hour before/after.
Similarly, my home base is 9 NM from EDDL with full METAR and TAF. Oviously, I use this regularly for my VFR flight planning. Were I an E-IR holder, I’d do the same. I would probably not file a flight to EDDL and then divert on a regular basis to EDLE. If somebody questioned by weather planning, I would make a reference to the close proximity of the two aerodromes.
OTOH, I can imagine conditions where a wider area forecast is not specific enough to be confident about the conditions at my destination for the two-hour range that I’m looking at. It has been shown before how bad it can be locally, even if the GAFOR area is open. I’ve had this myself recently on a flight to Koblenz, where the morning fog hadn’t cleared locally as quickly as it had for the rest of the GAFOR area. I phoned Koblenz a dozen of times to verify their conditions before I set out to fly there.
In such cases, I would say an E-IR flight should not be planned if a TAF is not available.
I would say an E-IR flight should not be planned if a TAF is not available.
I would say a VFR flight should not be planned if a TAF is not available
So, the EIR gives you a no-questions-asked passage through CAS (the biggest issue in Europe’s perverted airspace system, by far) and then you have to, ahem, “get imaginative” at the two ends.
Just like VFR, really
I would say a VFR flight should not be planned if a TAF is not available
Fair enough – but: To stick to my Koblenz example. VFR, this is what happened: I was setup and ready for departure at EDLE and kept calling the “Flugleiter” until he told me the local fog had cleared. I then took off for the 40 minute flight, based on that information and the generally favorable outlook for the rest of the day.
E-IR – demanding me to have information indicating VMC +/- 1 hour of the planned arrival… Works about ok in this case. I may have had to wait another 20 minutes to ensure that it’s been VMC for an hour in the past.
But then I see the E-IR as something I’d use for longer distance flights anyway, not for the burger (bifteki) hop. In that case, calling the destination to query current conditions isn’t going to be enough.
So, the EIR gives you a no-questions-asked passage through CAS (the biggest issue in Europe’s perverted airspace system, by far)
I couldn’t care less – with respect to the countries in scope I’ve flown in so far…
I agree, this is unsinnig Some months ago there was an article about this in Flynytt, and the writer pointed out the same fuzzy problem with no obvious solution, without applying some “creativity”.
However, she continued further, and applied the rules to a typical Norwegian coastal airport. In effect, the only way to do it, was to set the transition point far out into the sea and continue from there VFR. Navigating the same way they did on the old days without precision nav instruments. Yet, leaving the TAF problem unresolved and more or less irrelevant.
I don’t know. The EIR enables en route IR flight, and the intention was most probably not to make substitute for " full" IFR. Like the Norwegian CAA said. They thought it was totally impractical, but if it would give pilots the possibility and needed training to get out of problems in bad weather.
You can replace that TAF with a METAR with trend. As the trends are 2hrs you can fly to an airport with a METAR with trend only if it is 1hr away.
This would cover 99% of the bacon butty runs.