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FAA IR time, and IMCR time, and whatever other time, towards "50hrs IFR PIC" for the CB-IR or BIR

After DavidC’s comment, reading a bit more the regulations (I find it quite hard to find the most up to date one, as a part-FCL google will find one from 2011 and I guess all the rest comes as amendments. Any place where one could find just the “up to date” document?)

David, I see the EASA requirements as:
8. 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.

I find the bolded statement above conflicting with the one (also from some EASA document) from my previous post (about when you should log PIC). Not trying to push my point, as not a lawyer, but just curious as to how they decide that it doesn’t count. Is it someone at the CAA doing their interpretation, or some other point I might have missed (/ not put here)

I suspect the intent was not to make the FAA IR training route too attractive ;)

From reading the regs you quoted, you might argue that time flown as PIC after you gain an IR(R) would also count. I would think this would only be in the UK and exclude any instructional flights.

But this is only my opinion and worth what you paid for it.

FlyerDavidUK, PPL & IR Instructor
EGBJ, United Kingdom

Oh, and the one place for UK regs is CAP804 – latest edition found at www.caa.co.uk/cap804

But as explained there, the latest edition is out of date and will be updated to reflect the latest UK ANO changes soon.

Last Edited by DavidC at 20 Sep 19:59
FlyerDavidUK, PPL & IR Instructor
EGBJ, United Kingdom

I interpreted this reg as IFR time (block to block time under sn IFR flight plan) after having the FAA rating.
See http://www.abeam.be/easa_ir/
I admit that i had the luxury of taking this position because I did have that time logged. My interpretation might have been different if I didn’t.

Why not asking your CAA?

Abeam the Flying Dream
EBKT, western Belgium, Belgium

DavidC wrote:

From reading the regs you quoted, you might argue that time flown as PIC after you gain an IR(R) would also count. I would think this would only be in the UK and exclude any instructional flights.

I did count some of my PIC time (done under IR(R)) for the 40 hours. I also counted the instruction from the IR(R) for the minimum 25h flight instruction, which left me only having to do 10 at an ATO (and did a bit more, my instrument flying was a bit rusty)

For sure I will ask the CAA, just wanted to sharpen my knowledge, so I know there’s no goldplating. The time I count is all flown on IFR flight plans and flown as PIC, even according to the FCL definition. I understand why EASA would try to make the FAA IR route less attractive, but it isn’t clearly reflected in the rules/AMC as far as I can tell. Thanks for the inputs.

I suspect the intent was not to make the FAA IR training route too attractive ;)

Totally and obviously so….

The IFR time as PIC requirement is there to make the FAA PPL/IR in Arizona (etc) unattractive to the average European ATPL student.

Administrator
Shoreham EGKA, United Kingdom

Clearly the FAA IR route to the CBIR works best for owners of N reg aircraft….in which case racking up 50 hours or so can be done easily in one summer….

Conspiracy theories notwithstanding, I believe the intention is that by having 50hrs of flying in the (European) IFR system you have demonstrated knowledge and experience of real-life IFR…I can see why the CAA would think that way…

Last Edited by AnthonyQ at 21 Sep 03:32
YPJT, United Arab Emirates

I can see that too. I just don’t like it from my viewpoint. ;-) Oh well, one week in the USA and I’ll have enough hours.

Conspiracy theories notwithstanding, I believe the intention is that by having 50hrs of flying in the (European) IFR system you have demonstrated knowledge and experience of real-life IFR…I can see why the CAA would think that way…

Does the reg say where you have to do those 50hrs? If it did, it might just about begin to support your assertion of a “conspiracy”.

Even if the reg said that… if somebody was starting in the USA and converting, they are hardly going to do the extra hours in Europe where the fuel costs 2x more.

There was widespread protest in the aviation media at the time from FTOs who would lose a lot of business if the conversion was easy.

On a longer historical timescale, this is also why the JAA IR had to be done in Europe. The JAA PPL and the JAA CPL could be done in the USA but by crippling the IR, very few ATPL students would break up their training, and it would never make business sense to set up a JAA ATPL (=CPL/IR) FTO out there given that everybody would have to be shipped back to Europe for the IR portion.

It is not a “conspiracy”. It is just good everyday business. I would do the same if I was running an FTO… kick up a lot of stink, preferably under the table. And so would everybody else, seeing their livelihood being affected. Not just in aviation… in any industry, the incumbent lot always kick up a stink if something threatens their business. The only difference is whether they do it openly, or under the table and using various forms of influence.

You can also rent an N-reg, BTW. No need to own one. There just aren’t many to rent because most of them are used for serious flying. The few which I have seen being rented tended to be owned by pilots who no longer flew. And you have only till April 2017 (for most people) after which flying on FAA-only papers won’t work here.

Administrator
Shoreham EGKA, United Kingdom
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