mktime wrote:
French DGAC ask to have 50h PIC time to convert CBIR with a flight test, so seems instruction time do not count ?
Under FAA regulations PIC time is anytime the pilot is operating the aircraft by sole reference to instruments. It can be logged anytime after the PPL has been passed. In other words, one does not need an instrument rating to log PIC time. Simulator time is also logged as PIC time. The pilot acting as PIC for the flight is something different, and as mentioned above that person needs to have an instrument rating if the flight is operated under instrument flight rules or in IMC. That person can also log PIC time, but it may or may not be instrument time, depending upon the flight conditions. A safety pilot for a VFR flight can log PIC time, but not instrument time. The pilot flying under the hood on such a flight can log instrument PIC time, whether he/she has an instrument licence or not as long as he/she has a PPL.
What would be EASA justification for refusing to recognize FAA IR dual (training) hours? The pilot trainee is fully authorized and expected to log any of that time at the controls in IMC or under the hood as instrument PIC time. Can anyone point me to EASA regulations that would prohibit this?
The above FAA regulations notwithstanding, what do the French DGAC want to see for “PIC time”?
My understanding is that EASA regulations don’t use “instrument” time, and refer instead to “IFR” time. And I have been told by several instructors that EASA definition of IFR time is time on an IFR flight plan and that this is commonly interpreted to mean from off-block to on-block. So anyone flying IFR in Europe, either on an FAA IR licence (i.e. N-reg) or an EASA EIR licence could build “IFR” time much quicker using block time for flights on IFR flight plans, compared to only counting instrument time, which is much less. One just needs to take a two week trip in a C172 from the UK to the Black Sea, Greece, or up to Northcap and back on IFR flight plans and one has at least 30hr IFR time.
Part FCL, p.1211:
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 think they ask for 8(c) – 50hrs of PIC IFR, after earning ICAO IR.
I’ve used my IR(R) to get to the 50.
I guess the intent of this when they mean PIC is hours without an instructor on board, no it seems relatively natural that hours done with an instructor on board don’t count, regardless of what the intitial states calls them
The credit wording did use “instrument time” some years ago, which made it very punitive because accumulation of (even remotely genuine) instrument time is very slow, under IFR, where most flight is VMC on top. However, instrument time has its own problem in that it is unverifiable and thus easy to fake in the logbook.
Then it was changed to “IFR time”. Many people thought this was a gift from heaven, especially as a UK PPL could log IFR time in VMC, just by flying in accordance with IFR 
I am told the IFR time proposal came from a committee member from a particular country who could not understand how anybody could fly IFR in Class G.
Ultimately the intent behind the reg is to prevent large numbers of young airline pilot candidates going to say Arizona and doing a PPL/IR, then coming back to Europe and convert the IR, and knock off the EASA CPL (which is easy), and sit the 14 exams (which is not too bad if you are young and keen) and end up with a “frozen ATPL” for a fraction of the cost.
That would have destroyed the business over here.
@mktime, you surely have more than 34 hours of instrument time under instruction to have attempted a flight test. A Part 141 course requires 35 hours of instrument training and even that isn’t strictly ICAO Annex 1-compliant.
The competency-based modular training course for the Part-FCL IR does not amount to a conversion. The conversion of a third-country IR is addressed by the Aircrew Regulation, art 8, paras 2 and 3:
2. Applicants for Part-FCL licences already holding at least an
equivalent licence, rating or certificate issued in accordance with
Annex 1 to the Chicago Convention by a third country shall comply
with all the requirements of Annex I to this Regulation, except that the
requirements of course duration, number of lessons and specific training
hours may be reduced.
3. The credit given to the applicant shall be determined by the
Member State to which the pilot applies on the basis of a recommen-
dation from an approved training organisation.
Where UK CAA is the competent authority for example an alternative means of compliance with these is given in UK CAP 1721, p 8. A conversion of this kind is likely uninteresting to third-country IR holders who, on accumulating a mere 50 hours under the instrument flight rules while acting as pilot-in-command, may take advantage of the competency-based course credits to escape the theory courses and exams. If the theory course and exams are palatable then you could, instead of having the 50 hours, find such a conversion more favourable than a competency-based modular training course. The UK AltMoC only requires, say, 10 hours under instruction in an FNPT II, and 5 hours in flight, at an ATO. Or fewer if an HoT recommendation is accepted by the competent authority.
On a minor couple of points. The requirement for a flight review, or a substitute activity, under 14 CFR 61.56 need not be met in order to log pilot-in-command instrument time for US purposes. Your flight test for the US IR is pilot-in-command time because you acted as pilot in command and should interpreted accordingly for Aircrew Regulation purposes. The status of the examiner is addressed in the preamble to the final rule in 30 FR 8515 (03 Jul 1965) (link).
@chflyer, that’s an excellent summary of US logging rules. The condition on holding a PPL can be relaxed: sport and recreational pilot certificate holders also count. A safety pilot on a flight under the visual flight rules may log instrument flight time during actual instrument conditions. It’s a rare exception but one recognised in an interpretation from John H Cassady, acting as Assistant Chief Counsel, Regulations and Enforcement Division, given 7 Nov 1984 to Joseph Carr.
The Aircrew Regulation makes a clear distinction between instrument time and flight time under the instrument flight rules. The interpretations are given in FCL.010 of Part-FCL.
What would be EASA justification for refusing to recognize FAA IR dual (training) hours? The pilot trainee is fully authorized and expected to log any of that time at the controls in IMC or under the hood as instrument PIC time. Can anyone point me to EASA regulations that would prohibit this?
The Aircrew Regulation leaves the manner of recording flight time to be determined by the competent authorities. There is a clear congruency of duties and responsibilities attributed to a pilot-in-command whether relying on national regulations, administrative law judge findings, or international standards. In spite of this US regulations allow a lack of equivalence between capacity and role. Europe owes no apology for that perversion. The flying training requirements for acquiring an IR under the competency-based course accept instrument flight time gained under instruction, from other than a Part-FCL IRI or FI with IR-training privileges. Less obvious examples include instrument flight instruction received from the holder of a Canadian CPL which confers flight instruction privileges.
Peter wrote:
Then it was changed to “IFR time”. Many people thought this was a gift from heaven, especially as a UK PPL could log IFR time in VMC, just by flying in accordance with IFR I am told the IFR time proposal came from a committee member from a particular country who could not understand how anybody could fly IFR in Class G.
I’m not so sure. Sweden has “always” used “IFR time” (at least it did already in 1987 when I first got my IR). At the same time Sweden is one of the countries where IFR in class G has “always” been practised even for CAT.
@mktime.
Here is what happened to me in October 2018.
The DGAC required 50h PIC IFR meaning under IFR flight plan. Doesn’t have to be IMC or logged as Instrument per FAA rules.
Your ICAO/FAA IR must be current.
If you meet the requirements, you send your application to the DGAC in Paris, get it approved then the skill test. No ATO has to be involved.
Once you passed the test, send all documents back to the DGAC in Paris and you will receive your licence with an IR on it (10 days).
Note:
- Be smarter than me and get your PBN training done with an ATO BEFORE the skill test. if you don’t have the training completion certificate before the skill test, the examiner won’t give you the PBN privileges. you wouldn’t be able to flight RNAV during IFR operation. bummer! if you don’t do the PBN before 2020, your IR altogether will be invalid.
- Having no IFR experience in Europe, I did some IFR flying in my club with a certified instructor and prepare for the test the day before with an FAA/DGAC certified instructor (sim).
Emmanuel
Thanks Emmanuel for this information.
About PBN training, as my FAA IR is recent, i did all the training using RNAV, we did also Localiser, ILS for sure. What we didn’t do is NDB as it’s not on the FAA program anymore.
So i don’t know what i will learn more in a european ATO training PBN RNAV theory ?
You were not familiar with RNAV before with FAA IR ?
Mickael
One thing more on logging time / PIC time.
Those rules in the FARs about logging time only apply to how time has to be logged for the purpose of FAR licencing, nothing else.
For the EASA rules, only time where you are the actual pilot-in-command of the aircraft counts, because EASA sets the rules which hours are permissible for EASA licences, in the same way the FAA defines what gets recognised for FAA licences.
There are other differences between EASA and FAA, for example, what counts as “cross country” time. Any FAA examiner will check the minimum distance requirements are met, while in EASA-land, no minimum distance for a cross country flight is required.
