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Please don't invent problems where there aren't any - as far as I am concerned, the CAA has played a blinder with the IR(R), effectively NOTHING relevant changes for IMCR holders. It took a bit long, but it looks like it was all a game of "Chicken", and EASA blinked first. The only remainig questions are what happens in 2014, and what are the revalidation requirements for UK CPL holders with "implied" IMCR privileges.
Of course non-IR holders can fly in accordance with IFR whenever they want to! Or are you saying than now they MUST NOT fly above 1,000ft over the highest obstacle within 5 NM, but have to stay below, because otherwise they would fly in accordance with IFR, which is prohibited?
Or that the use of the quadrantal rule is prohibited? Because that's what the Instrument Flight Rules are.
What the EASA regs, badly worded as they are, actually mean in practice is that you need an IR or IR (R)
- in IMC, since you MUST fly IFR
- in CAS under an IFR ATC clearance
So in reality, the only thing being taken away is that a basic PPL holder in a zone transit can no longer get a "cross at..." IFR-in-VMC clearance through a CTR, but only a "cross not above..." VFR clearance. And the CAA can change that, too. Hardly a problem.
EASA is bad enough - with new ratings to blow your nose in the cockpit, taking away "common sense" AMC granted previously by the CAA, and serious drafting errors such as the 6 hour ME for CPL requirement even for a SE CPL, or CRE privileges that cannot be exercises because the underlying CRI rating does not exist...
Of course non-IR holders can fly in accordance with IFR whenever they want to! Or are you saying than now they MUST NOT fly above 1,000ft over the highest obstacle within 5 NM, but have to stay below, because otherwise they would fly in accordance with IFR, which is prohibited?
Or that the use of the quadrantal rule is prohibited? Because that's what the Instrument Flight Rules are.What the EASA regs, badly worded as they are, actually mean in practice is that you need an IR or IR (R)
- in IMC, since you MUST fly IFR
- in CAS under an IFR ATC clearance
So in reality, the only thing being taken away is that a basic PPL holder in a zone transit can no longer get a "cross at..." IFR-in-VMC clearance through a CTR, but only a "cross not above..." VFR clearance. And the CAA can change that, too. Hardly a problem.
EASA is bad enough - with new ratings to blow your nose in the cockpit, taking away "common sense" AMC granted previously by the CAA, and serious drafting errors such as the 6 hour ME for CPL requirement even for a SE CPL, or CRE privileges that cannot be exercises because the underlying CRI rating does not exist...
Beagle - You really must control these knee-jerk reactions, they are not good for you. I have read both documents carefully and there is nothing in either that changes the requirement of FCL.600 that a pilot must hold an IR in order to fly under IFR. The fact is that the IMCr will be entered into a Part-FCL licence as an IR (albeit restricted) and so the holder will meet the requirements for flight under IFR, the basic law is not changed.
CAP 804 makes the requirement absolutely clear, stating, in Section 4 Part G, Subpart 1 at the top of Page 2 "Operations under IFR on an aeroplane shall only be conducted by holders of a PPL, CPL, MPL and ATPL with an IR on aeroplanes or when undergoing skill testing or dual instruction." Thus my answer to the first part of dobbin1's question (which was the only part that I addressed) was absolutely correct. Where is the obfuscation?
CAP 804 makes the requirement absolutely clear, stating, in Section 4 Part G, Subpart 1 at the top of Page 2 "Operations under IFR on an aeroplane shall only be conducted by holders of a PPL, CPL, MPL and ATPL with an IR on aeroplanes or when undergoing skill testing or dual instruction." Thus my answer to the first part of dobbin1's question (which was the only part that I addressed) was absolutely correct. Where is the obfuscation?
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BillieBob, perhaps my previous post was a bit convoluted.
Yes, your statement is technically correct. An IR [restricted=IMCR or otherwise] required to fly IFR.
But in practice, this makes no difference - except for the above mentioned IFR-in-VMC clearance into Class D, there is NOTHING that a non-IR PPL/CPL holder can no longer do under EASA, thanks to the introduction of "Night VFR", which are almost identical to IFR.
Actually, the PPL limitations for flight visibility are gone, so a PPL can now fly VFR in lower visibility than pre-EASA.
Yes, your statement is technically correct. An IR [restricted=IMCR or otherwise] required to fly IFR.
But in practice, this makes no difference - except for the above mentioned IFR-in-VMC clearance into Class D, there is NOTHING that a non-IR PPL/CPL holder can no longer do under EASA, thanks to the introduction of "Night VFR", which are almost identical to IFR.
Actually, the PPL limitations for flight visibility are gone, so a PPL can now fly VFR in lower visibility than pre-EASA.
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BillieBob, your usual excuse for confusing everyone with your blinkered, individual views just wastes everyones' time.
The CAA has worked well to negotiate a pragmatic solution for the period extending to Apr 2014, yet all you can do is to spread doubt and gloom
Please just stop your pointless negativity - it helps no-one.
I have to agree with earier comments made by bose-x....
The CAA has worked well to negotiate a pragmatic solution for the period extending to Apr 2014, yet all you can do is to spread doubt and gloom
Please just stop your pointless negativity - it helps no-one.
I have to agree with earier comments made by bose-x....
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PPL Instrument Rating
Gentlemen
Apologies for being a little dim, but could someone clarify the situation regarding the proposed replacement rating for the IMC?
I realise that there is both concern and confusion regarding the status and ongoing validity of the UK IMC rating, but is the proposed replacement in the form of a Eurpean PPL poor weather rating in place yet?
When I read the early proposals for this rating, split as it was into two parts, I thought it looked quite sensible.
Or am I in a minority of one?
Apologies for being a little dim, but could someone clarify the situation regarding the proposed replacement rating for the IMC?
I realise that there is both concern and confusion regarding the status and ongoing validity of the UK IMC rating, but is the proposed replacement in the form of a Eurpean PPL poor weather rating in place yet?
When I read the early proposals for this rating, split as it was into two parts, I thought it looked quite sensible.
Or am I in a minority of one?
The FCL.008 rulemaking task came up with two proposals, one a competence-based modular IR (in short, a route to a full-privileges IR with a lot of the unreasonable stuff removed) and the other an Enroute IR. To be pedantic, neither was a "proposed replacement rating for the IMC", which is why BEagle's efforts with regard to the IMC rating are so important.
The next step for those is that EASA publishes a Comment Response Document incorporating a draft with any changes as a result of the comments from consultation (which, as far as I understand, went quite well). You then get a month or two to send a reaction to the CRD (send a nice supportive one!) and then EASA will publish an Opinion. It then moves out of EASA's hands, and typically takes about a year to become law if all goes smoothly. So realistically we're looking at Autumn 2013 before Part-FCL includes those ratings.
The next step for those is that EASA publishes a Comment Response Document incorporating a draft with any changes as a result of the comments from consultation (which, as far as I understand, went quite well). You then get a month or two to send a reaction to the CRD (send a nice supportive one!) and then EASA will publish an Opinion. It then moves out of EASA's hands, and typically takes about a year to become law if all goes smoothly. So realistically we're looking at Autumn 2013 before Part-FCL includes those ratings.
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PPL Instrument Rating
Thank you bookworm, that was very informative.
Might I press you further and ask you to clarify what exactly was proposed?
Again, at the risk of alienating the whole forum, my understanding was that there was to be a simpler 'en route' rating allowing PPLs to retain control of their aircraft whilst travelling from one VMC airfield to another, and then a higher standard 'proper' instrument rating which would allow take offs, landings etc in IMC conditions.
If I am correct, and the IMC rating is destined to remain a 'UK only' use, surely IMC holders would have little difficulty in attaining the lower 'en route' IR rating enabling them greater freedom in returning from say, a French trip' to a UK based field.
For my part, as a fairly 'average' PPL, I have resisted the challenge of an IMC rating but would welcome the 'en route IR' rating as a way of improving my safety margins whilst in flight but avoiding the complexity of instrument approaches etc. I would not, in all honesty, conduct a flight where the weather conditions at my destination had not been checked as VMC, but I could envisage a situation where en route weather proved to be not as forecast and required a limited period of 'straight and level' to regain VMC.
In short, is the new proposal for an 'en route' IR qualification to be seen in a positive light?
Might I press you further and ask you to clarify what exactly was proposed?
Again, at the risk of alienating the whole forum, my understanding was that there was to be a simpler 'en route' rating allowing PPLs to retain control of their aircraft whilst travelling from one VMC airfield to another, and then a higher standard 'proper' instrument rating which would allow take offs, landings etc in IMC conditions.
If I am correct, and the IMC rating is destined to remain a 'UK only' use, surely IMC holders would have little difficulty in attaining the lower 'en route' IR rating enabling them greater freedom in returning from say, a French trip' to a UK based field.
For my part, as a fairly 'average' PPL, I have resisted the challenge of an IMC rating but would welcome the 'en route IR' rating as a way of improving my safety margins whilst in flight but avoiding the complexity of instrument approaches etc. I would not, in all honesty, conduct a flight where the weather conditions at my destination had not been checked as VMC, but I could envisage a situation where en route weather proved to be not as forecast and required a limited period of 'straight and level' to regain VMC.
In short, is the new proposal for an 'en route' IR qualification to be seen in a positive light?
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I cannot answer for Bookworm who supplies an amazing amount of factual detail.
As things look if you can carry on with the IMCR privalages in the Uk and also have an EIR which allows you to fly in CAS within the Uk you will be in the better position of literally having an IR.
With my level of experience I am cautious of allowing people like yourself to as you put it fly straight and level to a VMC destination without proper approach capability.
The amount of times I have flown UK to the south of France to a VMC destination are many. Often the cloud tops rise, the cloud type changes, climbing puts you into icing !
Often with good VMC at destination doesn't mean it's good VMC 20 miles away where you are dumped out of CAS.
Often the airfields you fly over in blind bliss on top can be giving 200 overcast below.
Fine as long as no situation arises where you are forced to land with no solid instrument ability to minima.
For more experienced Pilots it's a workable option but one to use with maximum caution.
Pace
I cannot answer for Bookworm who supplies an amazing amount of factual detail.
As things look if you can carry on with the IMCR privalages in the Uk and also have an EIR which allows you to fly in CAS within the Uk you will be in the better position of literally having an IR.
With my level of experience I am cautious of allowing people like yourself to as you put it fly straight and level to a VMC destination without proper approach capability.
The amount of times I have flown UK to the south of France to a VMC destination are many. Often the cloud tops rise, the cloud type changes, climbing puts you into icing !
Often with good VMC at destination doesn't mean it's good VMC 20 miles away where you are dumped out of CAS.
Often the airfields you fly over in blind bliss on top can be giving 200 overcast below.
Fine as long as no situation arises where you are forced to land with no solid instrument ability to minima.
For more experienced Pilots it's a workable option but one to use with maximum caution.
Pace
The proposal is here, though in some places it needs to be read alongside the bits of Part-FCL that are changed.
That's a fairly good summary, but bear in mind that enroute IFR is often a great deal more than "retaining control of the aircraft". It's about understanding how to plan and execute such a flight, and work with ATC as required. None of it is particularly hard, but like many things in flying it needs thought and familiarity to do it right.
The differences between the EIR and the IR are only the skills/privileges to fly approaches and the total instrument flying experience (because ICAO insists on 40 hours instrument time for an IR). The theoretical knowledge exams and revalidation regimes are identical (the EIR test just omits the approaches).
The EIR was created to offer a stepping-stone to the IR -- to offer some operational experience to the student before they had met the 40 hours IF requirement, a bit like the student solo in a PPL course.
An IMC rating holder knows how to fly approaches and by the end of an EIR course would probably have 40 hours IF (15 hours for the IMC rating, 15 for the EIR plus a bit of operational IF). So although I've seen it proposed in a number of places, I don't really see why an IMC rating holder would want to do an EIR rather than an IR.
Instrument approaches are really not very complex, particularly in these days of GPS approaches. Learn the basic skills, practise, stay current. By all means set personal minima for yourself that reflect your capabilities, but I hope that one you got into instrument flying you'd find flying approaches to be reasonably straightforward, operationally useful and very satisfying.
I strongly believe so, yes, though personally I would rather see it as a means to an end than an end in itself.
Again, at the risk of alienating the whole forum, my understanding was that there was to be a simpler 'en route' rating allowing PPLs to retain control of their aircraft whilst travelling from one VMC airfield to another, and then a higher standard 'proper' instrument rating which would allow take offs, landings etc in IMC conditions.
If I am correct, and the IMC rating is destined to remain a 'UK only' use, surely IMC holders would have little difficulty in attaining the lower 'en route' IR rating enabling them greater freedom in returning from say, a French trip' to a UK based field.
The EIR was created to offer a stepping-stone to the IR -- to offer some operational experience to the student before they had met the 40 hours IF requirement, a bit like the student solo in a PPL course.
An IMC rating holder knows how to fly approaches and by the end of an EIR course would probably have 40 hours IF (15 hours for the IMC rating, 15 for the EIR plus a bit of operational IF). So although I've seen it proposed in a number of places, I don't really see why an IMC rating holder would want to do an EIR rather than an IR.
For my part, as a fairly 'average' PPL, I have resisted the challenge of an IMC rating but would welcome the 'en route IR' rating as a way of improving my safety margins whilst in flight but avoiding the complexity of instrument approaches etc. I would not, in all honesty, conduct a flight where the weather conditions at my destination had not been checked as VMC, but I could envisage a situation where en route weather proved to be not as forecast and required a limited period of 'straight and level' to regain VMC.
In short, is the new proposal for an 'en route' IR qualification to be seen in a positive light?
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For my part, as a fairly 'average' PPL, I have resisted the challenge of an IMC rating
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Thank you, I have had the chance to read through the EASA proposals.
I may be in a minority of one, but it looks very sensible to me and something I would like to pursue if and when it becomes available.
I may be in a minority of one, but it looks very sensible to me and something I would like to pursue if and when it becomes available.
Thread Starter
EIR THEORETICAL KNOWLEDGE
The only aspect of the EIR which may well prove disappointing to many would be the theoretical knowledge requirement. Although this is around 60% of the current gold-plated IR requirement and is the same as the C-B IR requirement, it seems somewhat disproportionate for a rating which merely adds en-route IFR privileges to a VFR-only licence.
With IFR privileges restricted to the en-route phase only, recovering to a Class D aerodrome will require good weather or some form of SVFR clearance...
With IFR privileges restricted to the en-route phase only, recovering to a Class D aerodrome will require good weather or some form of SVFR clearance...
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Apologies if this has been answered or clarified before!
As I understand it, the 'old' non-JAR-FCL UK CPL(A) conferred an implied IMC rating, plus the ability to fly to lower limits than 3km / 1800m. Reading the (now-defunct) LASORS, under JAR-FCL CPL(A), this automatic 'inclusion' of an IMCR appeared to have been removed. The EASA part-FCL bits on CPL(A), understandably, contains no mention of such things.
If one were to obtain a part-FCL CPL(A) (without IR), would one therefore need to seperately add an IMCR / IR(R) to said licence, as you would to a PPL?
As I understand it, the 'old' non-JAR-FCL UK CPL(A) conferred an implied IMC rating, plus the ability to fly to lower limits than 3km / 1800m. Reading the (now-defunct) LASORS, under JAR-FCL CPL(A), this automatic 'inclusion' of an IMCR appeared to have been removed. The EASA part-FCL bits on CPL(A), understandably, contains no mention of such things.
If one were to obtain a part-FCL CPL(A) (without IR), would one therefore need to seperately add an IMCR / IR(R) to said licence, as you would to a PPL?
Thread Starter
If one were to obtain a part-FCL CPL(A) (without IR), would one therefore need to seperately add an IMCR / IR(R) to said licence, as you would to a PPL?
However, I understand that if an existing UK (non-JAR-FCL) CPL(A) is converted to a part-FCL CPL(A) before 8 Apr 2014, an IR(R) will be included in the new licence (but will then be subject to normal revalidation / renewal requirements).
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Reading the CAA's revised statement on the IMCr from last month;
http://www.caa.co.uk/docs/2330/Revis...2012%20_v3.pdf
It won't let me copy an extract, but in para. 2, it says that an IR(R) on a Part-FCL licence "grandfathered" from an IMCr before 8th April 2014, "...shall be subject to the same revalidation and renewal requirements that apply to the UK IMCr
The renewal requirements that currently apply to a (pre-JAA) UK CPL/ATPL holder with embedded IMCr privileges are .... none. So, my interpretation of their statement would be that, when I apply for a Part-FCL CPL with IR(R), the renewal requirements will remain the same as they were with the UK CPL, nothing.
http://www.caa.co.uk/docs/2330/Revis...2012%20_v3.pdf
It won't let me copy an extract, but in para. 2, it says that an IR(R) on a Part-FCL licence "grandfathered" from an IMCr before 8th April 2014, "...shall be subject to the same revalidation and renewal requirements that apply to the UK IMCr
The renewal requirements that currently apply to a (pre-JAA) UK CPL/ATPL holder with embedded IMCr privileges are .... none. So, my interpretation of their statement would be that, when I apply for a Part-FCL CPL with IR(R), the renewal requirements will remain the same as they were with the UK CPL, nothing.
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CPL - IMCR revalidation
As a holder of a UK CPL I understand that I had an 'embedded' IMCr. I use my UK CPL with a SEP rating and a FI rating. Now, I understood that strictly speaking I didn't need to re-validate my IMCr separately in order to maintain IMCr privileges BUT what with all the EASA uncertainties I thought that it was prudent to do so. Now, like all SEP holders, I need to re-validate it every 2 years so this year I chose to use the time re-validating my IMCr. Peace of mind, I think and also a useful brush-up with an IMC examiner rather than a less useful hour.
Just a personal view...
The Odd One
Just a personal view...
The Odd One
Thread Starter
mrmum, not so!
Once you have an IR(R) in your part-FCL licence, it is a 'rating', not merely a set of 'privileges'. Hence you will need to revalidate it accordingly.
Be grateful that you're actually getting a 'free' IR(R) initial issue!
Once you have an IR(R) in your part-FCL licence, it is a 'rating', not merely a set of 'privileges'. Hence you will need to revalidate it accordingly.
Be grateful that you're actually getting a 'free' IR(R) initial issue!
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Ah, okay I see what you mean. I just don't know how grateful I can be to the CAA/EASA, for only making my life a little more awkward and expensive. However, I do know it could have been much worse and there are some individuals and organisations, whose efforts we should all be genuinely appreciative of.
Am I correct in thinking then, that in addition to a Part-FCL CPL/IR(R), which I'll have to renew every 25 months. I can still keep my pre-JAA UK CPL with non-expiring, embedded privileges, for use on annex 2 aircraft?
Am I correct in thinking then, that in addition to a Part-FCL CPL/IR(R), which I'll have to renew every 25 months. I can still keep my pre-JAA UK CPL with non-expiring, embedded privileges, for use on annex 2 aircraft?
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There are ratings that require no revalidation - for example the "Night Rating" [yes, it is now a Night Rating, not a Night Qualification anymore...].
It depends on what the UK CAA want to do. Up to 2014 it is within their powers to issue an IR(R) with no revalidation requirement. Considering that the first time they will actually issue that IR(R) to CAA CPL holders in September 2012, you could just wait and see what they print as expiry date on the revalidation pages...
It depends on what the UK CAA want to do. Up to 2014 it is within their powers to issue an IR(R) with no revalidation requirement. Considering that the first time they will actually issue that IR(R) to CAA CPL holders in September 2012, you could just wait and see what they print as expiry date on the revalidation pages...