Primarily for general aviation discussion, but other aviation topics are also welcome.
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By Timothy
#744138
1. FCL 008
As a reminder, FCL008 is the EASA Working Group formed late in 2008 to review 3 elements of the EASA FCL NPA which, it was felt, were not fully addressed in the time available to the original FCL Working Group. These topics were:
  1. The training process and requirements for the full EASA IR
  2. The possibility of a sub-IR IMC flying qualification (analogous to the UK IMCr)
  3. The issue of Glider flying in IMC

FCL008 is a small “Industry” group, and includes 3 members from European NAAs (including one from the UK CAA), 3 from Europe Air Sports (including the ex-Chairman of PPL/IR Europe, Jim Thorpe) and 1 from AOPA (the CEO of AOPA Germany) and Jim has also had the support and assistance of AOPA UK in the process.

2. PPL/IR Europe’s Input
Jim Thorpe has led a significant body of work from PPL/IR on topics 1 and 2 above, that many Exec Committee and other members have contributed to. It has involved an analysis of all the ICAO, FAA, JAA and UK IMCr training regimes and options for each of the regulatory elements. It has included a review of every one of many hundreds of line items in the JAA Theory learning objectives. We produced a detailed set of proposals, including the drafting of how they could be incorporated in the FCL NPA.

3. The outcome so far
The process has proved to be a very positive one to date. Although each stakeholder holds their own views on specifics, there has been a very welcome consensus around the key principle that IFR qualifications for European PPLs should be much more accessible and practical. In essence, the PPL/IR proposals have been adopted in full. Of course, there are very many steps left in the process:
  • EASA FCL008 has to produce its final report by the end of 2009
  • This has to be accepted by EASA and published as an FCL NPA amendment
  • This NPA is then subject to consultation and a final EASA redrafting
  • The EASA document then enters the whole EU review process before it becomes law
Therefore the outcome to date is not practically meaningful yet and items 4 and 5 below are only of interest as a draft of work in progress, but a draft that could be very materially re-drafted throughout this process.

4. Draft Proposals for the IR

FCL008 has adopted a much more “competency-based” approach to IR Flight Training, and has adopted a significantly slimmed down version of the Theoretical Knowledge (TK). In both cases, there is no lowering of standards. The TK syllabus work has simply eliminated content not specifically relevant to the privileges granted by the IR. The competency-based training process does not change the high standards of the IR Flight Test – these remain the same for all (private and ATPL) IR candidates. The key change is that instead of requiring a single, contiguous course of 50-55hrs with an Approved FTO, the minimum for such a course will be approximately 15hrs for candidates who have built up IFR training and flight experience through a variety of other methods.

5. Draft Proposals for a “Enroute Instrument Rating” (EIR)
The UK IMCr is based on “Airspace Restrictions”: it’s privileges cannot be exercised in Class A. This is contrary to EASA principles – EASA want to avoid individual countries using airspace design as a means of modifying EASA FCL privileges. Therefore, the qualification has to be based on License Restrictions. The proposal is that the EIR should permit enroute IFR in all classes of airspace, but that departures and arrivals must be VFR – based both on actual conditions and TAF planning minima. This is a reversal, to an extent, of the IMCr privileges; but, combined with the option of a more accessible IR, we think it should be effective. The necessity for a full IR in order to depart and arrive in IMC has a positive element we should welcome: EASA does not favour the denial of airports and airspace to private GA through a combination of pricing and Class A which is the only thing that makes IMCr privileges “acceptable” in the UK.
User avatar
By mmcp42
#744141
the EIR looks very similar to the Australian scheme
you start with the En-Route rating
then can move on by adding departures/arrivals (Command I think they call it)
User avatar
By Timothy
#744199
We did consider the situation in Australia (as well as in many other administrations) very carefully before reaching a proposal.
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By Katamarino
#744318
So this new rating would be no use if your destination or departure aerodromes are below VFR minima?

Or maybe I misunderstand; will there be two new Instrument ratings; a more attainable IR which enables full IR privileges, *and* the EIR?
User avatar
By Timothy
#744321
Exactly, there would be two ratings:

  1. A full ICAO IR with all the current privileges allowing the holder to fly in any airspace to legal minima anywhere in the world. The current requirements for unnecessary Theoretical Knowledge, compulsory attendance on courses and 55 hours training are replaced by a competency based system, allowing current skills to be taken into account, and quite low minimum hours.
  2. A brand new, non-ICAO, rating which allows the holder to fly in any airspace in Europe under IFR, but which does not allow approaches.
By Colonel Panic
#744382
Timothy wrote:Exactly, there would be two ratings:

Will these be valid with a non-Euroland registration?
By mm_flynn
#744452
Colonel Panic wrote:Will these be valid with a non-Euroland registration?

As usual that will depend on the laws of the non-Euro state of registry. It would be a little surprising if EASA chose to limit the validaty of a licence to certain registrations rather than certain geographies.
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By CaptChaos
#744469
Timothy, thanks for the update. In the discussions, was anything said about revalidating expire IRs? I ask becasue currently I would have to resit all the CPL theory exams and retrain with an FTO (not sure what time minimum). I wonder if this progresses as you expect, would it still be mandatory 15 hrs flight training as a new trainee or any dispensation i.e. sufficient to standards?
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By Timothy
#744515
CaptChaos wrote:Timothy, thanks for the update. In the discussions, was anything said about revalidating expire IRs? I ask becasue currently I would have to resit all the CPL theory exams and retrain with an FTO (not sure what time minimum). I wonder if this progresses as you expect, would it still be mandatory 15 hrs flight training as a new trainee or any dispensation i.e. sufficient to standards?

I'd be very surprised if any discussion has reached that level of detail.
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By KNT754G
#744666
CaptChaos wrote:Timothy, thanks for the update. In the discussions, was anything said about revalidating expire IRs? I ask becasue currently I would have to resit all the CPL theory exams and retrain with an FTO (not sure what time minimum). I wonder if this progresses as you expect, would it still be mandatory 15 hrs flight training as a new trainee or any dispensation i.e. sufficient to standards?

Maybe I am in pedant mode but why would you have to resit CPL exams to revalidate an IR??

do you mean resit IR exams perchance?
User avatar
By SteveC
#744670
CaptChaos wrote:Timothy, thanks for the update. In the discussions, was anything said about revalidating expire IRs? I ask becasue currently I would have to resit all the CPL theory exams and retrain with an FTO (not sure what time minimum). I wonder if this progresses as you expect, would it still be mandatory 15 hrs flight training as a new trainee or any dispensation i.e. sufficient to standards?


If you hold an IR that expired, then it appropriate training to pass the test not a minima. However I would be surprised if you managed it in less than 15 hours as for you to need to resit the exams then it is a very old IR.
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By CaptChaos
#744717
do you mean resit IR exams perchance?


Checking LASORS, you are quite correct. I am not sure how they compare to CPL writtens (the route I did it).

However I would be surprised if you managed it in less than 15 hours


I am not sure either but I had a good instructor and although it is not the same, renewing the IMC after that gap has showed the skills are not too rusty. I may well only do SEP-IR to help manage cost/time. It will be interesting to see how the FCL008 pans out.
By peterh337
#744765
So this new rating would be no use if your destination or departure aerodromes are below VFR minima?


Yes, and having been thinking about this for the last few months it isn't such a problem as may at first appear.

Basically it is a tradeoff between

1) Typical UK IMC-R usage where you (basically) are stuck low down, cannot climb VMC on top in most cases (due to Class A, or due to lack of a transit clearance of Class D) but do have the right to fly an instrument approach, but cannot do any IFR abroad, AND

2) Having full IFR privileges, on a full-IFR flight plan and therefore with the implicit IFR whole-route clearance, but needing TAFs (presumably) supporting some VFR criteria e.g. (presumably) 1hr before/after the planned arival, min 2000ft cloudbase, 5000m vis, or whatever. The FAA 1/2/3 rule for alternates comes to mind here.

Taking my long VFR trips across Europe, and the IFR ones I did later, I could have done most of them using 2). This is because being non-deiced and generally fairly conservative regarding drilling holes in weather fronts, I don't often land in conditions in which becoming visual using a descent to say 2000ft AGL would be a problem.

This is especially the case for UK pilots who tend to fly south if they go abroad, so the weather tends to get better. And back in the UK, one has the "fairly liberal" approach to VFR anyway ;)

So, overall, this is a highly novel and ground breaking approach, which I would support. The major drawback is that IMC-R holders will lose the right to fly approaches unless they do whatever becomes the full EASA IR.

Crucially the proposal does recognise the widely known FACT in European IFR flying that the IR training is way way way OTT for the enroute stuff and basically any monkey who can fly levels and headings and can work the radio well can fly in Eurocontrol airspace (and, listening to the radio while up there, evidently many do - employed by various "distant country" airlines, and sometimes they can barely work the radio ;) ). One can get ever so elitist about this "airways" stuff.

Of course the devil would be in the detail. It goes without saying that the training will have to include approaches because one cannot expect the pilot to kill himself just because the TAFs were wrong. I also think the basic module should include the right to fly an SRA - doesn't the Australian one do that?? The training will also have to cover proper IFR weather, which the IMC-R training basically washes its hands of, presumably because nobody is expected to use it to fly at FL100-150 at -10C etc. The training syllabus development will be interesting because the full JAA IR doesn't cover the "GA IFR weather strategy" subject either ;) I also think it is pretty hard to develop an adequate weather picture purely from the officially sanctioned weather data sources.
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By GrahamB
#744781
I'm still in the glass-half-empty brigade myself.

Now: I'm IMC rated and I can't go in Class A, but I can fly approaches. My aircraft needs very little expensive kit.
Future: I lose the right to fly approaches, but gain the right to fly in Class A.

Personally, at present, I will probably lose out, as looking back over my mission profile over the last few years, I've flown more approaches than I would have needed to go into Class A.

Class A would be nice, and it certainly will be nice to do legally do the intermittent IFR stuff one is tempted to undertake when on the continent, for example to get over a range of hill with a bit of cloud in the way, but overall, as an 'average' IMC holder I think I'll be worse off.

I'm still cynical though, that promises turn very empty when it comes to implementation. We are being stiffed with Part M, and I fully expect to be stiffed with this.

We don't know yet what training requirements will be dreamt up for the EIR - but it wouldn't surprise me if the innate hostility towards the IMCR is assuaged by an over-onerous training agenda for the EIR. Equally, what use are class A privileges to a PA28 driver with a Navcomm, ADF and DME if he isn't prepared to lash out another £8k plus on BRNAV kit which talks to his Mode S, when all he wan't to do is cut across a low bit of airway or TMA.

I say again, we are in a cleft stick, and the guys negotiating on our behalf need our support. I just don't think the outcome is going to be that great - even with a (slightly) more attainable IR, there'll be lots of IMCR pilots who won't go for it and they will have lost out a lot by losing the right to fly approaches.
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