Polite discussion about EASA, the CAA, the ANO and the delights of aviation regulation.
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By T67M
FLYER Club Member  FLYER Club Member
#1553494
I've just received notification IN2017/034 from the CAA, and I have to say that it has left me somewhat confused. The notice announces changes to the licensing requirements to fly under IFR in accordance with PBN (Performance Based Navigation) after August 2018. At the moment, this notice only applies to holders of the full IR, not the IR(R), however states that it will be extended to include the IR(R) "later this year".

My understanding of the content suggests that an IR (or IR(R)) will no-longer be sufficient to fly route sectors defined in accordance with PBN without an additional endorsement on your licence - a sort of "super-IR". Since most GPS approaches (LNAV, LNAV+V, LNAV-VNAV or LPV) are defined as PBN, surely this would add yet another hurdle to adopting these approaches?

Is my interpretation correct?
By riverrock
FLYER Club Member  FLYER Club Member
#1553520
Wow - my interpretation is that an IR or EIR will no longer be valid after 25 August 2020 unless the holder has added PBN privileges, via proficiency check after either training and exam, or declaration and oral test.

As you say - IMC rating / IR(r) info will follow (perhaps missing the Enroute part of the course).
It means certified GPS will suddenly be a requirement for a lot of people, who essentially use their IR(r) as a cloud break rating - as they would no longer be able to re-validate their ratings on their own aircraft without it.
#1553554
Life is in fact a little simpler than it may appear. The requirement - following an EASA regulatory amendment that was missed first time round - is that by 2020 all IR initial/revalidation/renewal tests will have to include at least one PBN (RNP/RNAV/GNSS depending on the terminology flavour of the month!) approach as one of the 2 approaches flown on test. After 2018 any IR holder wishing to fly in PBN airspace (the UK has defined RNAV5 airspace as non-PBN, so most enroute airspace is outside the scope) or fly a PBN approach will have to have proved competency by training and testing.

Where the IR(R) is concerned, my last interaction on this with SARG covered 2 possibilities, both reasonably pragmatic. Option 1: the IR(R) is a national rating and therefore not under EASA regulation, so the Part-FCL amendment does not apply. Good in some ways, less so in others. Option 2: the IR(R) is a national rating and therefore not under EASA regulation, but the regulation is not wholly without merit, therefore a good middle ground might be to require evidence of training/testing on PBN approaches for those IR(R) holders who wish to fly one.

We are certainly struggling to get sufficient approaches in some areas of the country to meet the timescales. On the ATO side the CAA have been pretty good rolling out training and testing approvals to those with sufficient experience who have actually applied, although rather slower to promulgate the initial change. There are therefore a reasonable amount of IREs and CREs to cover the cascading of PBN through the IR world, with a bit of planning. We may just have to wait and see what happens on the IR(R) and FE side of things!
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By T67M
FLYER Club Member  FLYER Club Member
#1553577
Thanks Alan - that's a really helpful explanation. Is this sort of explanation being shared clearly with examiners at this stage? I'm just about to renew my IR(R), and pre-empting the "PBN" endorsement would be highly sensible. What additional training/qualification will the FE require (now or in the future) to issue the endorsement? I imagine many FEs are airline (training) captains already, so presumably are fully familiar with PBN approaches, and many will hold TRI or TRE ratings to use in their capacity as training captains.
#1553626
Glad someone understood it 8)! At the IR/EIR level yes, IN-2017/026 gave Examiners the early details, with the remaining caveat of not knowing what'll happen with FEs and the IR(R).

It would probably make sense for the FE requirements to align with the CRE/IRE/TRE requirements, in other words the FE must themselves hold PBN to pass it on. As you say, a number will get this automatically from airline or smaller AOC work, while others will gain it from either instructing IRs or on their own IR come reval time. Given that PBN is an ICAO concept and initiative it might be sufficient for the UK to require logbook evidence of a PBN approach flown during an IR(R) test or as a separate addon with a suitably qualified Examiner - who knows.

The major push at NAA level has been for IR/EIR holders since they fall under the regulatory purview of the 2016 PBN amendment to FCL (539/2016 for those suffering from weekend insomnia). As such, the PBN tick simply doesn't exist on the IR(R) yet - maybe never will. It would be nice to hope we'll know by the end of the year, bearing in mind the implementation for IR holders has only just been finalised, but was at the discussion stage last September!

The continued existence of the IR(R) beyond 2019 as opposed to national ratings on EASA licences dying and being replaced by the proposed EASA-wide BIR will produce a new set of discussions and arguments I suspect, perhaps another reason why it just isn't a priority to add PBN to the IR(R). There is of course nothing to stop an IR(R) holder doing PBN/RNP/GNSS training at this stage for the benefit of it anyway... Under ATO approval the theoretical aspects take me a couple of hours to go through, with practical examples using various avionics trainers for the approach aspects. Simple enough really, just a case of evolution of approaches rather than revolution.
#1553806
On the fleets I see, I'd say about 50/50 - some took the decision to dip into funds and do a fleet upgrade with GNS430/GTN650/IFD440 etc as an extra opportunity to future proof against infringements, others went with a plausible bare minimum to maintain a safe standard.

The concern about IR(R)/IMCR holders - including FI/CRI - using the rating primarily to pop up and down through layers to facilitate flights rather than the enroute IR aspects was raised at a combined industry/CAA meeting last December, so rule makers are aware!
By johnm
FLYER Club Member  FLYER Club Member
#1553814
PPL/IR have published a PBN training manual, which is extremely comprehensive. They are less sanguine than AlanC about the availability of examiners able to sign off at reval though.
#1553817
Getting Examiners qualified has been a rolling exercise since July - FCL haven't done too badly sending out new licences to those of us with existing experience in the role. The major issue cascading PBN down through all Examiners over the next year is going to be the availability of approaches. So far up here we have Blackpool, Cranfield, or Liverpool - with varying slot policies (either non-radar or radar but busy). Hawarden and Humberside are going through the approval process, Coventry were before they changed ops.

Bit by bit we might get there!