Polite discussion about EASA, the CAA, the ANO and the delights of aviation regulation.
Forum rules: Please keep it polite!
The more people appear to "answer" my points with sidelines that have no real direct relevance always makes me think (whether fair or not) "ah so you DO agree but cannot say so" .
Ps I see myself nearer to the boy in the Emperors New Clothes story than Patrick Troughton in the Excorcist. I have often said i would give up all the money I have saved on medicals if only easa were not compulsory at ppl level and voluntary, like Jar was, so Frank could voluntarily have an easa licence to fly variously registered aircraft and Easa could sort out anyone for their standards in the courses to upgrade to airways, commercial or instructing
I flew without a licence for many years, I could have flown without a medical if I hadn't had a PPL. My aircraft didn't have a G reg on it & was maintained by perfectly competent maintenance people who didn't have to satisfy all the Part-M CAMO nonsense. Then EASA came along & messed it all up at my expense.

I flew & taught aerobatics for years without an aerobatic rating because I didn't need one & didn't have a licence to put one on ant way. Then EASA comes along & insists on a rating and mandates a training syllabus so inappropriate & asinine that it's doubtful that anyone will bother. Better not get started on PMDs and the micro to PPL route. Portraying EASA as the saviour of GA is stretching facts more than a little.
"The CAA has a long track record of gold-plating regulations and being obstructive in providing sensible solutions to common problems; they even had a 'cut the red tape challenge a few years back"

Which came to nothing.

"They could have easily afforded to allow PPLs to have an IR a la the FAA but the regulatory will was never there"

Hang on. Lets cast our minds back to pre JAR and EASA. There was the 700 hours route. All that was required for an IR was training as required and test and you could do the training with anyone suitably qualified. None of this ATO stuff

'Class 2 medical sufficient for instructing anyone?'

Pre EASA/JAR you were allowed to instruct on a class 2 medical
Flyin'Dutch' wrote:BTW how many IMC holders do any IMC flying between renewals?


Legally I fly IFR exercising the privileges of my IR(R) in class G quite a lot - but then I like to fly high, and thanks to SERA, flying with 40km visibility at 3,500' under BKN042 is now classified as IMC and requires an IR(R) or better.

How often do I fly in "actual" IMC rather than "legal" IMC, say with visibility below 5km? Almost never.

That the CAA thought it needed to have a red tape challenge was probably a fair indication that they themselves know that there is too much red tape/gold plating. CBIR does not even require 700 hours. I don't recall the medical requirements for flight instruction pre-JAR, happy to go with your statement.


So N = ?
Not quite sure I understand the question, @Flyin'Dutch'. How many pilots fly in SERA IMC using an IR(R) between IR(R) renewals? Some - not all, but thanks to SERA, probably more than used to. How many pilots fly in "real" IMC using an IR(R) between IR(R) renewals? Fewer, but still non-zero.

Perhaps a more interesting question is how many "plain old vanilla PPL" non-IR(R) holders now fly in SERA IMC without the required rating? My guess (and it is just a guess) is more than the number of IR(R) holders using their rating in "real" IMC.
nickwilcock wrote:Having been the IAOPA member of RMT.0677 which developed the BIR, I read this thread with something of a wry smile...

My original concept was for 3 modules:

1. Basic IMC flying skills.
2. IFR approaches to IMCR limits.
3. En-route airways flights.

You will note that 1+2 = IR(R) and 1+3=EIR.

However, the PPL/IR member persuaded the group that:
1. IMC flying outside CAS was much more difficult than airways flying.
2. The BIR had to be nothing less than 1+2+3

I think your recollection leaves something to be desired, Nick. What the PPL/IR Europe member of the group asked you was why you felt that someone who already has the instrument flying competence to fly instrument approaches needed further training to fly IFR "on airways" (a phrase which didn't help because that is a peculiarly UK concept), and what exactly you would teach them to be qualified to do so. And when you failed to come up with a plausible answer, we settled on the BIR as it is now.

That BIR is a qualification without a minimum number of hours (unlike the IMCR) with a modern and relevant groundschool syllabus (unlike the IMCR) that is of practical use to all pilots who want to fly IFR, whatever the flying they choose to do. You know I share your frustration that the qualification will only be available with the involvement of an ATO -- indeed I wrote our joint letter on the subject to Patrick Ky imploring him to reconsider. But without a minimum level of course at an ATO, there is an opportunity to build competence outside that environment.
Flyin'Dutch', johnm, Ibra liked this
I just came across this thread and reflecting on the direction of the comments I tend to the view of "airways" vs. "simpler" OCAS IFR flying as being a rather UK specific notion that does not have the significance we have historically attributed to it.

The need to enter enroute controlled airspace (ie "airways") might seem like a big difference between the IR and the IMCR and explain why the IR would take longer to achieve competency (despite the competencies appearing similar on paper), but actually having done IMCR, FAA IR and EASA IR (in that order), I think the perception of the gap is actually generated elsewhere. A few thoughts on this:

The IMCR has always been available at RFs and indeed most GA clubs / schools offer it. Historically it could be done in less highly equipped aircraft and without the need to enter enroute CAS, there was no need for dual altimeters, FM immunity and later BRNAV etc. Generally done in simple aircraft like the PA28 or C172. No need for course approval.

The IR however (unless you go back to the 700 hour route) needed course approval and is usually done in complex twins at more 'commercial' flight schools that charge much higher rates and are not the more 'club' environment that most GA pilots would be familiar with.

I did my FAA IR in a fixed gear PA28 with 80s avionics the same as you would find in a typical UK club PA28. At the time perfectly Part 91 IFR legal in the US, but would not have been UK IFR compliant. The training details were very similar to the those of the IMCR back in the UK except that an ATC clearance had to be obtained for the flight, which was mostly in class E with class D CTRs. In terms of practicing approaches it was very similar to going in and out of class D regional airports like you might in the UK. Most of the US airspace environment (like a lot of France and Germany) is such that you can't go far under IFR without a clearance, but once you've filed and got it there's not much to it at all - most low level "airways" in France for example are class E and much above 3000 ft the sky is empty.

A FAA IR check ride is probably a bit harder to fail than perhaps 10 - 15 years ago an IR in the UK was (I say that because I have no recent experience of the UK test style) - the FAA test standard is still high but I always got the impression IR tests in the UK could be failed (or 'partialed') on quite specific things that perhaps in FAA land would just be debrief items provided the overall standard of flying was good. The CAA were also notoriously precious around the IR with ground exams at Gatwick, screens, staff examiners, £700 fees etc all adding to this perception that it was only for the commercial or well heeled pilot.

The point I'm making is that if you taught the IR FAA style (ie less theoretical knowledge and no ATO requirement) in a more GA environment, with typical GA aircraft, you would find that the real difference in competencies required compared to what is considered a good standard for the IMCR, would fall to a small amount. The number of GA pilots doing it would probably increase since it would have the obvious attraction of being valid outside of the UK.

That's why I think the 'BIR' will work well. If the CAA are really ahead of the game perhaps post EASA it could be implemented under the ANO without the need for ATO involvement. I suppose an interesting question would be whether it could be considered ICAO compliant and therefore actually, a valid IR anyway... :wink:
Edward Bellamy wrote:I suppose an interesting question would be whether it could be considered ICAO compliant and therefore actually, a valid IR anyway... :wink:

I think it's unlikely it'll ever be considered ICAO compliant by any of the parties involved. That would destroy a bunch of organisations who are currently dependent on teaching the requirements of the "full" IR.
Interesting FAA comparisons ..

When I was doing Canadian PPL ground exams ('60s), the standard textbook was from Sporty's. They offered a 'new SPL' package: textbook, whizzwheel, protractor/ruler, etc. The textbook was the US edition but incorporating a Canadian 'differences and extras' supplement. My Canadian FC required all new civil ab initio student members to have this, the new cost of which was included in the Club initial joining fee. Canadian extras (eg RCAF 'ground/air emergency visual signals' card and Arctic survival guide!) were thrown in for free :roll:

In the basic American section were 'Victor Airways', straight lines (not 'corridors of discernible width' like Class A Airways) with 'V nnn' numbers printed on the VFR topo sectionals (reproduced in the book) with radial azimuths each way; these joined VORs or VOR/DMEs, the theory of whose function was included in the FAA syllabus for PPL students; I have no idea whether FAA students were then examined on them, but Canadian ones then were (and on NDBs and even Radio Ranges!). As it happened, our ancient FC aircraft (older than myself) did not have VOR receivers! The point was made in the textbook that they were to be used only in VMC, of course; but even basic PPLs (and SPLs) seemed to be expected (in the ground school course) to plan longer xc routes which would use them for most of the track, even if it meant doglegs to join and leave them at the beginning and end. OK, this was not 'flying Airways' in the IFR sense, nor of making cloudbreak approaches when unqualified to do so, but was indoctrinating early the idea of flying established routes known to other pilots and to ATCOs (at appropriate semicircular altitudes, of course). I do not recall from my UK PPL instruction any comparable teaching nor encouragement of planning xc routes VOR to VOR while still at the FMC only stage; rather, I recall UK FIs saying something like 'tune in VORs if you must, for cross checking, but don't rely on it and never fly directly via them as they are dangerous honeypots for those flying head down in VMC'.

I see from the latest dated North American VFR Sectional in my hoard, 2005, that they are still there, and with the same V numbers as one of the same area dated 1982. On a 2005 Canadian Sectional there are comparable lines between VORs, but without 'V numbers'.

I'm not suggesting either approach is 'better'. The North American one may better suit conditions there, with longer distances, joined-up ATC, more predictable VMC, and less congested airspace. But what it may also do, which may make easier training to IR (of any flavour) and flying Airways in IMC, is to get pilots used to flying longish distances along constant track, making proper allowances for drift through prior planning and en-route observation. There are fewer opportunities to do this in UK, or at least the more congested parts of it.

Obviously, as a mere Day/VFR bimbler, I'd welcome comments from the IMC-qualified, and especially from IRIs.