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Anti N-reg provisions - EASA FCL and post-brexit UK FCL

IMHO almost nobody in GA logs IFR time unless they are collecting it towards some specific entitlement – because anybody with an IR can log practically every long flight as 90%+ IFR time, and everybody knows it will be 100% on autopilot and – if the pilot played his cards right – in VMC, wall to wall sunshine, and 100nm visibility In Europe, by far the main point of an IR is to get access to CAS / get ATC working for you instead of working “reluctantly for you” which is what tends to happen with VFR.

So people tend to log instrument time / IMC time. This is very slow – around 5% of total time.

Colour vision used to be an issue for the IR but nowadays you can a non-CV IR officially (it was done under the table for many years, here in the UK).

One-ear deafness (common after measles, for those who didn’t get vacced) was a big problem with the Euro IR, requiring complicated routes and workarounds (an ICAO CPL/ATPL was one way) but was never an issue with the FAA IR. Only in recent years this has been fixed and you can get an IR with one deaf ear officially.

Cardiac intervention history is a big one, especially in the GA demographic combined with GA dietary habits Most pilots who had anything done chuck in flying completely, though Brits have the option of the PMD route (UK VFR only – rather crap IMHO).

Administrator
Shoreham EGKA, United Kingdom

Obviously, as a European pilot doing his IR in the US, one should log US IFR time all the way to the checkride and then switch immediately to logging EASA IFR time, in preparation for the conversion of the rating. After that, one should continue logging EASA IFR time, as 1) it is required by Part-FCL and 2) one might need it progressing towards an FI or so. There can be no doubt about that. The problem is that when one does the IR, one is often still quite at the beginning of one‘s learning curve in GA and doesn‘t know/understand these subtleties too well. One is also often misguided by narrow-minded instructors who don‘t understand the process.

Mainz (EDFZ) & Egelsbach (EDFE), Germany

@Peter you obviously live in a different flying world to me. All my flying is logged as either single command,double command, night and then the same again for multi engine. There is then a column for flight under IFR and another for simulator. So if you fly La Rochelle to Bordeaux for example in a DA 40 you put the block block time in the single command column. If it is a IFR flight with IFPL you then also put that block block time in the flight under IFR column. When you tot up the total hours on the page you only count the figures once.
I am tested for colour vision every year, but maybe that depends.on the AME.
Following a cardiac intervention the problem in France is not the AME but the Pôle Medicale at the DGAC who seem to decide what you need based on some weird logic. If I decide to turn to the dark side (ULM) or quit flying altogether in next couple of years it will be down to the DGAC medical committee thinking they know better than a specialist cardiologist.
The second weird logic is that every year now you fill out the same form in which you tick boxes with questions like “are you now or have you ever been suicidal” “are you now or have you ever been on phsycoactive substances” and the one I really don’t know how to answer is the follow up to, do you drink alcohol? If you answer yes the next question is how many units a day do you drink alcohol? Now I have the occasional glass or 2 of red. I am French after all. But it tends to be on special occasions or group meals. I calculate on average based on a year’s consumption at about 0.25 units a day, but there isn’t space for that. I like to be honest about these things.😀

France

You want to log IFR time if working towards an IRI, which is itself a requirement for an IRE.

Apart from that, the CB IR is probably the first thing which asked for “IFR time” and was thus the butt of so many jokes along the lines of a plain UK PPL being able to log IFR time just by flying non-radio VMC in Class G That ended fairly recently but anyway based on posts in that 50hr acceptance thread I doubt any European CAA would today accept such logbook entries.

I actually can’t remember what “actual instrument time” was logged towards. But by the time you have a few hundred hours of it, it is way more than could be useful towards anything. Could one treat it as “IFR time” in Europe even though you have no evidence e.g. IFR flight plans? On “eurocontrol IFR” flights one logs very little instrument time because – once you get the IFR clearance – you climb as fast as possible to VMC on top. It’s the “European paradox”!

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:


IMHO almost nobody in GA logs IFR time unless they are collecting it towards some specific entitlement

Most people do not take up IFR-flying with the goal to become an IRI after having accrued 800 hrs of instrument time, but rather decide somewhere along their career to go for an FI-IR, IRI or whatever. Much easier if you have kept your logbook clean and complete (logging IFR-time is mandatory under EASA) from the start…

Friedrichshafen EDNY

Surely one logs all time under IFR. It doesn’t have to be towards something. Most pilots I know just like to keep a record of what they have flown, where they have flown when, how and in what aircraft. It’s just like keeping a diary.
There is of course the 12 hours in the second year for your SEP revalidation by experience.
And I think the same applies to the 10 legs for revalidation by exeperience on an MEP. Plus the instructor/examiner requirements of course. Why do so many UK pilots seem to spend an inordinate amount of time trying to avoid or get round certain regulations whilst at the same time making things overly complicated?
This isn’t a dig it’s a genuine question from tje impression I get reading various posts on this forum.

France

Why do so many UK pilots seem to spend an inordinate amount of time trying to avoid or get round certain regulations whilst at the same time making things overly complicated?

Historically because of BSRFI time for IMCr & CPL as well as self-declared IFR in swaths of Golf with no RT/FPL?

The other reason is logging IFR in UK starts from the moment you taxi to the moment the aircraft stops but for training, the guidance to IRI and IRE is to log IFR once you are away from ATZ, at least what an IRE told me on my IR revalidation after doing Southend-Lydd, all under IFR but only time after passing above 2kft was logged and signed (the IRE thinks it’s impossible to log IFR time on the ground in VMC with IFR startup and IFR taxi clearance)

Same really in France, even after FCL/SERA have replaced the RCA1992, most IR pilots don’t log IFR time when not in radio contact with ATS and usually file Y/Z-FPL and the majority are clueless about how to log and fly IFR in Golf? as they “think they are” flying VFR bellow 3kft

Last Edited by Ibra at 24 Dec 10:15
Paris/Essex, France/UK, United Kingdom

Everybody everywhere logs pilot time as brakes-off to brakes-on (“block time”).

Even IFR time, which is obviously silly, but every bit helps when scraping together the CB IR 50hr entitlement. To be fair I think most N-reg owners affected by this measure easily have 50hrs IFR PIC, even if some may have trouble proving it. So far I have not seen any reports from the UK on the CAA’s acceptance criteria, which is a bit ominous

spend an inordinate amount of time trying to avoid or get round certain regulations

Which ones? France is full of N-regs; the difference is that the company which historically operated the French Govt (Dassault) ensured that its interests (lots of bizjets going onto the N-reg) were properly taken into account, when it really mattered in 2004 or so And Germany has reasonable representation in the form of Europe’s only functioning AOPA.

Administrator
Shoreham EGKA, United Kingdom

Ibra wrote:

The other reason is logging IFR in UK starts from the moment you taxi to the moment the aircraft stops but for training

It’s no different for EASA, is it? Well, actually, you’re talking about two different things. It is clear from the AMC to FCL.050 that IFR time is block time. But for training it isn’t IFR time that counts but “instrument time (under instruction)” and EASA defines instrument time is essentially in the same way as the FAA does.

Last Edited by Airborne_Again at 24 Dec 10:36
ESKC (Uppsala/Sundbro), Sweden

I think we agree but good luck finding an IRI/IRE who log and sign dual IFR time while taxiing under IFR with & without ATS in “VFR airfields” or “IFR airfields”, the one liner answer is “you can’t be IFR on ground surface even in LHR” the long answer is way more subtle than that…

Last Edited by Ibra at 24 Dec 10:42
Paris/Essex, France/UK, United Kingdom
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