but it would have been more elegant to twist the UK IR into something acceptable for both UK and the rest of EASA,
As the IMCR stands it can’t happen because it would be almost equivalent to the full IR in all countries which don’t use Class A for CAS containing passenger jets (broadly speaking) and that is not politically acceptable.
Is there really a rationale in those differences?
AIUI the BIR is not ICAO and therefore can be made completely competence-based and with no logbook hours requirements. Any ICAO IR needs 40hrs (or whatever) in the logbook, etc.
It’s slightly funny for me to see this, having been in PPL/IR c. 2005-2015 and seen them argue hard against any sub-ICAO IR, on the grounds that it could lead to some countries (or some airports) blocking the holders of it from certain airspace or certain airports. I don’t know what has changed, but then I don’t know if PPL/IR are involved in this anymore. It seems it is driven by new management in EASA, which is a good thing because it cannot happen without a buy-in at the top.
I thought these two tables were interesting
It could of course be due to selective sampling (the people likely to respond to EASA NPAs are those who are on their circulation list and have the time to read these very long documents) but otherwise it indicates that very few people are embarking on the FAA route nowadays.
huv wrote:
Now we are discussing 5 different instrument flight ratings in EU, and I am not even counting the sailplane cloud rating. We have the IR, the CB-IR (admittedly almost the same thing), the IR[ R] in the UK, the EIR, and now it seems we need one more, the BIR. In the US everyone seems to be happy with the one they have.
That British rating has an expiry date IIRC and EASA is of the opinion that EIR is redundant next to BIR with which I agree. So you’re down to three (and there really shouldn’t be the need to distinguish CB-IR and the old IR).
huv wrote:
Test for the IR/CB-IR is mandated by hard law, it seems the test for the BIR is in the AMC, subject to national preferences. Is there really a rationale in those differences?
That should be in line with EIR. I don’t know the rationale.
I quite liked the “amend CB-IR” option considering they specifically mentioned focus on theory to bring it closer to FAA IR.
An interesting bit is that ELP wouldn’t be required for BIR. I know there were discussions about using languages other than English when flying IAW IFR, with opinions usually against the idea if memory serves me right.
If we ever get the “lower than ATO” training organisations (registered, declared, whatever they’ll be eventually called), they won’t be able to train for BIR which I think is a wrong move.
All the questions for the tests will still come from the central question bank which doesn’t fill me with optimism. Reading this tempered my enthusiasm for “amend CB-IR” option because it would inevitably lead to the same thing (as I read the rationale) although perhaps with a single test.
One point where I was afraid how they’ll handle it is conversion to ICAO compliant IR. More specifically how would they deal with the theory. As I read it they propose oral assessment during the skill test as is the case when converting a third-country IR – that is surprisingly good, I wasn’t expecting that.
An interesting bit is that ELP wouldn’t be required for BIR
The French national IR was taught in French, IIRC. That is probably mandatory for any significant take-up, in countries where ATC is not done in English (and France has a law requiring French license holders to speak in French to French ATC!!). However, as Aviathor found and posted recently, only a small % of French pilots have ELP on their license so they can’t fly outside France anyway. But maybe there would be a substantial alignment between those who do have ELP and those who would do a “national IR” – one would expect that, due to the obvious motivation.
An IR without ELP is on the face of it worthless, but maybe not?
That British rating has an expiry date IIRC
No way would the IMCR be terminated. It would be a scandal. The 2019 date was a political solution called “kicking the proposal into the long grass”. And post-brexit it can’t happen anyway.
One point where I was afraid how they’ll handle it is conversion to ICAO compliant IR
If you have the ICAO required logbook time, a skills test should do it.
and France has a law requiring French license holders to speak in French to French ATC!!)
That’s not true when flying IFR though – otherwise one would not be able to take the test in English like many people do
Peter wrote:
It could of course be due to selective sampling (the people likely to respond to EASA NPAs are those who are on their circulation list and have the time to read these very long documents) but otherwise it indicates that very few people are embarking on the FAA route nowadays.
Those are responses to a questionnaire which the document says was sent to EASA member states. They don’t mention how it got to the pilots.
Peter wrote:
If you have the ICAO required logbook time, a skills test should do it.
Consider it. If the biggest problem of the IR was theory, you’re incapable of offering exam credit for CPL/ IR to gain ATPL and you suddenly create an IR with very reasonable theory and examination which, however, isn’t ICAO compliant, what are the chances one will be able to convert it into a fully compliant IR without having to do the exams? I could imagine credit for the actual instruction, but exams? I never saw that coming. Of course, such solution (having to do the exams) sucks and I know they wanted something convenient so I was wondering what they’ll come up with. This is a good surprise. It might render the theoretical part of CB-IR quite dead (depending on how convenient the BIR route will be).
Peter wrote:
No way would the IMCR be terminated. It would be a scandal. The 2019 date was a political solution called “kicking the proposal into the long grass”. And post-brexit it can’t happen anyway.
It was clearly a solution to buy time. To come up with something to address the specific needs. After you’re gone, there won’t be any need to extend this exception and IR(R) will be dead. Well, UK CAA wants to stick with EASA as I understand it and who knows what your treaty will say (if you’ll pursue one to gain EASA MS status).
Peter wrote:
The French national IR was taught in French, IIRC.
That’s hardly surprising. I would expect it to be the norm (training, phraseology, the whole lot in the official language of that country). However, on forums where the principal language is English the opinion that IFR RT should only be done in English and doing otherwise (mixing languages on a single frequency) is dangerous seems to be common.
Peter wrote:
However, as Aviathor found and posted recently, only a small % of French pilots have ELP on their license so they can’t fly outside France anyway.
I don’t want to open up the regulation right now but I believe you don’t necessarily need ELP. LP in the required languages is enough. E.g. if you have German LP, you could fly from Germany to Austria just fine. That is VFR. BIR would open this up to IFR as well.
That’s not true when flying IFR though – otherwise one would not be able to take the test in English like many people do
It came up here
It might render the theoretical part of CB-IR quite dead (depending on how convenient the BIR route will be).
For nearly private pilots in Europe, the CBIR will be dead because flying outside “political Europe” is quite a hassle and thus unattractive for most. I know some do fly further but it is a tiny % and quite a lot of them do it VFR anyway (esp. those who go into W Africa and/or within Africa). That is unless the BIR has limitations. A higher DH is irrelevant because it is pilot interpreted 
An RVR or say 1800m (as per the UK IMCR) would pretty well cripple it though.
on forums where the principal language is English the opinion that IFR RT should only be done in English and doing otherwise (mixing languages on a single frequency) is dangerous seems to be common
Well, it is dangerous, but you need to balance that against convenience, and the desire to protect the national identity/language from being diluted by Uncle Sam etc.
But the big thing for any IR is how well the process of getting it integrates into peoples’ lives. That is the biggest single thing – the need to go via an IR FTO, which for most means a hotel stay. I have spoken to so many people, not just IR but other stuff also, and the biggest thread is shitty hotels and more shitty hotels and wasting one’s time learning crap theory. This is the main reason why the US has much bigger numbers of IR holders. We have done this to death before of course but I can’t see how EASA can ever change that. It would need every little PPL school to be able to train it, and then you wonder what the FI qualifications would be – yet another factor which will make most PPL schools not offer it. Currently most UK ones can teach the IMCR but only because you don’t need an FI with a valid IR.
An RVR or say 1800m (as per the UK IMCR) would pretty well cripple it though.
Just nit-picking, but it is now 1500 m.
Instrument meteorological conditions rating (aeroplanes)
An instrument meteorological conditions rating (aeroplanes) entitles the holder of the licence to act as pilot in command or co-pilot of an aeroplane flying under the Instrument Flight Rules except—
in Class A airspace; or
when the aeroplane is taking off or landing at any place if the flight visibility below cloud is less than 1,500 metres
I fail to see why IFR RT would be more dangerous in many languages than VFR in many languages. I tend to thing VFR is much worse. For most IFR flights, you talk to people who are far away, and by definition you won’t have to really know what other people are doing, because you are separated. VFR is an entirely different thing, and knowing what others are doing has a much more significant effect on your situational awareness.
For IFR, airliners somtimes use data links, and I suspect others don’t receive them.
Peter wrote:
This is the main reason why the US has much bigger numbers of IR holders. We have done this to death before of course but I can’t see how EASA can ever change that
I did the EASA IR then took the FAA IFP test a year later. I found there was probably 2-3x the work on the EASA one, but it was all home school. Regarding the theory, I only spent 1 night in hotel (1 saturday on the saturday – sunday TK course). Would have been 4 maximum, if I lived in a remote place (day before TK course, and 1 for each day of exams (I did in 2).
Regarding the practice, I think the hours must be similar between the two. I did 20 hours with ATO (probably 6-8 hotel nights), and none when I did the IMC rating. Could have done with zero, if did my practical at Stapleford, but thought would be good to take some days relaxing and focusing only on that.
@Noe,
I agree on the subject of language. The English LP requirement is a barrier to IF proficiency for many Europeans, and to that extent it may well be a killer.
Questions for those who have done UK IMC, EASA IR and FAA IR:
Which part(s) of the “full IR” TK requirements do you see as relevant to the lifting of the two IMC rating restrictions (Class A and 1500 m vis) mentioned above?
Could any areas of TK missing from the IMCR syllabus be addressed by oral examination during a practical test?
