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The EIR - beginning to end

Nobody knows the EIR

Nobody knows how useful the EIR will be really. That’s because the practical implementation details aren’t known yet..

With today’s rules in Germany (no IFR below about 3000 feet AGL outside of instrument procedures), the EIR is / will have almost no “weather utility”.

I think this is not true. You can anticipate a minimum “usefulness” of the EIR by assuming that you will be able to fly IFR from MRVA to MRVA. This allows you for better and safer VFR travel, if you like to phrase it that way. In the last 3 Years alone, I have done at least 7 flights and cancelled 10, where an EIR (from MRVA to MRVA) would not only have been easy possible, but be safer, because it eliminates (legal!) scud running with a rising amount of wind turbines. Of course, EIR would not be sufficient enough to use the aircraft as a reliable business travel tool. Noone is suggesting it would be. But it makes – even in its least useful implementation – a phenomenal VFR travel tool. And if you have an aircraft with a good range, you can easily divert to a place where you can land VFR.

Plus, as I said, if you find out that the EIR isn’t enough, you can always upgrade to the CB-IR.


PS: I think this has nothing to do with the 150 kt aircraft or the implications of “not IFR registered”, hence the new thread

Last Edited by mh at 24 Sep 04:22
Aufwind GmbH
EKPB, Germany

It just nags me. Since the announcement of the EIR, tons of VFR-only pilots have been writing on the internet fora about how “fantastic” the EIR is, and how it is “totally sufficient for their flying”.

These pilots know nothing, zero, about the practicalities of flying IFR, in Europe, in SEP airplanes.

Thy don’t know that:

- in the enroute segment, the vast majority of flights can be completed without ever touching any cloud (see Peter’s trip reports).

- it is in the approach and departure segment where (low) clouds often need to be crossed.

Let’s look at the enroute segment. There’s summer and winter. In winter, there is either frontal weather activity (and nobody will want to fly in these conditions at all, in an un-deiced airplane) or it is usually rather calm weather with low humidity in the atmosphere and thus low cloud tops (yet often with a lot of fog and scud). No problem to fly VMC on top in these conditions.
There there is summer. Whenever there is massive (“untop-able”) IMC enroute it will be convective (cumulus, towering cumulus or CB type) and nobody will want to fly through that stuff anyway.

VFR pilots usually have no idea what flying IMC in the enroute section is like. Yet they seem to think it’s “cool” somehow.
Unless it is just some stratus type (and then one can usually go on top just by climbing a couple tousand feet!), it is totally unpleasant. For pilots, but even more so for passengers. They hate it. It is not only uncomforartable, it is also quite “problematic” in Europe, since MEAs will make the icing risk a continous companion, over most part of the year. Plus it always bears the risk of flying into some really nasty stuff.

An IR, for an SEP pilot, is really not much more than “depart and get back down safely in IMC, but cruise in VMC”-tool.

I am am quite sure that, a couple years from now, many EIR pilots, having gained some practical experience, will have become aware that the EIR is actually “the wrong way around”, i.e. it would have made much more sense to allow departures and appraoches in IMC, but mandate the enroute section to be flown in VMC.

Some people say “I don’t really want to fly at all when the weather is down, so the EIR is actually sufficient for me”. That’s is true, but it’s only half the truth. The other half of the truth is that it will happen that your home airfield is socked in on the way back from a trip. With a full IR, I will just fly home and not miss a day or two at work. The EIR pilot will.

I am not saying that the EIR is not useful at all. It will make flying easier due to airspace access and eased planning. It is also good because is breaks up the hurdles towards an IR into two modular steps, which is good. Thanks to the EIR, more pilots will come into the “IFR scene” and eventually progess to the full IR.
I am just saying that the waether utility / depatch utility is still to be seen and will probably be miniscule, at least in certain countries.

Last Edited by boscomantico at 24 Sep 06:09
Mainz (EDFZ) & Egelsbach (EDFE), Germany

Will the EIR allow those pilots into Class A airspace and airways?

I agree completely here Bosco. Especially with

An IR, for an SEP pilot, is really not much more than “depart and get back down safely in IMC, but cruise in VMC”-tool.

For me this line is the whole point of the debate. It is what I used to do with my IMCr when I was living in the UK. The only restrictive thing was that you were not allowed in Class A. Ok fine, that’s for the big stuff, which the average SEP does not need to mix with. It allowed me to depart IFR, climb above, cruise and then arrive IFR.

I still think the better option for EASA was copy the IMCr from the UK and adjust it slightly to fit the requirements of the other member states.

I still don’t understand what the EIR actually does, or said differently what it will give me. You can not depart IFR or arrive IFR… And, as you know, in Germany the flying is mixed VFR/IFR from a few thousand feet up. Given the controller has to separate IFR from me, doesn’t that effectively mean I am also separated from IFR? So if I flew encounter VFR/IMC how would anyone know, except me being sick I the cockpit because it is uncomfortable.

I do understand why a lot of VFR only pilots think it is cool to cruise in clouds. I used to… But then I got my IMC and that disappeared after 5 minutes… It is boring and tiring and if you want to stare at instruments for hours then go and buy a PC sim.

EDHS, Germany

Will the EIR allow those pilots into Class A airspace and airways?

Yes….making the EIR + IMCR equivalent to an IR in the UK (but only in the UK)….so for UK pilots with the IMCR it makes sense as a stepping stone to the IR…

Edit….before anyone points out the visibility (1800m) limitation of the IMCR….ok yes, almost equivalent

Last Edited by AnthonyQ at 24 Sep 06:43
YPJT, United Arab Emirates

I also agree with Bosco. I can see only two reasons for the EIR: to avoid ATC restrictions on VFR and as a stepping stone to the full IR. In some countries better airspace access will be a significant improvement, in other countries it will mean virtually nothing.

My club is planning to start EIR training. As VFR airspace access is not an issue in Sweden, it will be interesting to see how many people will actually seize the opportunity. Maybe the “coolness” factor will play a role, initially.

Of course from a safety point of view, any instrument training is a good thing.

ESKC (Uppsala/Sundbro), Sweden

It’s true that the enroute segment is usually VMC, and this is evident in my trip reports, but that is true only if you have a high performance plane, with a ceiling of say FL160 plus.

On the last trip (Corsica, Greece, Croatia – Sep 2014) which was 27.5hrs airborne, I did maybe 1hr IMC (carefully verified to be non-convective) and that was concentrated heavily into 1 or 2 portions where I was at FL180-190 and cold enough to not get icing. On Eurocontrol routings, IMC usually means below 0C and thus icing conditions.

I think the best way to think of the EIR is that it enables a VFR pilot to do long flights with the implied enroute clearance which is standard in IFR. Currently, such a pilot needs to plan a route OCAS (which will often put him into IMC and icing conditions – illegal too but I am being practical here) and then hope to get clearances into CAS which may come or may not depending on the unpublished policies of the various ATC units along the route. If you look here at say my 2004 VFR Crete trip and compare it with a later 2010 IFR Crete trip (the 2014 one needs to be written up) you can see the huge difference in the way it is planned and executed, even though the actual route is similar.

VFR and IFR are such artificially created distinctions. If aviation was invented today you would never have that. And if I was teaching somebody I care about to fly, I would not let him/her go solo if they are going to kill themselves in IMC. (You may have an aerobatics VFR-only PPL, perhaps). The EIR goes some way to addressing this.

But only a clever / cunning pilot will be able to make use of the EIR properly, due to the need to depart and arrive VFR in a manner which is obvious to anybody watching and especially ATC. Such pilots are the same ones who have been doing long distance “VFR” touring, and I have to shamelessly say I am/was one of those. Some IMC could almost never be avoided, on a “VFR” flight of say 700nm, and the tactics used on those will be used with the EIR, but will be much more useful because you will be able to play the game better, by not cancelling IFR until it suits you or until ATC absolutely force you to do so.

But whether the EIR training apparatus will transfer the operational knowledge required, I don’t know. The European IR training apparatus transfers practically zero useful flying knowledge (it is set up to manufacture large numbers of jet RHS occupants who don’t need to know anything much operational because they have a proper pilot in the LHS) so I doubt EIR holders (those without a lot of prior VFR touring experience) will be any more able to use it for real.

As with all this stuff, it comes down to mentoring i.e. finding somebody to fly with who knows how it works.

in other countries it will mean virtually nothing.

I’d like to know what countries those are. Where can you e.g. overfly a major international airport at say FL080 without a question, and it is 100% guaranteed? You may be able to do it on the day, and on the next day, but it is the knowledge of the implied enroute clearance that is the key. A pilot can’t plan a flight on the basis that something usually works.

I am certain that the EIR will add great value to the enroute segment everywhere, though this won’t be obvious to VFR pilots because naturally they have not been planning and flying in the relevant manner previously.

Will the EIR allow those pilots into Class A airspace and airways?

Of course.

BTW no such thing as “airways” – that is a UK PPL term designed to scare pilots from going into Class A All that matters is the airspace class.

Shoreham EGKA, United Kingdom

I still think that a lot of people get the wrong idea what the real benefits of the EIR are and why it is a good thing.

While I am currently VFR only, I did the whole IR (A) and therefore am well aware of what an actual full IFR flight entrails. Also I will get my full IR back the moment the new theoretical exams are available (I need to repeat the theory and do a IR flight test) and I got my plane upgraded, which will happen in December. So the EIR is not really for me, but WERE I in that position, I could see its benefits.

Weatherwise, boscomantico and others are correct. The EIR is not really a rating whose primary purpose is to allow people to fly in “bad weather”. It can be helpful if you need to cross an area of IMC enroute, but that is not the primary thing I personally think important.

What I like about the concept of the EIR is that it will make enroute flight for travelling a LOT easier than VFR is now. Because you can join, forget all about the airspace mazes of Europe, fly in decent altitudes and under ATC control. And then, for the arrival, you cancel IFR and do it as you’re used to. If I look at the Calvi flight, it’s a prime example for this. Out of ZRH, you’d have to climb to 10’000 ft at least to get over the Alps, then go down to 1000 ft AGL to get through the Milano TMA and then climb back up again to cross the Med to Calvi. Utter stupidity. With a EIR you can join either immediately, which means you need at least 14000 ft, or join after a VFR alpine crossing, fly at FL120 or so until in the intermediate Approach to Calvi. Faced with these two possibilities, I know which one I’d choose. Likewise, a friend of mine flew to Paris the other day. Also he needed a roller coaster profile, wasting fuel and time, to accomodate the airspaces in France. MUCH easier to fly EIR.

The other bit is, that it will allow people to do their full IR in steps. Do the theory, do the EIR, fly enroute IFR for a year or so and then continue to the full IR. This will indeed allow a lot of people who can not finance or make time for a full IR training up front the chance to do it in steps.

Since the announcement of the EIR, tons of VFR-only pilots have been writing on the internet fora about how “fantastic” the EIR is, and how it is “totally sufficient for their flying”.

And it is mostly IR pilots who are opposing the EIR on various grounds. And in some of them I see anger and frustration that they had to do the IR the “hard” way and it is now “given away” as they feel. Well, from what I have seen so far, that is quite a long way from the truth and people who think like that are pretty egoistic.

I fully agree with some of these people, not because they are stupid but because many of them are realistic in what their planes can do and from which airports they fly. 90% of light GA fly out of non-IFR airfields and avoid international airports for cost and complexity anyway. So if they do fly 80-90% to VFR destinations and are based at VFR bases, their ONLY interest in IFR is really ENROUTE. For them, the EIR is really a very practical thing and a valid and better replacement to the old CVFR endorsement, which did allow certain routes to be flown under ATC control.

The other factor is that a lot of the planes we SEP’s can afford are not really great IMC planes. Most of them are not de-iced, which makes IMC flying impossible most of the time, so “light IFR” means really to 90% that you will fly under instrument RULES but VMC. Combined with the fact that most of these planes are stationed at non-ifr airports, the EIR is really what will make a difference there.

One other very important factor will be that EIR rated folks will be MUCH less reluctant to ask for joining clearance if they encounter IMC on a VFR flight than a “normal” VFR pilot, or rather won’t get into the situation where he has to ask for help in the first place.

I think Peter sums it up nicely. The EIR is mostly a rating which allows much easier and safer travel for VFR pilots who would like to expand their horizons and do longer trips without the hassle VFR presents. That is for people who aim for the EIR only. For the rest, it will allow a gradual and step by step introduction to IFR flying.

I honestly don’t begin to comprehend the level of antagonism against this. For me, it is one of the best things to come along in decades.

“REAL” IFR, that is where you can fly in all those weather conditions, starts with a FIKI Twin or at least a FIKI – Cirrus with the CAPS as a way out. All the other smaller planes are “light” IFR. To make people understand the limits of their planes in no unclear terms is one of the tasks training has to accomplish.

Last Edited by Mooney_Driver at 24 Sep 11:56
LSZH(work) LSZF (GA base), Switzerland

I sense an attempt to avoid being UK biased on this thread…..but in the UK the EIR / IMCR combination will suffice for many, many pilots…allowing access to the airways and IFPS IFR flight plans….

YPJT, United Arab Emirates

It is an interesting debate, and I think there are many answers which all have one thing in common… our own individual self, each answer is a personal one! We would each benefit from something different and this is the key to the debate for me. Peter/Mooney Driver et al are correct, but equally so to I think are AnthonyQ and myself. The IMCr+EIR will give UK IMCr holders access to Class A, B and C airspace and therefore it is effectively a full IR, due to the UK National Approach privileges it brings.

For Pilots wishing to fly longer distances more easily, yes granted, it will make a Calvi trip easier. In my current situation the EIR gives me nothing, I can fly up to FL100 (limited by O2), all the zones in my area are Class D, so no problem flying across them. What would benefit me is the ability to conduct an approach IFR, like I used to be able to in the UK. (Yes, there are other limitations such as pop up IFR in Germany for example) But my point is this EIR seems to benefit a small number of the community and not the community as a whole where as the CBIR does benefit everyone.

I would like to obtain the CBIR myself, probably directly as that would be of benefit to me, and bypass the EIR, as it offers not much.

Last Edited by italianjon at 24 Sep 10:59
EDHS, Germany
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