EASA FCL Update
Nick Wilcock AOPA UK & IAOPA (EU)
IAOPA Representation
 Flight Crew Licensing/Implementation Forum
- NAA and Industry / Association groups
- EASA by invitation only
- Meets twice per year at locations as hosted by an NAA
 EASA TAG/SSCC/FCL
- EASA, EC, NAA and Industry / Association groups
- Meets twice per year at EASA Köln
 EASA CbM IR/EIR and LAPL review boards
- Meet as required at EASA Köln
 RMT.0XXX Task Force
- Simpler access to Instrument Flying qualifications for GA Pilots
2 May 2015
EASA FCL Updates
 Regulation (EU) 2015/445
- 2018 derogation for Aerobatic, Towing and Mountain Ratings
- 2018 derogation for LAPL, but RFs may now train for LAPL
- 2018 derogation for RFs to convert to ATO
 NPA 2014-28
- AMC/GM for non-complex ATOs
- Developed by EASA, NAA and Industry Associations
- No longer being progressed
- EASA considers limited support due to an extent to biased assumptions
 RMT.0YYY Task Force
- Training Outside an ATO
- What is ‘outside an ATO’?
- What is the scope of such training?
- IAOPA representation?
2 May 2015
EASA FCL Updates
 NPA 2014-29
- Aircrew Regulation amendments
- 30 IAOPA comment responses to NPA 2014-29(A)
- 7 IAOPA comment responses to NPA 2014-29(B)
- Comment response period extended to 17 May 2015
- Opinion Q4/2015
 GA Road Map
- 6 main objectives:
2 May 2015
EASA FCL Updates
2 May 2015
UK Instrument Rating (Restricted)
Background
Late 1960s:
 AOPA raised concern over accidents / incidents caused by:
- Loss of situational awareness in reduced visibility
- Controlled flight into terrain
- Loss of control in IMC
- Loss of situational awareness out of sight of the surface
 UK Air Navigation Order later amended for ‘VFR’ PPL holders:
- No flight out of sight of surface
- 3 km min. visibility outside controlled airspace (‘Open FIR’)
 IMC Rating proposed in order to:
- Enable pilots to cope with flight in IMC / reduced visibility
- Improve pilot handling skills and non-visual navigation skills
2 May 2015
UK IMC Rating
UK (pre JAR-FCL):
 IMC Rating regulated by UK Air Navigation Order
JAR-FCL :
 Flexibility provisions of JAR-FCL 1.175(b) ensured IMCR continuance
EASA Part-FCL:
 No provision in FCL.600 IR for:
- ‘Sub-ICAO’ instrument qualifications
- Flexibility to allow for ‘local conditions’
 FCL.008 group tasked to propose future European GA IFR solutions
2 May 2015
EASA FCL.008
‘Qualifications for flying in Instrument Meteorological Conditions’
 EASA review team analysed 1556 comment responses
 EASA Draft Opinion 03/2013 proposed 3 new ratings:
- En-route IFR rating
- Competency-based Modular IR
- Sailplane cloud flying rating
 FAA IR to Part-FCL C-bM IR conversion
 No acceptable solution identified for continuance of the IMC rating
 Commission regulation (EU) 245/2014 introduced Article 4 (8)
 UK implementation: Instrument Rating (Restricted)
 IR(R) identical to IMCR in all but title!
2 May 2015
EASA FCL.008
‘Qualifications for flying in Instrument Meteorological Conditions’
 EASA review team analysed 1556 comment responses
 EASA Draft Opinion 03/2013 proposed 3 new ratings:
En-route IFR rating
8. Until 8-April
2019, a Member State may issue an authorisation to a pilot
- Competency-based
IR to fly aeroplanes under instrument
to exercise
specified limitedModular
privileges
Sailplanethe
cloud
rating with all of the requirements necessary
flight rules- before
pilotflying
complies
FAAofIRan
to Part-FCL
C-bM
IR conversion
for theissue
instrument
rating
in accordance with this Regulation....
 No acceptable solution identified for continuance of the IMC rating
 Commission regulation (EU) 245/2014 introduced Article 4 (8)
 UK implementation: Instrument Rating (Restricted)
 IR(R) identical to IMCR in all but title!
2 May 2015
EASA FCL.008
‘Qualifications for flying in Instrument Meteorological Conditions’
 EASA review team analysed 1556 comment responses
 EASA Draft Opinion 03/2013 proposed 3 new ratings:
- En-route IFR rating
- Competency-based Modular IR
- Sailplane cloud flying rating
 FAA IR to Part-FCL C-bM IR conversion
 No acceptable solution identified for continuance of the IMC rating
 Commission regulation (EU) 245/2014 introduced Article 4 (8)
 UK implementation: Instrument Rating (Restricted)
 IR(R) identical to IMCR in all but title!
2 May 2015
IR(R) Privileges





Flight in IMC or under IFR in Class D, E, F or G
No flight in Class A, B or C if compliance with IFR mandatory
IFR departures / arrivals (including SIDs and STARs)
1800 m minimum in-flight visibility for take-off and landing
Instrument approaches to recommended minima:
- 200 ft addition to calculated DH / DA (or 500 ft HAT if greater)
- 200 ft addition to calculated MDH / MDA (or 600 ft HAT if greater)




Valid on any SPA for which the pilot holds a valid Class Rating
Only valid in UK airspace
No presumed intention of use
IF time as PIC creditable for CbM IR
2 May 2015
UK IR(R) Training
 May be delivered at a UK RF/ATO or by a ‘freelance’ training provider
 Applicant prerequisites:
- PPL(A)
- 25 hrs total flight time since licence issue, which may include IR(R) course
- 10 hrs PIC on aeroplanes, including 5 hrs cross-country
 Training:
- Theoretical knowledge training normally ≈ 20 hrs study time
- Ground examination syllabus defined in CAP 804
- 15 hrs instrument training (5 hrs may be in an approved STD)
- Single 2 hr ground examination (25 multiple choice questions)
- IR(R) Skill Test ≈ 1 hr in simulated IMC
2 May 2015
UK IR(R) Instruction
 IR(R) flight instruction may only be delivered by:
- UK FI(A) with IR instructional privileges
- UK IRI
- UK FI(A) who has:
• No supervisory restrictions
• Privileges to instruct on relevant single pilot aeroplane class or type
• Valid IR(R) or IR(A), not EIR
• 10 hrs instrument flight time on aeroplanes
• Completed FCL.095.FI(g) course as detailed in FCL.930.IRI
• Passed Assessment of Competence to instruct for IR(R) with FIE
• Instructor Certificate endorsed ‘(g)(IR(R))’
• 200 hrs IFR experience prerequisite not required
2 May 2015
UK IR(R) Testing
 IR(R) testing:
- Skill Test for initial issue
- 25 month IR(R) validity
- Revalidation by mandatory proficiency check
- Renewal by proficiency check if expired by less than 5 years
- Additional requirements for renewal if expired by more than 5 years
- Tests / checks may be conducted by:
• UK IRE
• Standardised UK CRE with IR examining privileges
• Standardised UK FE with IR or IR(R) instructional privileges
- Compliant with Annex III of Regulation (EU) 216/2008
2 May 2015
UK IR(R) Safety Record
 Over 14000 IMCR / IR(R) issued since introduction
 Number of fatal accidents attributable to improper use?
1 (not positively determined)
 Number of serious incidents or accidents avoided by correct use?
Probably hundreds!!
 Meets EASA GA Road Map’s No.1 safety objective commitment:
- Easy access for UK GA pilots to Instrument Flying qualifications
- A concrete measure which has improved UK safety for over 45 years!!
2 May 2015
UK IR(R) Future Considerations
 In-flight visibility limits should be harmonised with SERA definitions
 Syllabus should include more emphasis on safe GNSS navigation
 Training should address hazard of over-reliance on GNSS in DVE
 Training should address hazard of unapproved ‘D-i-Y e-approaches’
 Possible extension to other Member States
2 May 2015