JAA/EASA IR for an existing FAA/ICAO IR holder

This article was originally written in early 2011, from the perspective of an FAA IR holder, who is already a relatively experienced IFR pilot, with his own aircraft, who is acquiring the JAA IR using the "15 hour" conversion route.

It describes the process of getting through the JAA exams, lists some options for doing the IR flight training in the UK and abroad, and briefly covers my own flight training at the end.

The new EASA FCL (flight crew licensing) regulations start to come in, gradually, in April 2012 so certain things in this article will become obsolete, but the bulk of it is likely to remain useful.

The main purpose of this article is to assist FAA IR holders in obtaining the JAA IR in the easiest possible way. However, parts of this article remain applicable to an ab initio JAA IR student. It is also applicable to FAA CPL/IR holders wishing to get the JAA CPL/IR, though they will need to do all 14 JAA exams and the extra CPL flight training.

I hold an FAA CPL/IR and fly an N-reg aircraft, non-commercially, around Europe. Following the initial UK JAA PPL/Night/IMCR papers in 2000-2002, I did the FAA PPL in 2004 (UK), FAA IR in 2006 (Arizona, USA), and the FAA CPL in 2007 (UK). I also obtained, some time ago, both CAA and FAA Class 1 medicals which I renew concurrently and cost-effectively using the same AME.

As an aircraft owner who rarely flies a different aircraft, I have no use for a JAA IR except as an insurance policy against the aggressive EASA proposals which require EASA pilot papers (licenses/ratings and medicals) to fly, in EU airspace, any foreign registered aircraft whose operator is based in the EU, after April 2014. These EASA papers are additional to the State of Registry papers customarily required under ICAO. One bizarre aspect of this Euro-crap is that they will be required even if they are not themselves legal to fly the aircraft according to State of Registry (FAR 61.3) requirements!

What will happen after 2014 is a big unknown. The best case is a total de facto collapse of the EASA initiative despite it being nominally "EU law". The worst case is that the law is somehow enforced but no alternative IR conversion options emerge. I think there is a likelihood of a post-2014 "regulatory uncertainty" during which a regulation will exist on the books, will not be enforced because there won't be a pan-European airport-based inspection/enforcement framework for a duplicate paper requirement applying only to EU resident operators (imagine the average airport policeman trying to get his head around that) and in many cases the operator residence will be impossible to establish objectively post facto, but an insurer might be able to walk away from a payout. This insurance risk, rather than enforcement, is basically why I decided to collect these papers.

A more immediate reason for doing the JAA IR ASAP is that the 15-hour conversion route is proposed to be terminated (or modified) by EASA on 8th April 2012. See also the "Future of the IR" notes at the end. 10/4/2012: it appears that the 15hr conversion route is just carrying on, because nobody in the training business knows what to replace it with

This rather long article may give the impression that the JAA IR is exceptionally hard. It is not hard in any "intellectual" sense. Anybody with reasonable intelligence and a good understanding of English, who is able to do basic maths on a calculator, can do the seven theory exams which are anyway nowadays mostly reduced to swatting up the question bank (QB). Using the QB, they could even be passed by somebody who has no aviation knowledge whatsoever, albeit with considerable work. The exams are merely an extremely tedious exercise which involves the memorisation of a lot of material which is almost wholly irrelevant to flying. The degree of irrelevance, which is immediately apparent to any current IFR pilot, is de-motivating but one just needs to get one's head down and get on with it. A few months' of evenings, max, should see the back of it, and some bright people have done it in much less time. As for the flying part, an IR is an IR so it is obviously a lot harder than a basic PPL and instrument flight does require a good grasp of situational awareness, aircraft performance, avionics functionality, and weather, but the JAA IR is not significantly different in difficulty to the FAA IR. There is a different emphasis on different areas but if you can do one you can do the other, with a bit of airborne familiarisation with FTO processes and examiner expectations. The one big feature of the JAA IR - if done in the UK - is a heavy reliance on NDB procedures on which most pilots will need a lot of practice, and these procedures can be expected to take up most of any conversion training.

 

General Notes

JAA v. FAA Comparison

The JAA/EASA IR training process is structured very differently to the FAA IR. The following table is for the ab initio IR, with notes on the ICAO IR to JAA IR conversion where applicable. Obviously various assumptions had to be made and I hope these were reasonable; for example the 25hrs for the FAA IR does assume that you are already a competent and accurate VFR pilot when you start, and that you have accumulated some of the total of 40hrs instrument time required for the FAA IR, which under FAA rules can be done under a hood with another PPL holder in the RHS. Also most UK holders of the FAA IR (myself included) did start with quite a lot of IFR experience gained using the UK IMC Rating. Whereas an ab initio JAA IR requires the packing of your logbook with 50/55hrs no matter how good you are and regardless of any previous IFR training. Multi-engine IR strategies also vary widely, with many ME pilots doing it as a SE IR because the flying is a lot cheaper and then doing the ME conversion at the end. And everything changes for aircraft owners who can usually fly their own aircraft for less than even renting a simulator at an FTO...

  JAA FAA
Mandatory classroom (ab initio IR) Y (about 1 week) N
Mandatory classroom (FAA IR conversion) N (but there can be a lot of mandatory homework) N/A
To sit the exam(s) Need FTO signoff (min cost ~ £1000) Need instructor signoff (normally free)
Exam locations & timetable UK exams only at Gatwick, fixed timetable (every 2 months) Can do them at any Lasergrade or similar establishment, anytime
Theory exams 7 (£69 each in the UK) 1 (approx $100)
Relevance of theory to flying Under 10% About 80%
Flight training locations JAA approved FTO, JAA countries only Any Part 61 or Part 141 school, or a freelance CFII instructor, or any ICAO instructor outside the USA, worldwide
Training flexibility Limited; most flying is done on a few routes known to be favoured by the examiners Total flexibility; the whole IR can be done with a freelance CFII while flying on business trips etc
Aircraft Needs to be CAA approved, with window screens in the UK; no owner maintenance Any certified aircraft with suitable avionics
Checkride location Examiners work in various locations Examiners are fixed or freelance (availability of DPE examiners sporadic outside the USA)
Dual training time, min (ab initio IR) 50hrs (SE)
55hrs (ME)
15hrs
Dual training time, min (FAA IR conversion) 15hrs N/A
Minimum instrument time (solo or dual) N/A 40hrs
Ability to fit the training into one's busy life Depends on the FTO and how close you live to it Good, especially with a freelance CFII instructor
Revalidation Every 12 months with an IR examiner - average cost £150 (every 2nd year can be done in a sim) Various options incl. rolling currency (6 approaches within past 6 months) - cost £0 for a pilot normally flying
Revalidation after a long time After 7 years, must re-sit all theory exams, plus IR flight test BFR+IPC (2 flight tests), no exam re-sits needed ever
Approx cost (ab initio) £15000 (50hrs, SE assumed) $5000 (25hrs, SE assumed)

It can be seen that there is no single "killer" factor which makes the JAA IR inaccessible to private pilots. The cost, compared to the FAA IR, is of course much higher but this needs to be seen in the context of long term operation of an IFR capable aircraft, and since the cost is largely a result of very high aircraft+instructor hire rates in the FTO arena, an aircraft owner can reduce it substantially by using his own aircraft. It is more of a "death by a thousand cuts". The biggest hassle of all is without a doubt the work required to pass the JAA theory exams; especially for an older person. Probably the next one is the requirement to use an FTO; this means that most pilots cannot do the IR at their local PPL flying school, and need to stay in a hotel.

A popular and very cost- and time-efficient option for the FAA IR, in both the USA and Europe, has been doing it with a freelance instructor over a period of time, while flying one's own aircraft on business and leisure. This is not impossible under the JAA system but the high costs (anything up to £130/hour) of FTO instructors mean that practically nobody is going to do this with the JAA IR. A 700nm trip, with an overnight stay, is going to set you back some £1500 just for carrying the instructor along, but the flight-instructional value of a long trip is small.

The bloated JAA IR system is the result of decades of European job creation and protectionism, and a lack of political support for IFR GA. In Europe, and anywhere outside the USA with the notable exception of Australia, nobody in power cares for private IFR capability, which is permitted grudgingly under ICAO obligations. Whereas in the USA "professional pilot" status is correctly attached to the ATPL, in Europe it has become attached to the IR (an ATPL is given to a CPL/IR holder who has accumulated 500 hours in a multi pilot aircraft and passed a flight test) and this attachment has kept the IR firmly the province of "professional pilot training" with all the excess involved in that. Ultimately, the JAA system is propped up by the seemingly unlimited numbers of starry-eyed young men willing to pay an almost any price in money and time to become airline pilots - a job which ceased being glamorous some 40 years ago.

The upshot of all this is that, historically, the number of UK private pilots doing the JAA IR has mostly been in single figures annually.

On the other hand, for a European pilot, the JAA IR is a more streamlined process than the FAA IR. For the JAA IR, you go to a ground school FTO, spend a load of money, study, sit the exams, then go to a flight training FTO (which can be the same one) spend a whole load more money, do the flight training, and get the IR. Large numbers of airline pilot (ATPL) cadets work their way through this sausage machine every year and it works. The FAA IR is also streamlined if done wholly in the USA, and is much more accessible and much cheaper than the JAA one. Unfortunately, over the past decade, various changes have increased the "hassle factor" of the FAA IR for non-US pilots. Visitors to the USA need the M1 Visa for flight training (which restricts which US schools can be used, to Part 141 schools). For pilots wishing to do it all in Europe, FAA-acceptable training is easy. Various "outfits" offer it, or it can be done with freelance FAA CFII instructors, and (not many people realise this) all training done anywhere in the world including within the JAA system is acceptable to the FAA, regardless of the registration of the aircraft used. It is organising the FAA checkride in Europe that has usually involved various hassles. Today, I recommend anybody wanting an FAA checkride to just go to the USA and take advantage of the lower costs there to finalise their training.

Terminology: JAA or EASA?

At time of writing JAA has ostensibly ceased to exist and EASA has only just taken over Flight Crew Licensing (FCL). In general, EASA proposes to pick up existing JAA licenses and ratings directly, so these terms can be regarded as interchangeable.

JAA ATPL or JAA IR?

On the current EASA proposals, a private pilot will need a JAA PPL and a JAA medical, plus a JAA IR if he wants to fly under IFR.

Bizarrely, the full IR will be needed for UK night flight too which despite being "IFR" can at present can be done on a plain PPL with a Night Qualification. This is one of many examples of a cockup which has now been in the pipeline for several years without anybody doing anything about it.

Assuming you already have a JAA PPL, you have two options for the IR: (1) the 7 IR exams, or (2) the 14 ATPL exams. The former is what this article is about. The latter leads to a "frozen ATPL", which means you have met the requirements for the issue of an ATPL except the hours and the flight test. A separate application must then be made for an ATPL which also requires 500 hours of multi pilot time and a type rating on a multi-pilot aeroplane which obviously requires an airline (or similar) job.

The written exams for the two do not correspond. The 7 IR exams are not a direct subset of the 14 ATPL exams - at least this is the case in the UK and (4/2013) Germany . You have to do all of (1) or all of (2). A particular IR exam (e.g. Air Law) has a slightly smaller syllabus than the ATPL exam of the same name. The only exam cross-credit is that the holder of a JAA CPL, doing the JAA IR, is exempted from the Human Performance & Limitations exam. When JAA originally came along, the IR exams were a subset of the ATPL exams, but a campaign by PPL/IR EUROPE resulted in the reduction (in UK CAA versions of the exams, anyway). This was good news for private IR pilots but it greatly reduced the number of FTOs supporting this different package of study and exams.

It is however possible to sit all 14 ATPL exams, do the IR flight training and test, omit the CPL flight training and test, and end up with just a PPL/IR. Rather pointless, unless you need "CPL knowledge" or "ATPL knowledge" for some reason (see notes later on).

A useful concession is that the holder of an ICAO CPL/IR can do a JAA CPL/IR without having to do any mandatory classroom for either the CPL or the IR.

Here is an example of a dead end: Sit the 7 IR exams and do the IR flight training and test, and later (or earlier) sit the 8/9 CPL exams and do the CPL flight training and test. You now have a CPL/IR. But because the 7 IR exams were not a subset of the 14 ATPL exams, the resulting CPL/IR can never become an ATPL... Why would anybody do this? Perhaps a JAA IR holder who did the IR a while ago and doesn't want to go through the exams again, but who needs a CPL to do some paid work, but will never need to do a jet Type Rating. The exam workload is also slightly smaller due to the smaller QB: the estimate from one pilot known to me who did this route is that it was about 30% less work than the ATPL exams.

A number of JAA FTOs spout disinformation to get customers to do the whole 14 ATPL exam set because it fits into their classroom system and makes them more money. And if they can convince the punter to actually do the CPL and IR training (despite him having no ambitions to be a commercial pilot, or an instructor), so much the better However, to be fair, it is also not very economical to run PPL/IR courses for the small numbers of pilots doing them.

Remunerated N-Reg Part 91 Turboprop/Jet Operations

These are scenarios where an FAA (or similar, e.g. IOM validated) licensed CPL/IR or ATP is being paid to fly an aircraft owner (or company employees, in the case of a company owned aircraft) around the world. These are not public transport operations and an ATPL is not required even for the LHS of a jet. This is one of the most controversial areas of the EASA proposals because there are hundreds of such operations around Europe and the pilots stand to lose their jobs unless they somehow acquire the duplicate Euro papers.

Exactly what "duplicate Euro papers" will be needed is an area where different people have different views, because fundamentally the EASA requirements are non ICAO compliant. The strictest interpretation is described here (local copy) which is that you will need, in full, the EASA papers which would be required if the aircraft was EASA registered. At the other end of the spectrum is a view that since these EASA-mandated papers will not be valid (for most flights) under FAR 61.3 (because they won't have been issued by the owner of the airspace) and therefore a JAA PPL/IR (ME if applicable) should be sufficient as this legalises the flight itself in the particular airspace, and a requirement for a CPL does not make sense because while a CPL is required under ICAO to cover pilot remuneration, this EASA CPL will not have any State of Registry (ICAO) validity. In between these two positions, it appears that a straight JAA/EASA "CPL/IR" should be fine, even if it is the "dead-end" route mentioned above. It will be interesting whether the EU forces each member country to file the appropriate differences to ICAO... EASA has tried to get a seat on ICAO but was told - quite correctly - they can have one only if all EU members resign their seats, which of course they refused.

The only concession EASA is making in all this garbage is that ICAO Type Ratings will be accepted directly, with a flight test and some other requirements - page 171 here.

 

JAA IR Options Around Europe

Ground School

The bottom line is that a pilot who is flight training in the UK is best advised to simply sit the IR exams in the UK (at CAA Gatwick). They currently (8/2011) cost £69 each.

These well established exams are supported by the easy availability (example) of some "IR" question banks (QBs) which purport to contain the actual questions from the 7 IR exams. These QBs are actually far from 100% accurate but are good enough.

If doing an ab initio IR, JAA mandates a classroom attendance; it requires 200-250hrs of study for an approved IR course and 10% (min) of the hours must be in the classroom. However, the actual hours a school does in the classroom depend on what is specified in the course approval they applied for, and a lower figure is possible.

For existing ICAO IR holders, a number of European CAAs allow you to skip the classroom part entirely. In the UK, this is "at the discretion of the Head of Training" but in practice is standard. This alone can be a good reason for e.g. an FAA IR holder living outside the UK to do the UK IR theory and exams, rather than his local (e.g. German) ones. Germany in particular seems to have some weird minimum classroom requirements.

The English JAA exams can be sat at various places around the world e.g. USA and certain British High Commission premises in far distant places. Most of the papers are the UK CAA ones which is a significant source of revenue for the UK CAA.

Flight Training

European protectionism means the JAA IR flight training cannot be done outside JAA-land. The PPL and the CPL can be done in the USA, etc, but not the IR.

The UK runs a system with a strict reputation, which probably is historically deserved given the ex RAF examiners, the mandatory use of window screens instead of the IFR hood, and the enthusiastic pursuit of NDB holding procedures. During 2011, the UK CAA flight tests have become more flexible and up to date, with GPS and autopilot use being allowed in some enroute phases of flight (details). While NDB holds and approaches remain nominally in the test and must be 100% hand flown, the difficult requirement for being established within 5 degrees of the inbound track in the NDB hold for 15 seconds (previously 30 seconds) has been removed. 1/2012: Other nonprecision procedures may be tested instead e.g. VOR or possibly even GPS/RNAV. The "gate" method of flying NDB holds (necessary to achieve the old inbound tracking requirement) is still taught by most FTOs but is no longer examined. When flying an NDB approach you are still supposed to be established within 5 degrees of the track before commencing any descent, but you normally have a longer distance to do that than in the hold. Some slides from a presentation by a CAA examiner can be found here (local copy).

Unfortunately, the "170A pre-test test" remains. This was established in the UK in the 1970s because far too many poorly trained IR candidates were being put forward for the IR test, were failing, and were wasting the then very limited CAA flight tester availability. Today, the 170A is no more than a course completion certificate which the FTO has to give you once you have done the hours (15hrs for an IR conversion, 50/55hrs for the ab initio SE/ME IR) and completed the syllabus, and you can book yourself the IR test (IRT) directly with the CAA regardless of whether you have "passed" or "failed" some "170A flight test". If you pass the IRT then, with a completed SRG1161 which the FTO must also sign, you apply to the CAA to have the IR added to your licence, which can be done in person at Gatwick. This route ensures that an FTO is no longer able to block a candidate from proceeding to the IRT, e.g. by repeatedly failing him on various small points. Unfortunately there are UK FTOs who make the 170A "flight test" much harder than the real IRT and repeatedly fail the candidate on relatively minor points. This is a dishonourable practice because a candidate deemed ready for the 170A flight is ready for the IRT, but it achieves two objectives: it makes extra income (a 170A in a twin is about £1000), and produces good 1st time IRT pass figures (the CAA data does not show how long people took and how much money they spent ). This document deals with some changes under EASA, and page 18 has an interesting if cryptic note on the 170A... interesting it doesn't refer to any "170A flight test", which is actually correct.

Some JAA IR notes (from early 2009) are here (local copy). The "late 2009" date for the "slimmed down exams" mentioned in the foregoing actually slipped to late 2011.

In northern Europe, test standards are similar to the UK although only the UK uses the window screens. I don't think there is any point in a UK pilot looking to do the IR flight training and flight test in say Germany... Under EASA, the UK CAA window screens will probably continue, but you will be able to pop over to e.g. France or Spain for just the flight test.

Switzerland offers an interesting variation for the IR conversion: there is no minimum training (no 15hrs) but you don't get the ground school exemption. Unfortunately I never got any reply from Swiss FTOs when I asked if they will accept UK CAA exam passes. I did hear indirectly from an un-named Swiss FTO that they do not accept UK CAA exams, they do allow training in an N-reg, but the checkride needs a Swiss-reg aircraft.

I also checked out France and Italy. France is known for being "relaxed" on aircraft registrations used in private training but no French FTO returned a meaningful reply. One Italian FTO replied that they could do it if they got a dispensation from the FAA for an Italian CAMO to do "surveillance" on my aircraft; I can see where they are coming from but I am sure this is a misunderstanding of the ICAO process whereby the FAA merely requires Part 91 maintenance and anything extra can be done locally without reference to the FAA.

In southern Europe, things get more interesting, with less formal training and flight tests, not to mention more edible food For an already experienced pilot, these present an opportunity to collect the JAA IR papers more easily.

The UK IR system, with its high FTO costs (inflated further by the "170A pre-test test"), the emphasis on NDB procedures, the window screens (which are routinely derided by IR instructors outside the UK as unsafe) and the unpredictable weather have driven many pilots to do their IR training in the south, with Spain being a popular location. Some well-known FTOs are FTE-Jerez and Fly in Spain (FIS). As usual some Pprune comments can be found here. I have had good reports on FIS, they communicate well, and a couple of pilots I know did the IR conversion there in just 1 week. FTE has been known to have visiting UK CAA IR examiners who subject the candidates to the UK regime of NDB holds; a good reason to avoid it I believe that one can use one's own aircraft at FIS but it must be EASA-reg.

Other Spanish options are: Aerodynamics Malaga (described by a local pilot as a popular conversion route, if a bit of a sausage factory), and Aeroclub de Sabadell (a massive aeroclub with over a thousand members, and one of the first FTOs in Spain). The latter's disadvantage is that they insist on a joining fee of like €800 and have no temporary membership options. One would need to go there and talk with the examiners face to face to check them out.

Another option is Greece where I have flown a number of times in the TB20. A list of FTOs is here (local copy). With the exception of Egnatia Aviation at Kavala LGKV which I have twice visited (2009, 2011), I have not been able to make any meaningful contacts with Greek FTOs. Like the Spanish schools, Egnatia gets a mixed feedback on Pprune. Like many other people, I have found them less than responsive to written communications, but Greece will never be a "Germany"... There is no avgas at LGKV (or anywhere near, with Thessaloniki LGTS having lost its avgas supplier in 2010) so Egnatia operates Diamond diesel aircraft (2xDA40, 2xDA42). Egnatia offers a package for a conversion to a ME PPL/IR, done in a DA42, for about €6k including accommodation. The price falls a little for a SE conversion in a DA40. They provide free but basic accommodation in Keramoti (a very nice nearby former fishing village) and free transport and there are plenty of nicer hotels there anyway. This certainly beats hacking around the UK drizzle in a beaten-up Duchess The school is just 15 minutes away from Keramoti and car hire is a must (cheap: Europcar, Kavala, €170 for 1 week) otherwise one is relying on the "school bus" timetable, and taxis are pricey. Wearing the full pilot uniform, with no short trousers allowed, is unfortunately mandatory for all customers, which will take some getting used to in the summer, but you will have the immense satisfaction of setting fire to it once you have the new IR. Thomson fly from Gatwick direct to Kavala in the summer; the much better served Thessaloniki airport is 5 hours away by bus; 1.5hrs by car. Egnatia is at the top of the list for a pleasant environment to spend the (estimated) 2 weeks - if you are happy with their lack of prior written communication. Update 2/2013: Egnatia has been reported as rather disorganised, but its CPL/ME/IR training remaining effective. Car rental is also advisable i.e. avoid the "school bus" transport.

The southern countries have the advantage of good weather which ensures the project is done on schedule; this is obviously important as you will be staying in a hotel. It's worth noting that UK IR training will also involve hotel residence for most people due to the FTO requirement. The converse of this is that if you get bad weather, you will be stuck out there with nothing to do except perhaps some simulator time, and both Greece and Spain do get bad weather in the winter.

The reduced formality of the training and checkrides results in these countries being bad-mouthed by the UK FTO scene and this must be borne in mind when reading comments on pilot forums etc. The UK CAA is often quoted as not happy about people training abroad but in reality they present no obstacles to it. There have been cases where the CAA required a photocopy of the examiner's certificate to check that he had a valid IR when he did the flight test... it is highly advisable to obtain this document before handing over any money. Equally, the Spanish and Greek schools bad-mouth each other. A lot of the comments on Pprune are posted by what are obviously employees or owners of the schools.

Unfortunately there is a fine line between informality and poor organisation. A lot of time can be wasted and some of the accounts I have read of some other Spanish schools resembled Fawlty Towers. Nevertheless a lot of ATPL training goes on down there, despite private GA activity being very sparse.

Unsurprisingly, there are JAA IR training facilities in most of Europe, but most of the FTOs are not well organised for English-only speaking students, and it looks like most of them are simply not interested in talking to foreigners. For example, I checked out Croatia and Slovakia, neither of which were worth pursuing. One FTO in The Netherlands wasn't interested either. According to a pilot in Belgium who enquired via his CAA, no "15hr" or any other conversion route is available, so Belgian pilots are best advised to do theirs in the UK.

Aircraft Requirements, and N-reg Aircraft

The UK CAA has certain requirements (local copy) in Standards Document 7(A), for the aircraft used for training and test. This document details the window screens too. They are often attached by velcro which can leave a mess from the glue (which is not an issue if you are using the FTO's aircraft ) but I am advised that suction pads may also be used. The screens are required for the flight test only (the training can be done under a hood) but in practice most UK FTOs train with the screens so the candidate gets used to them. They can create a claustrophobic feeling in the cockpit (though I never had problems with those I constructed) and obviously the instructor's lookout for other traffic is not as good. Other relevant issues for owner aircraft are some required avionics, and no owner maintenance is permitted since the last service signed by an engineer; for an N-reg this means the last 50hr check needs to be signed off by an A&P.

For the screen construction one can buy a large pack - about 5x more than is eventually needed - of the Correx material on Ebay for about £25. It is an easy but time consuming job, starting with making a template for the curved LH window, cutting the material to fit that, and hot-gluing the whole thing together. I found that a standard hot glue gun (£10) does a great job, with the joint being stronger than the material itself. Thankfully, for an owner aircraft in which the screens will (hopefully ) be used only once, the screens do not need to be made to a high standard. The whole job took a day in the hangar. The 20mm suction cups also came from Ebay; fortuitously I bought two different lots because one lot turned out to be completely useless (too stiff).

To comply with the requirements, the screens (pics; 16MB zipfile) need to obstruct a 120 degree field of vision centred on straight-ahead. In practice this means blocking the forward part of the LH window and the whole windscreen. One can see above my front screens but all one can see is the sky. The screens used by the FTOs usually go all the way up to the ceiling (and make for a rather dark cockpit) but this is in excess of the requirements. The CAA approved my screens without problems.

An article here (page 6 onwards) describes the construction of the screens by another pilot, for the older TB20 airframe, a few years previously.

The various CAA charges which apply are in this document (local copy). On page 7 you can see the £177 charge for inspecting the aircraft and the screens.

Update 9/2013: The aircraft requirements are now in Standards Doc 7 (local copy).

The insurance needs to be amended for the flight test. Virtually all aviation policies already allow continuation training, but the UK CAA requires the insurance to contain specific wording: It is hereby noted and agreed that, notwithstanding anything contained herewith to the contrary, this policy is extended to indemnify the assured in respect of liability in connection with flying training and testing for pilots licences and ratings by employees of the Civil Aviation Authority (CAA) Flight Examiners and other approved Flight Examiners. The passenger legal liability insurance is extended to cover CAA employees whilst acting as crew members.

I was unable to find any non-UK FTOs which support N-reg aircraft for both the training and the flight test. However, much later (3/2012) I found this FTO in The Netherlands which reportedly does it.

Many FTOs refuse to work with a customer's aircraft and this attitude appears more common outside the UK, which makes the UK the favourite for an aircraft owner doing the IR conversion route. The price is probably the strictest flight test around (requirements local copy) and having to construct (or borrow, etc) the window screens.

The good support of foreign-reg aircraft in the UK appears to date to this 2005 helicopter-related document (local copy). The helicopter scene has a long history of using N-reg, which unlike the fixed-wing scene was not driven by the FAA IR (there are almost no IFR approved helis below the level of a twin turbine).

In the UK, if the aircraft is N-reg, or any non-JAA reg, you need to get the Department for Transport permission for the entire period of training and checkride. The details are here (local copy). To their great credit, the DfT processes this free of charge, entirely by email, and normally within a few days. The most relevant bit is the following which prevents an N-reg being used if e.g. owned by too-large a syndicate: Permission for flying training will normally be given only to the owners of the aircraft concerned or to any pilot employed by the owner to fly the aircraft on their behalf. If the aircraft is owned by a Trust permission may be given to the trustor. If the trustor is a group or company permission may be given to members of that group or Directors if the number of members or Directors is no more than four. However, the DfT is normally pretty good about giving permissions for user categories outside the aforementioned and for example they have given a permission to someone I know to do it in an N-reg plane borrowed from somebody else.

Problematic Combinations

Despite the JAA attempt at "unification", it is not possible to freely mix (geographically) theory exam passes, flight training, and checkrides. Some info on what is acceptable to the UK CAA can be found in LASORS here (local copy). After 17th Sept 2012 LASORS is replaced by CAP 804 which appears to contain similar information. Beyond what is in LASORS, one is into "grey" territory. I have managed to check out a few things:

All UK flight training FTOs, and many European FTOs, accept the UK theory exam passes.

But it does not work the other way round: if you sit the exams outside the UK, the UK CAA will refuse to add any resulting IR onto a UK license unless the flight training and checkride were done in the same country as the exams. So if you sat the exams in Greece (where they cost just €5 each, in Athens) you would need to do all the flying out there also. This low cost is not unusual (Slovakia is €18 total, for all the exams) and the UK CAA seems to be the biggest ripoff on the exam costs, by a vast margin.

Similarly, the UK CAA does not accept an IR onto a UK license where the training was done in one country and the checkride in another.

It appears that the only "mixed" IR combinations which are sure to work with a UK license are:

1) doing exams+training+checkride in the UK (obviously)

2) doing the exams in the UK and the training+checkride in another country;

3) doing exams+training+checkride in another country

Pilots who are resident, and flight training, outside the UK would naturally do the exams in their own country. However, if say you sit the exams in Austria, you may find that no Spanish or Greek FTO accepts the Austrian exams, and Austria is your only flight training option. I have never checked this out however, and it is probably false because at least one of the Spanish FTOs is run from Austria anyway.

As a general note, the IR exams must be administered by the State approving the FTO and this would appear to preclude option 2) above, but there appear to be bilateral agreements in place which cover - at least - specific IR FTOs outside the UK, and possibly only for exams done in the UK or in the FTO's country.

The CAA document for adding a non-UK (JAA) IR onto a UK license is here (local copy). You can see that it asks for various documents from the examiner, etc. In addition, the CAA has in the recent past requested a copy of the examiner's current IR.

An interesting bit of info is that if you do the IR conversion in e.g. Greece, the Greek CAA (HCAA) is not involved in issuing the IR. The HCAA examiner completes the UK CAA forms directly. This is just as well since the HCAA is known for taking months to issue new papers.

For the vast majority of UK pilots doing the IR conversion, it is advisable to do the exams first and then choose the flight training FTO as a separate exercise. If using a non-UK FTO, check that their local CAA (and their local CAA IR examiner) will accept UK exams for the IR issue, and get it in writing. Specifically check that they will accept the seven IR exams; certain non-UK FTOs I know of have formal acceptance only for the 14-exam ATPL set, and they do the 7-exam IR version under an informal agreement.

The proposed EASA system will change the above substantially, with exams, flight training, flight tests, etc, all doable in different places, but it is too early to consider this because so much is in a state of flux.

 

Need a JAA PPL or CPL

You must have a JAA PPL or CPL Licence to which the IR (a Rating) will be added.

In most cases, you will have a JAA licence from your own country, in addition to an FAA one. If not, you will have to get a JAA licence. It is easy to get a JAA PPL on the basis of an ICAO PPL; there is usually a "100 hour" route with 2 or 3 exams and a checkride. A CPL is more work and the most efficient ground school option is to sit all 14 CPL/IR exams.

Under JAA rules, you can have only one JAA Licence at any given time so e.g. you cannot have a UK JAA PPL and a Spanish JAA PPL at the same time. To apply for a local PPL, you need to show proof of 175 days' residence in the new country. This rule has not generally been tightly enforced, and there are pilots with a PPL from one JAA country and a CPL from another.

It would seem safer to go to e.g. Spain and get one's UK PPL changed to a Spanish PPL, add the Spanish IR to the Spanish PPL, and then fly around Europe on the totally-Spanish PPL/IR, which could be revalidated with JAA instructors / IR examiners anywhere. While this may be possible with e.g. the use of a Spanish "residence" address, it is likely to contravene the residence rule in Spain... and anyway the UK CAA does now seem to accept these non-UK IRs onto a UK PPL, so there is little point in pursuing that route.

Under proposed EASA rules, the same single authority will be required to hold the license and the medical records. This is quite an important change from previous practice. Whether it will actually be implemented, and whether one is prevented from getting a medical done outside one's own country, remains to be seen.

 

Medical Issues

For the JAA IR, you need either a Class 1 medical, or a Class 2 medical with the Class 1 audiogram.

The audiogram, done separately for each ear, is a pointless piece of European gold-plating of ICAO requirements, and is irrelevant to GA operations because one is wearing a monaural headset the whole time. It a big hassle which has stopped many older pilots (typically those with enough money to buy an IFR aircraft and actually fly it somewhere ) getting the JAA IR. If this audiogram is failed in either ear, the JAA IR is forever out of reach, even if the other ear is perfect.

There are some ways around this:

One makes use of recent CAA medical concessions (local copy) though these are new and mostly untested. The CAA does warn that EASA may overturn a medical granted in this way, but this is unlikely since EASA is way behind the curve in aviation expertise, and once you have a medical in the bag, and have renewed it a few times, you are pretty safe...

Another uses the obscure ICAO CPL/ATPL + ICAO Class 1 route, whereby if you have an ICAO CPL or ATPL and an ICAO Class 1 medical, you can arrange to have a UK CAA Class 1 medical done at Gatwick, and it is treated as a Renewal and not as an Initial which means you get the Demonstrated Ability (DA) concession on it. The CAA does not (nowadays) advertise this facility and the booking must be made by telephone. I don't think this option will be around for ever... Some notes are here. The ability to get DA on a renewal medical is available worldwide and is there to protect older airline pilots many of whom would otherwise be out of a job (e.g. hearing loss after 20,000 hours in a jet cockpit, mostly without a headset) but it is a moral perversion of the system, because it denies entry to demonstrably able newcomers while ensuring that any pilot flying paying passengers will have been flying with the full benefit of DA (on renewal medicals) for some years

Another route is this bizarre proposition which the CAA has made to occasional applicants: Having completed IR training, the applicant would be permitted to have the IR on a Class 2 medical, with Demonstrated Ability on the hearing. The obvious gotcha is that you are expected to spend a huge amount of time and money doing the IR, all the way to the flight test, in the hope that this concession is still around at the end and the CAA honours its unwritten undertaking...

 

Ground School

90% + Irrelevance

When I first got into this "project" I considered sitting all 7 exams in one go (which is possible over 2 days) without revision, and then revise properly those which I failed. This is not possible because you need an FTO to sign you off for the exams, which they won't do until you have handed in a quantity of homework. Also, the only exam in which a current IFR pilot might achieve the 75% pass mark without extensive revision is IFR Comms and even that one has a load of tricky questions.

If you are a pilot with good technical knowledge and "real IFR" experience you will get about 50% in each exam, right away. This is because you already know a great deal about aviation, and many of the questions are easily guessed if you think about them. I did a bunch of QB mock exams before doing any study at all and the best I managed was about 50-55%, and I was already a 1300-hour IR pilot who never had the slightest problem flying VFR or IFR around Europe. Reaching the 75% pass mark is far from easy, for a number of reasons:

1) At least 90% of the material is irrelevant to current practice in any conceivable branch of aviation (except just possibly flying DC3s in the Belgian Congo) so experience doesn't help
2) Many of the questions are ambiguously phrased or have multiple correct answers
3) Many questions are airliner ops related and a private pilot will be unfamiliar with these no matter how experienced
4) Many answers are all-4-wrong, due to regulatory changes since the QB was produced, or due to ICAO v. JAA/national variations (e.g. "descend to")
5) Guessing does not yield the expected 25% correct answers because the three wrong answers often contain one very plausible one, so the only way to get the free 25% is to be totally clue-less, which very few people are

The following comments apply to both the FTO study material and the QB:

Most of the JAA IR theory is irrelevant, out of date, garbage.

The aircraft-technical content often deals with equipment which went out of use at least a couple of decades ago - ancient 1960s RAF radar sets and early EHSI/EFIS products. Most avionics questions are based on a 737-400. Claims that "jet" related material has been removed are evidently incorrect since there is plenty of it, indirectly, in the study material. Some navigation and planning stuff is based on the old "virtual VOR" (KNS80-type) VOR/DME RNAV kit which has been practically useless for IFR in the Eurocontrol system for at least a decade. There are some aircraft performance exercises which involve specimen performance charts for "standard" (imaginary) piston aircraft types, but I have never seen such charts available for any piston aircraft. And it goes on and on, with reams of irrelevant stuff like working out the maximum range of a radar from the pulse repetition rate. There is of course the standard stuff about compass errors when turning in different directions; various mnemonics have been developed for that (example). It looks like the product of a committee made up of ground school instructors who have never flown any aircraft and whose expertise was well dated even by the time they started on this stuff.

HP&L plumbs the depths of irrelevance with questions on different types of sleep and their effect on the human body - stuff which is "somewhat" lacking in scientific consensus even today. There is some dabbling in CRM and random psychology topics (example example example). Getting one's head into the QB reveals a fortunately predictable "proper professional team player pilot, who goes to see an aviation doctor immediately if he suspects an ingrowing toenail " mindset of the authors. The HP&L exam is very small (24 questions / 30 minutes) but its QB has 840 questions which is bigger than most of the other subjects. The small size of the exam makes it easy to pass (I got 100% in one mock session) but it also makes it very easy to fail just by getting 7 questions wrong.

Flight Planning and Navigation are easy enough, so long as one remembers that most of it is unusable in Europe due to being out of date; the Eurocontrol computer will throw out most of the routes. Also, IFR flight in Europe is now a purely RNAV exercise, done with an IFR GPS, where even navaids are treated by ATC as RNAV waypoints and are issued as DCTs from much too far away to get signal reception. Due to the hands-on nature of these two subjects, I would recommend some sort of classroom or other similar "teaching" environment for this subject. One could learn it just by doing the QB but it would take a lot of work because no understanding would be developed. There are also some inconsistencies: questions concerning "cloudbase" or "cloud ceiling" apply only to BKN or OVC, not SCT or FEW. So if a question asks for the lowest cloudbase showing in a TAF which shows both BKN020 and SCT002, the expected answer is 2000ft. This is obviously nonsense if the SCT cloud happens to sit right on the glideslope when you pitch up there, but it apparently reflects some legal aspects of flight planning. However, this question uses the words "cloud base" while expecting an answer based on SCT cloud... Curiously, in the Met QB, everything I saw applied to the lowest cloud present, and "ceiling" was not used.

Meteorology is no more relevant but is harder to remember because the collection of facts doesn't fit into any kind of knowledge frame - unless you are a keen amateur weather forecaster or have Earth Sciences as a hobby. Bits of relevant material (icing, interpretation of TAFs/METARs, etc) are swamped by a vast amount of theory which cannot be applied because of a total disconnection between the theory and the ability to get real weather data to fit it. Modern pilot briefing is all internet-based but all this stuff pre-dates the common use of the internet by a number of years. Met is of course very important to flight safety, which is why the irrelevance of the syllabus was such a disappointment. On the plus side, an experienced IFR pilot already knows the "flight hazard" stuff like icing on which there are plenty of mostly very obvious questions. There are many altimetry questions, and questions on e.g. your true altitude reducing if flying into cold air and/or into a lower pressure; these are mostly straightforward. Many are variations of this one which you work out using the clue of "Melbourne" which being in the southern hemisphere together with the clockwise wind tells you that A must be a low pressure, so the true altitude there will be lower. QB revision is highly desirable to get a pass, however, because there are many atrocious questions like this one which has no less than three answers that are potentially correct, depending on the meaning of the word "passed" versus the meaning of the words "more than". There is a lot of overlap between Met and IFR Flight Planning.

Air Law is probably the hardest subject; very dry and packed with facts which need to be simply memorised. Due to reams of questions like this and this it took many mock exams to break through into the ~ 80% range. Reportedly the Air Law syllabus was written by an ATCO from Portugal; perhaps the EU felt obliged to compensate Portugal for its reducing influence on the world stage since their adventures in centuries past The most tedious are the light-medium-heavy traffic separation figures for different combinations of single and dual runways, etc, and I never did succeed in memorising those. In the classroom/FTO environment in which these subjects are traditionally done, various funny mnemonics have been developed which enable the otherwise intractable matrix of traffic separation figures to be generated, by writing down the mnemonic after entering the exam room and then deriving the separation matrix from it. For practical safety purposes, if you find yourself sharing an untowered airfield with a 747 (rather unlikely in Europe) a light aircraft needs to wait at least 3 minutes after a "big" one has departed. Due to the countless "traffic separation" type questions (which belong into an ATCO training syllabus, not into any kind of flying syllabus) just hammering the QB is not going to yield anywhere near 100%. Obviously it would work eventually, and it helps to memorise easy sequential things like minimum circling visibility requirements (1500/1600/2400/3600m for Cat A/B/C/D) because you are bound to get 1 question on that, but a reasonable policy is to "let go" of some questions, on the basis of their maximum likely weight in the exam.

I cannot help wondering why this situation, where almost the whole theory syllabus for not just the IR but the ATPL, is a load of garbage which is only marginally relevant to aviation, has gone on for as long as it has. While JAA got going only in 1999, the "ATPL" question bank has been packed with this garbage as far back as anybody can remember, and reading some old articles confirms it. Airline pilots routinely take the micky out of the irrelevant exams they did and immediately forgot, so why did they not make a fuss at the time, and perhaps made things a little bit more sensible for the thousands following them? The answer seems to be that most candidates are young ATPL cadets who are in debt up to their ears, they have done negligible flying at the time they do the exams so don't really notice the irrelevance, they are desperate to get an airline job which absolutely means not rocking the boat, and such campaigning organisations as they have are run by old fogies who couldn't give a damn about students. So they swat up, pass, get their flight training done, and get on with their job hunt. Many also became PPL instructors, to build up their hours, and since the JAA regime requires an instructor to have a CPL if he is to be legally paid for giving flight instruction (why, is an often asked question) there has been a lot of pressure on these cadets to get a CPL as quickly as possible.

The garbage theory is a missed opportunity, resulting in most ab initio PPL/IR or CPL/IR holders not knowing how to plan and execute a flight from A to B within Europe.

Where did this nonsense originate?

It depends on how far back one goes. The pre-JAA ATPL study material and exam questions date back to material which was used in the RAF post-WW2 and was discarded by the RAF in the 1950s. The civilian training scene has always been heavily populated with ex RAF personnel and some ex RAF people hacked the discarded material into the stuff which civilian airline pilot cadets studied for the following decades. During the last pre-JAA years, some of this long-obsolete stuff ended up in the right place and the right time as the only "approved" study material when JAA came along, so the FTOs had little choice but to buy it and run with it.

JAA started around 1999 by inviting each State to contribute exam questions. Different countries got to contribute different topics. These were combined into a Common Question Bank (CQB). With e.g. Portugal contributing questions on Air Law, this process resulted in a large amount of garbage, especially after translation from/to the various languages. Many questions were off-syllabus, had wrong answers, or were so badly written or translated that nobody could understand them. Over time, some of the national CAAs weeded-out the worst ones but many remain. Even now, 13 years later, it is common for a student to discover a question which is outside the syllabus, and if you failed the exam by just 1 question, it is worth an appeal. Reportedly, the UK CAA stopped acting on FTO objections to specific questions several years ago so appeals have to be done by the student personally. It is nevertheless widely accepted that the UK CAA papers are of higher quality than JAA papers from elsewhere in Europe, where the national CAAs have mostly not bothered to do much weeding. This also means that for a student sitting the UK JAA exams, the QB questions are significantly harder than questions found in the actual exams, but a student sitting the JAA exams elsewhere in Europe is going to get the garbage questions too. I am informed by a German IR student that the German version of the JAA QB has been substantially cleaned-up too in the past year or so.

The actual exam questions remain unpublished and even the FTOs do not have most of them. Originally, the largest UK FTOs compiled their own question banks by assigning each exam cadet 5 questions to remember, and a man from the FTO stood outside the exam room with a notepad and quickly noted down the details before the cadet forgot. Over years, each FTO built up a QB, which they used internally Some of these FTO QBs (e.g. Bristol or Oxford ATPL ground school) are nowadays circulating around the internet and can be found on P2P and bit-torrent networks. Some are PDFs, but some are executables which are best avoided for the usual virus reasons. I have a collection of the PDFs here. Later, around 2007, two groups of students did a "Freedom of Information" legal challenges in Denmark and Belgium and got the real JAA QB, and later it was translated into English. The FTOs have this too, of course, and they try to keep it reasonably current by asking exam students if they saw any unusual questions. So the "QB" is actually a number of QBs, none of which quite match the exam questions, and this is evident from seeing the occasional question appear in the exam which even the most diligent QB student has never seen before, but it doesn't matter because you only have to get 75%.

My impression is that the 7-exam IR QB is of the worst quality of the lot, because no real version of it was ever obtained by anybody, and the QBs that do exist (e.g. the FlyingExam one mentioned below) were generated from the ATPL QB by removing questions not in the IR syllabus. The CAAs will have done the same process to generate the exam questions but who knows which ex-ATPL questions they have removed... With the tiny number of people doing the JAA IR (compared to the large numbers doing the ATPL) there is very little feedback to correct things.

Update 12/2012: I understand that this site offers a much better question bank which corresponds well with the latest exam questions.

FTO Study

In the UK, an ICAO IR holder can skip the mandatory classroom attendance. However, this is worth less than it appears. An FTO is understandably concerned that they might get a load of people taking up this option, doing insufficient study, failing the exams, and making them look bad in the eyes of the CAA. Also, an FTO is required by the CAA to teach its CAA-approved syllabus and it has to somehow reconcile this with the no-classroom option. Consequently it is not possible to just pay some money, self-study, and sit the exams, as one does for the FAA exams. The FTO gets you to do a quantity of homework. There does not appear to be a formal minimum score but it is apparent that if you make a complete hash of it they won't sign you off for the exams.

The amount and format of the homework are highly FTO-specific.

Also, most FTOs do just the full 14-exam ATPL syllabus and only a few offer the 7-exam "IR conversion" option. The currently known UK ones are

GTS
CATS

GTS, which I chose for the ground school due to their proximity in Bournemouth, charge about £850 for which you get a number of ring binders (approx 3000 pages), a ~10cm thick Jeppesen ring binder with charts used in the nav exams, and a quantity of multiple choice homework sheets. Total weight is about 15kg. They also offer optional classroom study at about £180 for 3 days. This level of pricing is pretty standard in the UK. With the exams at £69 each, this makes the cost of passing the 7 exams about £1500, plus any travel, hotels, etc.

The GTS homework is based on their paper study material and is thus relatively time-consuming because it cannot be done without going through the study material fairly thoroughly. Simply reading the entire factoid-packed text does not, I found, result in a sufficient retention to do the homework adequately. It contains apparently only few QB or QB-like questions, so prior QB revision does not help much. More homework arrives by email nearer each exam session.

So even if you know enough to pass the exams straight off (which is highly unlikely - see below) work equivalent to many evenings is still required. A pretty obvious solution, which I recall from what some overseas students were doing during my university studies in the 1970s, is to get somebody else to do the homework for you while you are hammering away on the QB Alternatively, if sharing accommodation with other IR students, one could do it as a group effort and I gather this is exactly what happens on the ATPL cadet scene.

Due to the timing of my entry into the IR process and the fixed exam schedule, I did Module 2 first, and for this I took up the 3-day classroom option at GTS. The teaching was good. The full syllabus was taught, rather than concentrating on questions known to be in the exams. Whether this is an efficient use of the time obviously depends on your viewpoint but this is what an FTO is supposed to do. I was however disappointed at the lack of relevance to real aviation (which is mirrored in the QB) and an apparent discrepancy between the time spent on some topics and their likely weighting in the exams. Instrument errors were covered thoroughly, but these are either minuscule in modern avionics (e.g. acceleration errors on a horizon) or impractical to allow for in flight (e.g. the hard to remember combinations of compass errors during turns in the four quadrants; if you really fly on the compass alone, you turn gently, or do timed turns). Some would argue that this is how everybody studied before the QBs but in reality the big FTOs always had a big collection of questions known to be in the exams; the only question is whether they dropped them into the classwork and homework assignments discreetly, or openly. Due to my engineering / aviation background (and ~ 1300 hours) I had little trouble with most of Module 2, and I did pick up some bits which must have been worth a few % in the exams, but soon decided to not bother with the hard to remember stuff and take a chance on it in the exam.

A little bit of the material was relevant to actual flying. In IFR Flight Planning, we did approach plates and SIDs/STARs. Unfortunately one quickly got into areas which became obsolete a decade or more ago: route planning by following "suitable" airways on the airways chart has not worked in Europe since Eurocontrol got going about 15 years ago. The development of valid routes has long been a nice earner for premium-priced flight services, but nowadays it is accessible to anybody with the right software tools. It's particularly depressing for a current pilot to see how shallow the coverage of important IFR topics is in the JAA syllabus, but it came as no surprise since I have long lost count of the number of JAA IR holders who have told me they cannot fly anywhere.

On the plus side, when I followed up the GTS classroom time with some QB revision, I found I was getting OK marks on the QB quite quickly.

The charts used in the CAA exams are almost entirely Jeppesen, which at least recognises that Jepp have taken over the world and other chart providers (e.g. Aerad) are passing into obscurity and anyway were barely ever relevant outside Europe. The thick Jeppesen ring binder contains a selection of IFR enroute and approach charts and, surprisingly, some pages from the old Bottlang VFR guides (these now come as "VFR" pages in Jeppview). All this material is dated c. 1998 and even if you were allowed to bring current charts into the exam room they would not correspond to the exam questions (magnetic variation changes, etc).

One gotcha I found in the classroom is that the 1:500k or 1:1M ruler normally used in distance measurement did not work on the supplied Jepp charts, because they were not to scale. I was surprised by this, given that Lambert Conformal Conical aviation charts are supposed to be good for both angular and linear measurements, and the appearance was that the 1998 Jepp charts supplied to the FTOs are printed slightly reduced - about 10%. The scale printed on the edge of the chart must be used for all distance measurement, with dividers or some similar device. I have some later (2006) Jepp VFR charts and the scale on those is spot on, so either Jepp VFR charts in 1998 were not printed to scale, or the 1998 charts which the FTOs use (I have no idea who prints them; possibly Jepp have a nice sideline printing batches of 1998 charts ) are for some bizzare reason printed undersize!

To an existing IR pilot, the Flight Planning stuff is trivial but due to the hands-on nature of it, I would recommend some form of tuition (FTO or private) for this - even if it is just a day. You need to know which bits from the Jepp binder to use for what, etc. The remainder of the JAA IR theory is quite doable wholly using QB revision...

Due to being away, etc, I didn't do any classroom time on Module 1.

An FTO has to get CAA approval for its study material. GTS got their material from a business called PPSC which is believed to be the same company as GTS. Some other FTOs also use the same material, which is reportedly based on classroom notes used by the RAF in the 1950s and 1960s.

CATS has also been very popular for IR conversion ground school. Their pricing is in the same region as GTS but everything is online; the Jeppesen ring binder is available separately if you cannot find it on e.g. Ebay. I understand from recent customers that their homework comprises of "progress tests" which are extracts from the QB and one gets signed off for the exams on the basis of those. Since the majority of the CAA-approved FTO study material is of little relevance to practical flying, this approach appears to be much more efficient.

Question Bank Learning Strategy

The QBs are probably only about 80% accurate but that is fine because QB revision (generally, doing a large number of randomly populated mock exams) is dramatically more efficient than learning from the FTO study material. Also many actual exam questions, while not appearing verbatim in the QB, are re-hashes of questions found in the QB. I am informed by recent ATPL graduates that nowadays almost no ATPL student does exam revision from the FTO material and those who have tried to be "proper" have ended up failing a number of exams.

The trick is not to simply memorise all the answers. Well, in many cases like this that is all one can practically do, and reportedly the big FTOs have a lot of foreign students who speak poor English and they do just memorise the QB, but that is a very slow and tedious process. Try to use the QB answer to understand the question. In any given subject's QB, there are usually a dozen very similar questions and if you can do one you can do any variation of it.

Don't try to memorise the A/B/C/D answers e.g. "question ID #1575 is answer C". Doing so would be a superhuman feat of memory anyway, but the answer sequence will differ in the exams. Just memorise the actual correct answers, by thinking about each one for a little while.

I used the FlyingExam QB. Access to this, for a 1-month period, was offered as a part of the GTS package. It is a strangely designed website. To prevent ripoffs by screen-dumping each page, it is hacked to show only a part of the question (in most cases) so it requires scrolling to see the question. The Iphone Version of the site solves the scrolling issue, and works on all browsers I tried. But there is no way to print off a question, short of a graphical screen dump. The site uses extensive Javascript to download each subject QB to the browser, and to prevent copying of the text by selecting it (however, selection does work on the Safari browser on the Ipad...). These anti-copy measures seem pointless given that ATPL QBs, of which the IR QB is a subset, have been out there in PDF form for ages. A valuable learning feature is a re-sit of all questions failed during the most recent exam. Unfortunately, this feature fails (the Javascript code crashes) if you take too long to do a particular exam. For example, it crashed after I finished the 2-day HP&L and Air Law sessions so I lost the record of questions that I failed. Many of the weather charts provided are barely legible (example) but fortunately the actual exams have clear versions and most of those questions are easy for any current pilot who can read wind and SigWx charts. Some diagrams are dead links. I reported all this at the time but 2 months later it remains unfixed. The site works fine if you just sit the random mock exams of say 50 questions each. I recommend running this site on a device which makes screenshots easy (e.g. an Ipad); a screenshot of each failed question sidesteps the above mentioned loss of session when doing the entire QB for a particular subject. Despite my criticism of the site, it works well enough and I did all my QB revision on it.

The FlyingExam Air Law QB contained many obviously-ATPL questions and I reported these to GTS early on, and sure enough they were gone by the time I worked through the whole Air Law QB some months later. I don't know how many years this QB has been going but evidently most people just grind through this stuff and keep their mouths shut, which does everybody a huge disservice.

Another QB vendor is Peters Software. Unfortunately it is not clear if their IR material is the full ATPL version or the reduced IR-only version. They did not reply to my emails asking them, and when I asked their sales reps at the Aero exhibition at Friedrichshafen, they didn't have a clue and were more interested in the girls

One QB vendor recommended by some pilots is Dauntless. This one is €55 for the JAA IR QB. I had frustrating and inconclusive correspondence with them in trying to establish why their IR QB is 10 exams and not the standard 7 exams... I suspect they have the same product as Peters Software. I know of some pilots who used the Dauntless ATPL QB for the IR, but obviously they had more work because of the extra questions.

To the best of my knowledge (9/2011) the only "UK JAA IR" QBs are the FlyingExam one, and the one provided when you sign up with CATS.

Update 12/2012: I understand that this site offers a much better question bank which corresponds well with the latest exam questions.

Exam Validity

You must pass all 7 IR exams before the IR flight test. In practice, given the ease of failing some of the exams and the rigid exam timetable, this means getting all exams done before commencing flight training.

The exam passes are valid for 36 months, measured from the last pass to when the Rating is issued by the CAA (CAP 804 Section 4 A). If the exams expire before the IR checkride is passed, they all have to be done again, and anecdotal evidence is that the UK CAA enforces this strictly.

Officially, the only uses I am aware of for expired exam passes involve "CPL knowledge" (9 exams; required e.g. in current EASA proposals to allow a PPL FI to be remunerated) or "ATPL knowledge" (14 exams; required e.g. in connection with some turboprop class ratings). Just having the 7 expired IR exams appears to be worthless. However, there are known cases of expired JAA exam passes being allowed towards some license conversions or validations outside the UK.

The Easiest Way - for a pilot doing the IR conversion...

Due to the size of the FTO study material, and the irrelevance of most of it, heavy QB-based revision is the most efficient way by far, for all subjects except those involving the use of the charts in the thick Jepp ring binder. I had browsed the JAA study material on numerous occasions between 2000 and 2011 and was appalled at the contents. Now that I have had the "pleasure" of it close-up, it is no surprise that most aircraft owners don't want to touch the JAA IR with a bargepole. Had it not been for the QB, I would have never bothered with it; I would have never found the time to study all that garbage. The QB has really transformed the "doability" of these exams; I estimate the workload has gone down by a factor of 5-10 times.

For those who like to get extra help, there is no doubt that classroom time (GTS did 3 days per module i.e. 6 days if you do the whole lot) will help you pass. I certainly found it beneficial for the Flight Planning/Nav subjects (which use the Jepp binder) because of their hands-on nature. However ti think you will achieve more staying at home banging the QB on the remaining subjects.

Choose the FTO carefully. If the FTO homework is based on the QB that is much easier because you are going to hammer the QB anyway. If the FTO homework is based on their study material, it will be time-consuming and you may as well attend the classroom and do the homework there. In the UK, this universally favours CATS.

For the exams themselves, don't try to achieve perfection. You need to get just 75% and nobody will question (nobody can find out) which questions you got wrong. The JAA system avoids any discussion of actual exam questions. There is no FAA-style oral exam where the examiner knows which exam areas you were weak in, and questions you on them. So it is reasonable to skip particularly difficult-to-remember questions.

To be safe, you need to be consistently getting at least 85% across at least 10 random-question mock exams, in each subject. I also recommend working through the QBs in their entirety, just once, linearly (not using a random order). That session will take about a week full-time, will cure insomnia for life (because you get a dozen of very similar questions one after the other) but will give you the flavour of the subject which is important as many of the actual exam questions are not in the QB.

I am not a fan of Apple's "media players pretending to be computers" (Iphone/Ipad) because their functionality is crippled in so many irritating ways but an Ipad 3G is super for the online (or PDF) QB revision, especially if used with a stylus. You can lie on a sofa and just bang away at it... Taking screenshots of failed QB questions is very easy (press the power and the round buttons concurrently) and the images end up under Photos where they can be easily viewed later. The battery lasts a whole day of solid work.

If you could get study material which specifically covers just the QB, that would be better than doing lots of mock tests. The only ones I have seen are some ATPL PDFs which circulate on the internet. These will have many extra questions which should not appear in the IR-only exams, and it isn't obvious which ones they are - even the author of the FlyingExam QB did not get this right.

If the EASA-enforced dual paper requirement really does happen, and no easier route emerges, there will be an obvious business opportunity for informal ground training based purely on the QB, perhaps including help with FTO homework. The pilot would still have to pay an FTO (it will be called "ATO" under EASA but the end result will be the same because they will have CAA fees, etc, to pay and will have to make money somehow) to get signed off to sit the exams. An FTO can't do such a course because it is supposed to teach the approved syllabus. However I am informed that some of the biggest UK FTOs have practically given up on "traditional learning" and use QB exercises heavily; particularly in some subjects like HP&L. Most FTOs do flight training and it's not in their interest to make the exams hard because they don't make money on re-sits, and re-sits merely delay the cash flow from flight training for that particular individual. However, it is hugely obvious that currently (9/2011) the number of Europe's FAA IR licensed pilots (some thousands) doing the JAA conversion is running at an extremely low figure.

I did HP&L, Met, Air Law and IFR Comms study entirely out of the QB, and the only reason I did not do the whole lot that way was because after the 3-day GTS classroom session I found I was scoring enough in the QB on those subjects to make heavy QB revision unnecessary.

Exam Strategy

If possible, do the hardest exams first. This is because 4 failures of any one subject force a re-sit of all exams already passed. I know 2 people with a brilliant memory who have done all 7 in one go (over 2 days). However, a pilot of average memory retention is strongly advised to split it up into two sittings, 2 months apart.

Which exams are hardest will depend largely on your technical/scientific interests and education. A mechanical engineer, or an experienced pilot with avionics knowledge, will find the Module 2 exams OK. A doctor will find HP&L OK but will tear his hair out at the number of wrong questions. An amateur weather forecaster / atmospheric physicist will find Met OK. Everybody seems to find Air Law hard because it is a load of random facts.

Do serious revision to ensure that each exam is passed first-time, because each fail sets the entire project back 2 months, lumbers you with a pile of work because the FTO sends you a large amount of additional homework before they sign you off for a re-sit, and potentially pushes the flight training into the winter months when a lot of lessons are lost to bad weather. The flight training FTOs are mostly happy to train in IMC but nobody wants to be flying a light aircraft in serious icing conditions.

On the day of the exams, turn up early with an internet-connected laptop (or an Ipad, etc) and study the QB in the lounge outside the exam room, or in the car park outside if the building is not yet open. There is free wifi in the CAA lounge but it is very weak elsewhere so GPRS/3G connectivity is highly desirable. Every nasty/ambiguous question whose answer you can memorise could make the vital difference... I know I picked up a few % doing that.

Unless you have great close-up eyesight, bring a pair of cheap supermarket +2/+3 reading glasses as much of the chart material is badly photocopied, some text on the Jepp charts supplied is tiny, but magnifiers are banned. The circular slide rule is not mandatory as there are no questions which are purely wind calculations (although the GTS study material contained loads of them) but a means of calculating wind drift is still needed as a part of a few possible questions. A non-programmable calculator with trig functions is allowed but the invigilator will check that the memory is cleared.

In Module 2 where the thick Jepp binder is used, two students are picked at the start of the exam session and their binders are taken away, replaced with fresh ones, and the removed ones are examined for any notes. Reportedly, cheating is endemic especially among students from the Middle East. Very surprisingly however, I was informed at GTS that the Jepp airway charts do not have to be spotless. After all, they have been used in the classroom exercises where routes are drawn on them.

The CAA exam guide is here.

Don't forget to bring your passport. It is required to check that somebody else isn't sitting the exam for you, and it will be examined to make sure you have not filled it with answers

Obviously bad-English questions, ones with multiple correct answers, and questions which are believed to be off-syllabus for the IR, should be appealed. You cannot take anything out of the exam so the procedure is to write down the question ID numbers and hand this together with your details to the invigilator before leaving the room. One pilot I know appealed five questions and got them all credited!

If you really have no idea which of the answers to pick, the following strategy works surprisingly well:

1) Eliminate any options which are obviously nonsense
2) If it is a question of a regulatory nature, go for the one which is second-strictest (example)
3) If it is a question on a compromised terrain clearance (e.g. flying in cold / low pressure air) go for the lowest actual altitude (example)
4) Go for the one with the longest answer (example)

In options like "2 nm" or "2 miles" ignore the "miles" version. I wonder what the writer of these questions was smoking...

In altimetry calculations, 1 millibar is 27 feet.

Read each exam question several times. They are often cunningly phrased. I recall one asking about a "generator" and 2 of the 3 wrong answers used "alternator" instead but had otherwise correct wording. A widespread trick is mixing feet and metres for parameters which are always in feet in European/US aviation usage e.g. altitudes. Often a single word is inserted which subtly changes the meaning of the question, to ensure that the obvious answer is wrong. And a few questions have lousy English.

When you have passed the exams, you can sell the FTO manuals and the Jepp ring binder on Ebay...

The following is a progress diary:

 

The Exams

The UK CAA exams run every 2 months. For the IR, they are split into two modules as follows:

Module 1
Air Law & Operational Procedures
Meteorology
Human Performance & Limitations
IFR Communications

Module 2
Aircraft General Knowledge
Flight Planning
Navigation

The GTS classroom sessions are grouped similarly and are scheduled a few days before the applicable exams, for best effect.

As mentioned above, due to the timing of my entry into the IR process and the fixed exam schedule, I did Module 2 first, plus (for some reason I don't recall) I chose to sit the HP&L exam i.e. a total of 4 subjects. In retrospect this was good because those 4 subjects have a very broad syllabus and are good to get out of the way, leaving Met and Air Law which are almost entirely dry topics which can be done purely on QB revision. And IFR Comms is an easy exam to pass for any current IFR pilot who has done the small QB a few times.

The particular 3-day GTS classroom session did not include HP&L so I did that one by going through the study material enough to do the homework and then revising entirely by using the QB.

I got lucky on the first 3 exams (Aircraft General Knowledge, Flight Performance & Planning, Navigation) which turned out to be a lot easier than they might have been. Not one of the really horrid questions turned up so I finished in about 50% of the time, which in turn provided time to sit down with a laptop and bang away on the QB for the next exam. Without such an early finish, you have just 15 minutes between exams, and 1hr for lunch. The 4th exam (HP&L) turned out to be hard, with a number of questions I had not seen before. Evidently the QB is not quite up to date. I expected 3 passes and 1 fail (on HP&L) but got all four:

AGK 96%
FP&P 92%
NAV 90%
HP&L 79%

Among the garbage, many questions were so easy that one wondered where the trick was. One was asking about the tower frequency for a specific airport for which a plate was provided, so you look up the line which says TOWER 123.45 Do I think this is smart? Not really; this is supposed to be an instrument rating. One could spend the time learning something actually relevant, like how to fly various kinds of procedural approaches.

The second set of exams (which for me was Module 1) came up 2 months later but I could not sit them due to a holiday, so I had a 4-month gap in which to swat up the two truly horrid ones: Meteorology and Air Law. However, I quickly realised that starting 4 months early is a complete waste of time because my memory retention of most of the facts was a few days at most. I think the optimal time to start is about 3 weeks before the exams, and work intensively (say 5 mock exams per day per subject) during the final week.

It also became apparent that Met and Air Law study material from GTS was too big, too factoid-packed, too tedious, and too misaligned with any possible QB composition, to make it worth studying. I opened up the GTS ring binders for just long enough to do their homework, and after that did all revision using the QB alone.

It took nearly 40 mock exams to reach a reasonably consistent pass score in Met and Air Law; this is a couple of weeks' worth of evenings. The stats for most of my FlyingExam QB time are here. The 4/4/2011 to 11/4/2011 mocks were before the Module 2 exams; the later ones were before the Module 1 exams. The above PDF does not show the results of doing the entire QB in certain subjects because the FlyingExam website always crashed at the end of those long sessions and the statistics were lost.

I again got relatively lucky on the second set of exams (Met, Air Law, IFR Comms) which turned out to not have any of the tricky questions seen in the QB. In all three, I finished in about 30-50% of the max time. Speaking of the first two, about 20-30% of the questions were not in the FlyingExam QB, but most of those were composite versions of QB questions so if you knew the right answer you were OK. The IFR Comms exam was very easy indeed (as expected) but only because I did the entire QB on it a few times so knew the obscure questions.

I appealed 1 question in each of the Met and Air Law exams, in cases where there were two obviously correct answers. One of them was whether ground based weather radar can see A) CBs with hail, or B) liquid precipitation. From seeing some similar QB questions I think the writer was after A) but both are absolutely equally correct. I never heard anything from the CAA.

A notable feature of all the exams (except HP&L) is that the exam questions were considerably easier than the QB selections, with almost none of the really difficult questions appearing. This seems too much of a coincidence across 6 exams, and suggests that somebody in the UK CAA had taken a more generous view of what should be removed from the ATPL QB, than either GTS or the people who put together the FlyingExam QB. As I have written above, an "IR" QB was never released and can be produced only by taking the JAA ATPL QB and stripping out questions which are "obviously" not in the IR syllabus. Also, I saw very few dodgy questions, and none with incomprehensible grammar. Perhaps the £69 the UK CAA charges for each exam is worth paying

The results took 16 days to turn up...

MET 86%
AIR LAW 93%
IFR COMMS 95%

The study material was on Ebay within 15 minutes of receipt of the above Didn't sell for much though - only £50, plus carriage.

The practical learning value of the ground study process was zero. I cannot recall a single thing, relevant to flight, which I was able to take home.

Based on everything I have heard from other people following a similar route, the company to definitely use is CATS in Cranfield.

 

Flight Training

I have two FTOs at my local airport (Shoreham EGKA) capable of doing the IR conversion. One advised me they do not train in a customer's aircraft so I went to the other.

Historically, doing an IR out of Shoreham had been a bad move because the CAA examiners worked on a small number of predefined routes coming out of the test centres where they were based, so (on the south coast) one ended up flying the FTO aircraft from Shoreham to Bournemouth all the time to practice the "examiner routes" which all came out of Bournemouth, and usually went to Exeter or the Channel Islands. This made the training more costly and time consuming and some people I know had dropped out and re-based themselves in Bournemouth (or Cranfield, etc). However, during 2011 the system changed: the Bournemouth test centre closed and the examiners become mobile, some external (non CAA employed) examiners were recruited, and it became possible to do everything out of Shoreham, flying to Southend, Manston, Bournemouth, Lydd, etc. These are very positive changes which make the IR more accessible to private pilots who would have previously faced a likely hotel residence to be near an FTO.

The CAA prefers to keep the IR flight test (IRT) down to about 2 hours, which covers a flight somewhere about 50nm away, one precision approach, one hold, one nonprecision approach, and some airwork (unusual attitude recovery etc) on the way back.

There is an FTO which does all that is required at Bournemouth EGHH which is in range, just about, for a same-day commute using my aircraft. Bournemouth has an ILS, but the inability to return to Shoreham in "bad" weather would be likely to result in occasional hotel residence, which is worse if you don't have a car.

If you are happy with living out of a hotel, there are other FTOs in the UK which do IR conversions, and in customer's/N-reg aircraft. Cranfield is a popular one and has an advantage over Bournemouth in that while at Bournemouth the examiner can pick any of about five test routes (which results in manic preflight preparation once the route is notified on the morning of the test) at Cranfield there is only one test route I did not consider any of this relevant; anybody who can fly can fly any test route, and if I am going to live away from my home, in a hotel, I may as well do it in Greece and come back 2 weeks later with a SE/ME PPL/IR.

At this point, the options were: Shoreham, Bournemouth, Egnatia in Greece, and FIS in Spain. Each of these has - frustratingly - big benefits and big drawbacks. The UK options support my own N-reg aircraft which is a big plus in terms of currency on type and brings the big benefit of training in the aircraft one is actually flying afterwards. The use of one's own aircraft also reduces the costs; one pays "only" the instructor rate (£90 to £130/hour) and the marginal hourly cost of flying my own aircraft is far less than renting one from an FTO or even flying a simulator, and I fly once a week just for currency anyway. The non-UK options offer a simplified training process, avoidance of the UK CAA window screens, and in some cases a lack of NDB procedures in the IRT (which is priceless) but the extended time away involves considerable organisation at work, etc, and the fixed schedule can result in wasted time if the weather is bad. The last bit is significant if the 2-monthly exam timetable has resulted in the flight training being pushed into the autumn/winter months because practically all of JAA-land has bad weather during that time.

Are there any FTOs in the Canary Islands? There's a surely business opportunity for the hordes of worn-out timeshare salesmen from Lanzarote... they will feel right at home in the aviation business

The Training and the IR Flight Test (IRT)

I decided to do it at Shoreham. One simply cannot beat the convenience of doing it from one's home airport. I am sure I can already understand and fly every procedure involved in the JAA IR; the only question is how long it will take me to be able to do what is expected on the day, under pressure, and in accordance with the various requirements and examiner expectations.

It took the FTO only a few weeks to put the N-reg aircraft on their "paperwork", with the CAA approval.

I obtained a written confirmation from the CAA that the window screens are required only for the flight test, so training could commence under the hood (foggles). This saved time; I bought the material (estate agent "for sale" sign material called Correx) on Ebay for about £25 but it was obvious that despite having full workshop facilities it would take a lot of messing around at the airport to make the screens and get the fit correct. The CAA contact also confirmed that suction cups would be OK, which avoids the risk of velcro glue damaging the windows.

My son is at an aeronautical college at the airport on Fridays so I drive there on Fridays anyway. I chose to do the whole course on Thursdays and Fridays. Weekdays were chosen over weekends because (a) a mid-air collision is less likely on a weekday, especially if doing the lesson early in the morning, and (b) I have no hangar access at weekends so for weekend flying the aircraft would be sitting outside for 3 nights out of every 7, for weeks, even if lessons are cancelled due to weather.

There was one pre-training meeting for a briefing, covering the syllabus. The instructor was well known to me, having been more or less the first instructor I had for my PPL 11 years previously. One important item I brought up was the need to avoid shock cooling the engine, so manoeuvres involving a sudden potential power reduction (unusual attitude recovery, stalls, etc) would need to be preceded by a brief period of level flight at a low power setting, of about 16" MP (about 100kt) to cool the engine down. Similarly, I explained that for engine temperature management I transition to a 120kt climb as soon as clear of obstacles. This is acceptable for the IR. During departure, it is OK to maintain the 120kt, and let the VS come out at whatever value. It is only during enroute phases of flight and arrival descents that specific IAS and VS values should be flown.

I had a total of 14 training flights, which were mostly 1 to 2 hours. Nothing in this training was new or noteworthy. The first two were just basic revision. Of the rest, nothing was hard - except NDB procedures! I knew how to fly these in principle, ever since having got the IMC Rating in 2002, and the RMI in my aircraft made them much easier than the more common fixed-card indicator, but doing it to the required accuracy of 5 degrees was something else… The NDB/ADF system cannot achieve that level of accuracy anyway, especially at coastal airports where errors of 20-30 degrees are common.

Some effort went into making sure I was doing some of the special expectations of the CAA IR process e.g. speaking the words "ice check" every 1000ft in the climb and every 5 mins in the cruise. Navaids had to be identified with correct phraseology "VOR sierra foxtrot delta identified", etc all spoken aloud.

My total airborne time reached the required 15 hours after the 13th flight, but we did some more flight of NDB holds, plus one consolidation flight, just to be sure.

It became obvious that for a pilot of reasonable IFR experience the bulk of the JAA IR conversion process would be spent on NDB holds and approaches, especially if the aircraft doesn't have an RMI. If it wasn't for the NDB stuff, a competent pilot could be up to the flight test standard after just a classroom briefing! I can also now understand how people who did their IR conversion in Spain did it in one week... pick the right FTO (not one of the ones run from the UK ) and there are no NDB procedures in the flight test.

I then had an unfortunate break in the training of some 6 weeks, due to Xmas, due to an Annual service, and other factors, so I flew with a freelance IRE (who was also a bizjet pilot) whose input was hugely beneficial. This pushed my total JAA IR training to over 30 hours, but with less than ideal currency due to the breaks.

The IR Test

A private owner-pilot has to get a lot of things sorted for the IRT. There is a pile of documents to be presented to the examiner (aircraft CofA, maintenance records, insurance certificate, pilot logbooks, passport, etc). Normally the FTO would take care of most of this but if you are using your own aircraft you have to put it together yourself. The CAA Standards Document 7(A) is the starting point for a checklist, and the one I assembled is here. The Doc 7(A) is becoming obsolete in 2012 however; under EASA the aircraft will merely need to be airworthy and IFR legal, and the responsibility for that will pass to the FTO. However, with private owners, the CAA will continue some sort of aircraft and document inspection, which is understandable.

A private aircraft doesn't have a tech log (not that those kept by flying schools necessarily mean much, with occasionally crappy fuel records) but you should have a journey log where stuff like fuel and oil fillups, defects and rectifications, services, 30-day VOR checks (for N-reg), etc, are logged.

On personal matters, every pilot knows that sometimes one can get a sleepless night. With good preflight preparation and with the huge reduction of pilot workload made possible by modern cockpit automation, this is unlikely to impact safety on a normal flight, but if you do this before the IRT then it's probably game over. Even a partial pass (which is actually a very good result, because you have to re-do just a small bit) blows away £1000. So, have a calm evening before (no heavy clubbing ) and go to bed early. The examiner is likely to phone you about 6-7am (depending on how far he has to travel to you) to confirm things.

The FTOs always advise smart dress. Every ATPL cadet will turn out in the dress uniform anyway which looks ridiculous on a private applicant, and I think "smart casual" is more appropriate. If you can stand flying in a business suit, feel free...

Following changes in 2011, when booking the IRT, one can get a CAA staff examiner, or an "industry" examiner. However, the approval of the aircraft, and the window screens, needs to be done by a CAA staff examiner so aircraft owners may prefer one of those for the IRT because everything can be done on the day. I see no evidence that present-day CAA staff examiners are any more strict than the industry ones; in fact I am aware of individual counter-examples. 5/2012: under new rules, CAA examiners are no longer doing aircraft approvals, which are now done by the FTO.

The way the IRT works is that the examiner (who basically wants you to pass - unless he is a sadist and there are 1 or 2 of those around even today) starts with a handful of marbles and every time you make a mistake he throws a few out. If you bust the minima or mis-set the altimeter he will probably throw the lot out (he might keep 1). But if he starts the flight thinking that you know what you are doing, he will be starting with more marbles...

If possible, choose a day with light winds. You can usually get a pretty good idea from the MSLP chart, up to a few days ahead. Less than 20kt crosswind (at the expected procedure platform e.g. 2000ft) is OK. 40kt+ is going to make NDB procedures almost unflyable and you will be relying on the examiner throwing you a whole handful of marbles If you can get 10kt or less, which is rare, everything is easy because all the wind corrections can be almost forgotten.

In accordance with standard practice, the CAA examiner advised the route early in the morning (at which point the suitability of the weather was also agreed on) so I had about 2 hours to plan it, get to the airport, and preflight the aircraft. Not a lot of time to hang around However, I drove there the day before and made sure everything was in order - screens on the back seat, windows clean, GPS database current, etc.

The preflight briefing took 1.5 hours. The examiner went through the pilot and aircraft documents and then briefed the required route and approaches to be flown.

An interesting item which came up during the briefing was the "50ft add-on" on the ILS DA. This appears customary in UK IR training but was not required. The Socata POH does not mention a PEC correction (unless the alternate static source is used, obviously) and on an N-reg the altimeters are checked every 2 years, so one can fly right down to the published figures on the Jeppesen plate, for both precision and nonprecision approaches. In accordance with standard IFR practice it is permissible to dip below the DA on an ILS provided the go-around was commenced at/above the DA, but it is not permissible to dip below the MDA on a nonprecision approach. What this means for the purpose of the IRT is that adding 50ft in both cases and initiating the go-around at that figure is a reasonable policy which won't fail you for going around too early. As far as I can find out, the 50ft add-on on the ILS is an old practice by the FTOs which was originally instigated to improve the pass rates...

On nonprecision approaches, one is nowadays expected to fly a continuous descent profile (CDA), which makes good safety sense (Jepp are revising all their plates to show the CDA profile) and to commence the go-around climb when the MDA+50ft is reached i.e. not fly the traditional level-flight portion to the MAP. You still have to fly to the MAP while climbing, however, before doing any required missed approach turns, because obstacle clearance is assured only if following the lateral profile. It is also going to be jolly difficult to fly the common missed approach which requires you to turn back to the beacon unless you have crossed the beacon first In this example, in a high performance aircraft, you will be at 1500ft before you reach the beacon so turning left as instructed at 1500ft is not going to work.

The briefing was not quite the "half-day oral exam" well known to FAA IR pilots but it seems that the CAA may be moving a little that way, which would be a very good thing. Approach plate minima (height and visibility, with the 550m v. 800m RVR cases) were discussed, for example. This is very good because a pilot who flies for real should know this stuff, and a "discussion" is a good chance to earn some brownie points, because everybody is going to make a mistake (or few) on the IRT... I have always enjoyed oral exams. Some small and easy things probably help a lot. I presented a Google Earth image of the airport and discussed the EFATO options with reference to that.

I passed the IRT 1st time.

We went to Southampton EGHI where I had never been before; due to historically limited parking there is very little GA traffic landing there so I wasn't expecting it. Consequently I didn't have time to read the plates (although I had them, because I had printed off the plates for every conceivable airport suitable for a 2 hour flight test) but I got the VOR approach as the required nonprecision approach, which was a big piece of luck - it is much easier to fly accurately than an NDB approach. The ILS went fine. The next bit of luck was light winds - forecast at 280/20 (at 2000ft) and estimated around 270/15 on the day. Another bit of luck was being assigned the initial hold at SAM at 5000ft, above the clouds where the air was very calm.

The stalls and unusual attitude recoveries, partial panel stuff, etc, all went fine. When it was completed, the examiner advised that I had passed and I flew back home VFR.

The flight test was conducted as expected, with GPS and autopilot usage permitted during the enroute sections and the rest hand-flown, and was not at all stressful. The examiner - a CAA staff examiner - was the most professional and relaxed I have ever flown with. The only flight test I have had which was similarly relaxed was the FAA CPL (done with an excellent DPE visiting from Kansas, USA, in 2007). This is a long way from the traditional image of CAA flight tests. The modernisation that has taken place within the past few years is very welcome, and I hope it continues to include GPS/RNAV approaches and, later, GPS/LPV approaches.

It is also apparent that the CAA is ahead of the FTO industry when it comes to modernisation. The FTOs are still teaching all kinds of convoluted gate methods of flying "super accurate" NDB holds but these are not examined in the IRT, and anyway an NDB procedure itself is no longer the only option for the nonprecision part of the IRT. Many FTO aircraft do not have an autopilot (or a working one) or do not have an IFR GPS (or one with a valid database).

The window screens are also a non-issue. Admittedly mine did not go all the way to the ceiling so I had more light in the cockpit than with the FTO versions but they are much preferable to the hood/foggles. The examiner has to work harder to look out for traffic, however. Their construction remains nontrivial except for DIY-minded people and I suspect some owners will choose to use an FTO aircraft for this reason alone, which will work out expensive unless their own aircraft is very expensive to operate.

Having an RMI helped considerably with all beacon (NDB and VOR) tracking, and the vertical card compass made timed turns trivial.

So... it is all over now. I have secured the insurance policy against the politically motivated crooks at EASA, and passed what should be the very last "hard" flight test in my life.

On reflection, the FAA IR which I did in 2006 was much harder than the JAA IR, due to the difficult largely-partial-panel flying and the sheer intensity of the training and the flight test. In the FAA IR (in Arizona) I was so exhausted that I was ready to chuck it in every day I was there, and it "clicked" only on the last day. But the FAA IR had two things in its favour: (a) I was flying twice a day for 2 weeks, whereas on the JAA IR I was constantly losing currency by doing only a flight or two per week, and (b) the VOR/ILS procedures are basically easy to fly whereas the UK's NDB procedures are capable of throwing a spanner in the works no matter how many you have flown.

 

What did I learn in the JAA IR?

In the training, nothing of practical value. But it was necessary to pass the IRT. I cannot see any "modern pilot" (i.e. flying on GPS, VOR/DME, and ILS) doing it in less than 15-20 hours and then passing the UK CAA IRT so long as it has the possibility of the NDB procedures featuring in it.

In pure technical flying terms, one learns very little between a thoroughly taught IMC Rating and the FAA IR, or between a thoroughly taught IMC Rating and the JAA IR. No significant new procedures are introduced (and indeed none exist in "classical" IFR; I don't count SIDs and STARs as significantly hard) and 99% of IFR flying is no more than reading what is on the piece of paper and flying it within tolerance.

The JAA IR theory is something else however and that is covered further back in this article. That stuff was essentially worthless.

Most of the knowledge required to fly safely in real weather and with minimum hassle, in Europe, from A to B, is not taught in either IR. The FAA IR - if done in Europe - has a chance of imparting the knowledge because it has the 250nm cross-country flight, and an instructor who flies IFR "for real" (most FTO ones don't, but most of the FAA CFII freelancers who train FAA IR pilots in Europe do) gets an opportunity to get the basic procedures across at that point. The JAA IR has no x/c flight so little operational knowledge of IFR (beyond filing a paper flight plan EGKA DCT GWC DCT SAM ... ) is involved.

What an IR conversion candidate will be learning a lot of is the minutiae of classical IFR (e.g. not officially tracking a navaid until its morse code identification has been done - something one usually does not bother with when flying on the GPS and having a VOR/DME tuned as a backup) and of various IRT-specific requirements (e.g. ice checks every 1000ft in the climb and every 5 mins cruise; the aviation-alphabet name of each navaid identified to be spoken aloud to the examiner, etc).

Obviously one's hand flying currency benefits in the short term from the IR training, but my best training was some fill-in time I did with a freelance IRE (who flies business jets so he knows about real IFR) and clearly that is the way to go if one just needs some practice.

 

The Cost

Ground FTO course material and IR exam signoff (with 3 days' ground school) £1020
Online QB £13
CAA IR Exams £476
Training £2000
Approaches £350
CAA IR Aircraft Approval and IR Test fee £962
Adding the IR to the licence £87

On top of that is the cost of the aircraft. The fuel came to around £2500, and other direct operating costs (engine fund etc) roughly £500. It is arguable whether the cost of the aircraft should be wholly considered because I fly each week just for currency anyway, so only about 2/3 of the training was "additional" flying.

I saved a lot of money by flying my own aircraft which has a low marginal operating cost, but it is clear that an all-inclusive package in Spain or Greece (say 6k euros) is not likely to be cheaper except via the benefit of concentrated training (made possible by good weather) resulting in fewer hours flown. On the other hand, if you go somewhere where you do the IR in an aircraft very different to your normal one, you are going to need concentrated training to pass the IRT Probably half the training will be wasted on stuff like that...

I think that what will swing the choice for many private pilots is whether or not they can do it at their local airport and live at home - just like everybody can do in the USA. If they can't do it locally, Spain or Greece is going to look very attractive. In that respect, the recent changes whereby the examiners are mobile is a big help, but I don't think the number of FTOs willing to do "private aircraft IRs" is going to increase, in the UK, due to the CAA charges.

 

Keeping the JAA IR Valid

To be valid for flying, the JAA IR must be revalidated every year with an IR Examiner. The revalidation can be done anytime between t minus 3 months and t, where "t" is the day before the anniversary of the original issue of the IR.

If you let it slip past "t" then it becomes a renewal, not a revalidation, and different rules apply.

The examiner can be a freelance one. The cost varies; a typical figure is about £150 plus the aircraft. The revalidation of an MEIR in a rented twin will therefore cost over £1000.

Every 2nd revalidation can be done in a simulator. However this may not be any cheaper...

In the past, a JAA IR was never forfeited if you were flying in the meantime on the privileges of any ICAO IR. If it had lapsed, a revalidation flight with an IR examiner was enough to recover its privileges. This was a great concession for pilots who were living/working outside Europe for many years. EASA's gold plating bureaucrats have ended this and imposed a strict regime whereby after 7 years you have to re-do the whole IR - theory exams, flight training, and flight test. The reference is in AMC1 FCL.625(c); the full 562 page tome is here and the relevant page is 226 (local copy).

The UK CAA changed the wording from LASORS 2008 which said

However, where IR privileges have been exercised in another category of aircraft (i.e. UK/JAR IR(H)) or under the privileges of an ICAO licence (Aeroplanes and Helicopters) or under a UK military IR qualification (fixed-wing or rotary), the renewal requirements will be based on the expiry date of that IR.

to the following text in LASOR S2010:

Where less than 7 years have elapsed since the IR(A) expired but IR privileges have been exercised since in another category of aircraft (i.e. UK/JAR IR(H)) or under the privileges of an ICAO licence (Aeroplanes and Helicopters) or under a military IR qualification (fixed-wing or rotary), the renewal requirements for the IR(A) will be based on the expiry of that other IR.

According to AMC1 FCL.625(c), if the rating has expired by less than three months, no refresher training is required but you still need a certificate issued by an ATO to get the rating renewed. If the period of expiry is less than 3 months there are no recommended minimum requirements for refresher training. However, you will still have to obtain a certificate from an ATO to confirm either that they determined that no training was required or that the required training has been completed. Obviously the ATO has a commercial incentive to determine that you need retraining!

If the rating has expired by more than three months, there is mandatory refresher training, in accordance with AMC1 FCL.625(c), and the rating has to be re-issued by the CAA, for which there is a fee. In the absence of any approved alternative means of compliance, the requirement is for 1 training session if the rating has expired by less than 1 year and 3 training sessions if the rating has expired by more than 1 but less than 7 years. "Training session" has not been defined and therefore need not necessarily include any flying.

If the rating has expired by more than 7 years, the applicant is required to undergo the full training course for the issue of the IR (as well as re-taking the IR exams).

So, even allowing the IR to lapse for 1 day can invoke some time and money at an FTO, which can grow to a number of flights because there are no set standards for the syllabus. Once an FTO has got you, they can so easily say you are not good enough and "another flight" is needed...

Many airline pilots, working abroad, have been hit by this measure which doesn't appear to have any basis in safety since re-doing the ab initio IR training will be of no relevance whatever to them.

There are some strange timings associated with the revalidation/renewal situation - example.

Update 10/2012: The Irish CAA offers a way around the restrictive UK CAA interpretation. They are happy for pilots with UK-issued JAR-FCL licences to change their State of Issue to the Republic of Ireland, in order to avoid retaking exams after 7 years of JAR-FCL IR expiry even though IR privileges are being exercised on other ICAO licences.

Update 6/2013: The UK CAA has issued this exemption (local copy). It means that if you are flying on say an FAA IR, you can go for up to 7 years without revalidating your JAA IR before you have to retake all the IR exams. However the notes above still apply in that after just 1 day past the JAA IR expiry you are back to the FTO...

 

The Future of the IR in Europe

2 year derogation

The situation is dynamic and is likely to remain so for several years.

There is now a 2-year derogation (till April 2014) on the enforcement of the duplicate Euro papers requirement on an EU resident operator. However each EU country can individually decide whether to apply for this delay, and at present time most of the EU countries have not bothered to apply. A hopefully up to date list of countries known to have applied for this can be found here.

Some additional text is here (local copy). Here is a great article by a well known and accurate German aviation writer.

It is also not known whether the derogation applies to the country of operator residence, or the country of the airspace being flown in. Common sense would suggest the former (only because the latter, which would make more sense under ICAO, is unworkable in the context of how EASA has defined it) but one can never tell. This UK document suggests the UK sees the former interpretation as more likely (para 3.1, bottom of page 1). This also suggests that the UK could, during its derogation period, arrest a pilot who flew into the UK and whose operator is based in a country which didn't apply for the derogation (in practice, this means pilots flying in from most of the EU can be arrested). It is all a complete mess and it's no wonder that most of the EU appears to have simply ignored these idiotic regs

As for penalties, nobody yet knows but presumably this will mirror the current penalty for flying without an appropriate licence ie £5,000 on summary convicton or a (unlimited) fine and/or up to 2 years imprisonment on conviction on indictment.

This stuff is straight out of Kafka.

What Next?

I believe that common sense will prevail and the 2 year derogation will become pan-EU. Then, there is a good chance that we are likely to see a series of post-2014 postponements in implementation (to 2016, etc) because the reasons for the 2014 postponement are not going to magically disappear in 2014. This proposal is unprecedented on the European pilot licensing scene where almost every change has involved grandfathering of previous papers into new ones. EASA has ripped up the grandfathering principle, which is doable with light GA (which has no political clout) but will prove difficult with the business jet community (which has considerable political connections).

The Worst Case

If only a few countries apply for any derogation, but in the meantime the EASA FCL "law" is somehow enforced, the private IFR pilot community in Europe will be largely wiped out. Most IR holders are not young men, most are busy in their businesses, etc, and for many this will be the last straw. I know of several long-term FAA IR holders who are selling up and getting out of flying completely. Others have left the EU, by moving to the Isle of Man...

The Bottom Line: A "more accessible IR" has been "just around the corner" for as long as anybody can remember, but all attempts have been clobbered by various establishment interests. If you want an IR now, you need to get off your underside now and get on with whatever options are on the table now. None of us are getting younger...

The 15hr conversion route

The 15-hour IR conversion route was set to end in April 2012, and be replaced with

Applicants for Part–FCL licences already holding at least an equivalent licence, rating or certificate issued in accordance with Annex 1 to the Chicago Convention by a third country shall comply with all the requirements of Annex I to this Regulation, except that the requirements of course duration, number of lessons and specific training hours may be reduced.
The credit given to the applicant shall be determined by the Member State to which the pilot applies on the basis of a recommendation from an approved training organisation.

(from EASA FCL May 2011 Article 7 page 6 here local copy)

which basically means that the 15-hr conversion route may be replaced with another 15-hr route, or something shorter, or longer, and it may vary from one country to another. This sounds like good news, except that few FTOs will want to deprive themselves of income by offering something shorter... And no shortcut is proposed around the JAA exams; even a 20,000hr FAA CPL/IR has to sit the whole lot if he wants a JAA PPL/IR. Exception: an ICAO ATPL holder who has 2000+ hours on a Part 25 aircraft can now and will be able to convert directly to a JAA ATPL, without sitting the exams. The fact that an FAA ATPL is reasonably accessible to a private pilot (SE or ME) with 1500hrs TT (100hrs night) is rendered worthless in this context. An ICAO CPL/IR with any amount of experience also confers no advantage under current proposals.

However it appears (10/4/2012) that the existing 15hr conversion route will just continue - if only because nobody in the training business knows what to replace it with

Under EASA, the IRT will be doable with an examiner from any other EU country. However, for the UK, there is a CAA proposal to charge £630 (ref here, local copy, page 15) for the right to nominate a non-UK examiner; this appears to be an attempt to block such examiners from doing IR tests on which the CAA will not get their fee. It's not clear whether this charge will apply to the case where the training was done in the UK but the IRT was done outside.

New IR exams

Recently, slightly reduced (by about 10-15%) IR theory exams, called JAR 7, were developed in JAA-land and were implemented in late 2011. Some info is here (local copy). This sheet (with acknowledgement to GTS) describes the main changes from the previous JAA IR syllabus. In the meantime, the CAA has placed a time limit on the completion of the current IR exams of March 2012, so anybody doing it presently must pass all the exams before March 2012, otherwise some passes will be forfeited; the credits for the old exam passes are described here.

When I did these exams during 2011, I had the option of doing the JAR 7 ones, but decided to ignore them, even if they are a bit easier, because the lack of a QB increases the revision workload by an order of magnitude. But anybody reading this now (4/2012) will be doing the JAR 7 exams.

For the future, reportedly, a German company was paid €50 per question to generate a new Common Question Bank (CQB) from which each JAA State would generate their own exam papers. Initial reports are that this CQB is poorer than anything seen before, with only 20-30% being meaningful in English. The indications are that EASA is going to mess up this business even more thoroughly that appears from their proposals...

"FCL008 IR" / CBM IR

The only other "Euro IR" in the pipeline is one developed within EASA by the FCL008 committee during 2009/2010 whose terms of reference are here (local copy). This has a much reduced FAA IR- like ground school and one exam and the minimum flight training reduced from the present 50/55hrs to the FAA-like figure of 15hrs.

In the context of the nonexistent European track record on making the IR more accessible, the FCL008 IR proposal is an astonishing achievement. However, at the time of writing (8/2011) it has not even reached the comment stage and has a number of hurdles to get through in the EU apparatus, during which it could get dramatically more bloated or even eliminated totally. The "FCL008 IR" does not deal with the institutionalised prejudices in European aviation regulation which have blocked every previous move, and could turn out to be a "bridge too far". Or, in standard EASA/EU under the table dealing, it could get sunk as part of a deal to get an agreement on something unrelated. Or it could get delayed for several years. Some notes are here (local copy); I don't agree with everything in these external links but they are useful background reading.

The "FCL008 IR" is now called the Competency Based Modular (CBM) IR. While it is a full ICAO IR (the final flight test is to the same standard as the normal IR; all that has changed is the training process and the study syllabus) it doesn't give any credit towards gaining a commercial licence. Therefore, a PPL aspiring to get a CPL/IR will be able to do the CBM IR for the IR portion of his course but will have to do the full ATPL theory course of 14 exams.

The CBM IR is not currently restricted to a PPL and thus is certain to become popular with commercial pilots also, for the IR portion of the CPL/IR. This is a good result for all pilots, especially commercially working N-reg pilots and all other pilots who have existing experience, but it does increase the controversy level considerably because whereas in the past an FTO simply pushed all ATPL cadets through its 55 hour IR sausage machine (at the end of which nearly everybody passed the IR flight test) now they will have some candidates who are ready for the flight test at an earlier stage, with the resulting reduction in FTO income... The FTOs should see this as an opportunity to expand their business into training the CBM IR to private pilots but I suspect they will not see it that way... another reason for grabbing whatever conversion option is on the table right now.

There is a proposed conversion route from an ICAO IR to the CBM IR which involves sitting the written exam(s), zero flight training, and the IRT. This has two gotchas however: (1) nobody will pass the JAA/EASA IRT (with NDB procedures, etc) without substantial training (so in reality this is no better than the current 15hr conversion route), and (2) the conversion requires a minimum of 100hrs instrument time as PIC (i.e. instrument training does not count). The latter is obviously a nod to the Euro FTO business who are scared of ATPL cadets doing an FAA CPL/IR in the USA and then converting in Europe, but it is a very high bar because most experienced IFR pilots spend little time in IMC There are hopes that the 100hrs will be reduced to 50hrs. Usefully, instrument time logged while flying on the UK IMC Rating will count towards this, and pilots are now strongly recommended to carefully log every minute of instrument time!

The "EIR"

Together with the above "FCL008 IR", the same committee developed an "Enroute IR" (EIR). This has no instrument approach privileges; only the enroute portion would have the traditional whole-route IFR clearance with implicit access to all airspace classes. As departure and destination would be VFR, the flight plan would likely be a Z flight plan, which specifies the VFR-IFR and IFR-VFR changeover points. Some details of this proposal were published in pilot forums, with the release sanctioned by EASA, but at time of writing (8/2011) nobody I know appears to know how it should work in practice if the conditions at the destination IFR-VFR changeover waypoint are not VMC at the instant the pilot gets there... presumably the pilot would have to declare a Mayday, and the training will have to include instrument approaches.

The EIR proposal has predictably attracted a lot of controversy. I would not knock it, because it is a privilege additional to any existing ones, and it would be an excellent capability enhancer for "clever" long-distance pilots who mostly fly VMC on top and, being limited to "VFR", are getting regularly screwed enroute by controlled airspace access issues.

It is however also possible that the EIR was developed as something to throw away, to get the real objective (the FCL008 IR) because in any negotiation you never start by proposing the desired endgame

FTO to ATO

Under EASA, an "FTO" will become an "ATO" but this will not change the costs. There is no difference in the approval fees charged for an ATO as opposed to an FTO. For the CBM IR, the proposed initial approval fee for 2012/2013 is £1294 per module (BIFM & PIFM) with an extra £647 if the course is to include synthetic flight training. The current fee for initial approval of the existing IR course is £1269 (+£634 for the addition of synthetic flight training) so splitting the course into 2 modules appears to result in the initial approval fee more than doubling. This does not include the fee for qualifying the FSTD (£7431 for initial qualification of an FNPT II). Proposed annual re-approval fees are £1156 per module and £1676 for renewal of the FNPT II qualification. So nothing really changes.....

Possible removal of the QB

According to this EASA study which looks like a stunning waste of taxpayers money, they are trying to get away from publishing a workable QB - either by not publishing a QB, or by creating a QB which is too huge to be of any use for revision. This is another reason to get the present "JAA" exams in the bag sooner rather than later, because despite being full of dross they are efficiently doable using concentrated QB revision.

No improvements on the Medical front

No "new IR" proposal does anything about the audiogram requirement referred to earlier, which is a pity but it reflects (1) the great power of the medical departments within the national CAAs; (2) a lack of interest among those who have been pushing for changes to address this issue; (3) a long standing irritation within the European regulators with the FAA IR option which has been chosen by a not insignificant % of pilots for its more sensible medical.

A "PPL/IR" should simply require the Class 2 medical; the failure to address this is another missed opportunity which will ensure the exclusion of many "older" pilots from the IR

However, some of the routes listed under Medical Issues above should remain available under EASA - if only for a while.

National IRs

EASA is trying hard to prevent national variations but, in the future, there may be interesting developments in the form of ad-hoc but usable IFR privileges for flying around Europe. Contrary to widespread fears over the past few years, the UK IMC Rating is likely to stay, for UK IFR below Class A.

France has recently (4/2011) announced that they will create an FAA-like ICAO-compliant IR, ostensibly for use on F-reg aircraft and in French airspace only. Hilariously, it may have started here although more likely it is a finger-up to EASA (at times like this you have to admire France) to protect the huge N-reg business of Dassault and Socata. If this IR is accepted around Europe, and becomes available to non-French pilots, or is mirrored by similar moves in other countries, it may provide a de facto "Euro IR" which is separate from any EASA offering. To me, this move by France is not surprising because I have often discussed EASA proposals with senior executives in French aviation and they were always totally unconcerned about them - as if they knew that France will always look after its pilots. 6/2011: this US AOPA news item (local copy) suggests the French will validate an FAA IR into their new IR, which is a bombshell. More details here (local copy). The official site is here (local copy). A French magazine article is here (translation). The best information I can find suggests that this French move was at some early stage supported by EASA, with EASA's likely payoff being that the approval of its FCL008 IR proposal would be a fait accompli if France is already running something similar Ostensibly, this French IR must end after April 2012 but it's obvious (from the amount of work involved in setting up the infrastructure for training, etc) that France plans to carry on with it after that point. A more subtle question is why France is doing an IR whose training requirements are significantly more onerous than the FCL008 IR is claimed to offer, only about 9 months later... And why is France making such publicity over it being ICAO compliant while saying it will be valid only in French airspace. It could just be ignorance/cockup, or it could be that France, which clearly has the inside track on what is going on at EASA etc, thinks or knows that the FCL008 IR is doomed, yet they want to protect their N-reg business, and probably also their N-reg pilot community. 1/2012: the French IR is now being trained at Limoges.

 

FAA-JAA Shortcuts

Various options have appeared over time, mainly for commercial pilots, and may be worth researching for the CPL/IR or ATPL objective.

For some years, Ireland was converting FAA ATPLs into JAA ATPLs, with very little work, and even the UK CAA was doing this 20+ years ago, but I am not aware of any such route today.

Some European countries have been more willing to accept Canadian papers than American papers; probably because so many people in European aviation dislike the way the FAA system has demolished the FTO revenues they hoped to get from private pilots And the conversion from FAA to Canadian papers is not onerous. It can be found here (local copy).

A route which remains generally open is this: most countries will validate an FAA CPL/IR or ATPL into their own version, if you have a relationship with a commercial operator on that country's registry. Let's say you have an FAA CPL/IR and get yourself a job doing aerial surveys in a Bulgarian registered aircraft; you can apply to the Bulgarian CAA for a Bulgarian validation of your CPL/IR. This enables commercial pilots to change their country of residence and continue working, etc. JAA prohibits such a validation beyond 12 months but there are places in the southern parts of Europe which not only ignore this but in some cases offer a complete conversion so the new papers are permanent and no longer tied to the original FAA ones. If this gets you a national (non-JAA) license, that is not worth anything in the context of this article because only JAR-FCL compliant papers will meet the EASA proposals. But if the country later joins JAA/EASA and gets its papers grandfathered into EASA-FCL ones, that does the trick nicely. Unsurprisingly these options are not advertised but I have come across some in the Balkans.

Recent appearances on the "soon to be JAA compliant" scene are Hungary and Turkey. I've made personal enquiries when passing through Budapest. Several Malev airline pilots informed me (9/2010) that their FAA to Hungarian CPL/IR conversion is real but is a dead end because the Hungarian license is not JAR-FCL compliant. Turkey is rumoured to convert an FAA ATPL into a Turkish one, with just one exam and a flight test... I tried to check this out via Turkish private pilot contacts, without success. The question is whether / how long before that Turkish piece of paper is grandfathered into EASA. A very long shot I think... This doc (local copy) suggests that Hungarian, Croatian and Turkish papers look likely to remain a dead-end.

 

Is the FAA IR / N-reg option dead?

Not at all. Unlike previous French and UK proposals, EASA is not proposing any long term parking limits on N-reg aircraft. This is an extremely rare piece of good news from EASA. It is "only" the pilots they are proposing to screw (by requiring them to get EU licenses and ratings, though their existing ICAO type ratings will be accepted) and even then only if the "operator" is based in the EU.

Long term parking limits cannot be enforced (on aircraft) in a meaningful/consistent way, and countries that do it (Denmark, most of Africa, and most 3rd world dictatorships/police States everywhere) tend to do it in an opaque manner involving sporadic fines, sporadic and gradually increasing "attention" from the local police, and a gradual increase in the sizes of bribes which have to be paid to local government officials in the normal course of life...

Many larger operators will have easy and obvious workarounds to get the required "non EU operator" status. In fact I find it hard to believe EASA will actually implement this stupid stunt as currently proposed because the bigger players will easily circumvent it, by setting up a non-EU operating company, etc.

EASA is also proposing to require foreign reg aircraft based in the EU to be subject to EASA Part M maintenance but, in the private flight context, only if it is a "complex" type which they define as multi-engine turboprop, or a jet, or over 5700kg, or over 18 seats. This means the vast majority of private GA is not affected, though it will increase the operating costs for King Air owners and will put a damper on - currently nonexistent - single engine jet sales in Europe. This is an openly anti-American move, favouring Socata and Pilatus.

I have some notes and references on this issue here and at the end of here.

If you have a capable aircraft on the N-reg, keep it on the N-reg, and continue to take advantage of the more sensible maintenance and modification regime. You can use any US engine or parts supplier or overhauler which opens up access to high quality services which are very hard to find in Europe. Both minor and major mods are easier and this enhances safety via the installation of more capable avionics and other systems. Some notes on the FAA modification process are here under Certification Issues.

In most cases, I cannot recommend the transfer of an existing Europe-based aircraft from N-reg to EASA-reg. It will cost thousands, possibly opening a huge can of worms if modifications are discovered which are not EASA approvable, saddle you with more expensive and often pointless maintenance, and save you nothing in terms of what European pilot papers you need to collect personally. All it will save you is having to do an FAA BFR every 2 years (which is a triviality) and keeping the FAA IR current (likewise). The problem is not that EASA Part M maintenance cannot be done at a reasonable cost (it can) but a percentage of EASA Part M maintenance companies use the poorly understood system to rip customers off, for no safety gain. There are also many life-limited parts which need to be changed just for the sake of it. In fact the only thing I can think of which EASA has ever done to help GA is the grandfathering of national certification to anywhere in the EU. For example, if the German CAA approved a particular mod on a PA28-161 (of a specific airframe S/N range) then the mod can be applied to any EASA-reg aircraft of the same type and S/N range. However, in practice, this facility is largely wasted due to the lack of a central EU modification database.

There are some narrow scenarios in favour of being on the EASA register. They are connected with the NY IFU having washed its hands of certification work (Major Alterations i.e. with a 337) which affects N-regs by forcing Major Alteration mods to be done via an expensive DER route, or via an unusually helpful FSDO in the USA if you can find one. This project illustrates the problem. For a VFR syndicate, an EASA-reg aircraft also makes more sense.

For new instrument pilots, the FAA IR makes little sense unless

1) You plan to fly an N-reg aircraft in which case N-reg delivers significant advantages which get bigger as one goes upmarket in capability (and this more or less implies ownership, as few exist for rental), or

2) You have time to play with and can spend time in the USA, in which case the FAA IR followed by the ICAO IR to JAA IR conversion costs less than an ab initio JAA IR, or

3) You need one of the relatively obscure concessions in the FAA medical which are not available in the CAA/JAA medical (but EASA proposes to remove this option, by requiring an EASA medical)

 

Last edited 3rd September 2013.

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