EFR rating: When VFR rating is not anough and IFR rating is too much.

[Marc Zeitlin]

Don't forget to carry over the 6 hours of currency from the requirements for being legal to file IFR...

I don't remember when they got rid of that, but to be legal to fly IFR you need to follow 14CFR Part 61.57, which only has the following three requirements for IFR:

within the past 6 months:
6 approaches
Holding Procedures and tasks
Intercepting and tracking courses using navigational electronics

No more instrument "time" requirements...

Obviously, all the general requirements apply.

[WLIU]

Right, but my point was that guys who just fly enroute and don't do approaches will be required to have some sort of currency requirement to satisfy the ELOS. Which will be problematical for the pilots who only fly 10 hrs a year but want to fly through clouds.

Best of luck,

Wes

[martymayes]

I don't remember when they got rid of that

1997. >20 yrs ago.

[martymayes]

Thank you for the link and advise. I will prepare and submit a proposal. However I suffer no delusions that this will ever come to pass in my lifetime. When I get a docket number, I will post it on this site. If anyone wants to join me in this endeavor, please let me know.

Not to be Debbie Downer but it could be over quite quickly if they outright reject your petition. Yes, if they give it consideration it could be a lengthy process because they have to consider all ramifications. It took from 1989 to 1995 to rewrite Part 61 so I wouldn’t think it will take that long but 1-3 yrs is probable.

[Andre Durocher]

I have been preaching exactly that to anyone who would listen and have also suggested it to the FAA once when I had the opportunity. It is often met with the same response as the "I don't cotton to" one that you got. How often are you ready to go, and there is an overcast at 1000 ft., and tops at 3500 or so, and your destination is either VFR or at least is VFR below 1000 AGL? So you have to sit on the ground or commence on one of the most dangerous ventures in aviation known as "SCUD running".

In my opinion, IFR is the most safe way to fly. I have equipment that is probably better than most aircraft in the GA fleet that are certified IFR. I don't have a rating, but would certainly pursue the EFR ( what does that stand for? ) if there were one. There is a special VFR, and I would call this a special IFR.

To get a full IFR rating and equip my plane with the minimum required for GPS approaches, would cost a minimum of $20,000. I can fly on instruments, I do have synthetic vision and autopilot, but without adding an almost useless piece of certified equipment ( and that is all you could get for $10,000 ), it is a no go. Training for the current IFR rating would cost at least $10,000 with IFR Certified plane rental. This Special IFR or EFR rating should cost no more than half that. To be able to do what you have suggested, and what I have been preaching, for that price, I will jump on it in a minute and never again even be tempted to venture into that dangerous venture known as "SCUD running"

Thanks for bringing it up!

Hello Dan,

EFR stands for Enroute Flight Rules (my suggestion).

I did a presentation at my local club and all VFR pilots were very interested to get this licence. This may be a step towards their IFR rating. They will take instrument training and will be safer pilots. They will get more utility of their airplanes. Lots of pilots stop flying because they cannot fly nowhere because of the wx.

[Andre Durocher]

So the original poster is in Canada. Would likely be more helpful to him to post a link to the Transport Canada rules change petition process. If there is real motivation to try to create change, he is much more likely to get the process started successfully on his home turf.

But the posters above who are in the US (Joe citizen) can indeed step up and learn how the FAA works. Warning, great persistence is required. Plan on the process taking years.

Best of luck,

Wes

Thanks!
I started to talk to my local club and my plan is to talk to larger VFR private pilot groups and at the end those groups will talk to COPA (your AOPA). I would like COPA to present this idea to TCCA (your FAA).

[max_reason]

It seems I always have a minority opinion, so no surprise here. I agree that pilots should always stay within their abilities. BUT...

So many here completely ignore what has changed in the past 25 years. A large and increasing number of VFR pilots own VFR airplanes that contain a set of avionics that includes: 1 or 2 Dynon Skyview HDX1100 screens with modern WAAS GPS, autopilot, ADS-B out, ADS-B in, etc (or Garmin or other equivalents).

This means (assuming the pilot is familiar with his own avionics):
- the pilot always knows where he is within 10, 20, 30 meters.
- the pilot can observe his position, altitude, direction and speed on a moving map and/or 3D synthetic vision.
- the pilot can observe the position, altitude, direction and speed of every nearby airplane (unless he is in a canyon or between mountains) via ADS-B out/in.
- the pilot can push a single LEVEL button to tell the autopilot to fly straight and level (in case he becomes disoriented, or isn't sure).
- the pilot can tell the autopilot to take him to any nearby airport (or far away airport for that matter).

This is not even REMOTELY similar to what pilots used to face with a conventional 6-pack or 8-pack of instruments.

Therefore, I have to agree with the original post.

One way I look at this from my VFR perspective is the following. I have listened to dozens of youtube videos where IFR pilots fly IFR routes in, around and to large airports. They follow a blizzard of complex instructions given to them by ATC. Many of these pilots seem to love becoming a slave to ATC, and love being able to follow such complex procedures. I have ZERO interest in this, since my only interest in flying is to fly on spectacular days through gorgeous scenery. Because of this, I have never gotten even near getting trapped in IMC... not once.

However, I am a realist. Just because I never found myself in even remotely marginal conditions (even during many night flights)... doesn't mean it can't happen to me, or won't happen to me.

And so, my takeaway is the following. I still have ZERO interest in landing at any ATC controlled airport... ever. After all, about 95% of airports have no control towers at all. Since I hate cities, and stay away from cities (even when I'm on the ground)... I have no need or desire to land in cities. Which pretty much means "at ATC airports". So screw all that hyper-complex nonsense that I see other pilots practice until they're blue in the face. I am a "live and let live" and "to each their own" sort of guy, so those other pilots are welcome to love IFR flying and IFR training. And seriously, if they want to fly for a living, they almost need to be competent at everything IFR.

Given what I said above, if I ever get myself trapped above the clouds or otherwise find myself faked into IMC... what do I want to be able to accomplish? The answer should be obvious.

#1: I want to be able to fly to a small airport and land. So step one is to find an airport that is clear near ground level, no matter how thick the soup may be at higher altitudes in the area. That should be possible with ADS-B and/or tuning in to ATIS or equivalent at every nearby airport and/or asking flight service (or even some ATC far away) to find me an airport within a couple hundred miles that has good visibility near the ground.

#2: I want to be able to fly to whatever airport I select and safely fly to the appropriate runway. When I get close (and within 200 or 300 or 500 feet of the ground), if I can see the airport, I can land safely. If I am still in soup at 200, 300, 500 feet AGL... then on to the next airport that might work.

Obviously I don't want to get vertigo and fly into the ground, or a mountainside, or into an uncoordinated stall-spin. But I had no problem with that during the 2 or 3 hours I spent under the hood during my VFR training. For some reason I am opposite most people... I instinctively trust instruments more than my own sensations. But, that doesn't matter much with an autopilot that has a LEVEL button, much less an autopilot that will fly me to anywhere I want to go. I friend of mine ran a test where he had his autopilot fly actually land his airplane on the runway. He only took over manual control 10 or 20 feet above the runway threshhold to flare and land the airplane. I wouldn't let an autopilot actually land my airplane, but how close can we get?

So I very much DO see IFR as two very distinct sets of activities. The first is to avoid becoming disoriented and crashing the airplane (which the autopilot can do if you can't or don't want to). The second is to fly the airplane to somewhere the pilot can land. It seems like 99% of the time this simply means "fly though a limited stretch of clouds to get to a nearby airport" or "drop below a deck of clouds you flew over wrongly thinking you'd find a hole before your destination".

I don't see why full IFR training is necessary for pilots who never want to go anywhere near any ATC controller directed airports, but might someday need to pass through a deck or patch of clouds to get to a rural airport or airstrip. To convince me I'm wrong, someone will need to explain to me why I need to know all those very complex processes to land at a large ATC controlled airport... when I want to fly to one of the 95% of airports and airstrips that has no control tower or ATC at all. Maybe someone can do that. But I doubt it. Go ahead and give it a try.

I vote for EFR.

[dougbush]

Max, your autopilot may seem reliable in clear weather, but I don't trust them. I've had autopilots shut off in turbulence during approach and turn in unexpected directions and fail to intercept a glideslope. No way mine could safely recover from an unusual attitude. Unless your autopilot can hold pitch (as opposed to vertical speed), you wouldn't want to use it in severe turbulence, probably not even then. In an updraft, most autopilots will lower the nose and accelerate above maneuvering speed.

Also, an approach at a towered airport is not usually more complicated than at a pilot-controlled airport. At towered airports, I usually get vectors to the ILS, which could not be simpler.

When you are talking about 200, 300, and 500 feet, there are all these tall antennas sticking out of the ground, so you can't safely roll your own instrument approach at a random airport, even with synthetic vision. The only safe way to do it is to follow a published procedure.

Which is okay, because getting an instrument rating is not that hard. It took me about as much effort and money as my private certificate.

Also, I don't think adsb is dependable enough for you to locate and coordinate with all conflicting traffic yet. An instrument approach is a precise course, and another aircraft could be on it at a different speed or opposite direction. Other pilots would be very upset if you did one in IMC without a clearance from ATC.

At rural airports a GPS approach is more common. It takes some training to do safely. Most of the IR training is on approaches, not on en route IFR.

Like you, I had no problem with simulated IMC during my private training and trusting my instruments. I've also been tossed around in turbulence on approaches in the soup. I can see how someone could get disoriented if they didn't focus on what they should. You could argue 40 hours under the hood is excessive, but some IR pilots still get disoriented sometimes, so maybe it's necessary.

[Andre Durocher]

It seems I always have a minority opinion, so no surprise here. I agree that pilots should always stay within their abilities. BUT...

So many here completely ignore what has changed in the past 25 years. A large and increasing number of VFR pilots own VFR airplanes that contain a set of avionics that includes: 1 or 2 Dynon Skyview HDX1100 screens with modern WAAS GPS, autopilot, ADS-B out, ADS-B in, etc (or Garmin or other equivalents).

This means (assuming the pilot is familiar with his own avionics):
- the pilot always knows where he is within 10, 20, 30 meters.
- the pilot can observe his position, altitude, direction and speed on a moving map and/or 3D synthetic vision.
- the pilot can observe the position, altitude, direction and speed of every nearby airplane (unless he is in a canyon or between mountains) via ADS-B out/in.
- the pilot can push a single LEVEL button to tell the autopilot to fly straight and level (in case he becomes disoriented, or isn't sure).
- the pilot can tell the autopilot to take him to any nearby airport (or far away airport for that matter).

This is not even REMOTELY similar to what pilots used to face with a conventional 6-pack or 8-pack of instruments.

Therefore, I have to agree with the original post.

One way I look at this from my VFR perspective is the following. I have listened to dozens of youtube videos where IFR pilots fly IFR routes in, around and to large airports. They follow a blizzard of complex instructions given to them by ATC. Many of these pilots seem to love becoming a slave to ATC, and love being able to follow such complex procedures. I have ZERO interest in this, since my only interest in flying is to fly on spectacular days through gorgeous scenery. Because of this, I have never gotten even near getting trapped in IMC... not once.

However, I am a realist. Just because I never found myself in even remotely marginal conditions (even during many night flights)... doesn't mean it can't happen to me, or won't happen to me.

And so, my takeaway is the following. I still have ZERO interest in landing at any ATC controlled airport... ever. After all, about 95% of airports have no control towers at all. Since I hate cities, and stay away from cities (even when I'm on the ground)... I have no need or desire to land in cities. Which pretty much means "at ATC airports". So screw all that hyper-complex nonsense that I see other pilots practice until they're blue in the face. I am a "live and let live" and "to each their own" sort of guy, so those other pilots are welcome to love IFR flying and IFR training. And seriously, if they want to fly for a living, they almost need to be competent at everything IFR.

Given what I said above, if I ever get myself trapped above the clouds or otherwise find myself faked into IMC... what do I want to be able to accomplish? The answer should be obvious.

#1: I want to be able to fly to a small airport and land. So step one is to find an airport that is clear near ground level, no matter how thick the soup may be at higher altitudes in the area. That should be possible with ADS-B and/or tuning in to ATIS or equivalent at every nearby airport and/or asking flight service (or even some ATC far away) to find me an airport within a couple hundred miles that has good visibility near the ground.

#2: I want to be able to fly to whatever airport I select and safely fly to the appropriate runway. When I get close (and within 200 or 300 or 500 feet of the ground), if I can see the airport, I can land safely. If I am still in soup at 200, 300, 500 feet AGL... then on to the next airport that might work.

Obviously I don't want to get vertigo and fly into the ground, or a mountainside, or into an uncoordinated stall-spin. But I had no problem with that during the 2 or 3 hours I spent under the hood during my VFR training. For some reason I am opposite most people... I instinctively trust instruments more than my own sensations. But, that doesn't matter much with an autopilot that has a LEVEL button, much less an autopilot that will fly me to anywhere I want to go. I friend of mine ran a test where he had his autopilot fly actually land his airplane on the runway. He only took over manual control 10 or 20 feet above the runway threshhold to flare and land the airplane. I wouldn't let an autopilot actually land my airplane, but how close can we get?

So I very much DO see IFR as two very distinct sets of activities. The first is to avoid becoming disoriented and crashing the airplane (which the autopilot can do if you can't or don't want to). The second is to fly the airplane to somewhere the pilot can land. It seems like 99% of the time this simply means "fly though a limited stretch of clouds to get to a nearby airport" or "drop below a deck of clouds you flew over wrongly thinking you'd find a hole before your destination".

I don't see why full IFR training is necessary for pilots who never want to go anywhere near any ATC controller directed airports, but might someday need to pass through a deck or patch of clouds to get to a rural airport or airstrip. To convince me I'm wrong, someone will need to explain to me why I need to know all those very complex processes to land at a large ATC controlled airport... when I want to fly to one of the 95% of airports and airstrips that has no control tower or ATC at all. Maybe someone can do that. But I doubt it. Go ahead and give it a try.

I vote for EFR.

March 22, 2019,I met Transport Canada and they are interested in the EIR (Enroute IFRRating: T-O in VMC, fly in or above the clouds and land in VMC) project. They want me todo a study and present to them a report.

Yesterday, COPA (Canada Owners and Pilots Association) sent a survey to theirmembers to see who is interested to fly EIR. My own survey shows thatlots of pilots would like to fly EIR.


My project is moving...slowy. Andre.

[Mike M]

"(assuming the pilot is familiar with his own avionics)"

Many are not. The new avionics are much too capable for those who fly VMC - work for a living - have families - to remain proficient with the button sequences. Next up, voice command? "Alexa, you know where I am. I want to go to........ Make a flight plan, get the weather briefing, interpret it for me, file the flight plan, program the avionics, and change the frequencies as we go along the flight path. Oh, yeah, I almost forgot - use that new Garmin Autoland when we get there and make a reservation for dinner at the airport restaurant."