Enabling access to IFR

And we are still waiting for the BIR. The NPA was in 2016!!?

Julian makes a good point. Availability of not just instrument ratings, but also the related route infrastructure and services is an important safety enabler for GA.

The BIR opinion was published in early 2019 by EASA and has now been voted positively with publication expected (after translations etc.) in a few weeks time - in fact exactly in the timetable foreseen in the opinion. Also the already available competency based IR has been an important step in making the instrument rating more easily attainable.

However there are still notable shortcomings in the availability of instrument approaches and related services. This is an issue that goes beyond just regulation and requires also the commitment of airports and air navigation service providers, as well as more widespread adoption of new technologies.

As I've said before, it's not a lot of theory that will keep you alive, but what your instructor taught you, hopes that EASA will understand this :-)

Having an IR and reading the report, it looks to me that they had lack of situational awareness. CAnt descend into terrain, IFR or VFR. IFR does not mean that the flight is in controlled airspace watched by a controller. You´d better always know what you are doing.

Just a notice, long term personal experience.
IFR is fine and very well improving safety. But, the most important for IR is to be properly trained - not only to get license, but to keep current. And this part is not very well understood by many GA pilots. Practice of IFR procedures and instrument flights to be ready for IFR conditions is really hard work, time consuming as well. One need to have manual skills as well as capability to evaluate weather conditions and aircraft performance without visual reference. Hard job, even more if we are speaking about single pilot operations.

Thanks for your comments so far.

I agree with Thomas that minimum level awareness is vital, whether IFR or VFR. IFR is no magic solution, but a fundamental aspect of IFR is flying a trajectory that is known to be safe against terrain and obstacles, whatever the meteorological conditions. By coincidence, I flew from Cascais to San Sebastian (under IFR) 2 months after the accident flight. Such a trajectory is not difficult to arrange. The problem for the accident flight was that they attempted to descend to make a VFR arrival, presumably because they were not allowed to make an IFR arrival.

I also agree with Jozef about currency, and would echo Jyrki's remarks. It is not sufficient simply to create a BIR. To enhance safety through IFR, we need to foster an environment for GA in which IFR is practical on a regular basis. That means availability of instrument approach procedures at smaller aerodromes, proportionate operational rules in Part-NCO, and affordable avionics. While EASA was undoubtedly correct to prioritise the instrument qualification (the BIR), it is also working on the other aspects.

Absolutely, Julian. Talking of availability of instrument approaches: I just realized during flight planning that Mannheim City Airport cannot be (practically) used as an alternate. That airport requires all IFR pilots to first fly with an instructor at EDFM. Such local restrictions are reducing the safety effect of the instrument rating. EASA should possibly keep an eye on situations like this (more info here: https://www.pilotundflugzeug.de/artikel/2016-12-06/Auflagen_Mannheim_ED…).
The BIR and CBIR are phenomenal, but the infrastructure must be accessible and based on the same standards in all of Europe -- absolutely not on local rules at each airport. I even think that airports should only deviate from standards when absolutely necessary.

I wonder if the Commission or EASA might consider an initiative to eliminate such local inconsistencies. The FCL requirements at EDFM are one example. There was discussion elsewhere about LGMG, which imposed the maximum demonstrated crosswind in the POH as an FCL limitation. I'm sure there are other examples that, though well intended are oblivious as to the bigger picture.

Such local rules are not consistent with the intent of creating a predictable and consistent system, where safety is managed by a holistic process. FCL and OPS are regulatory domains within EU competence.

Local restrictions for GA traffic, VFR or IFR is commonplace across Europe. It is rarely based on objective problems. For instance, restrictions on the number of IFR approaches or departures per hour from GA airports such as Toussu-le-Noble (LFPN) are ridiculous. Let's think about it for a second. Toussus is one of the two GA airports that opens partially at night (open from 0600 to 2230 LT), the other one is LFPT (open 24H) and open to IFR traffic. We are limited to 3 arrivals or departures when ATC is not present. We regularly see Notams that tell us that ATC services will not be provided on weekends and bank holidays. Strange for an airport to serves GA only... So there is a procedure to allow IFR pilots to get their clearance by phone and contact Orly departures after take-off (One of the three international airports of Paris). So it tells me that ATC at Orly cannot manage a few GA IFR traffics. Strange also when you think about it...
So the alternative is to arrive VFR or file a Y FPL. Super nice! If the weather is marginal, it is the best way to increase accident probability!
And if you have to take off early in the morning, you will file and/or fly VFR departing. As the class A airspace is all around Paris, that means that you will be flying 1500 ft AGL max, waking up all the neighbors, instead of climbing to 3000 ft minimum immediately.
The neighbors have already convinced our government that, despite the fact that the airport is over 100 years old and the houses around much, much, much younger, the airport should be closed to traffic on Sundays and bank holidays from 1200 to 1500 loc during half of the year. (April 1 to September 30). Needless to say, said neighbors are frothing at the mouth each time we depart IFR or Zulu outside of ATC presence.

There are tons of restrictions local or national that don't make sense. With EASA's willingness to treat GA differently from CAT, the next step is to start to act against these local diktats that have no safety benefits and actually are promoting a state of affairs that leads to a negative attitude towards GA and encourages bad decision making.

Well said Emanuel!

I will take this topic on board for discussion during our next GA Roadmap task force meeting. EAS and/or IAPOA could take the lead in organising a meeting in Manheim that we could support in order to better understand the problem and try to find a way forward.

Unfortunately, I do not believe that a formal standardisation action would deliver expected results rapidely...

Unfortunately, I can only agree.
GA is permanently underestimated across Europe. The value of proper and early started flight training as part of GA with progressive development to professional level is, notably last years, very deeply underrated. This is very short-sighted policy driven by "only profit" oriented managers and leaders. Some movement is already here, but not in our area. FAA Wants Action On Declining Pilot Skills and is writing letters to ICAO ...
It is real view to safety issues.
We know that situation in our part of the world is worse - but we are here more able to create papers and followed expenses rather then actions.