EASA publishes draft IMC flight 'Opinion'

[BEagle]

The unloved €urocrats have now released draft Opinion 03/2013 concerning Qualifications for flying in IMC - see https://www.easa.europa.eu/agency-measures/docs/opinions/2013/03/Opinion%2003-2013%20-%20Explanatory%20Note.pdf .

In particular, it is evident that Goudou has not been prepared to accept the need for flexibility:

2.4.2.4 Request to maintain national ratings

Several stakeholders expressed their concern on the lack of flexibility of FCL.600 when compared to JAR-FCL 1.175. More specifically, stakeholders requested that national instrument ratings be maintained. This issue has been discussed during each phase of the drafting process. The Agency fully appreciates the stakeholder reasoning of allowing MS to maintain some of their national licences, ratings, and certificates. It is true that this may not have an adverse effect on safety, however, it would contradict the general concept of a uniform European harmonisation and the aim of creating a standardised European regulatory system allowing for mutual recognition of licences. In its current form, the Basic Regulation does not provide the scope for introducing or retaining such national licences, ratings, or certificates. It was, therefore, decided not to amend Subpart G of Part-FCL in this regard.

In other words, while it might be safe to retain the UK IMCR, it doesn't fit in with their idea of a common Europe....:ugh:

However, AOPA will continue efforts to find an acceptable solution.

[BroomstickPilot]

I've just joined UKIP.

BP.

[BEagle]

Indeed - Goudou is Nigel Farage's best recruiting sergeant as far as pilots are concerned...

This "Ein Volk, ein Reich, ein EASA!" nonsense must be robustly challenged.

[maxred]

It is certainly not what the UK wanted, but, having read the document in full, it does make some sense. I thought the manner in which the Opinion was drafted, from a Eurocrats point of view, was clever. IMO it is going to be difficult for anyone to argue that draft. Not saying we should'nt, but it will be difficult.

From my point of view, it will mean additional expense in training and conversion, but is that a bad thing? I was going for an IR anyway, be it FAA, or be it EASA, so wait and see and then decide.

[Bob Upanddown]

BEagle. I appreciate that UK CAA are issuing IR(R) in place of the IMC rating on the EASA licence but is there a chance that the eurocrats could invalidate the use of the IR(R) in the future??

(As for UKIP, I have written to them dozens of times banging on about EASA. Not one reply from them. There is a UKIP MEP in my region and not even he bothers to reply if you write to him. I won't join them or vote for them. But I will vote against the EU if we ever get the chance)

[BEagle]

....is there a chance that the eurocrats could invalidate the use of the IR(R) in the future??

I very much doubt it, but who can possibly tell what these €urocrats might try?

[jxk]

It is true that this may not have an adverse effect on safety, however, it would contradict the general concept of a uniform European harmonisation and the aim of creating a standardised European regulatory system allowing for mutual recognition of licences. It's a bit like WW1 when despite knowing that 'going over top' was going to kill hundreds, 'orders were orders' and you would be shot for disobeying.
We have ways......

[Pace]

From my point of view, it will mean additional expense in training and conversion, but is that a bad thing? I was going for an IR anyway, be it FAA, or be it EASA, so wait and see and then decide.

Max Red

If I was you I would hot shoe it and get an FAA IR as soon as you can!

The only way forward for retaining the IMCR would be for a challenge on safety grounds in the European courts.

As for the easy conversion from FAA IR to EASA IR? Lets hope EASA are as good as their word and this is not another smoke screen for more caustic intentions?
I hope very talented people like BEagle put their hard efforts in making sure EASA come good on offering a sensible EASA IR which does not take a lot more effort to achieve than the IMCR.
FAA style would be a good goal as one with sense.

As for the UK saying no that sadly is not our style as we seem to bend to every whim of European demands! well almost

Pace

[Slopey]

It is true that this may not have an adverse effect on safety, however, it would contradict the general concept of a uniform European harmonisation and the aim of creating a standardised European regulatory system allowing for mutual recognition of licences.

So what he's really saying is that safety is secondary to some European federalisation paperwork exercise :ugh:

[mad_jock]

Lets hope EASA are as good as their word and this is not another smoke screen for more caustic intentions?

You are screwed get the exams done.

[Johnm]

The beautiful words of the cynical French bureaucrat:

The Agency fully appreciates the stakeholder reasoning of allowing MS to maintain some of their national licences, ratings, and certificates. It is true that this may not have an adverse effect on safety,

So allowing us to to retain the IMCR may not have an adverse effect on safety, but of course NOT allowing us to retain the IMCR WILL have an adverse effect on safety. :ugh:

[englishal]

If there is ever a referendum on leaving the EU, I am voting OUT !

[Pace]

It is true that this may not have an adverse effect on safety, however, it would contradict the general concept of a uniform European harmonisation and the aim of creating a standardised European regulatory system allowing for mutual recognition of licences.

EASA s mandate is as a safety agency not to dictate or mold political objectives!

Without doubt the french have very bad safety statistics for VFR flight, the UK have a pretty good one partially because of the backup of the IMCR in case the weather goes bad.

Take that away with nothing equivalent in place and our safety stats will drop to meet a political end.

Disgusting if that happens buts lets see if all the other positive promises are kicked into court for one false reason or other

Pace

[Whopity]

the Basic Regulation does not provide the scope for introducing or retaining such national licences, ratings, or certificates.Unless they are FRENCH! Article 4 of Part FCL7. A Member State may authorise a student pilot to exercise limited privileges without supervision before he/she meets all the requirements necessary for the issuance of an LAPL under the following conditions:
(a) the privileges shall be limited to its national territory or a part of it;
(b) the privileges shall be restricted to a limited geographical area and to single-engine piston aeroplanes with a maximum take-off mass not exceeding 2 000 kg, and shall not include the carriage of passengers; The Brevet de Base by any other name!

[Pace]

and shall not include the carriage of passengers;

The fly in the ointment as they say!so you can only exercise those privalges on your own :{ and in a single piston not a twin even one like the Seneca at 1999 kg!!!
The IMCR always was for twins too

Pace

[Whopity]

The same as the first 10 hours on a LAPL!

[Pace]

Sorry Whopity I thought you were referring to a loophole for retention of the IMCR in existing regs my fault :)

Pace

[flybymike]

Are the French still doing their own separate IR thingy?

[Johnm]

The bureaucrats have a clear mandate for their idiocy in the mindlessly phrased EASA mission statement which is "promote the highest common standards of safety and environmental protection in civil aviation". To the bureaucrat that's easy, everybody meets the standards set for heavy CAT.

So now you know why they operate the way they do, it's not their fault, they're just following the orders of the even more barking mad European Commission :mad:

Our problem is we try and implement this nonsense to the letter instead of trying to avoid doing anything at all which is the well practiced French approach to bureaucracy:*

[Ellemeet]

@englishal

what is your problem? You get what you want? An oral and checkride in your own Commander.

Do a bit of prepwork, you do not even need an ATO.

...

As far as uk imc I understand that it is the clear intention .. and even maybe rightly so .. to go for 1 set of rules.

Still why can t the uk caa accept an additional national license for eithin their own border.

...

ps I am not sure that at a national level it is much better. On another forum I am reading horror stories about the UK Caa wanting 500 gbp per year for every trainingcourse an ATO wants to provide.. This is clearly a local interpretation.. because this is UK only uptill now.

[jxk]

In the cause of unity and standardisation everyone will drive their cars on the left and speak English within Europe! :ok:

[bravobravo74]

As far as uk imc I understand that it is the clear intention .. and even maybe rightly so .. to go for 1 set of rules

As for the opinion that disallowing the IMC rating is justified by the facilitation of greater European standardisation, I couldn't disagree more.

Why should flying be made less safe for British pilots just because our provisions aren't common to other states? The idea epitomises European bureaucratic nonsense. If indeed the IMC rating is compromised by EASA then, irrefutably, safety will have been sacrificed for the convenience of the regulators.

[A and C]

You only have to look at the accident statistics to see that the UK is up with the best of the world, the problem is that we can't offend those in Southern Europe who miss the mark by some distance.

So rather than be shown up by those Brits it is more politicly correct to seek to drag the UK system down to the same low standard.


Its European harmonization of a sort !

It's UKIP for me because the Tory did nothing much to help safeguard the IMCR and other national interests.

[englishal]

what is your problem?
Eurocratic Bulls*it! In everything we do these days.

PS does ANYONE know how these rules will affect our NON EU EASA members, ex. Norway?! Surely as non EU residents.......

[Pace]

To address the safety issue, the Agency proposes a competency-based instrument rating (CB IR) and an en route instrument rating (EIR) for private (PPL(A)) and commercial pilot (CPL(A)) licence holders. The proposed changes are expected to increase safety with regard to the accident category of controlled flights into terrain (CFIT) by establishing a better accessible IR, thereby enabling more European General Aviation (GA) pilots to commence this type of training. The proposed new ratings will amend the training and checking requirements in Annex I to Commission Regulation (EU) No 1178/2011 (Part-FCL). The associated decision will also amend AMC and GM to this Regulation and Annex VII to Commission Regulation (EU) No 290/2012 (Part-ORA). More specifically, the proposed CB IR course will contain a reduced theoretical knowledge (TK) syllabus appropriately reflected by a different level of TK examinations and a reduced amount of instrument flight instruction time when compared with the existing IR courses. The EIR requires less training, but nevertheless consists of more comprehensive flight training when compared with the basic instrument flight module of the existing IR. The EIR is considered an EASA MS only rating as it is below ICAO SARPS. As the EIR only provides en route IFR privileges, the Agency envisages that this rating will serve as a module to be credited towards the IR using the proposed competency-based route.
Both CB IR and EIR include provisions for crediting a certain amount of instrument flight time under instruction outside of an ATO or prior PIC instrument experience on aeroplanes. To evaluate this prior training and experience, a pre-course entry assessment will be required at an ATO. Moreover, as a result of consultation, the maximum amount of instrument ground time on an FNPT II for the CB IR was increased, the specific English language requirement for IR (and EIR) holders (FCL.055 (d)) was removed, an IFR-by-day restricted IR for PPL holders was enabled by making the night rating prerequisite flexible, and additional crediting provisions and reduced requirements were established for third-country IR holders.

If EASA stick to the above is this not in fact a big victory? a full IR which is easily obtainable and not only opens up IMC flying departures and approaches in the UK but Europe wide too with an almost swap for 3rd country IR holders?
Think lunch in le Touquet on **** days;)

I was never even 2 years ago a supporter of retaining the IMCR for the simple fact that it would deter the fight for an FAA style IR in Europe.
As long as EASA are good to their word that looks like what we have achieved.
As I posted before the IMCR was an excellent UK rating but maybe it had past its sell by date and could never be sold to Europe! That was the problem!
So lets be positive and excited by what appears to be on the table.
If like many you fly N reg on an FAA IR the conversion should be a doddle

Pace

[BEagle]

Pace, you can rejoice in the C-b M IR all you like - but it would still be a wholly disproportionate price to pay for MOST UK pilots who don't want to play airliners in little spamcans, they just need a safe way of coping with UK weather.

The FI who needs to pop up to VMC-on-top to teach S&L 1/2 can do that with an IMCR - the added cost in time and money for 60% of the current IR syllabus would be completely disproportionate. Have you even looked at the difference in cost between obtaining an IMCR and a C_b M IR?

Goudou knows that certain Member States will certainly vote against the draft Opinion in its current state, due to their concerns about the EIR. Equally, others may vote against it for its lack of flexibility. It is not possible to vote for selected parts of the draft Opinion, it's all or nothing.

Pressure will be brought to amend this stupid document - and if that delays your precious 'FAA-style IR', or the conversion of flags-of-convenience IRs obtained elsewhere for use in foreign-registered aircraft, then you can thank Goudou for not heeding the EASA Managment Board's call for flexibility.

In its current form, this document deserves to be rejected.

[Pace]

BEagle

The EIR would achieve the ability to climb on top to do air work!

2 years ago I argued that EASA would never approve a part IR unless it was a modular step towards a full IR.

That appears to have been the case in presenting the EIR although I have my own doubts on a part IR without approach and departure privalages.

Until the fat lady sings nothing is set in stone and I have concerns that all these promises will get watered down or an excuse why not given at some point!
It all appears to good to be true.

Hence why it is vitally important that efforts from talented people like yourself should be put to making sure an FAA style IR goes through as well as an EIR and not fighting for something which IMO could never happen.
The other concern is member states scuppering the lot in petty squabbles and self interest.

I really do not like being correct as I have flown with an IMCR for years and know its benefits but we really do need to make sure the IR and EIR go through or we are all stuffed :{

There are approx 11000 N reg pilots in Europe! Most because of the FAA IR so its not true that pilots cannot afford or want a full IR and an FAA IR is not a lot more effort to achieve than the IMCR
If the whole thing was scuppered then EASA would be forced to do something on safety grounds as they are a safety agency not an anti safety agency.

My dream has always been to see a harmonization of FCL worldwide which is right and proper and the IMCR was too insular
We should be looking to winning the war not a minor battle and loosing the war
In the process because we are focused in the wrong direction

Pace

[BEagle]

The EIR would achieve the ability to climb on top to do air work!

The theoretical knowledge requirements for the proposed EIR are the same as those for the proposed C-b M IR: roughly 60% of the current IR.

The IMCR is not being proposed for anywhere except where it is currently available - regrettably, some appear to have missed that point.

[Pace]

But is that still a viable option or now realistically a dead duck ?
What are the options now of retaining it other than the UK taking a French like stance and saying NON? Historically something we rarely do!
Two fingers and stuff you we are keeping it whether you like it or not !!
Will that happen ? NO !
BEagle I know this has been your baby for some time what are the options to resurrect this back into a reality knowing EASA!
I do not trust them one inch! Smiles and yes yes then NO and we did our best not our fault !
They have an agenda! Con people to keep the piece, make false promises and always have an excuse at the end to get out!
I too am
Not confident on the IR or EIR and globally I see it as imperative that FCL becomes closer between nations to an eventual common standard

Pace

[Silvaire1]

I see it as imperative that FCL becomes closer between nations to an eventual common standard

Seems to me that's what will happen, effectively. EASA is finding, and will find, that naive political one-upmanship relative to FAA is a losing battle. They will then save face by allowing reasonable conversion from FAA certificates to their own gold-plated "EASA as Part of the New EU Ruling Class" licenses. The effective standard for European pilots will be (remain) the FAA standard because they will train to that standard before converting.

Eventually politics must succumb to economic reality, even if that means maintaining the illusion of supposed 'leadership' and the elite class of bureaucrats that want to justify it, and the paychecks it gives them.

[Legalapproach]

Beagle

"Ein Volk, ein Reich, ein EASA!"

At least then our licences would be valid for a thousand years without having to pay for the privilege of renewing them every five years.
:ok:

[Level Attitude]

Not sure of the Law on this one:

The CAA has said that an EASA Licence will be valid for
Annex II aircraft (it didn't have to).

The CAA has said it will continue to issue IMC Ratings on
National Licences (it didn't have to)

Can the CAA not say that National Licences will allow pilot
privileges on EASA aircraft in UK Airspace only?
Hence allowing IMC privileges if someone holds both a
National Licence and an IMC rating.

[stuartforrest]

I keep reading all this stuff and I don't get it. I think it would be great to make the switch to a simpler instrument rating for all. I don't mind being forced to do some more studying to change my IMCR to an IR. I just don't get what the grumbling is about. Obviously there is change but they are only proposing the new IR because pilots moaned that the old one was too hard to complete!

Does anybody know when this could become law in reality. Are there any proposed dates. Its seems to have gone on for many years.

[Whopity]

I just don't get what the grumbling is about.Then wait and watch because without the IMC there are going to be more DEAD BODIES than before, when those with no training attempt to fly in marginal weather. Throwing away a well established rating that is even recognised by insurance companies as improving safety, in favour of an expensive alternative that few pilots will take up, is not just lowering the standard, its grossly irresponsible!

In 1916 Capt Smith -Barry RFC invented Threat Error Management; ICAO didn't discover it until 1994, EASA some time later. In the UK the weather is a Threat, for many years we have Managed it with the IMC rating, now EASA who are new to this game, are making a fundamental Error by failing to recognise such a well established Threat for political expediency.

[englishal]

I am not sure about dead bodies, but what you will get are people flying "VFR" in IFR conditions and telling ATC they are "VFR" ;) You could never be prosecuted for this as only the pilot can report flight conditions.

There are something like 10,000 FAA certificate holders in Europe, the VAST majority of them hold an FAA IR (as it was the reason to get an FAA cert for most of us). I really wonder what EASA's thinking is - Is it a grudge against the FAA? Are they that petty?

The FAA system is tried and tested, and whether you talk about maintenance, certification, or whatever, IT WORKS. Why don't EASA just accept this fact, make their life easy and by a copy of the FAR/AIM and say ok, this is how it is going to be....and copy the book.

Actually I know why not....Job Creation. Big salaries, expenses, trips for the boys and girls - Paid for by US. I have a poster stuck on the wall of my office at work says "HOLD A MEETING, FEEL IMPORTANT; OFFLOAD DECISIONS" and then "MEETINGS - THE PRACTICAL ALTERNATIVE TO WORK" :} I might send a copy to EASA.

Actually this whole EU thing p*sses me off on principal. Actually so much so, that I have even inquired about an internal company transfer to the USA....Then I can have my big house, with the local airport a few mins away, and my N reg Super Commander parked in the hangar and no Eurobull !!!

[Ellemeet]

Well that really helps.

It means a quantumleap forward in terms of an accessible ir.
It means you can actually start using your imcr abroad as well if you have it transferred to EIR
It means you get a very easy way in to a full easa ir..
It means you will lose the right to do an approach.

Mmm well if **** weather was unexpectedly encountered than you can allways claim force majeur and do the approach anyway.

You claim the Faa ir is so muchbetter ... And I agree .. But the practical training is completely the same as in Europe. The difference is the written part and at least that got a lot better. The FAA ir requires a lot more training than the imcr and still you did it.

Be happy with all the plusses. Imcr where you can make an approach throughout europe was never going to happen.

The only thing I disagree with is, that if the uk CAA has allowed it and it seems to work fine than let this "national thing" remain in existence within their borders.

Imc will continu to take lives ., also from rated pilots. It proves that it should not be messed with .. And yet rated and unrated pilots continu to do just that.

[Pace]

Ellemeet

And I agree .. But the practical training is completely the same as in Europe. The difference is the written part and at least that got a lot better. The FAA ir requires a lot more training than the imcr and still you did it.

To fly in CAS we have to be trained to a standard while any instrument training is better than none to operate safely in CAS is a lot to do with surveillance and a lot to do with trust that everyone is where they should be doing what they should do not a half trained loose canon creating Havoc.

Yes some IMCR pilots are as good as equivalent IR pilots because they have survived to the point where experience took over.

The proposed EIR is fine but there has to be a get out of jail option if it all goes pear shaped at either end.
Maybe a Tyro type call with an immediate vectoring by ATC and a ban on such flights where enroute airports report beow 1000 foot cloudbases ?

Pace

[A and C]

You make the case for the IMCR superbly ! Just a pity that EASA are too busy playing petty politics to act as a SAFETY AGENCY and listen to common sence.

[Bob Upanddown]

In another forum, people are suggesting that the EIR plus the IMC (IR(R) as will be on the EASA Licence) is a wonderful result.

The people suggesting how wonderful the EIR will be are members of PPL IR, the very organisation that (if we believe what is posted on their site) suggested the EIR (with no approach privileges) as an alternative to the IMC (with approach privileges).
The EIR is fine for flying airways. And how many people flying on an IMC have something suitable for UK airways?? (ie above FL100, with 8.33 radios, IFR approved BRNAV....etc - very few)

It is a question of politics and no-one in EASA will admit the best solution for light GA is an FAA style IR. Even your CB IR will be more expensive to obtain and maintain.

I seriously think a judicial review (if there is such a thing in the EU) is called for as this is a case of politics over safety.

[piperarcher]

The EIR is fine for flying airways.

I cant see why you cant take off VFR from x airfield, land VFR at y airfield and en-route fly in or out of cloud, in our out of CAS (with approval in CAS of course), using the semi-circular rule and IFR terrain avoidance rules as you see fit. I don't think the EIR is forcing anyone to fly airways is it?

[Bob Upanddown]

I don't know where I said the EIR forced you to fly airways??

The EIR is being promoted as offering access to airways. EASA refer to flights being IFR in the en-route phase but ending VFR at an airfield without any nav aids. Is UK not unusual in having so much off-airways IFR anyway??

[bookworm]

Can the CAA not say that National Licences will allow pilot
privileges on EASA aircraft in UK Airspace only?

No. An EASA aircraft (i.e. non-Annex-II) requires an EASA Part-FCL licence.

It is a question of politics and no-one in EASA will admit the best solution for light GA is an FAA style IR. Even your CB IR will be more expensive to obtain and maintain.

Why will the CBM-IR will be more expensive to obtain and maintain than an "FAA style IR"?

There are probably four factors:

1) The higher cost of aircraft operation in the EU
2) The requirement for ATOs to be approved, hence passing on the fixed costs
3) The requirement for an annual proficiency check
4) The greater theoretical knowledge content, even though it's 50% of what it was for the JAR-FCL IR

Factor 1 is just a fact of European life. It's never going to be as cheap to fly in the EU as in the UA. Enjoy the free/cheap healthcare though. :)

Factor 2 is a consequence of the EASA system, which appears to equate "approval" and "certification" with safety. It will affect all training, including, if it were retained, training for a future IMC rating if is to be applicable on EASA aircraft. For the CBM-IR, only 10 of the 40 hours need to be at an ATO, which should help with costs.

Factor 3 makes the IR a bit more expensive. I don't see much difference between a prof check and a BFR which the FAA pilot is going to be doing anyway. The IMC rating has a biennial renewal, which isn't much different.

The cost and convenience difference of factor 4 is probably more dependent on the mechanism by which the theoretical knowledge training and testing is delivered than the amount of stuff in the syllabus. The FAA IR has a single exam and the preparation is a single book, but covers much of the same ground.

The UK solution to the original gold-plated IR was to create a rating for PPLs (and included in the CPL) requiring 15 instead of 40 hours, slashing the ICAO standard for IFR privileges. The safety record of the IMC rating speaks volumes about the appropriateness of that hours requirement, but I fear that another one of EASA's flawed assumptions is that ICAO's word is sacrosanct, even if activities are confined to the EU. I'd like to see the IMC rating be offered (for use in UK airspace) alongside the CBM-IR and EIR.

So the key factors to attack are the requirement for ATO approval and the ICAO Annex 1 hours requirements (which might be replaced by something a bit more competence-based). The requirements affect a lot more than just the IR. PPL/IR Europe, IAOPA-EUR and Europe Air Sports are working hard to address those and other issues with EASA and the Commission.

[peterh337]

5) The lack of FTOs willing to handle private pilots (non ATP)
6) The huge lack of FTOs willing to handle pilots with their own plane

The above two factors inflate the IR process with a big disruption to one's life and extra costs and hassle (hotels, travelling, etc).

Whereas in the USA you can do the IR in the same school where you did your PPL.

I could also add the FTO moneymaking scam called the "170A flight test" but that may go away...

[englishal]

7) A 170A which could cost another £1000 all in with aeroplane hire etc....
8) the CAA test fee which will no doubt set you back another grand

All these extra Grands add up, plus with over inflated sim prices (£200 per hour is not uncommon - the SAME sim in the USA would cost you $100 per hour).

Is it Greed in EU land? That flying should be limited to the very few privileged people? That is what it seems like sometime.....

[mad_jock]

Most of the cost difference is the instructor pay.

And the instructor cost will only get higher as there is no easy way for ppl instructors to get the IRI with having to build hours which most won't be able to afford without going to fly commercially first. Once they have stepped out of the instructing side of things most never return.

[Johnm]

All these extra Grands add up, plus with over inflated sim prices (£200 per hour is not uncommon - the SAME sim in the USA would cost you $100 per hour).

Is it Greed in EU land? That flying should be limited to the very few privileged people? That is what it seems like sometime.....

The core problem is a restrictive GA regulatory environment which is generally getting worse under EASA, but I still believe that is more to do with CAA interpretation of rules than direct EASA issues. The second problem is that most of the kit is USA made and pricing tends to be done on the basis of just changing the sign in front from $ to £ an issue that has been a problem in IT and comms for aeons.

[Ellemeet]

..... guys, can you please read yourselves back.... you are starting to moan like a bunch of old women who have been married for 50 years and have not have had sex since the first day of marriage.

If this is the way we go about when progres is made .... ???


regarding

1. go and live in the usa
2. true but some real competition is coming up. you will find a good ATO willing to accomodate you more than you will expect at a very reasonable price .. otherwise come to Rotterdam and I will gladly sort this or you.
3. the US way is much better but 1x per year is doable.
4. agreed, but it is still a quantum leap forward.. If you push it, you can do this really quick.
5. Hey, it is one Europe, just make a deal elsewhere and you will see ATO's waking up to the new reality. You will find plenty good and willing ones .. else see 2.
6. Ditto .. just a matter of finding a willing ATO. I know my ATO iN Rotterdam will gladly do it and be of service.

7. a170a? I presume you mean the checkride? I know in Holland they will charge you £ 300-350 for an ir checkride. And this is perfectly allowed while he would be accredited by your CAA .. so you are rid of these CAA employed examiners.

8. see 7.

...

Europe means a very strange way of finding a compromise solution whichs outcome is in many cases not the wanted endresult as there are allways a few countries who will hold you back regardless of logic or reason. It however also means that you have to look from a much broader perspective and find and see the oppertunities which arise from this.

I know that french ATO's are very willing as well. You will even find ATO's with dual Faa/easa fi .. making for an interesting combination. (for example if you would like to add a twin rating). Allthough I did hear some strange things about the cost of insurance when under a French ATO but that might be a purely french thing.

[mad_jock]

A 170a is a UK thing which dates back to when all IR's and a lot of CPL's were tested by CAA employed examiner.

There was a set of examiners who weren't employed by the CAA who were authorised to pre test the candidate which they had to pass before getting sent on to the CAA ones. It was I think a way of only making likely passes going for the full thing.

Unfortunately it was perverted by some schools as a method of extracting more money from the student.

There was never a requirement for a flight test for the CPL only a paperwork check but many schools still demand a flight test outside the CPL course.

For the IR there is a bit of a grey area now as its not compulsory for you to use a CAA examiner. The test is normally done but there have been some who have managed to by pass the test and go straight to test because under EASA and JAR I believe there is no requirement for it. Obviously the schools don't like this as its 2.5 hours in the aircraft and also the local examiner also gets a fee for the test. In a twin including approach fees this can cost over £1000 per test.

At the beginning of JAR there was a bit of confusion about how it was all applied. And quite a few of us managed to get the 170a included in the course and also that the full time in the aircraft from taxing to stop was included in the course hours. Which personally saved me about 5 hours on the course of 55hours and a 2.5 hour test and approach fees. So about 2.5k at the prices at the time. The UK CAA won't allow this now.

[Ellemeet]

tx

Did not know this but it is apparantly another typical UK thing ...

Hurray again .. you do not need this what so ever.. :cool:

[mad_jock]

The pre JAR set up was in some ways a lot better.

You could count IMC rating training and could also do training as required with certain experience requirements. That all went to the wind in 2002ish.

[Ellemeet]

mmm

interesting.. The imc rating training ... can you or can you not count this towards the full CBM IR? It would make sense that you can?

[mad_jock]

I don't have a clue about that side of things.

I could never justify the cost of getting the no instrument applied restriction when I was a full time instructor. So would now need to get an IRI unless I went through regaining my FI and upgrading.

And now I have loads of hours flying IFR but in a twin turbo prop and my FI lapsed recently.

So to become a FI capable of teaching on twins and single I would need.

FI revalidated which is a two day course and skills test £1000
MEP rating back which apparently is a full course now to learn how to use cowl flaps and mixture levers. £4000

30 hours PIC in a MEP £7500 (the 3000 IFR hours as PIC of a twin TP don't count)

MEP added to FI £3000

IR added to FI £1500

So as you can see from those costs there isn't going to be many Commercial pilots going to go near becoming able to teach IR. And the current PPL instructors don't have anywhere near the IFR experience levels to be able to teach it.

So in some ways it really doesn't matter what the rules are about gaining a flavour of IR there is going to be no bugger to teach it. And the few that do will be able to charge a fortune so will price most out of the market.

[englishal]

(the 3000 IFR hours as PIC of a twin TP don't count)
This is bloody madness isn't it! And why the FAA have it right when it comes to revalidations etc.....Catagory / Class and all that.

[Ellemeet]

Mad Jock

I am lost. The question was wether you can or can not count the trainings hours for the imc rating towards the CBM ir, not what it takes for you to get current. This with respect to your remark about the pre jar era.

getting a sep rating back should be nothing more than a proficiency check.
mep you should still be?

For FI I have no idea but I think your assumption is wrong as your experience will count or may be used on special request to waive certain requirements.

[mad_jock]

Sorry I don't think you can, but my slight rant was to say that I am not really current to be able to say yes or no.

MEP is covered by the currency rules and basically after 3 years you have to do the whole thing. I am way way past the 3 years.

Then you have to send it back to the CAA to get the rating re-issued. SEP is slightly different as there is no defined course for a SEP class rating. I presume though you would still have to send the license off to get the class rating re-issued. Any way that's still current for me. I just go up with a tame examiner when ever its due and get my IMC and SEP signed off at the same time for aircraft time and loads of beer.

And they won't give any credit I have asked and been told NO you will have all the boxes ticked. Even guys who have been flying single crew in F406's have been knocked back.

[Ellemeet]

are you talking about MEP rating or ME FI ?

As you fly twins you have your ME rating??

[soaringhigh650]

BEagle, you're so focused on preserving this sub-ICAO 'IMC Rating' that you've completely forgotten all the positives of the CBM-IR and EIR where the very "€urocrats" you mention have actually listened to the plight of many pilots across Europe who all want more accessible qualifications for instrument flying.

[mad_jock]

MEP rating is a class of aircraft, ME is a subset of the IR rating.

You can be a IR instructor on the F406 which is ME but you would need to be a CRI on that type as well. But unless you were a CRE on MEP you couldn't teach IR's on it.

It all gets a bit involved but to teach IR on piston aircraft single engine.

You need.

SEP class rating
SPA-SE-IR.

IRI-SE.
or in the UK FI with applied instruments removed.

For MEP

MEP class rating
CRI MEP
SPA-ME-IR

IRI-ME
CRI on the class or type your teaching on
or UK FI with MEP and applied instrument restriction removed.

Pre-Course Entry Requirements

An applicant for an IRI(A) certificate shall:

(a) hold at least the licence and the rating for which flight instruction is to be given

(b) be entitled to act as PIC on the aircraft during flight instruction

(c) have completed at least 800 hours of flight time under IFR, of which at least 400 hours shall be in aeroplanes


That's what the current pre course experience levels required. There is no way in hell that any single engine PPL instructor will be able to get 800 hours IFR time.

plight of many pilots across Europe who all want more accessible qualifications for instrument flying

Even if you get the qualification there isn't going to be anyone to teach it. The teaching IMC was within the grasp of most PPL instructors and in fact before 2000 it was a requirement to become unrestricted. Which was why the IMC rating had such a huge uptake as people very easily could go PPL, night then IMC.

[Adrian N]

BEagle, you're so focused on preserving this sub-ICAO 'IMC Rating' that you've completely forgotten all the positives of the CBM-IR and EIR where the very "€urocrats" you mention have actually listened to the plight of many pilots across Europe who all want more accessible qualifications for instrument flying.


Well said.

[BEagle]

I hereby appoint soaringhigh650 as my sexual advisor....

As for the plight of many pilots across Europe who all want more accessible qualifications for instrument flying you'll find that it was only the French who actually bothered to propose a national IR before the leaden hand of FCL.008 descended. None of the other Member States did....:ugh:

As has been said, try and find anyone with the right qualifications to teach the EIR and/or C-bM IR, at least in the short-to-near term, and you'll be looking long and hard.

The UK fully supports the EIR, C-bM IR and SCFR. But unless the Draft Opinion is amended to include the flexibility of JAR-FCL 1.175(b), it will NOT be possible for the UK to vote honestly for the Draft Opinion at comitology. For which Goudou and his gang of €urocrats can rightly be held to blame.

[mad_jock]

at least in the short-to-near term

I can't see it changing unless the salary's go up to short haul Captain levels. So 50-60k a year.

And whats that going to make the course price up to?

[Pace]

BEagle

If you looked in your crystal ball and with all the knowledge you have with the various goings on In EASA what are your predictions for the eventual outcome and the time scales?

Pace

[BEagle]

I have no idea!

There will be a deal of lobbying going on shortly to reject the Draft Opinion in its current form for a number of reasons, not least its unacceptable inflexibility.

Some NAAs are fundmentally opposed to the EIR, so that's another reason why the Draft Opinion may well fail at comitology....

Goudou seems to consider the one-rule-for-all (unless you're French) vision of Brave New €uroland as more important than safety. Perhaps after he's left office (and I hope the door doesn't hit him too gently on his backside), the incomer (who is actually a pilot) will be more prepared to listen. Stonewalling tactics might be necessary to ensure this happens!

[Adrian N]

unless the Draft Opinion is amended to include the flexibility of JAR-FCL 1.175(b), it will NOT be possible for the UK to vote honestly for the Draft Opinion at comitology. For which Goudou and his gang of €urocrats can rightly be held to blame

Perhaps they'll be open minded enough to realise that a pan-European, accessible instrument rating trumps the need to continue offering a national qualification for flying under IFR in IMC without an instrument rating? Especially as everyone who currently has that national qualification would be able to carry on exercising its privileges.

The way I read it, the people who you slag off (quite inappropriately, given your role with AOPA, whatever your personal opinions might be) have produced a set of proposals that satisfies existing UK IMCr holders, gives a sensible path to a proper instrument rating that can be used by those not too xenophobic to venture abroad, and lets the thousands of FAA IR holders convert to EASA ratings.

Sure there are things that could be better, and problems that will need to be sorted. But this proposal is so much better than it might have been, and I am sure that the tone of any official AOPA response will be very different from the one you are giving on various Internet forums.

[Pace]

Some NAAs are fundmentally opposed to the EIR

BEagle

As a fairly experienced pilot I would have concerns over the EIR as proposed and feel there need to be arrival and departure safeguards built in as well as en route weather restrictions but all those points could be covered by some fine adjustments.
You mention certain countries will scupper the EIR do you know for what reasons?
Finally do you yourself think that 2014 will be the launch date or a further delay added to 2016? Which is the info I have received ?

Pace

[BEagle]

Adrian N, you have no idea about what's actually going on....

You chose to move to France and can no longer use an IMCR. OK - but don't criticise those fighting for its retention. We do not share the glazed-eyed view that €urocratic 'one state' administrative ambition is of greater importance than the safety of future generations of UK pilots. A vastly more expensive pan-EU IR most assuredly does not 'trump' a rating whose safety has a proven 40+ year track record in this country.

Pace, we made a lot of proposals for both the EIR and C-bM IR, most of which have been accepted (e.g. less onerous FAA IR conversion criteria for the C-bM IR, more specific definitions for the EIR which met the safety concerns of many, etc.). But there are some NAAs who will not accept the perceived 'threat' EIR holders will allegedly pose to them in terminal airspace (due to SID/STAR/IAP limitations), others who say that their ATSUs are not established for the additional workload - and others who have deep fundamental concerns about sub-ICAO instrument pilots sharing airspace with CAT traffic....

[jxk]

Have we any proposals for what the training syllabus might be for someone wanting to obtain an EIR in the future - or hasn't this been considered yet?

[englishal]

and lets the thousands of FAA IR holders convert to EASA ratings.
Why would I want to convert, I fly an N reg?!

[Bob Upanddown]

Why would I want to convert, I fly an N reg?!

+1

There are many reasons to fly N. If you think offering an IR will mean all N reg disappears, think again.

[mm_flynn]

Why would I want to convert, I fly an N reg?!
Because sadly we lost that part of the battle - you either need to not fly, come up with some dodgy 'not established in the EU' structure, or get an EASA licence (and IR rating to go with it) to keep flying in the EU.

[Adrian N]

Adrian N, you have no idea about what's actually going on....

You might find I'm not quite as uninformed as you imagine. I don't criticise arguing to retain the IMCr, but I do criticise obsessing about it in the face of an overwhelmingly positive proposal from EASA. If the response began "this is a good proposal, which if adopted would give European pilots what they have been asking for for years, but...." then I wouldn't mind so much. It's the immediate criticism of the whole thing that I object to. That and the inappropriate personal jibes at EASA staff.

And I have no problem with the IMCr when it is properly taught - in which case it is fairly indistinguishable from training for an IR other than that the end result has restrictions which make it of limited utility (no class A, UK only). Looking back, I have a big problem with it when it is taught as appallingly as it was when I did the rating in the 1990s - qualified in minimum hours, examined by the 28 year old who had instructed me, and who only had an IMCr himself. Complete waste of effort for me and for many others who used the same school.

By the way, why do you always replace the "e" in "euro.." with a € symbol?

[Ellemeet]

The French always have their own agenda.

The sole purpose of the French is that they have many people who fly under FAA including some very high placed officials in the DGAC

[S-Works]

That and the inappropriate personal jibes at EASA staff.

I have to agree. Whilst I know Beagle personally and have the greatest respect for his work and experience I do think that the constant xenophobic jibes do him and AOPA no favours. I find quite a lot of the comments about EASA and its staff to border on being racist.

Sometimes the rabid dog attacks on EASA remind me of the poppy burners....

With regard to this vein of this thread the argument is actually running at a tangent. The IMCr discussion should be totally separate from the discussion around an achievable IR and conversion path.

The IMCr should be retained totally separate from any other discussion. Personally as I have said a number of times, I think that the decision was made a long time ago to do away with it and I would be most surprised if that were to change. A real shame as I love teaching it and the safety benefits and continuing education to pilots to keep them active and involved are without doubt.

[Ellemeet]

@beagle

rejecting the draft in Commitology would be the biggest disaster. As you say yourselve .. there are quit a few opposing countries as is. So I presume the draft to be the best possible compromise which was reachable.

In that case you win some you loose some.

Trying to score your one single point against a quantum leap forward in other aspects is a bad move for the large group. Having said that I would not mind having uk keeping the right to their Imcr within their own airspace.

What I fail to understand is what the big deal is with class A. More and more IFR is from gps point to gps point or you will be vectored.

The Ir rating requires 45 hrs minimum and also Icao and the Faa seem to agree on that. This includes approaches, flying in imc conditions, recoveries and interceptions.

In the Uk you have an IMCr where you do this in 15 hours, may do just about anything you please including approaches ... except that you may not enter class A (and mayb do a Sid? but that is easy).

So either the 45 hours is ridiculous ... or the IMCr is a stay out of trouble solution.. However it is used quit often as a normal planned feature.. I realise the system seems to work, I just try to understand why.

[englishal]

I still don't know how EASA can talk about "EU" and "EASA member states" and mix the two up like they are the same thing. They are not. Also "Operator" is not strictly defined anywhere. Very wishy washy the whole thing.

For example, if one flew an "out of EU" registered aeroplane (N or M say), for someone who lives in Switzerland (and owns the plane) but you live in the UK, what rules apply?

If you fly an N reg aeroplane, owned by a Trust in the US, what rules apply?

If you changed that around and registered your aeroplane with a US Citizen living in the USA, who is the operator now and what rules apply?

How would that work if you "sold" your aeroplane to say a US flight school, operating in the USA, but you flew it in the UK? I presume the operator would be the US flight school and not in the EU.

What about if I lived in Norway, but fly an N reg, owned by a US trust, hangared in the UK - That is not in the EU but is an EASA member state?

There is no wording anywhere that says "Pilot" or "Commander" but there is wording "based in the EU" (which of course there are many EASA member states NOT in the EU)....

[BEagle]

I am not racist, Francophobic or whatever else you may wish to call me. However, my personal opinion is that someone who signs a document which states:

The Agency fully appreciates the stakeholder reasoning of allowing MS to maintain some of their national licences, ratings, and certificates. It is true that this may not have an adverse effect on safety, however, it would contradict the general concept of a uniform European harmonisation and the aim of creating a standardised European regulatory system allowing for mutual recognition of licences.

is utterly beneath contempt. Because it says "We know that it wouldn't hurt safety, but it wouldn't fit in with our €urocratic ideal of Brave New €uroland".

We should enjoy the unique nature of our diverse European nations and cultures and benefit from European economic co-operation and free travel. But it is becoming abundantly clear that many people in the UK do NOT want to be part of some single monolith regulated by the EP and are becoming increasingly frustrated with the behaviour of the EP, EC and EASA.

[soaringhigh650]

But it is becoming abundantly clear that many people in the UK do NOT want to be part of some single monolith regulated by the EP and are becoming increasingly frustrated with the behaviour of the EP, EC and EASA.

And other people like myself as a US and UK citizen DO want the UK to be part of the EU! The EU isn't perfect at all but your personal remarks at the "money grabbing" €€€uroland politicians is out of proportion.

I've mentioned to you numerous times on this forum before and I make no apology for saying it again: You're much better off seek a positive working relationship with your colleagues in EASA so you can actually find a solution to the IMC rating. Besides this point everything else looks incredibly positive and the work that IAOPA and other groups have done deserves recognition. Unfortunately having an unjustified UKIP-slanted poke on an anonymous forum ain't gonna get you very far.

[Adrian N]

my personal opinion is that someone who signs a document which states........ is utterly beneath contempt.

Don't you see that as you represent IAOPA in discussions with EASA it is wholly inappropriate for you to publicise your derogatory personal opinions on internet forums?

[Johnm]

I think there is genuine frustration at the behaviour of arrogant French bureaucrats brought up in the Napoleonic tradition who pervade the EU institutions, which themselves were thought up by Jaques Delors the archetypal French Bureaucrat.

In the UK we have a tradition of agreeing rules and sticking to them and this makes the situation with EU very difficult. In France the bureaucrats are tolerated in their inventing of daft rules as long as they don't interfere too much with everyday activities and when they do the French remind them of their place by blocking motorways, ports etc. until the bureaucrats retire to their desks.

[Ellemeet]

I think the French are far from perfect but so are the British judging from all your complaints about the CAA. All I read is the cost of examinations and the "must be CAA employed examiners" and the costs of a170 and ... and ...

The only positive seems to be the IMCr....

The FAA has certainly a much more pragmatic approach to things than EASA.

Alas ... we live in europe .. and allthough the EU and EASA brings us quiet a bit of limitations and extra burden ... it has also brought peace and prosperity to our region with far to many countries with each their own unique identity on a small area.

And frankly .. I rather enjoy the French wines.

[Aware]

Under the new proposals what would be need to upgrade IR/R to SE IR

No exams valid I have:

Taken UK CAA CPL exams in past and thrashed through question bank to do JAA ATPL exams but never used other than to get my UK CPL to JAR CPL.

Easa CPL
IR/R
1200 hrs
80 IFR

I have an FI with the instrument privileges to teach IR/R but looking around the various forums it seems the ability to sit with IR holders for remedial training maybe useful as many of my ex students have gone on to get IRs and their own aircraft, I am looking to do some touring as I get older and kids are not costing me a fortune.

[Johnm]

I think the French are far from perfect but so are the British judging from all your complaints about the CAA. All I read is the cost of examinations and the "must be CAA employed examiners" and the costs of a170 and ... and ...

The only positive seems to be the IMCr....

The FAA has certainly a much more pragmatic approach to things than EASA.

Alas ... we live in europe .. and allthough the EU and EASA brings us quiet a bit of limitations and extra burden ... it has also brought peace and prosperity to our region with far to many countries with each their own unique identity on a small area.

And frankly .. I rather enjoy the French wines.

French wines have improved greatly since they imported Austalians to show them how to make it:O

The peace and tranquility is liable to go the way of the Russian empire thanks to the excessive expansion and the cock up over the Euro.

If Stalin and Roosevelt hadn't stitched Churchill up, Europe would have been absorbed into the British Empire in 1946, everyone would speak English and it would all work swimmingly :E

[Ellemeet]

I give up :ugh::ugh::ugh:

:cool::p

[Silvaire1]

https://en.wikipedia.org/wiki/Judgment_of_Paris_(wine)

I think Europe was progressing quite nicely postwar until about 2000. The commies had been driven out, and standards of living were rising everywhere. With the US pulling out of its mediating role, the rise of the Euro and EU bureaucracy and centralized power, Euro-boosting propaganda preaching that leisure could replace work, plus German ambitions to use national economic and political power to crush industry elsewhere in the EU, things started to turn in my view. I think the potential of a single currency was buried under those factors. EASA is pretty much a microcosm of everything negative.

My wife the lovely Bavarian mostly agrees although she maintains that its really better for everybody if they use 100% German products, including Dornfelder Red with dinner. ;) :)

[Johnm]

My wife the lovely Bavarian mostly agrees although she maintains that its really better for everybody if they use 100% German products, including Dornfelder Red with dinner

Hmmmm. Word on the street is that if you want a good value and reliable car from VW Audi Group buy Skoda made in Czech Republic. Mercedes Benz quality is rubbish since they merged with Chrysler. Half the Geman badged domestic appliances are made in Italy, shall I go on? :)

[englishal]

The best VW /Audi's are those made by SEAT in Spain :)

My BMW X5 gives me so much grief - annoying electrical issues, telling me to check my fog lights every trip even though I know they are ok. I'd never buy another Beemer....

PS German Red?! :eek:

[Silvaire1]

What I actually buy in new consumer durables is often Japanese, for the usual reasons. ;)

German stuff ran out of steam in the early 90s, now they sell on image and buy out their EU competition with the money made. It's nonsense, but is setting them up nicely to profit from the EU as a client state, with the profits going home.

Bayern does seem to have a good soccer team.

[Silvaire1]

PS German Red?!

As I remember its about €3 a bottle and actually tastes fairly OK-ish. :)