Some very useful contributions to this debate:
1. EASA will not permit the CAA to issue any EASA licences or ratings with further 'UK airspace only' restrictions on them.
The reason I asked for information on this was that I saw a possibility of the CAA issuing (on behalf of EASA) EASA-FCL IRs restricted to existing IMCR privileges only and in UK airspace only. A simple way out of the currently looming mess - but not permitted under EASA regulations....
2. The only way to retain the IMCR is to convince the other EU states of its value. Otherwise it will be swept away.
I have seen a draft RIA (EASA, of course) which seems to think that the only way forward is to let UK IMCR holders 'convert' their IMCRs into EASA FCL IRs by an additional 5 hours training and testing and a 'theoretical examination'. However, this so-called Regulatory Impact Assessment has not given any cost estimates for this process, neither has it assessed the loss of business for those RFs currently teaching for the IMCR. It is a totally flawed draft RIA in every respect and is the product not of any GA organisations.
Personally I consider EASA fundamentally unfit for purpose - its whole rationale must be questioned by MEPs and this whole lunacy delayed.
When the NPA comes out, you must comment. But do NOT cut and paste the comments of others. Every single comment must be answered individually, so the more comments the better as this will slow everything down considerably... Beagle
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So please just answer the question.
I will answer it. There are two scenarios:
The European Parliament does not vote in that part of the amendment designed to give EASA exclusive competence in Flight Crew Licensing = national authorities retaining competence; or
They do but do not rubber stamp the draft regulations put before them, arrived at by what sounds increasingly like a cosy stitch-up, and instead provide a power for a for IFR ratings to be added to the euro sports licence (which I believe is what EASA originally envisaged).
In the first scenario the IMCR is retained; in the second a euro version will emerge. That may not be for some years, but the power will exist.
Of course the phasing of any EASA take over of licensing is an aspect we haven't really considered. It is possible that any amended Regulation will have a longer transition time that is envisaged.
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If you feel that the only way to press the case in favour of having an IMC rating is to quote stats and statements about the IMC rating then thank God you were not part of the team trying to establish the IMC rating in the first place because there was not much experience of how the IMC rating would work back then..............just like there is not much experience in the rest of Europe now.
No: you rely upon the evidence which is available at any particular point. Forget figures for a moment and tell us what anecdotal evidence there is thet pilots exercising the priviliges of the IMCR are causing a danger. I am unaware of any such evidence. The difference as regards Europe is that whilst they may not have experience themselves there is substantial evidence from the UK of how such a rating works in practice. Europe should therefore be in a better position to judge than the UK was when the rating was introduced. Of course it may not be desireable to transfer the concept wholesale. There are airspace differences, for example, and there may be valid issues on the degree of training. The may be a case for splitting the privileges into a number of different qualifications or sign offs, as I believe they do with approaches in Australia.
What we seem to have from Europe is a knee jerk reaction which fails to consider how such a rating would work in practice, how it works in the UK and whether it may be desirable as a means of increasing safety by enhancing pilot skills.
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All this talk of the IR being a professional rating is utter tosh. The IR is the qualifiecation for a PPL to fly IFR. It is not a professional qualification and confers nothing more than the ability to fly when VFR (or special VFR) is not possible.
So why do the theoretical knowledge requirements contain so much which is wholy irrelevant to PPLs? Why is there no credit for instrument flying already done, as is allowed by Annex 1 of ICAO (and is recognised in the FAA IR training)? I believe that recent proposals for modifying the knowledge requirements are on hold and may not see the light of day for some time, if at all.
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The fact that if a PPL holds an IR that get a credit for the training they have completed if they apply for a CPL simply makes sense...............or would you prefer that applicants for the CPL who hold an IR must sit the exams to demonstrate the knowledge they demonstrated previously.
Am I alone in not understanding the relevance this comment in relation to the issues Credit across the various aspects of the training is to be welcomed. However the existing system is cumbersome: for example, anyone initially getting a CPL or an IR and who later wants to go the ATPL route has to redo exams by sitting the full set of ATPLs. Why we do not have a progressive system of training and exams like the US is beyond me. Justiciar