IMC rating in theUK?

[mm_flynn]

Originally Posted by homeguard

BEagle has outlined a very clear syllabus and standard for the EU IMCr. I see no need to water down an IR or treat the IMCr as a module. ... The IR requires many elements not required by a vast number of PPLs and this accounts for much of the additional hours within the IR syllabus and the testing content. The IMCr should/does satisfy civil concerns for the specific privileges it confers. The safety statistics over 35 years establishes that fact.

The syllabus is reasonable, it is the privliges and scope which need working on in a European context. The IR doesn't have that much more technical content than the IMCr and leaving aside the gold plating of the JAA IR, the knowledge and flying requirements of an IR seem reasonable for planning airways routed IFR - which is all that will ever be available in the rest of the world.

There is a fundamental problem that the IR is currently gold plated. A more appropriate IR is critical for a whole range or reasons. This is not the same as a watered down IR.

Originally Posted by homeguard

Whilst the particular EU bodies who are reticent to accept the IR need to be brought round by persuasive argument we must just the same hold a firm line and believe in what we have. Should those against an EU IMCr not be persuaded of the need, then they must understand that the UK will not just roll over. Persuasion must be the best way but you don't win a difficult argument going at it half-cock.

There are four strategies we can pursue

1. Fight to keep a separate IMCr just like it is today with no chance of extending it to Europe (i.e. a status quo opt out)
2. Try for a more sensible IR (which is unlikely to have lower requirements than the FAA IR)(but still pursuing the other strategies)
3. Try to morph the IMCr into something which could work in the rest of Europe
4. Create a two tier IR with a tier similar to the current IMCr and a sensible set of requirements for the full IR

Just rolling over and loosing the IMCr is, I agree, not an option which should be considered.

At the moment, I believe we need people pursuing all of these strategies, and developing proposals in each of these areas (my previous one was clearly targeted to the last option). However, option 1 probably needs to be maintained till the end to cover for failure of any of the other three.

Originally Posted by homeguard

With regard to airspace. The UK has had a long tradition of preserving airspace for all. Generally the Controlled airspace in the UK must be fully justified. It would appear that within much of the EU controlled airspace is given willy nilly. ... The idea that an IMCr holder cannot use their privileges at an airport used by an airline, with respect, is daft.

Only in remote areas of the world (other than the UK) is the concept of uncontrolled IFR flight allowed. Notwithstanding the fact that the big sky theory works, everywhere else in the world puts controlled airspace in that generally allows pretty free VFR access but requires clearance for IFR. Bizarrely, the UK sees fit to have uncontrolled IFR allowed to run through ILS's and operate 100 feet below the London TMA, but for virtually all commercial enroute bans VFR traffic from sharing the same airspace. Other than Italy, the UK seems to be the only EU country with this ultra protective view of the enroute airspace.

Until recently (I would guess the last decade) the IMCr was only allowed in some Class D airspace (which broadly would be described as not air carrier airports), for people using the IMCr for personal satisfaction and basic safety they probably aren't using these airports. For people who are, they are probably using the IMCr as a 'poor man's IR' and I believe sustaining this is only viable in my first strategy.

Originally Posted by homeguard

We are a country of 60 million with the most congested airspace in the world. Things work here with little or no objection to the IMCr, who then can have an excuse to resist the IMCr.

While 60 m population is true, most congested airspace in the world is not. The UK is just like many other countries, with some busy airports and a lot of empty space (particularly true below FL195).

Originally Posted by homeguard

EASA/EU, if all cannot be persuaded, should approve an IMCr but allow each state freedom to adopt it or not

I think the only way this is likely to happen is through some kind of UK opt out.