If the UK is not granted a national "exception" - that is the end of the IMC rating, so far as AOPA is concerned.
Is that what AOPA asked EASA for?
I hope not because it would be rather stupid to set out on a programme to properly harmonise pilot ratings and licensing requirements across the EU and get rid of the major flaw with JAR-FCL - local interpretations and local differences only to insist on establishing local differences.
Everyone has to remember that national aviation authorities are not swayed by the number of pilots wanting to do something.........they will dig their heals in and not budge until they can be assured that safety and thus their credibility as a regulator is not going to be comprimised.
AOPA and others should have plenty of experience of that position - there are thousands of pilots in the UK with the same ideas on GPS as IO540. If the popular position was what regulators went with then we would have had mandatory GPS and GPS approaches in the UK years back.
That is an example of where sheer numbers of pilots requiresting something does nothing to speed change. The same thing applies with the IMC rating. Other national aviation authorities are going to look at what would happen if they had IMC rating holders active in their airspace and more importantly the posibility of something happening and their public / government minister turning round and saying that the introduction of the rating was a bad idea while beating them round the ears with ICAO Annex 1, the FARs or whatever comes to hand.
The proposal has to be European wide and has to be a rating that will ensure safe enroute IFR flight in all classes of airspace. The idea that the flying instructor getting on top to teach a lesson needs only limited IFR training is not a credible position because they can find that when they wish to descend the weather is below minima and they have to divert.........and they may have to divert to a major international airport in Class A airspace.
First question from a foreign NAA regarding the IMC rating is........if it is so safe why do you not permit IFR flight on the airways and at a major international airport?........What happens when Heathrow is the best available IFR alternate?..........If the Airways are there for enroute IFR flight why are enroute IFR flights excluded and even discouraged from flying along the alignment but just below the base?
One also has to overcome the simple position that most NAA's (including the FAA) as well as the ICAO standard position is that an IR is the minimum qualification for IFR IMC flight. That is the wall that is going to have to be broken down. Claiming that the safety benifits of the trainng will not work because the training can be provided to anyone without them having to be given some poor man's IR - they simply get the safety benefits. How do they then keep current? - ask the majority of IMC rating holders and the answer is they don't.
It is unfortunate that this is on the table at the same time as a growing case for the rethinking of the IMC training element of the PPL course. I remember the arguments across Europe when it was implemented and the agruments that it would give the basic PPL too much confidence in IMC flight and that the simple - enter cloud and you'r dead message will be lost are still ringing in my ears. The heli guys have gone down the road of removing the IMC training element and chances are that the fixed wing position will change slightly.
Now if pilots and NAA's across Europe are starting to push for the 180 deg turn in cloud requirement to be removed from PPL trainig then how can you expect that the safety benifits of the IMC rating will sit with their thinking?
Regards,
DFC