Beagle
the EIR proposal has been supported by no-one apart from this one FCL.008 member - whose opinion must be considered his and his alone
If this is true, then why on earth are you worried about it? It will never get through FCL008 or any other rulemaking. End of story.
Fuji,
That is not the point it demonstrates.
It demonstrates that instrument rated pilots very rarely get caught out by the weather going below minima but they would get caught out by this type of artificial minima
In which case your point is not relevant to what I was saying. I wasn't saying that instrument rated pilots often get caught out by weather minima. I was saying exactly what you are saying - that both VFR and IFR pilots are able operate safely despite the inherent uncertainty in weather forecasts.
they would get caught out by this type of artificial minima.
It's not an "artificial minima". It's the same kind of planning every non-UK PPL is exposed to every time they venture VFR on top, out of sight of the surface. The forecast weather has to indicate that they will be able to get back down again in VMC.
Show me the studies and evidence of PPLs with VMC-on-top privileges "caught out" by not being able to descend to land VMC. There are hundreds of thousands of them in the USA. If it is so utterly fraught with risk and danger, there must be evidence in the US. If it is anything like as risky and dangerous as you say, there must be articles, advisory circulars, NTSB reports all supporting the dangers you are so convinced of.
In my experience IMC rated pilots, and indeed the majority of IR rated pilots, when flying GA type aircraft do not "push" the minima. I cant think of a single occasion when I have arrived and the ILS has been below minima. Indeed it is rare to find these conditions on days (note days) on which GA pilots typically fly.
I also cant think of a single accident involving an IMC rated pilot during the approach segement of a flight but I can think of many involving pilots with an IR. Whatever IMC rated pilots are doing they seem to have developed a pretty good means of flying approaches to the same minima as pilots with an instrument rating. Given the population of GA IMC rated pilots in the UK is more than 10 times the size of those pilots with an instrument rating they would seem to be doing a pretty good job.
What evidence do you have they are not?
I am not saying that IMCr pilots are not doing a good job. In fact I am agreeing with you that they do a good job. My point is that if they can be trained to do such a good job on IFR approaches in the IMCr, then why couldn't EIR holders be trained to safely handle an IFR approach in the event of the emergency situation created by weather being systematically worse than forecast.
That's my only point on this, in reply to the specific argument that the EIR must be 'thoroghly dangerous' because EIR holders might end up caught out by unexpectedly worse weather.
That is a problem. Your argument has little creditability without
I am happy for whatever points I make to be judged, ignored, disagreed with, or whatever, on their own merits or lack of. If you want a forum where people should declare their quals before they venture an opinion, then my impression is that PPRUNE isn't the one. If those are your rules for engaging in a discussion, then I will understand why you won't want to continue this one.
Moreover for all we know you might be "representing" one of those arguing for the adoption of the EIR? If you are you should have the courage to nail your colours to the mast.
Well, I'm not. I am doing what I think this forum is intended for. I read it and I have an opinion. I post that. We exchange replies.
I am happy to be guided by the moderators if there is some special rule about replying to you, or posting on this particular topic. Or for that matter, if I should stop posting because I am outnumbered by posters with opinions different from my own.
I am sorry to keep referring to evidence, but it seems to me this is the crux of the issue. Those seeking change HAVE NO EVIDENCE to support the changes they seek. I am happy to accept change if there is good reason, but change for change sake is a very bad idea.
The crux of what issue? I am sorry, but I am confused by some of your replies. I sense you are writing in reply to points you want someone to have made, so you can wheel out your reply. But the problem is no-one is making those points.
What is the change "they" are seeking and have no evidence for? If it is the "abolition of the IMCr" then no-one is seeking a change; unless it is a change that has already happened when a) the EU gave EASA powers over FCL and b) EASA published the FCL NPA without an IMCr in it.
If the "change" is the introduction of the EIR, then my understanding is that this is a concept or early stage proposal - in fact, if Beagle is right, it is nothing at all except the workings of a lone person unsupported by any other stakeholder or FCL008 member. Nevertheless, the concept can be discussed in principle, which is what we are doing.
brgds
421C