The problem is that any reasonable argument for retaining the IMC rating has to take into account the position of the people who make up that majority. Unfortunately, like it or not, the UK is a minority part of EASA and consequently for any proposal to suceed it needs support from other members.
EASA are considering a sub ICAO IR – call it what you will. The IMCr is just that. The proposed EIR is also just that. Since a sub ICAO IR is on the cards the issue is not whether the member states agree to adopt one, but the form it will take. How has that form been reached? By all means let’s have a discussion about the evidence on which the Commission has relied. Doubtless proper studies have been commissioned? Presumably the Commission has evidence that demonstrates there is a higher accident rate among IMCr pilots whilst flying the approach. Why is it every time the discussion turns to hard evidence most advocates go very quite?
that pilots of SSEA aircraft holding a UK NPPL can not add an IMC rating to that licence.
They can’t add an IR either. It might just be something to do with the reduced medical – do you think?
The UK data shows that the majority of GA operators fly from VFR aerodromes. How many diversions to aerodromes where an Instrument Approach procedure was required were made by IMCrating holders from say.....Popham or Blackbushe or Rochester or White Waltham etc
Nonsense. The majority of IR holders do exactly the same. Consider for just one minute how much time the average IR holders spends on instruments and how much they spend flying visually.
Is the method of deriving the safe minima based on being able to get airborne or to ensure a safe operation - for all?
Please point us to the evidence that indicates the existing minima for IMCr holders is unsafe. Unless you have evidence its just words – you can set whatever minima you like and of course everyone can adhere to those minima, but they mean nothing. Minima exist to protect the pilot because the EVIDENCE shows that for a pilot that is current descending below the minima is unsafe. If the pilot is not current he should revise his minima – it matters not what name appears on his rating.
but the ability of the Club pilot from Popham to pop up through a layer and do some aeros on top before descending back down again is gone.
And do you imagine that is not exactly what they already do, rating or not, or what they will continue to do. After all I wonder if EASA is about to stop gliders flying in or near cloud.
En route IFR is a serious business. I see nothing wrong in ensuring those that do it are adequately equipped – that seems to me a far more reasonable safety concern.
As a barrister told me there are only three things that should count in determining a case:
EVIDENCE, EVIDENCE, EVIDENCE.
So lets see it - otherwise it is all hot air.
EASA can do what they like for all the wrong reasons, if they do they are not fit for purpose, it will not stop them - I know that, but it is no less lamentable.