421C,
Correct me if I'm wrong, but I understand you to be saying that FCL.008 was intended to carry out its objective to review the requirements for IR, but to ignore the objective about IMCR (or at best pay lip service to it).
But given what you say about the attitude to it, reviewing the requirements of the UK IMCR is a bit pointless, as we already know that the answer is "you can't have it".
You seem to be saying that the requirement to "Review the existing JAR-FCL requirements for the Instrument Rating" will produce results, whereas the requirement to "Review the requirements of the UK IMC rating and other national qualifications for flying in IMC" won't. (The en-route IMC rating is a pointless and dangerous fudge.)
The uncharitable amongst us might assume that FCL.008 is merely an exercise to stop IMCR holders whinging without actually doing anything for them. Sort of Euro Sir Humphrey at his best.
Freda, (to your post #75)
I think the wording is pretty unambiguous (my underline).
Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges
They did consider whether there was a need to develop an additional European rating. They agreed there was. They defined that as the EIR.
Review the existing JAR-FCL requirements for the Instrument Rating with a view to evaluate the possibility of reducing these requirements for private pilots flying under Instrument Flight Rules
They also reviewed the existing JAR-FCL requirements for the IR and proposed a more flexible training route.
There was no bad faith in any of this process as far as I can see. It's simply not true to say that the IMCR was ignored, because the outcome of the review wasn't what you want. It's not just some faceless bureaucracy who thinks the IMCr is not acceptable across Europe, people who genuinely care about GA and making it flexible and accessible also think so. It's been explained so many times, I don't know what the point is of doing so again, but I will try.
There are some unique features that make the IMCr "acceptable" in the UK. Primarily, it's that Class A is very prevalent - including all airways and large TMAs - even some not very major ones like the CI Zone. Secondarily, we have a fairly undemanding IFR environment - for example, very little terrain, relatively few thunderstorms, little night flying (because GA airports close early).
Plenty of countries in Europe have low-level airways which are Class D or E and large TMAs which are Class D or C. They won't accept the IMCr in their airways and major TMAs
anymore than the CAA will in the UK.
Therefore the IMCr can not work in Europe. Isn't that pretty obvious?
No-one has proposed a definition of IMCr privileges that would work across Europe without the qualifier "where permitted by national laws". But that is a massive qualification which EASA can not accept (as I understand it). Therefore, it isn't that the IMCr was rejected out of hand - it was simply that no workable proposal was found. Without the UK's unique partition of Class A the IMCr becomes......an IR for all practical purposes.
The problem with all the "privilege limitation" options is they are completely misguided in the correlation they draw between limited privileges and training requirements.
Take BackPacker's proposal in post #82
Acceptable limitations to warrant the reduction in requirements vs. the full IR:
- Private flight only. Even if the holder of the IR also holds a CPL, CPL privileges cannot be used while under IFR?
- SEP/MEP classes only. For SET/MET/TR aircraft, a full IR would be required.
- No RVSM airspace, no Oceanic airspace?
It's just a definition
of the current IR with some meaningless tweaks. The current IR confers no commercial privileges, it confers the privilege to fly in IFR. The commercial world has its own processes and training for an IR holder to be able to use those skills in public transport. Similarly, there is nothing, nothing at all, in the 50/55hr JAA IR course specific to Type Rated aircraft. This "limitation" is meaningless. Likewise, RVSM has its own specific training requirements - there is nothing in the JAA TK or flight training for RVSM. Or Oceanic operations in IFR (eg. MNPS across the North Atlantic).
BackPacker's "limitations" are effectively those of the full ICAO or JAA or EASA IR - which can't be used in Commercial flight without a Commercial license, or on a turbine aircraft without a Type Rating, or in RVSM/Oceanic airspace without the specific crew training/ops approval. Therefore, this "consensus" proposal is for a full EASA IR. And FCL008 have proposed making that more accessible by removing the remnants of Theory that are not specific to the privileges granted (there is some commercial and turbine stuff in the IR exams currently) and making the training more accessible for private pilots.
Beagle's "limitations" are equally minor in relation to the IR syllabus. Adding a couple of hundred feet to minima is a tweak along one single attribute of IFR. It does not transform the training requirements. The minima are system-based anyway. They are not linked to training requirements until you get into specific approvals for CAT II/III.
Of course, in the UK, adding 200' to minima does mean that pretty much any blunder on LNAV will keep you clear of terrain and obstacles in most places. The rest of Europe simply isn't like that. Flying around the terrain surrounding some airports in Spain, France, Switzerland and Italy on an instrument approach, 200' or 250' added to minima makes little difference to the risks. The brutal truth is that the only thing which makes sense
systematically across Europe to fly instrument departures, arrivals and approaches is an Instrument Rating.
The EIR is the only "partition" of IFR privileges that FCL008 could come up with that made sense. And I've yet to read a better proposal from the IMCr campaigners which doesn't conflict with the basic premise of
a) no national variations on FCL privileges
b) no minor or practically irrelevant tweaks in the full IR privileges used to "justify" major reductions in the qualification requirements
I don't get the impression that anyone representing the UK considers the IMCR is worth fighting for. Not enough to make a nuisance about. Other countries do that (quite properly) on issues that really matter to them.
But the question is what fight? I think most reasonable people accept why Europe won't have an IMCr valid across Europe - and FCL008 was about Europe-wide qualifications. FCL008 is a positive outcome for IMCr holders, given an EASA-wide IMCR is just not supportable, possible or realistic. It's positive because it proposes a more flexible/attainable IR and a sub-IR qualification (the EIR) to allow some IFR privileges and a stepping stone to the full IR. That's a big improvement on the original FCL outcome. The irony on the EIR is that all the knee-jerk "chocolate teapot" attacks may actually be counter-productive because the EIR may just be a more acceptable way for the UK to "maintain the IMCr difference", by adding IMCr approach privileges to it within the UK.
Instead of all the pointless angriness and finger-pointing, someone who really cared about the IMCr would get real about what is possible. David Roberts has articulated the process very well.
The best outcome for IMCR holders may be
1. grandfather rights for existing IMCr holders to continue with their privileges indefinately, at best, or for a multi-year transition period
2. transition credits towards the full EASA IR
3. UK-only "extension" of IMCr approach privileges to the EIR
I don't know which of these is possible, but it seems like the best avenue to pursue. Otherwise, if you think 5000 signatures is going to produce a Europe-wide IMCr, you are deluded. All the 3 above are UK CAA issues - not EASA or FCL008 ones. IMCr campaigners should be focused on achieving these objectives rather than trying to win battles on PPRUNE already lost in the real world.
brgds
421C