Well said, Fuji.
421C, I don't doubt the facts in your post (95), but I don't agree with some of the interpretation, and what seem to be the underlying assumptions.
Quote:
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.
I don't agree that the EIR can be regarded
on its own as an acceptable outcome. It must be explicit that:
...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.
as you suggest later. Without that, I don't consider FCL.008 have met their objectives.
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
Option 3 is fine (so long as it really is equivalent capability to the IMCR). Options 1 and 2 are not good.
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.
I'm not suggesting it's bad faith, but given that everyone is busy telling us that the IMCR is not going to happen old boy be reasonable don't ask for the impossible, it amounts to being ignored. This is not simply because the outcome isn't what I want. I simply don't agree that they have done what they were asked.
They won't accept the IMCr in their airways and major TMAs anymore than the CAA will in the UK.
Doesn't that doom the EIR as well?
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).
To be blunt, EASA must be persuaded to accept it. You also say:
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
Where are these basic premises defined? Thing is, you say (twice) that local exceptions aren't allowed, but then finish by suggesting: "3. UK-only "extension" of IMCr approach privileges to the EIR".
I think I agree with you that this option 3 - a permanent UK IMCR - is all we can hope for, but given that EIR seems a non-starter (as it would allow flight in non Class A airways, which you say isn't going to happen), then a UK extension to a non-starter is a bit of a chocolate teapot.
I'm sure you are not confused, but the points you are raising of EASA's views, and the views of other countries, are rather confused and contradictory. Still lots of opening for a compromise that gives us a continuing IMCR in the UK, I'd say. And of course, let's try to get training for a proper IR fixed, too. But as well as the IMCR, not instead of.