Fuji,
Finally I am pretty fed up of those who promulgate the usual nonesense about the rating being unsafe. Why pander to the detractors and ignore the evidence. I wouldnt mind your doing so if you (or they) had any factual basis for doing so.
Then why do you trott out your thing about how safe the IMCr even when
no-one has said it's unsafe? I repeat. No-one on this thread has said the IMCr is unsafe.
Can you not understand that the following two positions are not inconsistent?
1. People accepting that the IMCr works safely in the UK with the UK's specific Class A structure and the Class A limitation of the IMCr
2. People outside the UK not accepting the IMCr in their airspace which has a different structure in which Airspace Class limitations can not achieve the same effect they have in the UK.
A number of posters, myself included, have tried to explain our understanding of why EASA isn't going to take the UK IMCr and turn it into a European qualification, and why the basic principles of EU standardisation mean that they didn't just draft EASA FCL NPA17 with a "UK only" qualification, and why, subsequently, FCL008 wasn't able to do so either.
Now, as we have all said, there may be "secondary" methods of getting the UK to hang on to IMCr privileges through transition/grandfathering/opt-out whatever. It would be great if there was such a mechanism. I just don't know what it is.
I know, I know all petitions are a complete waste of time. As I said earlier I will mention it to Gordon next time I see him. Oh, perhaps you might mention it also to the 4,000 odd pilots that signed the petition.
No-one said it was a waste of time. It's your thing again of replying to points no-one has actually made. I only said I didn't believe any petition was going to make EASA publish a Europe-wide IMCr. David pointed out that the reply to the petition didn't seem to add anything to the established CAA position on the subject. That doesn't mean it didn't raise awareness etc.
This is what was said only this month. That seems completely out of step with some of the views expressed here. Either we should believe and rely on what emanates from EASA officials or if EASA is allowing officials to mislead us then clearly EASA is not fit for purpose.
It does seem that there is an inconsistency here. I don't understand it any more than you do. Could the weak link be the reporting of these comments?
The EASA Working Group FCL008 had been set up to look at the IMC Rating, he said, and if it did not produce an acceptable solution to the problem, then it had failed in its task.
The other issue may be in the "acceptable". Acceptable to whom?
We need to be very careful. There are those who would rather see the demise of the IMCr or its son or daughter for all the wrong reasons. You can bet there are some on this forum. After the comments I have read by EASA, the CAA, the Dti and others, only some of which I have reproduced I have a little more faith. Unfortunately there may also be individuals on committee with less apparent agenda
This really does read like some sort of odd paranoia. If you have read comments by EASA, the CAA, the Dti, AOPA that give you "faith" then why don't they just turn their faith-giving comments into action? What mysterious force of darkness is preventing them?
The truth I believe is that, in principle, a lot of people are sympathetic to the IMCr but, in practice, no-one has worked out how to preserve it.
Freda,
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 can see how some of that looks contradictory. I think there are two levels in how European laws and rules operate. Firstly, there is a "Primary" level - the regulations that are standardised across Europe and become EU law. Then there is the "secondary" level of national deals/opt-outs/exemptions/whatever that uses a variety of other mechanisms and legal/political methods. EASA's draft rules, developed by the FCLxxx Working Groups, are at the "Primary" level. At that level, I don't think you can have national exemptions etc. I don't know what can be achieved at the "Secondary" level - perhaps a lot - eg. keeping the IMCr or attaching approach privileges to an EIR etc.
brgds
421C