421C
I am sorry for my robust response to David. I will be frank when saying it dismays me when commentators like David appear to have given up on the IMCr and any replacement (the EIR is not a replacement). I wouldnt mind if he was in step with UK pilots (and even many outside the UK) but I honestly believe he is not. What may or may not be politically achievable is one thing but there are times when you should reflect the wishes of your members. I am not convinced that AOPA supported the UK IMCr two years ago but I suspect if they did not they realised they were out of step with their members and have now had the "guts" to nail their colours to the mast.
But if the Agency is now instructed by the EC to leave sub-ICAO/JAR licences to the national authorities, then its future in the UK appears to be secure.
As I stated earlier here is one possible mechanism. There are others if the Commission wish to use them. We should be pushing for them to do exactly this.
I could set a number of solutions that I believe would be acceptable but there is little point until we have a better idea in which direction EASA will go. One possibility would be a Euro wide EIR with sub-ICAO approach and departure priviliges granted by the CAA in UK airspace.
With regards to the IMCr I understand the safety case perfectly well. If an IMCr holder has demonstrated that they can safely negotiate the arrival into Glasgow what makes you think he cant do so into Maastrich? In fact I think you are entirely wrong - it is the EIR that extends the priviliges of an erst while IMCr holder in Europe because European airspace is not compatible with IMCr holders operating off airways. The reality is many are uncomfortable with a rating that they perceive as being equivalent to an IR lite by another name - which also many do not want in Europe (or historically the UK). The IMCr rather neatly side stepped the issue by keeping IMCr holders out of class A. An EIR with approach and departure priviliges on the face of it does neither. However the imposition of a height restriction and higher minima might have been a better approach to placating the IR lite by another name brigade. In fact it is interesting when you tell some that the minima for an IMCr holder are the same as for an IR - quite simply they are horrified. I suspect the wording the CAA adopted in the ANO was very cleverly drafted.
So much better progress could have been made on this issue if our representative organisations had not just caved in before the first hurdle. Let it not be forgotten how powerful a lobby GA could be. Their numbers are far far greater than all the European commercial operators combined and nearly every single one is a voter. Many are politically or economically active and therefore very influencial. I was pleasantly surprised how relatively easy it was to ask over 4,000 pilots to sign the No 10 petition - that is more than the membership of AOPA UK. I was surprised how with only a little education European pilots were arguing the case for a Euro instrument rating with approach and departure priviliges. It should be to the chagrin of so many of our representative organisations that on these big and important issues they could not find a way of working together, of educating European pilots of the benefits of an IMCr style rating and on lobbying the Commission rather than walking away from the campaign as we have seen on this thread.
As they say in American its the difference bewteen their starting from "of course we can" and our starting from "of course we cant".