Originally Posted by
dublinpilot
What if we were to take Jim Thorpe's EIR, and make two significant changes:
1. The airlines don't seem to want to share the airways with EIR trained pilots.
I think your starting point here is wrong on a number of counts.
- In most of Europe GA are able to mix in the airways with CAT today (just not in IMC)
- FCL.008 seem to think that the airlines and regulators ARE willing to accept EIR trained pilots operating IFR in IMC during the enroute phase.
- Point 2 above is not surprising given the proposed EIR knowledge requirement is significantly greater than the current IMCr
- The concerns around extending the IMCr into Europe are rather more generalised than just airlines trying to maintain a private club.
Also, in the environment you propose, the UK would have a logic to move to Class C around air carrier airports for 'European Harmonisation' so this could be a pyrrhic victory strategy for saving the IMCr.
There should be two very clear focuses of effort
First, moving to a sensible training, testing and TK structure for instrument flight in Europe - which would improve safety, reduce the relevance over the long run of sub-ICAO IR qualifications and help contain the growth in N-Reg aircraft. (I do accept history is not on our side on this one)
Second, a robust defence of the IMCr, almost surely built around the CAA,DfT, UK securing a right to add additional sub-ICAO privileges to EASA licences valid only in UK airspace. This may result in all States having this privilege and any State that wished could introduce or recognise the IMCr (but given no one has yet picked it up - this is aspect is likely to be a long shot).
The quest for a mixture of training, TK, testing and privileges to build a sub-ICAO IR seems unlikely to succeed. The non-IR rated GA community (UK in particular) is opposed to any meaningful privilege limitation and the regulators are opposed to moving general IFR operations to a sub-ICAO training and testing level.