Utfart,
Thank you for bringing some objectivity and a fresh pair of eyes to this discussion.
I didn't have time to dissect Fuji's post, but now you have started, I'll continue
Thus pilots with 15 hours training, possibly from an instructor whose own experience is quite limited
Instructors with limited instrument experience teaching an IMCr .. .. .. Now there is a brave statement made without reference to a single fact and hidden behind a “possibly”.
You can't deconstruct an uncertainty into a certainty by saying it was "hidden", or suggest something untoward by the use of possibly.
Possibly alien life forms have visited Earth. Is that "a statement hiding behind a possibly"? No. It is what it says.
More importantly, there is the factual point that an IMCr may be taught by an instructor who does not have an IR. Personally, I have no problem with that - I think flight instruction is more about motivation and teaching skills and currency in teaching than it is about other experience. Also, I think the IF course is the same as the IRI and a very good course. Nevertheless, the point is factually true an IMCr holder may flying IFR departures, enroute, arrivals and approaches having had their entire instruction conducted by someone who wasn't an ICAO IR holder themselves.
I am not making a judgement either way. I am stating a fact. That fact may not concern you or me, but there are stakeholders in the UK and Europe, I suspect, who don't think it's acceptable.
Oh I am so sorry you had to manage minority concerns. I am also sorry that one nuter is the only thing you can remember of a very valuable meeting. One would have hoped for a little more maturity.
He is making a point that balance and maturity are not exactly hallmarks of some of the IMCr campaigning and that this, at times, may be counter-productive. I imagine the irony is lost on you.
I think it is very disparaging to criticise something that has evolved with and stood the test of time. I know of no better test, and you can bet it is a far better test than a bunch of hypocrites inventing something which they haven’t tested at all
You don't get it, do you. The European system has evolved 2 features
- standardisation through the JAA and, now, EASA
- a "standards paradigm" (I hate the word but can't think of a better one) which is distinct and very firm in the European regulatory mindset.
In respect of training, that standards paradigm involves
- long, structured courses of Theory and Flight training
- written exams conducted by NAAs
- flight courses conducted by FTOs with all the approvals paraphenalia
From the EASA point of view,
it doesn't matter that the IMCr has "stood the test of time". EASA's goal is about raising safety standards to a common level in Europe, as defined in the thousands of pages of JAA and, now, EASA documentation. Your inability to grasp this point is why you will be typing the same stuff post after post after post. It doesn't matter. Whatever the strenght of your claims about the record for the IMCr (most of which I agree with), it doesn't fit the "standards" of EASA.
I can't think of a single new European/JAA regulation or restriction that didn't replace something that previously had "stood the test of time" equally well. What happened to the old self-improver route to the IR? What happened with smaller schools teaching commercial stuff? What happened to independent engineers? What happened to engines running more than 12 years? The list is endless.
You have got the entire debate the wrong way around. You think EASA or someone is killing the IMCr because they have a case that it is unsafe. You write thousands of words opposing that. Most of them I agree with. You've used a legal analogy before and one is useful now. You are in an empty courtroom defending the IMCr against charges no-one has brought.
EASA are in a different courtroom. The EU has legally empowered and directed them (it's the EU Basic Regulation laws, not EASA's discretion) to
1. develop a set of high common standards for aviation regulation in Europe
2. standardise those across the region without national exceptions
It doesn't matter that the IMCr is safe and has met the test of time. A million non-EASA or non-JAA practices and methods meet the same criteria (eg. the entire FAA system). Europe has chosen a different model. You can either choose to do your best within the model we are in, or you can write endless posts which are irrelevant. Good luck in overturning the entire European regulatory paradigm in your "campaign". I think this is an ambitous goal. Achieving it may need a brief respite from your main activity of slagging off Jim Thorpe.
I absolutely understand the apparent contradiction between the proven IMCr and the unproven EIR.
At its heart is a misunderstanding some people may have; let me call it the "Privilege Limitation Fallacy".
The IMCr is a rating which permits a pilot to fly under IFR in IMC in every phase of flight. From the point of view of knowledge, training and skills, there is no meaningful difference between the IR and the IMCr, if, as EASA does, you took
the current IR as the baseline and said "how can the training be reduced if we removed Class A privileges and recommended higher minima"; what would the answer be?
- a tiny bit of air law relating to Class A and airways
- the dog-leg join of an airway you do on IR test routes (one of the easiest bits)
- the ~40s on each ILS it takes to descend from 500' to 200'
Teaching a non-precision approach would be identical, except there'd be a different number on the altimeter at MDA.
Therefore, from the perspective of the EASA IR, the reduction in IMCr privileges simply does not correspond to the reduction in training and "approval" standards for training.
Let's take the example of all the other ideas for "limited privileges" I've seen on various threads.
- can't be used in RVSM airspace
- can't be used in pressurised aircraft
- can't be used in Type Rated aircraft
- can't be used in Oceanic routes
- can't be used in aircraft with more than 6 seats.
It's all clap trap. The JAA/EASA IR is conducted in a light piston aircraft at low level. What could you eliminate from the flight training as a result of
all these "restrictions"?
- err, nothing
The reason FCL008's output is the best achievable for GA is that EASA's current "baseline", the IR, is simply not up for debate. Jim's success on behalf of GA has been to
- push for a more flexible, competency based training method towards the IR
- push for the IR TK to be more relevant to the privileges granted.
The EIR is perhaps achievable for the very reason
its privileges are meaningfully limited. Approaches and departures are the hardest part of IFR training and flight. If a safe model for the EIR and its privileges can be defined (and I agree it's a new concept, so far from certain), then it is probably the best "sub IR" that can be achieved at a standardised, EASA level. The problem with all the "sub IR lite" proposals is that they openly tweak the privileges and then implicitly flip the training paradigm from the "EASA high standards" one to a more informal IMCR/PPL/FAA traning model. EASA won't accept that. You can tweak privileges and training in a
consistent manner within the EASA training model (as the EIR tries to do), but something outside that model (as the IMCr is) will not be accepted in Europe.
brgds
421C
As a final thought, if his article was so weak and dribbly, why not try writing an article or paper of your own? Let us hold your writing and analysis to the same scrutiny you apply. It would be illuminating.