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Old 5th Jun 2011, 17:27
  #11 (permalink)  
Gertrude the Wombat
 
Join Date: Nov 2000
Location: Cambridge, England, EU
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Well, I've sent this, for whatever good it might do:
Dear Andrew,

As you may know I am a private pilot and have been flying for quite a while now. I have invested in further training to upgrade my skills and acquire the UK Instrument Meteorological Conditions Rating.

To my dismay it has come to my attention that under the new EASA FCL regulations I'm about to lose the flying privileges of my IMC-rating. This rating is very useful as it allows me to fly through cloud cover, should the weather conditions deteriorate below what was forecast, a condition that we face quite often in the UK; without it there would be far fewer days of the year on which it would be prudent to take off.

The proposed EASA legislation doesn't offer any reasonable alternative or compensation for the lost course money and flight lessons or for the removal of the rights that I currently enjoy. The UK Civil Aviation Authority (CAA) also hasn't been very helpful, mainly because the proposed legislation is currently undergoing a scrutiny procedure in the transport committee of the European Parliament and the CAA's line seems to be "we don't really know exactly what's happening, and it's out of our hands anyway, so we can't help you".

There is no conceivable public policy driver for removing this right that I and other pilots have worked hard for and paid out thousands of pounds for; indeed the only relevant public policy driver that anyone can think of, safety, points the other way - pilots with an IMC rating are safer than those without. As far as I can see this rating is falling through the cracks of a regulatory harmonisation effort that is really aimed at commercial pilots who are responsible for fare-paying passengers, and general aviation (GA) pilots like myself have simply not been thought about properly. (There are other problems with the proposed EASA regime that will hit other GA pilots - I'm only writing about the IMC rating because that's the one issue that I understand as I am directly affected.)

I would like to encourage you to do what you can to reject the current proposal, sending EASA and the Commission a strong signal that imposing the abolition of a safety enhancing feature in private flying in the UK is not the way to go.

I gather (I haven't studied the details of the relevant law, this is advice I've received) that it would also be helpful if you could urge the Commission to amend Basic Regulation 216/2008 so as to postpone its implementation until a viable alternative for private flying under instrument conditions (similar to the UK IMC and with a grandfathering principle) can be worked out. I have been informed that only the implementation article (article 70) of this regulation needs amending.

If you would like me to take you for a ride to demonstrate the type of flying that EASA is seeking to ban I'm happy to try to arrange this; however this could be difficult - British weather being what it is, any day we arrange will turn out to have clear blue skies!
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