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Old 12th Nov 2011, 18:59
  #378 (permalink)  
David Roberts
 
Join Date: Mar 2004
Location: Cirencester UK
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Some of us, including a few on this forum, took the trouble to attend (a) the EASA workshop in Cologne on NPA 2011-16 on 30th September and (b) a CAA workshop on NPA 2011-16 on 9 November.

It is clear to me that both the CAA and EASA want to find a solution for grandfathering the IMCR for UK pilots of EASA aircraft beyond the date when the final EU IR becomes effective - which in practice will not be until at least 2013 probably. In my view, since the new IR (and EIR) will not be in place by the implementation date of Part FCL (8 April 2012 - but deferred effectively in the UK until 1 July 2012 and beyond for transition periods) pilots have to be able to continue using existing national instrument ratings (including JAR IR) until the new rules are in place. This should include the IMCR for UK airspace only. Any other scenario would be daft, as it would be regulatory gap which I highlighted to EASA some 4 years ago when pressing for what became the FCL.008 working group task.

There are often many uninformed critics on this forum - and other forums - who still persist in accusing the members of FCL.008 of 'missing an opportunity'. That is frankly not correct (I am being very polite), as has been explained several times by those in the know. The IMCR was NEVER a candidate for transposition to an EU IMCR, period. However good a rating it is.

What is crucial now - apart from getting the IMCR grandfathered - is to support the NPA 2011-16 proposals which are a major step forward for non commercial aviation. If we do not register our support through the CRT process on the EASA website, be sure that there will be plenty of 'other interested parties' who may want to kill off the proposals. On a pure numbers count they could win due to the consultation process and protocols EASA is bound by. You may of course wish to make some suggestions for improvement of the proposals for the IR and EIR, but whatever, support them in general. This opportunity for a change to the JAR IR will not come again for many years.
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