Re. the NPA:
1. The sailplane cloud rating will suit sailplane pilots; however, it must be carefully worded to avoid inappropriate use by TMGs using it as a 'poor man's IR'. The other problem is that is doesn't cater for tug pilots needing to operate close to cloud; under present proposals they would need to hold an EIR, which is clearly disproportionate.
2. The C-B IR is a good proposal. People should comment on any Learning Objective they feel to be superfluous. Theoretical knowledge examinations for 'Third country' IR conversions are not mandated in the NPA: it proposes merely that the applicant can demonstrate that the requisite level of knowledge has been achieved. So please suggest ways of achieving this when responding to the NPA. My opinion is that the Examiner can make sufficient assessment of an experienced FAA IR holder by observing the applicant's pre-flight planning as well as the practical in-flight conduct of the C-B IR Skill Test, perhaps with a few oral questions where necessary. Which, incidentally, is the way I used to assess pilots when I was conducting IR tests on the VC10 in the RAF.
3. The EIR will require diligent pre-flight planning and a Z-type FPL which includes VFR-to-IFR and IFR-to-VFR transition points in the Route section. It will also require a good standard of radio work. Correctly used within its privileges, there is no reason to doubt that the EIR can be used safely. Particularly as a stepping-stone towards the C-B IR.
4. NPA 2011-16 does not include provisions for the national needs of several Member States, including the UK whose IMCR is not provided for - and that is something we cannot accept. So a meeting was held at Gatwick on 9 Nov at which a formal proposal was handed to the CAA. The aim being to secure a solution which will satisfy the national needs of all Member States - and which would greatly simplify the UK CAA's workload in several areas. The UK CAA also stated that, contrary to rumours rife amongst certain parts of the GA community, they would NOT be abandoning efforts to find a solution to the UK IMCR - so if you hear silly rumours such as "Oh well, the CAA will palm us off with the EIR and won't bother with the IMCR", please tell the rumour monger to STFU, because it simply isn't true!