So what you are saying is you want a concise reply, but you don't like the reply you got?
No, that is as removed from what I said as it is possible to get.
OK, so let's see what you said:
With regards the IMCr and the CAA as I said earlier their reply is certianly concise after nearly three years of this process - the CAA doesnt know.
Well if they dont know, I guess no one knows. Worringly one suspects they do know, or have a jolly good idea - but they are not saying. That would be reasonable at the start of this process, it would be reasonable after a year of consultation, it might be reasonable after two years of consultation but it is no longer reasonable.
That reads to me like
a) you acknowledge the answer is concise, which is what you wanted
b) you don't like their answer.
That's all I wrote. How is it "as removed from what you said as is possible to get"? Did you like their answer? Did I misread that in the para above?
If, as you suggest, the Euro IMCr was never part of the process, then you have demonstrated even more convincingly that the process was flawed.
No, that is the opposite of what I said. There was a structured process to review what the standardised EASA FCL qualifications should be. The IMCr was reviewed and rejected in that structured process.
You cant embark on a structured process that ignores elements that must be resolved, and if you didnt realise in the first palce that those elments would need to be addressed or sought to exclude them for political purposes then the process was flawed from the outset.
They did embark on a structured process. It didn't ignore the IMCr. It did realise that it needed to be addressed. It didn't seek to exlude it. However, in including and addressing it, they rejected it. Your problem is that you can't accept that a legitimate process could reach an outcome other than the one you want, therefore you keep pointing to conspiratorial/political/process flaws. The EASA FCL process was one of standardisation or integration or harmonisation, call it what you will. It's happened hundreds of times in the EU and it happens all the time in the private and public sector to organisations that are integrated or merged. In such a process a heterogenous set of things get harmonised into a homogoneous one. That means that some of the old individual things get rejected. There you go. It happens. You may not like the decisions the process arrived at - I don't either - it doesn't mean the process was illegitimate. The UK has accepted this kind of outcome as part of joining the EU.
At the start of the process everyone knew national qualifications existed.
They did. But what you don't grasp is that, very obviously and directly, being part of the EU means being subject to harmonisation processes that can abolish national things that aren't accepted as part of the harmonised European model.
EASA saw fit to abolish national qualifications whilst retaining the option to encompass these qualifications within EASA qualifications in some shape or form.
Not quite, it's what the EU
told EASA to do when the EU law was passed that extended EASA's scope to FCL.
At a very early stage it was therefore clear that the future of the IMCr would have to be addressed
"Addressed" is different from "preserved". It was addressed in FCL and rejected. That's my point about the difference between a process being "illegitimate" and your not liking the outcome.
and more especially thought would need to be given to those who already held national qualifications
Thought was given, just not urgent priority. Unfortunately, EASA's more urgent priority has been grinding through the regulatory process for Part FCL, Part OPS, Part ARO, etc that it has to produce to a tight deadline. Individual national conversion and grandfathering was a secondary point because it is not relevant to most countries in the EU, given they fully implemented JAR-FCL 10 years ago and they don't have anomolous non-JAR-FCL qualifications. The UK is one of 27 countries, and the IMCr is an issue which is confined to a segment of UK GA. It may be at the top of your priotity list, but isn't it parochial to think it had to be a big priority for EASA
EASA had ample opportunity to set out their proposals for addressing this issue - so far as I am aware they failed to do so, and have still failed to do so.
How can you say "they have failed to do so" when the following words appeared in Para 7 of the FCL008 NPA in September:
Although the conversion of existing IMC ratings is not within the scope of this task, the Agency is aware that this issue is closely linked to it. This NPA provides several options for pilots with prior instrument experience to be credited towards the new ratings. However, it should be mentioned at this stage that a conversion of existing IMC ratings is already covered by the draft Commission Regulation laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council. This draft Regulation clearly defines that Member States should convert existing licences and ratings into Part-FCL licences and ratings. It is highlighted in this Regulation that Member States should aim at allowing pilots to, as far as possible, maintain their current scope of activities and privileges. The Agency already discussed this issue with the CAA UK and industry experts in order to identify possible options for UK IMC holders. The most favourable solution seems to be that a Part-FCL licence and an IR will be issued with certain conditions on the basis of a specific conversion report in order to reflect the current privileges held. This would allow the existing UK IMC holders to continue to exercise their IMC privileges.
The irony is that despite your endlessly portentous criticisim of just about everyone and everthing involved (AOPA, EASA, the CAA, the process, the clarity, the communication...) the outlook at present seems to be pretty much what has been communicated for the last couple of years
- an FCL008 improvement over FCL001, in offering a less onerous full IR and a sub-IR rating which is, however, not an IMCr
- a very likely grandfathering solution for the IMCr
- no prospect visible for preserving new IMCr issues in the future (other than for Annex II aircraft) but UK people still trying