Why do you make something so simple so complicated?
Easa rejected the inclusion of the imcr at an early stage. Had they consulted and had their rejection been transparent it would have been clear (at any early stage) the void left was untenable. The eir and the grandfathering of the imcr was never on the table when the imcr was rejected, or certainly not publically. Both arose because easas rejection was untenable. Had the process been transparent it would have been clear much earlier that the proposals were untenable and we would not be in the mess we are now in.
Your attempt to rewrite history is therefore simply not supported by the facts.
It is simple, but you aren't reading or grasping my replies. Let me try line by line, with your text in italics
Easa rejected the inclusion of the imcr at an early stage
The FCL001 working group, responsible for the first draft of EASA Part FCL rejected the IMCr as an FCL qualification. I am glad we agree on this simple point.
Had they consulted and had their rejection been transparent
This is you rewriting or not grasping history. The FCL NPA was published. It transparently DID NOT include the IMCr. They DID consult. The FCL NPA went through the whole CRT-CRD process leading to a Final Opinion that then went through the EU Comitology process.
it would have been clear (at any early stage) the void left was untenable.
It clearly was tenable to the European Union since Part FCL became EU law. You mean it was "untenable" and "unnacceptable" to the IMCr minority interests. I agree. There is no law of the political universe that nothing can happen which some minority consider "untenable".
The eir and the grandfathering of the imcr was never on the table when the imcr was rejected, or certainly not publically.
That's right. We agree. So what? The first step in the process was to produce a draft Part FCL. They did that. It was a subsequent matter to deal with problems arising from that.
Both arose because easas rejection was untenable.
So EASA conducted the FCL process which produced the result it did. They got feedback that IFR qualifications needed to be made more accessible and feedback that UK stakeholders were unhappy giving up the IMCr. So the FCL008 process produced the EIR and CBM IR and the parallel process of negotiating transitions has suggested the IMCr grandfathering mechanism.
Had the process been transparent it would have been clear much earlier that the proposals were untenable and we would not be in the mess we are now in.
Where exactly was the missing transparency? The outcome has been perfectly clear that EASA Part FCL doesn't include an IMCr. You keep using this word "untenable". "Untenable" to you, "untenable" to IMCr holders fine. But clearly the Part FCL outcome was tenable because
a) the European Parliament passed it
b) the UK didn't threaten to leave the EU over it
and we would not be in the mess we are now in.
Relative to the Basic Regulation which imposed a standardised European FCL system and requirements for FRA operators to comply, and relative to Part FCL which was essentially a cut&paste of JAR FCL with a few bits of gold plating and some improvements like the LAPL, we have made some useful progress. We have the EIR and CBM IR, we have the outlook for IMCr grandfathering described in the NPA. So the next step is to secure those outcomes. Sure, relative to a parallel universe in which the Basic Regulation hadn't been enacted, or a parallel universe in which EASA had copied Part 61, or a parallel universe in which the UK government chose to expend the political capital it would have taken to ringfence and assure the IMCr, we are in a mess. But given the universe we are actually in, the present outlook since the NPA was published seems encouraging relative to the outlook before it was published.
As to your reference to easas statement that really is clutching at straws.
It's harder to have a useful discussion with you when you don't even accept the basic meaning of the English language in what you have written. You said "
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." I pointed out Para 7 of the NPA. Their proposal is a restricted EASA IR giving IMCR holders grandfather privileges. How can my pointing that out be "clutching at straws". Isn't it a factual and obvious counterpoint to your writing "
so far as I am aware they failed to do so"? I would have thought it a useful improvement in your awareness?
The straw of a statement issued less than one month ago the clarrity of which at best leaves a great deal unanswered
It's your old problem of clarity vs. transparency. They have published an unfinalised proposal. Not every detail is clear, although I find the essence pretty important and useful. So, as I said previously, the choice you have is between transparency (publishing interim things where not everything is clear and finalised) and clarity (publishing nothing until the final instrument is enacted and everything is clear and certain). They did the former and you say it's "not clear". If they'd done the latter, you'd have said they weren't being transparent. What's the point of your endless pursuit of an incompatible combination of clarity and transparency - ie. knowing, at the same time, what the end result is and knowing the steps of the process that is deriving the end result? Really the only substance is one of
timing. EASA could have tackled it earlier. Well, launch a campaign to complain about that. I think you are missing the fact is there is a vast amount of incomplete regulatory work - on the implementation of FCL, on the FCL008 NPA, on Part MED, on Part OPS, on Part ORA. We are in a process were few end outcomes are certain and clear. The issues that affect all of Europe are probably a greater priority than the issues that affect just the UK. Are you surprised?
Finally i am obsessed with the imcr because it is the subject of this thread. I have no illusions that easa are a great deal less obsessed
I did not use the word obsessed, so I don't know why you bring it up. I merely thought it helpful to point out that what you interpret as a conspiracy of opaqueness, in not having the clarity you want with the transparency you want at the time you want it, is probably more the result of a regulatory agenda in Europe in which the long list of things that need to be completed and clarified doesn't rank the IMCr (unsurprisingly) as far up as you would like.
I am not writing all this to defend EASA. I have a myriad of things I would like to see changed in how European GA is run and regulated. Probably much the same as any of us. I am writing to suggest that what you percieve as a conspirancy to deny you clarity and transparency is simply a very large and complex process in which the IMCr issue is a minor one that is not addressed with the priority and vigour you would like. Given that, I think AOPA and the UK CAA are doing a pretty good job trying to push the IMCr forward against 26 other countries for whom, unsurprisingly, it is a distraction and nusiance relative to the huge task of implementing EASA regulation.
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