So, trawled through all the pages on here (25-odd on the EASA and the IMCR thread plus a few others) and I am trying to summarise the situation here, as I really am trying to work out whether to do the IMC or not before April...
There is always here-say and rumour, but let me start with the facts and work slowly through. The CAA published in September: -
European Legislation - The Expected Effects on the Licensing of Pilots in the UK - September 2011
Frequently Asked Questions concerning the new European rules for pilot licensing
In the first document, there is no specific mention of the IMCR, but I guess that is expected given the extract from the second document.
25. What is going to happen about the IMC rating?
This has still to be decided. EASA is due to publish a Notice of Proposed Amendment
setting out its own proposals for a simplified instrument rating in September 2011. It is
unlikely that EASA will agree a position on the future of the UK IMC rating, and the
privileges of existing holders of the IMC rating, until sometime after the EASA NPA is
published.
Which obviously aligns with the statements of some in the EASA and the IMCR thread that there is a separate working group for the IR harmonisation.
I also get the feeling from reading the threads that there has also been a lot of compromise from EASA. The original NPA made no reference to the IMCR and effectively abolished it. There is some discussion about EASA making credit for the IMCR and also some credit towards an EIR. (See quote below, from Page 24 of EASA and IMCR thread): -
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.
So, with that summarising the position so far, as I understand from the trawl, my thoughts and questions are around the worth of doing the IMCR before April.
There is obviously benefit in having some IR skills as a get out of jail card. So either the IMCR or the EIR will offer this benefit. From that perspective there is no advantage in rushing to get the IMCR done before April.
However, if there is a credit, even if restricted to UK airspace only for the full IMCR privileges then there is benefit in extra effort to get the IMCR before April.
Where I am is do this before April or not..........
But having written this, and allowing me to think things through, the IMCR does teach Instrument Approach, which the EIR will not... and as a get out of jail card, I would rather bust everything and get myself on the ground and have the argument, rather than the alternative of trying to teach myself an instrument approach when I am above cloud and don't have much fuel left because I am on my fifth alternate with no cloud breaks - which let's face it will put a smile on an Undertakers face somewhere!
So, with all that said, anyone up for a JAA school in Florida in Feb/March???