PLEASE READ THIS AND HELP SAVE GA IN THE UK - Save the IMCR

[Fuji Abound]

THIS IS VITAL TO EVERYONE NOT JUST THOSE WHO MIGHT AT SOME TIME CONSIDER AN INSTRUMENT RATING.

PLEASE AT THE VERY LEAST TAKE THE TIME TO READ THIS THREAD AND THE OTHER ASSOCIATED THREADS AND GIVE YOUR SUPPORT.

EVEN IF YOU DONT HAVE ANY COMMENTS TO MAKE HAVING READ THE THREAD PLEASE AT LEAST RECORD YOUR SUPPORT.

IT REALLY DOES EFFECT EVERYONE.

A report in Flight Training News suggests UK pilots will no longer have the benefit of an IMC rating when, or shortly after, EASA takes over FCL.

http://www.*****************/default.asp?sourceid=&smenu=81&twindow=&mad=&sdetail=283&wpage=1&skeyword=&sidate=&ccat=&ccatm=&restate=&restatus=&reoption=&retype=&repmin=&repmax=&rebed=&rebath=&subname=&pform=&sc=2209&hn=ftnonline&he=.co.uk (HERE)

There is little if any news to suggest that the IR will be made any more accessible for the average private pilot.

It is possible the UK s unique arrangements for night flying could be under threat.

For those with a CAA life time license these licenses will be effectively revoked. The new EASA license will have to be renewed every five years - a purely cash generating exercise.

HISTORY

The IMC rating was introduced during the 1960s. Before then a private pilot was entitled to fly outside of controlled airspace in IMC without a instrument rating. It was felt this was dangerous. The regulators accepted an IRing was beyond the means of most private pilots. The IMC rating was therefore made available to UK pilots as a national rating. Since the rating was introduced some 50 years ago there has been no evidence produced to suggest the IMC rating is unsafe. Many pilots over the years have found the IMC rating provides an excellent way of developing their instrument skills beyond the basic elements taught during the PPL.

PURPOSE

The IMC rating is often promoted as a “get you out of trouble rating”.
It has always been restricted to UK airspace and to flights outside of class A airspace. In addition to enabling the pilot to fly in IMC it also permits flights in VMC when the in flight visibility is less than ideal for a pilot with more limited instrument skills.

Practically there are many pilots who use the rating to enable them to legally transition from flying beneath to on top of a layer of cloud. There are others who will fly part of a sector in IMC and a few, with experience, who will use the full privileges the rating confers.

Our climate offers relatively few days when there is not some cloud in the sky. Whilst metrology has improved, our climate is significantly influenced by the close proximity of the Atlantic ocean and the prevailing south westerly winds. Consequently forecasts are not always accurate.

It would seem patently obvious that UK pilots should be entitled to undertake further training which at the very least would enable them to cope with un-forecast changes in the weather. They should also be able to plan their flight to take advantage of the safest conditions - for example flying at higher altitudes in good visibility rather than scud running beneath the base.

Controlled flight into terrain remains one of the greatest causes of aircraft accidents and almost always results in the pilot and passengers being killed. There is ample evidence to suggest that these accidents are far less likely to occur if pilots are trained and licensed to fly in IMCs.

For these reasons there are many pilots who consider the loss of these privileges to be disastrous. There are those who believe so far as UK pilots are concerned it will be the single most dangerous development in licensing that has ever taken place.

If this is allowed to occur there will be many pilots who have held an IMCR for many years who are no longer able to fly through cloud. They will often find they will have to decide whether to continue the flight in conditions that they consider unsafe or break the law. There will be many new pilots who through their own mistakes, or as a result of inaccuracies in the forecast, find themselves in conditions with which they are unable to cope. For these pilots the outcome is usually fatal, whereas with accessible instrument training beyond that provide by the basic PPL, this need not be so.

Who does this effect?

In summary, whether you are training towards your PPL, you have a PPL but are not considering an instrument rating at this time, you are considering an instrument rating, you have an IMCR or IR or are considering or have a night rating this effects you now because of the wide ranging impact it will have on GA in this country in more general terms.

It effects you if you own an aircraft that is equipped to operate in IMC, even if you don’t currently use it in this way. The market for these aircraft in the UK if these changes are adopted will suffer because very few pilots will be able to use them for their intended purpose.

It effects you if you are a member of a flying school or run a flying school. IMC training provides a valuable source of income and contributes towards the running costs of the school, the instructors and the infra structure. In exactly the same way so does night training.

It effects you if you are involved in the operation of an airfield. How many days are too poor for pilots to fly unless they have an IMCR or IR. On these days almost no flying will take place.

It effects you if you are involved with the manufacturer or maintenance of aircraft or the aircraft industry in general. The demand for aircraft equipped to operate in IMC will all but vanish.

In fact it effects everyone.

Many of us feel very strongly we need to do something about it before it is too late.

What you should do?

I have suggested that the following is a list of some of the actions we could take.

1. Write to Diamond and the other GA manufacturers in Europe - there are a few. I would point out that they shouldn’t bother making any IFR equipped aircraft because other than the few schools teaching the IR and the even fewer PP with an IR the market will die. They charge a lot more for an IFR fit, and guess what, that translates into profit downstream. They are very influential.

2. I would write to the flying schools and I would ensure there were flyers with every letter. I would have a web site from which these flyers could be printed so students and members could lobby their flying schools. I would point out the significant loss of income that will ensue because there will be no IMCR to teach. (You can forget the average flying school teaching the IR if you have any idea what is involved).

3. I would write to every single one of my members if I was AOPA, PPL IR, PFA etc. I would encourage them to write to their MP, Euro MP, EASA members and the CAA and raise the matter with their flying schools, groups, clubs etc. I would make sure they knew exactly how to do so, what they should consider saying and where they should write.

4. I would write to my MP, my Euro MP and whoever I could at EASA and make a complete and utter nuisance of myself. I know a fair amount about planning. People will tell you the planners ignore all the emotional and unsubstantiated objections they receive. Well they don’t. If they come from enough people and people of influence at the very least it causes the entire application to be carefully reviewed, as much as they might like to ignore them. I am not suggesting the complaints should be emotive, avoid it if you can, but it doesn’t matter if you cant. I would do it now. Make a complete nuisance of yourself now.

5. I would prepare a well researched document about the IMCR which would deal with why it was introduced, the benefits it has brought, its safety record etc and I would ensure this is in front of every member of EASA that was relevant, and every flying school I could get hold of in Europe.

6. I would launch a wide ranging complaint about commercial operators activities in open FIR and the way in which this was encroaching on GA. My purpose would be to make it quite clear to the commercial operators that if they want our help with widening their access to airspace we had better see some reciprocation.

7. Whilst I was about it I would may sure that the risk to the night rating, life time licenses and maintenance organisations where all spelled out.

8. I would ask everyone to sign a petition - and sign they should not because they were intending to do and IMCR or had one, but because of the impact of the wider reaching changes on GA that EASA will have. On the basis of what I read be I am in no doubt whether intended or not this represents a sustained attack on the way we do GA in the UK and it should be ignored at our peril.

9. I would make sure I had the support of all the GA mags, that they really understood what we were about and why the campaign was so imprortant.
10. I would ask everyone for a tenner or whatever amount was appropriate so I was properly funded and I would be prepared to mount a legal challenge.

Where do we go from here?

The purpose of this thread is to gather support, exchange views and to take the message to EASA that we object to the loss of these privileges in the strongest way.

There is already a lot of discussion here.

http://www.pprune.org/forums/showthread.php?t=302466&page=5 (HERE)

[bigbloke]

Fuji

The link to FT news doesnt seem to work. Not sure why.

This (http://www.*****************/default.asp?sourceid=&smenu=81&twindow=&mad=&sdetail=283&wpage=1&skeyword=&sidate=&ccat=&ccatm=&restate=&restatus=&reoption=&retype=&repmin=&repmax=&rebed=&rebath=&subname=&pform=&sc=2209&hn=ftnonline&he=.co.uk) hopefully will work better.

BB

[englishal]

Well done FA :ok:

Is someone going to start a petition? I can try to help between work commitments if you need it...and where do you want me to send the tenner ;)

Cheers

[peter_harrison]

Fuji,
Normally I am reader rather than a writer in flying fora. But this threat of loss of IMC has galvanised me to action.

I fully support you. You have proposed a very good & comprehensive plan.

To get the poltical and commercial engagement going with MPs & GA vendors we need to establish a list of email addresses & old postal addresses. Then lets share template letters and activate as many people as possible to send them..I assume that the pilots associations and magazines have the contacts. What we need is co-ordinated & concerted action.

Peter

[Pilot-H]

Apologies for a similar posting in other fora, but I think the "French Lesson" is of vital evidence to us, literally a matter of life-and-death. It needs to be distributed as widely as possible.

The IMC rating in the UK, like the Instrument Rating in the USA, has democratised the life-saving skill of being able to fly and land on instruments safely.

There is evidence from France which suggests that our fatal accident rate COULD DOUBLE with the loss of the IMC rating.

This report was commissioned by the french ministry of transport, and was published in April:
http://lesrapports.ladocumentationfrancaise.fr/BRP/074000415/0000.pdf

It shows that GA in France has twice the number of fatalities than either the UK, or the US (4.2 fatalities per 100,000 hours, versus 2.0 in the UK, and a similar level in the US)

Why?

Part of the reason is because both we and our American cousins have a large proportion of private pilots trained to fly on instruments, while the French PPL is almost strictly a visual flyer with no training or access to the safety of IFR when the weather turns bad.

So they have a far higher proportion of VMC to IMC related accidents: both loss of control and "classic" CFIT.

The sort of accidents which led to the introduction of the IMC rating in the UK by wise people, and there are plenty amongst the pilot population and their passengers (no doubt some reading this forum) who owe their lives to the IMC rating.

The report makes several recommendations, amongst which, relevant to this discussion, are the need for an accessible IR for private pilots in France; an IMC rating if you will.

Amongst interesting points in the report, is the fact that 80% of Accidents are due to "Human Factors". Furthermore when human factors were studied in depth, an analysis of 60 such accidents in france found that:

"The great majority (43 out of 60, with 98 fatalities) took place in unfavourable weather, underlining the problems with lack of training, over-confidence, poor decision-making and pre-flight preparation.

All areas which are dealt-with by the IMC rating.

It would be worth one of our representative bodies going to the expense of formally translating the "French Lesson".

[julian_storey]

This is excellent.

I am happy to help with this in any way that I can.

In addition to Fuji Abound's excellent list, would we do well to complie a list of MPs who understand and are sympathetic to light aviation? I believe that Lembit Opik for example holds a PPL.

[FREDAcheck]

I had a go at drafting a template letter on the other thread, but I don't have enough information. Here it is again, modified a bit. Forgive the repetition, but I'd appreciate help.

It needs to be fairly pithy if MPs or MEPs are to read it. But can anyone help with the bits at the bottom please? What are we asking our MPs to do? We need to state what (precisely) we want them to do. What order, statute or whatever they should oppose. If we don't suggest what they should do, then sure as heck they won't do it.

Please help me stop another case of the European standard banana; excessive and unnecessary harmonisation.

In future aircraft pilot licensing is to be done on a European basis by EASA, rather then country by country (by the CAA in the UK). But it is being done by forcing the lowest common denominator on each country; we must all be the same.

To fly in cloud, pilots need an “instrument rating”. This greatly increases safety, even for private pilots who get caught out in bad weather. However the instrument rating is designed for commercial pilots and is both expensive and excessive as a “bad weather safety skill” for private pilots. Uniquely, the UK has an “IMC rating” – a lower qualification that is within the reach of any private pilot. There is evidence that this increases safety for UK private pilots (and those that share the airspace with them – that is, all of us).

Quite simply: the IMC rating saves lives.

No other country has this rating, and for reasons that do not reflect on why the UK should – or should not – have one. But once EASA takes over, every country must be the same. The UK IMC rating must go. Why must we lose something valuable for the sake of mindless harmonisation?

(Help needed here on: )
Please help lobby for a UK exception or opt-out. (Or what?)
This rule/regulation/order/whatever originates from EASA (which stands for…) subgroup JAA FCL 001 and is to be presented to… by… on such and such a date…
And please will you… (do what?)

PS - If the experts think this is not an appropriate form of letter, please draft something better.

[Fuji Abound]

Tmmoris

We all need this:

MEPs can be found here:

http://www.europarl.org.uk/uk_meps/MembersPrincip.htm

(second link down if you Google 'Who is my MEP' :-) )

Tim

[tmmorris]

Absolutely - you beat me to it!

Also this would be useful:

http://www.theyworkforyou.com/

(finds your MP and allows you to contact them directly)

Tim

[Fuji Abound]

In addition to Fuji Abound's excellent list, would we do well to complie a list of MPs who understand and are sympathetic to light aviation? I believe that Lembit Opik for example holds a PPL.

Thank you.

Do you have a contact?

Do we have any others?

[julian_storey]

Lembit Opik's details as follows . . .

http://www.libdems.org.uk/party/people/mr-lembit-opik.html

He holds a PPL and less relevantly was engaged to Sian Lloyd the weather girl and dated one of the 'Cheeky Girls' :ok:

[tmmorris]

A Google for 'MP pilot licence' produces of course Opik but also:

Grant Shapps (Con) - Welwyn Hatfield
Gerald Howarth (Con) - Aldershot (also Shadow Defence minister)

but there must be more, even if they are lapsed.

Tim

[julian_storey]

Thinking about it, Lord Tebbit has more than a passing interest in aviation and was an airline pilot before entering politics.

He seems to like a scrap with the Europeans and could be a useful chap to get on side.

Don't think he ever dated a 'Cheeky Girl' though ;)

[tmmorris]

Thinking about it, Lord Tebbit has more than a passing interest in aviation and was an airline pilot before entering politics.
though there's a danger that like many airline pilots he thinks the IMCR is a dangerous waste of time!
Tim

[Gertrude the Wombat]

There's also the conventional appeal to human rights - in a liberal democracy the idea is that we don't take away someone's right to do something without a good reason.

[Fuji Abound]

I think we need to start with a list of pilots willing to support resisting the dropping of the IMCR.

What about a web site with some background information and a place where you can register your email address?

[IO540]

Excellent ideas.

One thing I would point out however is that we need to save the powder for when it will have the best effect.

Currently this stuff is in what might be described an early committee stage within EASA. These committees are stuffed with highly prejudiced people who are for the most part out of touch with GA - even if they ever were in touch with it.

Fortunately, these committees, whose representatives are not elected and whose makeup we cannot hope to influence anyway, are not the most harmful stage of the legislative process. It is what comes afterwards.

Let me also add this is all tied up with the N-reg issue, because the FAA option would be a natural escape route for the more determined IMC Rating holders. So if you fly an N-reg or know somebody who does, this affects them too. The two issues are closely linked.

[Three Yellows]

Fuji,

Well done.:ok:

And Pilot H, very interesting French Lesson.... I guess we need as many hard facts as possible.

Thanks for starting this thread, you have my full support.

Maybe we should get the Cheeky Girls onside too;)

[Fuji Abound]

Thank you - 3Y and I0.

The French lesson is very a superb contribution.

Please keep the comments coming.

I am going to see if we can roll out a petition and a dedicated web site if I can.

Anyone like to get something going on Flyer please!

[jez d]

Julian,

Lembit is already aware of the IMCR situation and has pledged his support in an article in the latest issue of FTN.

I suspect however, that little will happen before a Notice of Proposed Amendement (NPA) concerning the IMCR is released in the New Year by EASA.

[Justiciar]

"The great majority (43 out of 60, with 98 fatalities) took place in unfavourable weather, underlining the problems with lack of training, over-confidence, poor decision-making and pre-flight preparation.

All areas which are dealt-with by the IMC rating.


I suspect that this is the cause of the majority of accidents in most countries. I think we need to be careful in the way we draw conclusions. The report is interesting and highlights that more regulation does not equate to better safety. It points to the better fatality record of the less regulated ULM sector and also concludes that flights from within the strong club environment generally result in fewer accidents. The report is an argument for devolving downwards the responsibility for flight safety to 'local' organisations. It comments on the unsuitability of a regulatory system aimed at the professional pilot for regulating leisure flying.

The report is not unfortunately an endorsement of the IMCR ! It points out the relative similarity of accident rates in the US and UK. Whether that can be turned into an argument for an IMCR I doubt. It may be an argument for a more easily obtainable IR, but the report does not say so. It seems more to support the concept of a sports aviation licence (lightly regulated but with a safety and skills ethos being strongly promoted at local level), which may or may not be ICAO compliant and I would guess would be restricted to day VFR, but I bow to others with far more knowledge on this aspect than I have.

[IO540]

It may be an argument for a more easily obtainable IR

Since there is close to zero prospect of getting a significantly more easily attainable IR in Europe for some years, I would say that makes it a reasonable supporting case for the IMCR.

[Justiciar]

Yes, we just have to convince all the other 27+ countries in the EU to set up facilities to train for an IMCR. Is that not the real problem. No one but us has the skills base to do it or the interest in doing it. But, are we not some way off the point at which the IMCR goes? Plus, as I mentioned on another thread, what will happen to the French Mountain ratings, which are also national qualifications and will presumably go if all national ratings and licneces are swept away. They will be less than happy with unrestricted access to their altiports and glaciers.

[IO540]

Yes, the assumption that the choice is either (a) a euro-wide IMCR or (b) no IMCR at all anywhere, is fundamentally flawed and totally stupid.

But that is how Europe is working in this instance.

They would probably like to mandate that we all have greasy hair like the Italians, but that would be politically difficult :)

I do not have any idea whatsoever why national ratings cannot continue. It just seems a pointless piece of political ideology.

[S-Works]

The likelihood of a Euro IMCR is prop 0.1%. The airspace structure in Europe does not support the IMCR type flying like the UK. French Class D airways for example, germany has no concept of IFR flight outside CAS etc etc.

If you are going to continue with this crusade you have to actually decide what exactly you want and stick to your guns. You also REALLY need to get an understanding of the rule making process rather than just shooting from the hip.

As IO points out there is very little sense in pointless rule making, yet the Europeans are fond of signing up to pointless stuff. Look at Galileo.....

[Justiciar]

If you are going to continue with this crusade you have to actually decide what exactly you want and stick to your guns.


Agreed. Surely the objective should be the maintenance of national ratings for use in that country's airspace? There seems to be a dawning recognition even in the EU that people are being turned off by the top-down regulatory approach and that devolution of regulation and responsibility is the way forward (as mentioned in the French report, above). The one size fits all approach no more suits us than it would the French with their mountain ratings and there may be other countries who also have their own licneces and ratings which they are equally attached to.

[S-Works]

What you mean back out of the agreements that we have already signed to hand over regulation to Europe? Keep the current system of 'common' standards with national control?

[rustle]

If only we'd known this was coming (http://www.pprune.org/forums/showthread.php?t=135201)

[S-Works]

We would have had the opportunity to respond and make representation, even forming a working group to try and make the IR more available in the event of the loss of the IMCR.....

[dublinpilot]

I think what Justiciar is suggesting is that national ratings would stay under EASA, but only be valid in one particular country.

For example, the IMC rating would simply be an EASA rating, which could be attached to any EASA licence issued by any EASA country, but would only offer privlidges within UK Airspace. I could add an IMC rating to my Irish issued EASA licence, but I could only exercise it within UK FIR's.

Likewise a UK issued EASA licence could add an Altiport rating to it, but again it would only have privlidges within French airspace.

Specific 'local' ratings for on an EASA licence....seems to make sense.

dp

[S-Works]

dp, Thats exactly what we had under JAA (which worked fine in my mind) but under EASA we do not have this option. Under JAA the national authorities were responsible for licencing with there own ANO etc but fitting into the JAA framework.

Under EASA we now have a European aviation authority that will have a european ANO and issue a European licence. It is because EASA are the licencing authority now and they have declared there will be no national differences that we have the issue.

We have signed our rights away completely.

[englishal]

The Norwegians have it right.....Get all the benefits of Europe while remaining outside of the EU...

[rustle]

Nice fjords, too.

[Pilot-H]

The report is not unfortunately an endorsement of the IMCR ! It points out the relative similarity of accident rates in the US and UK. Whether that can be turned into an argument for an IMCR I doubt. It may be an argument for a more easily obtainable IR, but the report does not say so.

If you read the report fully, you will see that it does indeed argue for a more easily obtainable IR, which is about all they can do, hamstrung as they are with airspace and rules which could not permit an IMC rating.

It also cites the British NPPL as a good thing (in the context of a sidestep from JAR-FCL) Given these points, and the fact that their fatal accident rate is twice as bad as ours, it is an endorsement (albeit tacit) of the IMC rating, and shows where we will be without it.

A few relevant parts loosely translated:

"JAR - FCL: A training system poorly suited to private pilots
The JAR-FCL training system is concieved as a professional qualification structure, because it aims to train pilots from ab-initio and bring them to a professional level, (CPL, or ATPL) whether by the integrated route or the modular route. In this second case, the training for a PPL constitutes the first step on the route to becoming a professional. The training programme is therefore conceived and implemented with this view, without being particularly adapted to pilots who consider the PPL as their goal...."

"Certain countries, such the United Kingdom, becoming aware of limits of JAR-FCL decided to impliment a National Private Pilot Licence, whose privileges, naturally, can be exercised only within UK airspace.

It is in this framework that we look towards private IFR flying: even though the JAR-FCL Instrument Rating concerns probably a very limited number of Private Pilots, due to the implicit requirements and costs (maintaining an appropriate level of currency requires regular practice on relatively complex aircraft), it doesn't make it less true that the qualification itself is percieved as very difficult to obtain. The major obstacle cited, with good cause, is the theoretical training, the requirements for which appear dis-roportionate to real need.
Henceforth, nothing should oppose the implementation of an Instrument Rating theory appropriate to the PPL"

[Fuji Abound]

.. .. .. and the answer is,


we are going to try and get a national difference agreed.


On an aside issue, I was pondering how EASA intends to enforce its new ANO. Presumably this is to be left to the respective national authorities (who will effectively be EASA satellite offices). For example, a pilot is accused of low flying - will this still be prosecuted through the local magistrates court?

On another side issue what will happen to the special exemption permitting pilots to operate in class A without an IR for the purpose of parachuting, glider launching or high performance civilianised jets? Are these to be national differences, rights abolished or exceptions?

[S-Works]

Good luck. I hope you succeed. Who will you be approaching to get this exemption?

I am curious about the Class A airspace exemption you mention, please can you point me in the direction of it?

Yes you are quite right about prosecutions etc, they will be left to the local CAA office with European visibility.

[Justiciar]

f you read the report fully, you will see that it does indeed argue for a more easily obtainable IR, which is about all they can do, hamstrung as they are with airspace and rules which could not permit an IMC rating.

Yes, you are right - that is the trouble with speed reading a 62 page document in French :oh:.

It mentions the content of the extensive theoretical element as not being suited or necessary to real conditions. It also suggests that a reduced theoretical knowledge could be devolved down and be administered by local organisations.

All this supports what I believe bose-x and others have been arguing for, a review of the training requirements of the IR across the EU which only incorporates those elements necessary for the IR and places other airline orientated parts in their proper place, i.e. in the CPL or ATPL exams. There have already been some changes to the theory element in JAR-FCL 1 but these await implementation by the CAA (bose-x will shoot me down if I am wrong on this).

We have to fight for what is achievable. Reading what has been said it seems that national ratings will go - we should not be wasting time arguing for something which is not achievable in the current legal structure (and I doubt the UK will or can withdraw from EASA). Can any country file national differences as they can under ICAO? I don't know the answer nor what would be involved in doing this.

What we seem to have is support from other countries, e.g. France, for the idea of devolving down the implementation of EASA licensing requirements and training. We could therefore see exams administered at local level as in the PPL training. We already have a split in the practical training requirements. Perhaps we should be building on this.

[Fuji Abound]

We have to fight for what is achievable. Reading what has been said it seems that national ratings will go - we should not be wasting time arguing for something which is not achievable in the current legal structure

I think there is a significant danger in that line of argument.

It is simply that the IMCR will go as part of early implementation of legislation but will not be "replaced" in a hurry, or at all, with a "simplified" IR.

History would seem to predicate that there is not an appetite for a simplified IR.

Personally, I think this would be a very wise alternative and I wish Bose and AOPA very well in their quest.

EASA has a mission statement:

"Our mission is to promote the highest common standards of safety and environmental protection in civil aviation."

The abolition of the IMCR hardly promotes safety, especially if it is not replaced with an alternative. Moreover, arguable for those with an IMCR already adequate for their purpose withdrawing their existing rights without offering an immediate alternative is contrary to EASAs mission.

[S-Works]

This is where you miss the point entirely. In the opinion of the rule makers you already have an option for flight in IMC it is the IR. It is the only option that the rest of Europe have. So as far as they are concerned this is a non issue. It is only because you have the IMCR that is so easy to obtain that the IR looks so difficult and while I completely agree the accessibility is not that great which is the fault of our own CAA to a large extent, the IR is not difficult to do.

Like I said I am just pragmatic. However I really do wish you the best and will watch with great interest your progress. Mostly to work out where to insert the 'I told you so's'........ :p

[Justiciar]

I think there is a significant danger in that line of argument.

It is simply that the IMCR will go as part of early implementation of legislation

I am afraid that those two sentences defeat your own argument. There will be, under EASA no legal basis for the preservation of national licences and ratings. It is not a question of arguing for the use of a power to allow the continuation of national licneces: there is no such power, as I understand it. The only way of doing that would be by the UK withdrawing from EASA. I doubt that is possible or likely.

Certainly, changes will take some time. How long have the changes to FCL 1 taken? Several years, I suspect. But then the CAA is not noticable by the speed of making changes to legislation.

[dublinpilot]

It is only because you have the IMCR that is so easy to obtain that the IR looks so difficult

I know you're pointing out what the Eurocrats would say rather than what the case actually is, but that one's easy enough to knock down. The almost non existance of PPL/IR's in countries where no imc rating exists proves that it's not the availability of the IMC rating that's putting people off the IR.

dp

[Fuji Abound]

Justicar

I dont think so.

EASA states "it expects to take over FCL in 2008".

It is my guess the legislation is still in the early stages, and that if there is sufficient support national variations or opt-outs are possible, or that if there is sufficient support alternatives can be found.

Politics is the art of the possible, if enough private pilots are up in arms lobbying their MPs, EASA, the press etc it might just make the art of the possible a bit more difficult.

Politicians also tend to take note of commercial operators. Make no mistake the loss of the IMCR will result in a very significant loss of income to the FTOs. I suspect it will also hit the pockets of people like Diamond. Why would you want to spend another £40,000 on an aircraft to fly IFR if you are not permitted to do so?

Of course we could just roll over .. .. ..

[Fuji Abound]

Bose

I know, I know .. .. ..

but you will recall saying this seven months ago:

The most significant recommendations are
A. Redesigning the PPL IR Theory syllabus so that it excludes material relevant to CPL, ATPL privileges and Type Rated aircraft and focuses only on knowledge relevant to IFR privileges
B. Removing the mandatory classroom attendance for the theory course
C. Making the exams available "on-demand" at 3rd party testing centres
D. Making the flight training more "competency-based" rather than requiring 50hrs for all candidates. Pure competency based training would not have any minimum training hrs. The recommendation is a hybrid, with 25hrs minimum consisting of the 10 hr Basic IF module already in place and a further 15hr Applied IF module. This is a major step forward from the current 50hrs. IMC holders may be able to get credit towards the 10hr Basic module

The main subject we have not made progress on is relaxing the requirement for all training to be at JAA Approved FTOs. This principle is deeply embedded in EASA and JAA thinking and it was considered futile at this point to try and push it forward.

The next steps are that a formal report will be finished and submitted to the Head of PLD ( the Personnel Licensing Dept of the CAA). A significant number of the recommendations should be within the discretion of the CAA, the remainder will be submitted as the UK position to EASA and EU-FCL.

I would be cautiously optimistic that something may happen in the next 6 months to implement some of these recommendaitons, but the outlook will not be clear until the CAA's PLD have reviewed the recommendations and decided how to act.

.. .. .. and what changes have there been?

Are you convinced that an accessible IR is likely and how do you define accessible?

Like it or not, it is my perception that private pilots are not prepared to pursue a course of theoretical training based on any other model than the FAA IR (or for that matter the IMCR - note my use of the words model).

If EASA continue to pursue this line I can tell you that the up take of IRs by private pilots will remain at almost zero. The number of N reg aircraft operating in Europe will continue to rise as will those pursuing the FAA IR route - perhaps until EASA then try and tackle N reg aircraft parked in member states. You have been warned that is the logical conclusion.

Europe will then be a dessert for private instrument flying (much as it is now) and our own little oasis will just become part of the same dessert.

[Justiciar]

I think you are wrong - I wish you weren't but the evidence is against you. The Commission proposals to bring flight crew licensing was brought out in 2005. The DoT consultation ended in 2006. The loss of the IMCR is a fairly insignificant (in pan European terms) consequence of adopting common rules fixed at European level for the licensing of flight crews. The emphasis in terms of the benefit of common rules is in the commercial sphere. The up side is a less regulated sports licence - whether you wil be able to add an IR to that remains to be seen. As IO540 suggested, it may mean that you can only add the IR if you get the full professional licence.

[S-Works]

Fuji,

I have to agree with Justicair, I think you are wrong and equally don't wish you were.

As outlined in the post you have quoted the changes we have asked for are what I consider to be reasonable in terms of achieving an IR.

There will never be an FAA model I am afraid, so the only way that is going to happen is for you to up and move to the states (think of the exchange rate!). Plain and simple the Europeans will not adopt anything american (look at Galileo).

As for the n reg, that is a separate issue but current proposals will allow them to stay providing they have european oversight and licensing synergy, this means still having to get an EASA IR if you want instrument flight as well as an FAA one.

[Fuji Abound]

As outlined in the post you have quoted the changes we have asked for are what I consider to be reasonable in terms of achieving an IR.

Do you believe you will get those changes?

I assume you do, but do you believe that pilots already with an IMCR will pursue an IR, and even if these changes are adopted, do you think the FBO structure is in place or likely to be readily put in place to support IR training?

this means still having to get an EASA IR if you want instrument flight as well as an FAA one.

So what do you see the existing European private N reg operators having to do? Do you see this group also being under threat?

[Sir George Cayley]

I understand Graham Forbes has been elevated from Head of FCL at the Big Grey Building to higher things, and that there's a new person in his old desk on the ground floor.

Would it not be worth asking the CAA what their stance on this is? I can't beleive they will just shrug shoulders.:(

As no NPA has been issued yet by Cologne, we (yes, us and them) will still have a chance to influence the shape of the legislation. MDM032 was highly modified by a number of amendments, many of which were supported by our regulator. Or so my man at the PFA .. sorry LAA told me.

Can't a similar situation be envisaged? EASA will only deal with National Aviation Authorities or representative Governing Bodies or Unions, hence the recent formation of the EFLEVA (www.efleva.eu )

I wholeheartedly support the retention of the IMCR and the NPPL for that matter, and I'll be having a word with my man about it pronto. But, just to reiterate, it's as much the approach to this and how it's put over to EASA that will get results as names on a petition.

Sir George Cayley

[radicalrabit]

The European Convention on Human Rights, may prove an effective tool because if I am not mistaken the government has to foot the bill for the case as it is supporting current law. (you legal people know more than I do obviously) And that is one route which The Europeans tend to fight shy of because if they go against one case then it refelects on their own similar actions down the line. If it is an inalienable right to wear a headscarf because of relgious beliefs despite the risk of being dragged into machinery etc etc then it ought to be an inalienable right to receive training to stay alive in unforseen circumstances and to use the training you have without it being against the law to do so .:ugh:

[S-Works]

You have the right to receive training, it is freely available to you in the form of the IR. Just because you want something easier does not make any infringement of your rights......

[Fuji Abound]

You have the right to receive training, it is freely available to you in the form of the IR. Just because you want something easier does not make any infringement of your rights......

Hmmm, please explain if you will then how it is that European States are ICAO signatories, have adopted the ICAO mandate, have filed a few differences in most cases exactly in the same way as has America, but they will not recognise the standard?

Fly an N reg aircraft on a FAA IR ticket - not an issue,

Fly an F reg aircraft on a FAA IR ticket as a non EU citizen - not an issue,

Be the same pilot, same qualification, same ticket, nothing else has changed, other than you just became an EU citizen - it is illegal.

[S-Works]

Because as I said on the other thread you just started. OVERSIGHT. European regulators want oversight of Europeans.

Just the same as if you move here you pay tax here.

Honest mate it's not rocket science.
:ugh::ugh::ugh::ugh:

[Fuji Abound]

Just the same as if you move here you pay tax here.

Actually we fully recognise our obligations under the international and bilateral tax treaties - if we didnt, the Revenue would be in the High Court quicker than you could say EASA.

[S-Works]

Whats that got to do with it?

If you live and work in Europe you pay European taxes. If you live and fly in Europe in European aircraft you follow European rules.

It's not hard!!

Anyway I am done debating with you now. Good luck with your plan.

[Pilot-H]

I am sure these are a naïve questions, but I am not very familiar with the NPPL, however:


1) Does this mean that we will also lose the NPPL?

2) If not, what obstacles are there in attaching an IMC rating to it?

3) Could the NPPL be extended to include more powerful aircraft so that anyone flying within the UK on a PPL IMC could side-step EASA?

The average PPL/IMC wants to fly his/her PA28 etc safely, in IMC, outside of class A airspace. An extended NPPL/IMC would serve the vast majority, leaving the remainder (as now) who want to fly internationally or in airways to follow the route to an IR.

Until (or unless) the more accessible IR arrives, this would be a neat solution.

As I say, I am sure I am just being naïve in thinking this could be possible, but when JAR-FCL was introduced I would never have guessed we could have an NPPL, so why not extend it?

[Roffa]

I don't know if the NPPL will disappear but I suspect the biggest obstacle might be the lack of a formal medical.

Though as one can fly on a NPPL using a JAR-FCL medical one could argue that, if such a situation arose, anyone who wanted to utilise an IMCR on a
NPPL would have to be able to pass the JAR-FCL Class 2 medical.

In this hypothetical world it would probably also require an increase in hours required for the issue of the IMC rating to cover gaps in the NPPL syllabus.

Whatever, the remit of what the NPPL does and does not allow is currently home based so anything is possible at the moment, but it is worth bearing in mind what the thinking behind the NPPL was. I'm not convinced it was ever envisaged that it would or should include IFR/IMC privileges.

[Fuji Abound]

Bose

What cr*P you sometimes come up with.

I am sure they want oversight but that is neither a reason nor excuse for ignoring their treaty obligations. If they (and in fact it is we) cant honour our obligations be it in spirit or in law they should they be called to task.

AOPA UK have a history of failing to confront the issues I suspect becasue they no longer represent private pilots - how very very different it is in the States.

Your call that you are done debating with me, shame really as I suspect there are many who share my views about how ineffective AOPA has been to date.

I hope I am also proved wrong, but history is very much not on their side.

[S-Works]

You have your view of AOPA, I have mine. I know what they are doing on this and what can be done. As a paying member I am satisfied with what they are doing for me.

I think you are wrong and so do others. Argue when you have a real understanding of the issue.

In the meantime we are done.

[Fuji Abound]

I can only base my judgement on the evidence. Give me the evidence and I am happy to reconsider.

On the whole IR issue, the IMCR was introduced nearly 50 years ago. At that time IR students could entirely self study, a class 2 medical with the requirements concerning eye sight and hearing was good enough, and importantly a "self improver" route was available to all.

AOPA has presided over that all going in the last ten years or so until today when the next step will be the loss of the IMCR. Their efforts to tinker with the IR is nothing more than window dressing a rating that is of no interest to private pilots what so ever.

What has AOPA done over the last 10 years?

Point out a single achievement in the tide of making instrument flying less and less accessable to the private pilot?

Do let us know how many IRs were issued to private pilots last year in the UK?

Do let us know the percentage of IRs here compared with the States?

Why does AOPA not point out what a farce this is? Why doesnt AOPA publish the stats?

Sad to say at least it would be very very difficult to achieve any less, so at least I can be certain I will not do any worse.

I know you think because you are now on the block that will change - but it worries me that you are so concerned with achieving somethng, that the odd crumb EASA might hand you will be heralded as a major achievement.

You people just dont seem to understand what the pilot community is telling you - anything short of an FAA style private IR is of as much value as doing nothing.

Losing the IMCR in the process will move this from a disaster to an unmitigated disaster.

[Justiciar]

I am sure they want oversight but that is neither a reason nor excuse for ignoring their treaty obligations.

Which obligation are they ignoring? There seems to be the impression that the ICAO Annexes are vastly prescriptive. They are not and accord a fair measure of discretion to individual sovereign states. Whilst under ICAO there is a requirement for countries to recognise and facilitate international commercial flights, there is no obligation to allow permanent stationing of another country's aircraft in its territory, nor the privilieges which go with it. In the US, for example, you cannot keep a foreign registered aircraft permanantly - it has to be put on the N register. So in fact, the UK and indeed Europe are more generous than the US!

[Fuji Abound]

Justicair

So how do you interpret article 33?

Recognition of certificates and licenses

Certificates of airworthiness and certificates of competency
and licenses issued or rendered valid by the contracting State
in which the aircraft is registered, shall be recognized as valid
by the other contracting States, provided that the requirements
under which such certificates or licences were issued or
rendered valid are equal to or above the minimum standards
which may be established from time to time pursuant to this
Convention.

[machel]

This is a very interesting thread. It would be a tragedy if the IMC rating was lost and I give my full support to any campaign to save it.

Fuji, for what it's worth, my interepretation of that quote is that regardless of the member state's right to issue licenses and certificates, they will only be regarded as valid if they meet the minimum standards of the Convention.

If the minimum standards are equivalent to the "IF" rating, then the IMC will not be recognised as valid.

Maybe I'm wrong:confused:

[Fuji Abound]

OK - some help needed please.

Someone has very kindly agreed to provide a dedicated server with very good band width. A web site is needed to publish the background and to define the reasons why the IMCR should be retained as a national difference.
Emails and letters need to be sent to as many FBOs as possible - they are going to suffer a significant loss of income.

Some campaigning of Euro MPs, and others who will be receptive to the arguments is essential.

Please, if you are willing to help send me a PM.

I really need your support please.

(Machel - you are correct, this was a slightly off topic discussion why EASA are unlikely to recognise the FAA IR despite their ICAO treaty obligations to do so - or so it might be argued - thank you very much for your support).

[rustle]

You have your view of AOPA, I have mine. I know what they are doing on this and what can be done. As a paying member I am satisfied with what they are doing for me.

I think you are wrong and so do others. Argue when you have a real understanding of the issue.

bose-x, for what it is worth, I too am satisfied with what AOPA-UK are doing for me as a paid-up member. :ok:

Thanks for your hard work over the last few months. :D

Out.

[machel]

Fuji, please excuse my ignorance, but what's a "PM"?

[machel]

Rustle said:

bose-x, for what it is worth, I too am satisfied with what AOPA-UK are doing for me as a paid-up member. :ok:


I know I've come into this rather late on in the discussion, but I don't see why campaigns can't come from many different fronts. AOPA et al will do what they can, but individuals can also influence. If we don't try, then how can we complain when it does disappear? :ugh:

[Fuji Abound]

Machel

Left click on Fuji, and selecting PM - a private message.

Brilliant to have your support.

On your other point I want to be clear as to my position.

Bose has done an excellent job with his work at AOPA - he seems to be a breath of fresh air. I have no persoanl issues with him at all. I have made my views with regards to AOPA known - with regret I think their lack of record on this issue in the past supports my view. Never the less I hope I am wrong this time.

It does concern me AOPA appears to have already settled for not second but third best, but perhaps that really is all that can be achieved.

Rustle enjoys a bit of banter on here. I always enjoy humouring him. It is a love hate relationship.

[rustle]

I know I've come into this rather late on in the discussion, but I don't see why campaigns can't come from many different fronts. AOPA et al will do what they can, but individuals can also influence. If we don't try, then how can we complain when it does disappear? :ugh:

The biggest difference is that AOPA and those representing AOPA generally have some idea what they are talking about and won't make themselves and their GA colleagues look bloody stupid writing letters about things they clearly do not understand.

But if you think people writing whining letters about their alleged "breached rights" will get you somewhere I promise not to laugh.

Much.

;)

[Justiciar]

So how do you interpret article 33?

The same way as you I think. This is not the issue. The issue may be one of limiting the abilty to base foreign registered aircraft not used for commercial operations in the EU. This is, as I understand it, what the US does. This will remove the utility of the FAA IR to private pilots. There is nothing here in breach of the ICAO Annex. States are free to determine whether to allow another country's aircraft to be based in that state. This is not a difficult problem: no different from deciding if an individual is domicile or ordinarily resident in a state. Such a step would of cours affect others beyond the owners of N reg aircraft; owners of russian and Lithuanian Yaks would also be in trouble!

[Fuji Abound]

Are you suggesting this might be next on the agenda Justicar.

[Justiciar]

I suspect it is quite likely. EASA scrutiny of third country aircraft is an active proposal in the amendment to the regulation which set up EASA and this issue was flagged with ICAO in 2004. They have to step carefully so as not to undermine the convention, but an extra level of checking seems to be certain. Although an outright ban on non commercial foreign registered aircraft does not appear to be a firm proposal yet I suspect it is only a matter of time. Once EASA "certificates" third country" operators in the EU then every aircraft not certificated could be judged to be private and therefore required to be re-registered. What with the recent DoT consultation on this issue and a similar issue being raised by the Frence a while ago I think it would be foolish to ignore this as a very real possibility.

[Slopey]

Not wanting to promote thread drift, but if the IMCR is a UK only rating - what's the story on the NPPL?
Is that, as a UK only licence, also under threat? Or is there an EASA proposed equivalent, or a current equivalent in other European countries?

[S-Works]

Slopey. The NPPL is being replaced by the LAPL, light Aircrafts Pilot Licence a Euro wide NPPL.

The regulators want to clearly branch private flying from recreational flying. If you are a fun flyer you do a LAPL if you want to be a pro you do an EASA licence.

LAPL is currently day/vfr but discussion is under way for night qualification. If you want MEP or Instrument privileges you do an EASA licence.

You can thank the permit evangelists for the LAPL.......

Now can you see the road map?

[Slopey]

Excellent :) Got it - thanks Bose :)

[Justiciar]

if you want to be a pro you do an EASA licence


Bose-x

What if you don't want to be a pro but want an ICAO licence to enable you to fly abroad, i.e outside the EU? Is the new EASA licence going to be more difficult than the current PPL? This would seem to be contrary to the spirit of ICAO Annex 1 if it is. The EU has already had one shot across the bows from ICAO over its idea for additional maintenance requirements for non EU registered aircraft and they were told by ICAO that this would be contrary to the Convention. Lets hope they are not going the same way with licensing.

[tmmorris]

I'm afraid I've seen this coming for some years now - the driving of a wedge between Sport Flying on the one hand, and 'proper' flying - CPL and above - on the other. The whole EASA approach seems to be tending to set in stone that distinction between people who fly for fun - and only need day VFR, naturally (have they ever actually visited the UK?!) and those who fly for work, and need a CPL.

Lost somewhere in between are those who fly themselves around for personal transport and actually need to get somewhere. Sadly they are a very small group, unlike in the US, and are being trampled on.

Tim

[radicalrabit]

"(This) principle of risk management is an established principle of English law, known as ALARP. It is a requirement formulated by Lord Asquith in these terms: one has an obligation to reduce risks As Low As Reasonably Practicable. This formulation was emphasised by Lord Cullen in the Piper Alpha inquiry, as I understand it."
I borrowed this from a different thread but it speaks volumes not TO BE TRAINED TO DEAL WITH ADVERSE WEATHER CONDITIONS or TO USE THE TRAINING YOU HAVE to deal with the same, would constitute a breach of that duty of care. It would seem then that this change would go against what is already recognised in English Law...(do tell me if I am wrong)

[Fuji Abound]

But if you think people writing whining letters about their alleged "breached rights" will get you somewhere I promise not to laugh.

Oh, you are such a tease!


This formulation was emphasised by Lord Cullen in the Piper Alpha

Yes, I think form all the PMs I have received and other comments this summates very much how people feel. There is something uncomfortably worrying about denying people the ability to use skills they have already proven they have.

I think this is where AOPA have so fundamentally missed the point and sold GA in the UK down the river. What they have ended up asking for is something hardly anyone wants, so that even if they get it, it will not be a worhtless victory.

[englishal]

AOPA UK have a history of failing to confront the issues I suspect becasue they no longer represent private pilots - how very very different it is in the States.
I suspect that AOPA don't like to take on a battle they can't win, or else they will look like losers (their thoughts, not mine).

I think we'll see the ground school element *slightly* reduced, but that will be it with regards to a "more obtainable IR".

I say this as one of teh 400,000 pilots in AOPA who AOPA claim be be part of (see their website) and also a member of PPLIR. AOPA UK and AOPA US are chalk and cheese.

By the way, I can donate server bandwidth Fuji if you haven't found any yet.....

I expect Bose will get all upset with me for saying this (BTW I have no problem with Bose, he assures me he is a very nice chap and I'm sure he is right :)) , but until this "perception" changes, I won't be paying them any money...

[S-Works]

I am posting this on both threads to save wasting any further breath......


I am sorry fuji but you are so far off track here that you are not even on the same continent. I find it unbelievable that you can blame AOPA. They have broadcast the message, they have formed working groups to address the issue and have made representations at the correct level. It is now down to the rule makers to decide if the case is valid. What do you want to do hold them to ransom with a grenade until they come around to your way of thinking?

It is also your responsibility as a pilot and as an adult to keep abreast of developments in aviation not expect to have someone hold your hand and guide you through it. I spend my time sifting through the EASA and CAA sites to keep abreast just like many others. I take the time to read and digest the stuff that is out there and judge what effect it may have on me. This stuff has been in the public domain for more than TWO YEARS!

As a result I chose to do something about it not gob of about how bad a job others were doing about it.

As has been said by others I think AOPA are doing a good job, they were hard in a difficult climate and as a result I will keep on paying to support them. You are clearly unhappy with what they are achieving and are starting your own crusade. Good on you. But I would suggest that if you really want to make a difference you get an understanding of the process.
I AM NOT AOPA, I am a MEMBER, I was unhappy with what AOPA were doing so rather than slagging them off on a faceless forum I took my concerns to them and they invited me to help put things right. The other was extended to a few other people on these forums and the result is the MWG. We influence AOPA, we assist by bringing manpower and experience to the table and participating in the process that effects us all as pilots.

I think this clearly shows that AOPA listens to it's MEMBERS and acts on feedback. There is still improvement to be made, but I as is demonstrated on here as a very vocal forthright person feel they are making good progress and deserve support.

I realise that you are frustrated and concerned about the loss of the IMCR, but bashing AOPA and those that support it does nothing to further your cause.

Getting a few words of support on a faceless forum is not going to get you a seat at the table either.

This time we really are done, so I would ask that you desist from the constant goading and AOPA bashing, as I said it does nothing to help you and will end up in a fallout.

Good luck with your crusade.

[Fuji Abound]

I am sorry fuji but you are so far off track here that you are not even on the same continent.

Dont blame me.

Here are a few comments - none from me I might add!

Worth listening to what pilots say me thinks.

The biggest sin AOPA UK are guilty of is a failure to adequately explain what they do.

However, personally speaking, I don't find it an organisation that I find does a lot for me personally compared with others, such as the PFA and BGA.

I don't mind championing the cause of GA in this country, but may find some other way of investing my £72 for the priviledge.

I am surprised to read that your AOPA UK Membership is 72 pounds..
Here in the US AOPA membership is just $39 per year - and I reckon that we get a good service from AOPA here in the US when it comes to lobbying Congress etc.. Bearing in mind $39 is only around 21 pounds..... that makes your 72 quid damn expensive.

I am a member and I personally dont get much from them in material sense .

By comparison AOPA trends to be supportive of its corporate members, which is a vital source of money for them.

Don't hold your breath waiting for a reply from AOPA. Unless it involves them hob-nobbing it on quasi important committees they're not really interested. And as for Mr Robinson

OK, so why don't they talk about it more openly. I have tried explaining in the past that if AOPA wants to attract members, not only do they need to act on their behalf but they need to be seen to do so.

and finallly

Like any member based organisation, AOPA needs the support of its members but it must realise that it has no absolute right to expect that support automatically, it must work with and for its members.

I say again it is no good AOPA going down a path pilots arent interested in.

Far better to fight for the IMCR and lose, than claim a victory for tinkering with an IR that remains as inaccessible to most as it ever was.

Bose you need to understand it is not personal, just a case a picking up on the evidence without which we have nothing.

[S-Works]

Last time or we are going to fall out.

The title of this thread is to help you support the IMCR. Not lets all bash AOPA.

You have expressed that you are unhappy with what AOPA have done and wish to run your own campaign. I have wished you the best of luck with it. It is your horse to flog.

I am satisfied that AOPA have done everything within there power to assist this cause. Bashing them is not going to change anything.

It just shows a lack of maturity on your part at a time when you are hoping to convince others to join your cause and pay money to support it. Why do you think Martin does not enter into these debates nor does he enter into publicly bashing the competition.

I look forward to meeting you representing your alliance at the committee table.

[Fuji Abound]

The reason why the discussion moved on to AOPA is because there is a perception that AOPA are seeking to protect the future of the IMCR. Were that the case we might well conclude the work was in safe hands and that AOPA would do their best to achieve what they set out to do.

I think I am correct in saying that the message is clear - AOPA are not seeking to save the IMCr - so far as AOPA is concerned it is already dead and their attention is solely focused on trying to persuade EASA to adopt an IR that is more accessable by private pilots.

The suggestion is that it is all our faults that so far as AOPA is concerned the battle has already been lost. I am sure we would disagree on whether or not AOPA ever went to battle over this in the first place, but we do agree that would not be productive.

My purpose has not been therefore to bash AOPA as you put it for bashing sake but becasue I think it is important everyone understands that they should not look towards AOPA to argue their corner for the IMCr - because AOPA have already given up on that - unless I am very much mistaken?

[rustle]

My purpose has not been therefore to bash AOPA as you put it for bashing sake...

Bull****.

It's just something you do - anyone who has read these pages for more than 10 minutes knows it.

IO540 is GPS man

You are bash-AOPA man

Fact.

[Fuji Abound]

Rustle

You are bash-AOPA man

True - because I think they have done a poor job on many issues - as do many. At least I have provided the evidence - and your evidence is .. .. .. ah yes, non existent.

for bashing sake

well the subtleties of the English language are never lost .. ..

I would love AOPA to do a good job. At least I have put forward some suggestions and at least Bose has been kind enough to acknowledge they are weak in a number of areas. I suppose you subscribe to the train of thought that it is better to do nothing other than cancel your subs. Look at their accounts and ask yourself why their subscriptions have barely increased from last year - hardly the first sign of a vibrant organisation at a time when your first thought would be, given all the unpopular change taking place, pilots would be flocking to join.

Bose

Sorry, I really was trying not to comment on AOPA again, but some people just cant leave it alone. At least you have the temerity to accept they could do better - thank you for that. I promise not to mention it again, unless someone else does!

.. .. .. and in so far as GPS goes while we are on the subject I expect IO will be along to defend himself. However I suspect he believe GPS is a major contributor to safety and I think that is also a very worth while message to broadcast.

[S-Works]

My purpose has not been therefore to bash AOPA as you put it for bashing sake but becasue I think it is important everyone understands that they should not look towards AOPA to argue their corner for the IMCr - because AOPA have already given up on that - unless I am very much mistaken?

You are very much mistaken. AOPA are ardent supporters of the IMC, it as after all an AOPA course. The last thing they want is to see it lost.

However they have followed due process and made the correct representations. Now we wait until the NPA comes out in March and the next round starts. AOPA understand and follow the process you do not.

The only thing you can do that AOPA won't is kidnap the EASA bods and hold them hostage until they give into your demands.

But like I said if you think you can have a greater impact by going off as a loose canon then you are welcome.

Just don't make an ass out of yourself by making assumptions about AOPA.

[englishal]

So really if our future is really so pre-ordained by the powers that be in Europe, then there is not a thing we, AOPA, or anyone else can do about it.....So we may as well take IO's advice and just "wait and see" just in case the soothsayers are wrong.

If the **** hits the fan, at least I know EASA can't touch my FAA ratings, and if I can use them in Europe, all well and good, if not I'll just go to America every two months and spend my money there.....

[S-Works]

Good on you Al!! Sadly not that I expect the eurocrats to loose any sleep over loss of income from you.

Believe me I am as frustrated as you all at the blind signing away of our rights by politicians. Another example of how our rights are being given away from under our noses by the blind desire to create the United States of Europe.

Can the last one out please turn out the lights (to save the planet).

[bigbloke]

Hi

I notice there is a fairly brief article on this subject in the AOPA page of this month's Pilot magazine.

At least this will get read by a number of folk 19000 + a month on their circulation figures.

Now if enough people write and respond to that article, it will prompt more press coverage which should wake up more of the GA community to the threat.

Surely whether you are a small organisation trying to generate awareness and pressure, or AOPA then having some thousands of pilots banging the drum is no bad thing.

So for anybody interested, can I suggest letters to the Editor of Pilot mag and let's share our views.

BB

[IO540]

and if I can use them in Europe, all well and good, if not I'll just go to America every two months and spend my money there.....

That point, Englishal, will not be lost on a bunch of much bigger people than you or I.

If N-reg are kicked out of Europe, all the big fish (there are loads of privately owned turboprops and jets) who are mobile will not be wasting their "max 90-days in Europe" (or whatever) by having their big iron sitting in some maintenance hangar in Europe with the inspection covers opened up, are they?

At the appropriate time, it is most important to draw the attention of anybody and everybody with a commercial interest in the matter to this proposal.

Not just manufacturers but all maintenance organisations.

[Fuji Abound]

Bose

Thank you, I am very pleased to be corrected.

However, with very little searching you did say among other comments.

Well my personal view is that it is probably already a done deal. A year ago when I tried to warn you would have been better to mobilize resistance.

Perhaps just me, but I had certainly formed the impression that AOPA have given up on the IMCr?

Let me please ask this:

1. Would you set out in clear terms exactly what it is AOPA are doing / intend to do towards preserving the IMCr,

2. What is the timetable? The suggestion seems to be not a lot will happen until March 2008. EASA are on record as saying they will take over FCL by the second quarter of 2008 at the latest.

3. If AOPA is not going to do a great deal more until March 2008 do they understand how important it is to engage people well before.? If they do when and how are they going to engage their membership and the wider audience and how? I see nothing on their web site. I have just spoken to a large local FBO. As you can imagine the income they derive from the IMCr is an important part of their revenue. They tell me they have not been asked to engage with AOPA on this issue. Is the intention to engage the flying schools and when?

4. Can you set out AOPAs case for why it is so important to preserve the IMCr?

There are some on here who seem to take pleasure in pointing out we were warned. Well we were. They also point out you did nothing. Well that is also true - but not this time. If you are asking us to put our faith and trust in AOPA I for one would like to know why I should so that some smart alec cant take pleasure in reminding us in a years time - “you were warned” if the perception is AOPA did not do enough.

You may have guessed I fervently believe this could prove to be the greatest derogation of light aviation safety that I have seen.

I don’t think it is good enough to accept on that basis and as you put it - “it is a done deal”!

[S-Works]

My opinion that it is a done deal is my own and not necessarily that of AOPA.

AOPA put forward papers to the EASA FCL Core Group regarding retaining the IMC Rating and introducing it into Europe, but did not get a very good reception. However, the current 'state of play' is that EASA is supposed to be putting out an RIA followed by the formation of a small specialised working group to look into the possible future of the IMC Rating in Europe. That is where we are at the moment as far as EASA is concerned.

We have one further FCL Core Group meeting this year at Cologne with EASA in December, so I might learn more then.

I know that Mike Dobson has been working on a delay in implementation to give countries such as UK time to handle their national licences: UK issued PPLs, CPLs etc of which there are many, not to mention our BCPL, an arrangement where an experienced FI holding a PPL could be issued with a Basic CPL and receive remuneration for giving flight instruction. (Another of Ron's Campbell's clever arrangements with the CAA!) Plus of course the IMC Rating. This has not produced fruit so far but is still being actively pursued.

I am not at liberty to post the actual documents to a faceless bulletin board however I can assure you that the representations have been extensive including a safety case for retaining the IMCR.

All of the corporate MEMBERS have been consulted via the corporate committee and direct communications.

[rustle]

Thanks for the update bose-x: I'm happy the money I give to AOPA is being used wisely.:D

[englishal]

Just a thought....

If national ratings go, then surely the NPPL will be binned as well, being a "national thing". If so then many many pilots will suddenly have wasted their money and be grounded, some of whom cannot "convert" to EASA.

If the NPPL is NOT binned, then surely the CAA could in theory issue national ratings onto an NPPL, such as an "imc" rating could it not?

If the NPPL and IMC are binned, then we're going to see many flight schools put out of business over night, and many instructors unemployed over night. Flight training in the UK will drop dramatically and all the FAA US places will suddenly become very popular (there are ways into commercial aviation via the FAA which are far more attractive).

Looking at the amount of "FAA" topics on Pprune and Flyer at the moment, it appears that this handover to EASA may just do exactly what getting rid of duty free did to Europe.....make not one slightest bit of difference to "oversight" and in fact "worsen" the problem.

The "problem" is the Europe wants oversight. By getting rid of stuff like the NPPL and IMC, Europe are going to force people onto other authorities, like the FAA, and if Europe does recognise ICAO licences then it *may* mean that they effectively shoot themselves in the foot (as usual).

If the IMC is at risk, then so is the NPPL. If they are at risk, so is every permint operated aeroplane. If they are at risk, so is every microlight and glider.........

Still, my crystal ball is not working at the moment........

[ThePirateKing]

You have the right to receive training, it is freely available to you in the form of the IR.

It's not freely available to me...:uhoh:

TPK:*

[dublinpilot]

Why don't we leave the whole pro/anti AOPA out of this thread?

Fuji's idea is for those that either

a) Don't like how AOPA are representing them,
b) Don't believe AOPA represent them, or
c) Believe that brining pressure to bare in as many different ways as possible will help.

Let's not get distracted into arguing about AOPA, and get on with Fuji's efforts.

Fuji....your compaing will get lost, if you let it get distracted over AOPA....don't let that happen.

dp

[rustle]

If national ratings go, then surely the NPPL will be binned as well, being a "national thing". If so then many many pilots will suddenly have wasted their money and be grounded, some of whom cannot "convert" to EASA.

If there weren't so many disjointed threads about the same thing you would have seen the answer to this ;)

Search for LAPL and all will be revealed.

"Answers, not egos".

[Fuji Abound]

Bose

I am not at liberty to post the actual documents to a faceless bulletin board however I can assure you that the representations have been extensive including a safety case for retaining the IMCR.

Please can I ask this:

I think people would be very interested in these documents. I cant imagine why they should be such a secret (whilst accepting that a faceless bulletin might not be the best place).

Where are these documents and how can then be read? How can AOPA expect comment if no one is aware of the safety case that they have put forward.


I refer you to question 3. I think AOPAs stance on this would be of great interest. I still dont understand how they are engaging pilots, and politicians and MEPS (if appropriate). Can you tell us?

Rustle

You agree with everything AOPA does as well as reminding us at every opportunity we have been warned so there is nothing new there but thanks for taking part.

Thank God I am not married to you though - I can imagine every time something went wrong your saying.

I TOLD YOU SO :D

(why do I have to add the icon :confused:)

[S-Works]

Fuji.

I am sorry I have discussed as much with you as I am prepared to.

If you want to know know more than I have told you please contact Martin Robson at AOPA and ask him for the details.

I have enough work to do actually working on this stuff in the right places without having to justify every move that AOPA does to you.

Are you an AOPA member? If so just ask AOPA directly. If not then you really have no right to question AOPA's activities.

Now as far as your own crusade is concerned, go get em tiger.

[Fuji Abound]

Bose

Fair enough.

I was afraid that was the conclusion we would reach.

Is it just me who would like to understand what AOPA are doing,? Clearly it is all top secret?

Such a shame that they are unable to engage the people they represent - not that I am even clear who they are!

It is not your fault Bose - c'se I guess they read these forums as well and I appreciate you do your little bit.

Mind you, you can fall out with me if you like, but about twenty posts ago you said that was your last, twenty posts later it is your last again perhaps conveniently becasue it seems when ever people try and understand what is taking place the answers arent forthcoming or are intrigueingly vague.

What an earth is so secret about letting everyone know about the safety case AOPA has presented in support of the IMCr - I would have thought they would want the world to know.

Well I am inclinded to publish my own warning:

So I shall warn everyone when the IMCr is lost it is because AOPA and the other representative bodies decided not to engage with the people they represent earlier enough for it too make a difference. You read it here - I warned you

Is it just me who believes our representative bodies should bring this message to us - not that we should have to ask them what the message is?

It is bizarre.

[rustle]

Let's not get distracted into arguing about AOPA...

dp

Nice idea, dublinpilot. :hmm:

[Fuji Abound]

Dublinpilot and Rustle

Very good advice thank you.

Lets be done with AOPA.

One request though, despite how it may seem, we are all in this together and I would hope can all help each other.

Frankly, comments like you dont know what you are doing frustrate me - I dont and thats why I ask for your help - but I think that at least this thread has already got more of us discussing the issue than has ever happened on here before - surely that is already progress of sorts?

Moving on

Would some one like to set out the safety arguments for the IMCr.

[S-Works]

Right this is our fall out.

I have tried to explain the situation to you but you blindly run your mouth off with no understanding of how things actually get done in the real world. You are intent in goading me, well now you have. It still won't change the fact that in my opinion everything that can be done by AOPA at this stage has been.

You started this thread with a view on saving the IMC, why don't you go off and do that and report to us how you did it instead of running your mouth off all the time about how bad a job AOPA have done?

I have told you it is not my place to post documents on a forum and where to go and get them. There is nothing secret about the content, I have told you exactly what is in them, what is the point of copying them word for word into a public forum?

AOPA engaged with the MEMBERSHIP fully and actively, they formed working groups and those working groups sought the input of the membership who were prepared to actually bother to read and understand what was going on.

How do you think I got involved as an AOPA MEMBER??????

You are intent on bashing AOPA blindly and stupidly and are beneath contempt.

Your lack of understanding of bureaucratic process is breathtaking and will be your down fall.

So I will publish my own warning.

AOPA have engaged everyone possible on this matter and as a MEMBER I am satisfied. However it is the responsibility of every pilot to ensure that they stay up to date with the rules and regulations that govern their flying and changes that occur to it. Just as they are resonsible for the upkeep of a log boog, medical and revalidation.

This is the reason for NPA and RIA procedures, so that anyone with an interest can comment. People who join AOPA and PPLIR etc. join to allow people with more expertise to comment on their behalf. We rely on their integrity to make sure that that the common interests are looked after. In the case of AOPA and the IMCR the common interest is the preservation of a rating that AOPA created in the first place. To this end AOPA represented the MEMBERSHIP to the best of their ability, drawing on the experiences of the MEMBERSHIP as well as within and put across a strong case. Where this goes at the moment is anyones answer.

I personally think they have done an incredible job.

But what do I care? I have no restrictions on flying in any airspace so why am I bothering? Because I also believe that the IMCR is particularly worth saving. Pre IR days I used it extensively and believe it is one of the single most important things to happen to GA in the UK.

I however made the effort to understand the process of dealing with rule making and how it is contested rather than gobbing off about how wrong and unfair it was and then blaming everyones else.

[2close]

Let me also add this is all tied up with the N-reg issue, because the FAA option would be a natural escape route for the more determined IMC Rating holders. So if you fly an N-reg or know somebody who does, this affects them too. The two issues are closely linked.

I have also come into some reliable information that there are also moves afoot within EASA medical regulation that comes into force in September 2009 to prevent persons flying foreign registered aircraft based in the EU unless the flight crew hold EASA medical certificates.

I have no idea of numbers but it is no secret that a number of pilots flying corporate N Reg in the UK are doing so because they are unable to obtain JAA Class 1 medicals - those persons will be well and truly stuffed if this gets through.

The authorities tried and failed in their attempts to get rid of N Reg once so now they attack the process another way.

I often wonder whether we are dealing with responsible adults or with petulant children who, when they can't get their own way by one means, resort to dirty tricks methodology to get their way via the back door.:{

[S-Works]

2close, you are quite correct, it is all in the documents for the RIA next year.

It is part of the desire for EASA to gain 'Oversight', which includes the proposal for foreign crews based in Europe to have dual licensing and all that goes with it.

[Fuji Abound]

I have told you it is not my place to post documents on a forum and where to go and get them. There is nothing secret about the content, I have told you exactly what is in them, what is the point of copying them word for word into a public forum?

Sorry missed that post.

Can you let us have the link again to the documents in which the safety case for the IMCr is set out please?

2close

Interesting.

AOPA have engaged everyone possible on this matter and as a MEMBER I am satisfied. However it is the responsibility of every pilot to ensure that they stay up to date with the rules and regulations that govern their flying and changes that occur to it. Just as they are resonsible for the upkeep of a log boog, medical and revalidation.

What cr*p.

Sorry I could not agree less. It is your responsibility to keep up to date with every development in tax legislation. Good luck.

If not then you really have no right to question AOPA's activities.

Sharp in take of breath.

Anyway time for a truce. Can we just beg to disagree on many of these issues and take Dublinpilots comment on board please.

If you will agree not to keep pointing out what a waste of time it is doing anything outside of AOPA and keep pointing out how everyone else has absolutely no idea what they are talking about then I will stop telling everyone my views about AOPA.

[rustle]

If you will agree not to keep pointing out what a waste of time it is doing anything outside of AOPA and keep pointing out how everyone else has absolutely no idea what they are talking about then I will stop telling everyone my views about AOPA.

The two things - you not having a clue what you're talking about and your opinion of AOPA - are linked, but perhaps not in the way you imagine. :}

Do you really think you are going to have the last word on the AOPA subject again?

"Answers, not egos"

[S-Works]

The 'link' for the documents is to write to AOPA and ask for them. I assume you are a member? I have said this several times but you are so busy on your anti-AOPA tirade you keep missing it or ignoring it.

I have never said that anyone outside of AOPA has no idea what they are doing. I have said YOU have no idea what you are doing, big difference.

It is not up to AOPA to educate every person on the effects of legislation, it is there job to REPRESENT you, they do this very well.

I would also suggest you go and take a good hard look at who it was that actually sold us down the river looking after their own interests.........

I do know it is my responsibility to keep up with changes in tax legislation that effect ME. If I don't understand it I go and seek advice.

[Fuji Abound]

I'd love to see the 'pitch to keep the IMC' to see what arguments were put across in what way with what emphasis - and how long it lasted, given some of the attitudes listening.

If we'd come out of the meeting with a positive thumbs up, then basically we would be on a train, only having to make sure we didn't fall off it. As it is, we seem to have missed the train, which means enormous effort to chase it and try and board it, and that may or may not be possible, but it's certainly harder work!

The actual concept of presenting such a rating to other countries in a brief 'pitch' and asking them to understand it fully is flawed.


I would like to see the arguments made against an IMC (or equivalent rating) as much as those made for. In fact I would like to see any factual information about these Core Groups - they appear to be closely guarded secrets at the moment.

I think this is important.

http://www.joinaopa.com/forum/viewtopic.php?t=263

from this forum, and AOPA members.

Perhaps this information is in the public domain or even in AOPAs public domain. I shall look forward to seeing it.

We have missed the train so lets catch it back up, enough side tracking.
I would be very interested on comments regarding the safety ptich and the reasons why we should fight for the IMCr.

I am very pleased to say we now have a web domain dedicated to this issue which will run along side this thread. The web site will provide a source of information for this campaign.

[julian_storey]

OK ladies and gentlemen. Put your names to this . . .

http://petitions.pm.gov.uk/IMC-Rating/

Apologies to Fuji for nicking his fine wording.

[rustle]

Apologies to Fuji for nicking his fine wording.

Fine wording indeed.

You might want to have checked the "50 years" bit before sticking it up there on the PM's website - was the IMC rating really around in 1957? :hmm:

[2close]

Well done JS.

Signed.

I've fired off a short e-mail to Lembit Opik MP with the relevant links to information sources, although I'm sure he's aslo aware of what's going on.

[englishal]

Toys...prams...back in now?:D

I've signed...

[Fuji Abound]

Thanks Julian.

Well you beat me to it, but that is no bad thing. The web site is nearly ready to roll out so I can link to the petition.

As things progress there will be a developed action plan on the web site.

I have had some lengthy discussions with the CAA an EASA member and a parliamentary member which have all proved very useful.

There is rather more to this than meets the eye I have now discovered.

[Fuji Abound]

was the IMC rating really around in 1957?

http://www.pprune.org/forums/showpost.php?p=3112484&postcount=3

.. .. .. around 1967 I think.

[2close]

There is rather more to this than meets the eye I have now discovered.

Ooh, Fuji, you tease.

Spill the beans then.

I am security cleared......Nato Lavatory Level 1....and I promise not to tell anyone else....honest!!!

[Fuji Abound]

bose-x said:

Quote:

The IMCR is a rating created by the late Ron Campbell in the mid 70's for AOPA. So it has not been around the 40 and 50 years people are spouting off on here. How can you be taken seriously at representing this when you have not even done your research on the background of the rating?????
Good advice, bose-x; advice that perhaps you too should heed!
The IMC Rating was originally introduced in 1970. The syllabus at that time (10 hours) was biased towards basic instrument flying, with VDF its only let-down procedure. Prior to its introduction, a UK PPL could legally fly IMC OCAS without any instrument qualification. The syllabus was subsequently extended into a 15-hour course at the behest of Ron Campbell and AOPA in March 1981.

Worth repeating here.

I am sure Bose would not wish to claim credit for AOPA introducing it if they in fact did not, and if they did AOPA might want to fight a bit harder to keep it.

[S-Works]

Boy you really do dislike AOPA don't you?

Regardless, you are gobbing off without being in possession of the facts, I assume to fill your need for constant attacks on AOPA.

Fuji wrote:
.. .. .. around 1967 I think.

The IMC rating has been in existence in the UK for over 30 years. According to those involved in the original IMC rating Working Group, it was designed to provide private pilots with enhanced skills and greater confidence when faced with deteriorating weather conditions, by increasing a pilot’s instrument flying knowledge and radio navigation skills, when compared to the limited instrument flying instruction provided under the PPL syllabus.

The rating was originally lobbied for by industry representatives, most notably AOPA, who wanted to see a stepping-stone between the one-hour instrument navigation training provided under the PPL curriculum and the full-blown commercial Instrument rating, used by commercial pilots operating in Class A airspace.

The 15-hour IMC rating course finally settled upon, allows a private pilot to climb through cloud and operate ‘VFR on-top’ before letting down again through cloud at their destination airport on either an Instrument Landing System (ILS) approach or non-precision let down. The privileges are more limited than those afforded to holders of an Instrument rating, but are nonetheless said to enhance safety and prevent pilots "hedge-hopping" at low-level to remain in sight of the ground. Fundamentally, the IMC rating provides pilots with the skills to get themselves out of trouble when faced with deteriorating weather conditions, and was never designed as a ‘cheap’ Instrument rating. IMC rated pilots, for example, are not allowed access to airways, or Class A airspace and for flights within Class D airspace, which includes the airspace around many of the UK’s airports, Minimum Descent Heights (MDHs) allowed for instrument approaches as well as minimum horizontal visibility distances are much more restricted than they are for IR qualified pilots.

Nonetheless, renowned UK aviator, display pilot and ex CAA employee, Barry Tempest, who was involved in the original IMC consultations back in the 1970s, told us that the rating originally came up against heavy criticism from the professional pilot unions, who saw it as little more than a budget Instrument rating which could compromise the safety of their operations. And according to those present at the recent JAA FCL 001 group meeting in Cologne, the same negative reaction by professional pilot unions would appear to have occurred again, albeit this time by unions outside of the UK.

[Fuji Abound]

Fuji wrote:
.. .. .. around 1967 I think.

Fuji also drew attention to

http://www.pprune.org/forums/showpos...84&postcount=3

which says

The IMC rating was introduced a few years before I learned to fly in 1970.

few = more than two, so 1967 seemed reasonable.

The IMCR is a rating created by the late Ron Campbell in the mid 70's for AOPA. So it has not been around the 40 and 50 years people are spouting off on here. How can you be taken seriously at representing this when you have not even done your research on the

Bose, I dont mind your being wrong - I am all the time. But this is what you posted (and now appears to have mysteriously vanished I might add). What I do mind is your constantly telling us that WE cant be taken seriously because we havent done our research.

I gave you an open invitation to point us in the direction of AOPAs rational for preserving the IMCr - do I need to remind you of your response?

I rather hoped we were in this together .. .. .. but it would seem we are not.

.. .. .. and yes, I dont much like AOPA for one reason alone, they tell us their mission is to support GA - ha, well even their own members have this to say

These days it's not good enough to do lots of hard work without ensuring everyone knows that you've been doing lots of hard work. Worse still a lack of communication is virtually an open door for someone else to claim credit or use the lack of communication as a weapon against you.

Communication with the membership is important, but promotion outside the membership base is probably more important. Especially so when competing with other organisations to be heard.

I have been generous. If you like we can explore some of the other comments.

[S-Works]

I am still at a lost to see why you are so intent on bashing AOPA. You really do have a bee in your bonnet over them.

I am also at a loss at to what you don't understand about AOPA's rational on saving the IMCR. Do you want a copy of every email and letter that has ever been exchanged on the subject or something?

AOPA have made it totally clear to the CAA, EASA the other member of the working groups that they want the IMCR to stay. They even went to great lengths to participate in a working group to change the rating enough to make it acceptable as a Euro Wide rating and pitched that at EASA. When the RIA is released the same people will review it and pass back comments again in support of the rating.

You are seriously being sidetracked by your venomous hatred of AOPA from the cause you are trying to gain support for and it really is quite pathetic.
Cross posting more comments to attack AOPA does nothing for your cause just makes you look like a dick. I have not seen AOPA attack your project for saving the IMCR.

As an AOPA member I have merely pointed out that if you are going to base a campagn on poor foundations and lack of knowledge about the very rating your are trying to preserve and a severe lack of knowledge on the process then you are doomed to failure.

At no time have I suggested that AOPA will do any better than you, merely that those who serve the AOPA membership interests have been involved in the rule making process for a very long time and know when discretion is the better part of valor.....
.


THE UK IMC RATING
Since its inception in the 1970s, the UK CAA has issued 18,000 IMC Ratings.
In looking at the statistics over the period 1980 – 2004, there are very few cases where pilots have lost control whilst legally using
the privileges of the IMC Rating in a serviceable aeroplane in UK airspace. In 25 years only 3 were found to have been failure to cope by IMC Rating holders.
This we know, but what we will never know is how many cases there were where the IMC rating got people out of trouble.
We do not have actual statistics for the other countries in Europe, but we do know that there are considerably more accidents caused by inadvertent or even intentional flight into IMC where the pilot has not been able to cope than there are in the UK.

The Arguments for Adopting the IMC Rating throughout Europe
• The IMC Rating has been a key element in the UK’s programme to improve safety standards amongst General Aviation (GA) private pilots, instructors and even CPL holders who do not hold an Instrument Rating, through the additional training for more than 30 years.
• The IMC Rating, which has been held by 18,000 UK GA pilots, is considered to be one of the reasons why the UK has achieved one of the best GA safety records in Europe.
• A number of pilots from mainland Europe are prepared to come to the UK each year to train for the IMC Rating, even though they may only exercise its privileges in UK airspace, as it gives them additional experience and confidence in their flying.
• The incidence of controlled flight into terrain (CFIT) and loss of control accidents are thought to have been significantly reduced as a result of the UK’s IMC training programme. These accidents are almost always fatal and it is thought that large numbers of lives have been saved.
• At mixed GA and CAT airports it is generally safer and simpler to have as many approaching and departing aircraft as possible following a single set of procedures. The IMC Rating makes this possible.
• In the interests of safety and utility almost all manufacturers of light aircraft now equip their aircraft with instruments required for IFR flight. A European flight crew licensing system, which does not provide for private pilots to be trained in the use of these safety enhancing instruments, is inappropriate and contrary to the interests of safety.
• No European Agency should be introducing legislation, which prohibits the use of safety enhancing equipment.
• For pilots wishing to progress to a full Instrument Rating the IMC Rating is a natural stepping stone.
• Any attempt to introduce European licensing laws, which remove the privileges of UK IMC Rating holders is likely to produce a very hostile reaction from large numbers of general aviation pilots, with well funded legal challenges to EASA.

We believe that with the IMC Rating we, in the UK, have the highest safety standard for non instrument rated pilots in Europe – think how we could improve the standard of safety in GA throughout Europe if all EU Member States were able to benefit from allowing their GA pilots to train for and hold the IMC Rating.

There is no threat to Commercial Air Transport aircraft from this activity. On the contrary, infringements into their airspace are less likely to occur by a holder of an IMC Rating, than by an untrained pilot flying inadvertently into their airspace and losing control.

Europe needs this rating – give European GA pilots the chance to go for it, and for UK pilots to be able to retain it!

[Contacttower]

with well funded legal challenges to EASA.



bose what sort of grounds would those be based on?

[S-Works]

Well considering all the hot air blowing on here, I am sure Fuji's next plan is to get you all to stick your hands in your pockets for a fighting fund, shortly after I wonder if his Canoe will be found on a beach.........

I should imagine in realty there are enough interested parties to mount some sort of legal challenge. How far it would go remains to be seen. I would stand to be guided by some of the lawyers on here.

The point I have been trying to make all along is Fuji is fighting with the wrong person, I and AOPA are stout supporters of the IMCR.

It is just sad that he seems so intent on diverting his attentions from a worthy cause to attack AOPA.

[Contacttower]

The point I have been trying to make all along is Fuji is fighting with the wrong person, I and AOPA are stout supporters of the IMCR.


Thank you bose for stating in your post exactly what AOPA have put forward in the IMC rating's defence. Is there somewhere where we can keep up to date with all this?...Perhaps I haven't tried hard enough but the EASA website doesn't say much in detail about the situation with regard to European integration of FCL.

Hopefully if there is a legal basis for cases to be brought the combined strength of the UK's FTOs will have enough clout to put up a reasonable fight.

[Fuji Abound]

I am not at liberty to post the actual documents to a faceless bulletin board however I can assure you that the representations have been extensive including a safety case for retaining the IMCR.

THE UK IMC RATING
Since its inception in the 1970s, the UK CAA has issued 18,000 IMC Ratings.
In looking at the statistics over the period 1980 – 2004, there are very few cases where pilots have lost control whilst legally using
the privileges of the IMC Rating in a serviceable aeroplane in UK airspace. In 25 years only 3 were found to have been failure to cope by IMC Rating holders.
This we know, but what we will never know is how many cases there were where the IMC rating got people out of trouble.
We do not have actual statistics for the other countries in Europe, but we do know that there are considerably more accidents caused by inadvertent or even intentional flight into IMC where the pilot has not been able to cope than there are in the UK.

The Arguments for Adopting the IMC Rating throughout Europe
• The IMC Rating has been a key element in the UK’s programme to improve safety standards amongst General Aviation (GA) private pilots, instructors and even CPL holders who do not hold an Instrument Rating, through the additional training for more than 30 years.
• The IMC Rating, which has been held by 18,000 UK GA pilots, is considered to be one of the reasons why the UK has achieved one of the best GA safety records in Europe.
• A number of pilots from mainland Europe are prepared to come to the UK each year to train for the IMC Rating, even though they may only exercise its privileges in UK airspace, as it gives them additional experience and confidence in their flying.
• The incidence of controlled flight into terrain (CFIT) and loss of control accidents are thought to have been significantly reduced as a result of the UK’s IMC training programme. These accidents are almost always fatal and it is thought that large numbers of lives have been saved.
• At mixed GA and CAT airports it is generally safer and simpler to have as many approaching and departing aircraft as possible following a single set of procedures. The IMC Rating makes this possible.
• In the interests of safety and utility almost all manufacturers of light aircraft now equip their aircraft with instruments required for IFR flight. A European flight crew licensing system, which does not provide for private pilots to be trained in the use of these safety enhancing instruments, is inappropriate and contrary to the interests of safety.
• No European Agency should be introducing legislation, which prohibits the use of safety enhancing equipment.
• For pilots wishing to progress to a full Instrument Rating the IMC Rating is a natural stepping stone.
• Any attempt to introduce European licensing laws, which remove the privileges of UK IMC Rating holders is likely to produce a very hostile reaction from large numbers of general aviation pilots, with well funded legal challenges to EASA.

We believe that with the IMC Rating we, in the UK, have the highest safety standard for non instrument rated pilots in Europe – think how we could improve the standard of safety in GA throughout Europe if all EU Member States were able to benefit from allowing their GA pilots to train for and hold the IMC Rating.

There is no threat to Commercial Air Transport aircraft from this activity. On the contrary, infringements into their airspace are less likely to occur by a holder of an IMC Rating, than by an untrained pilot flying inadvertently into their airspace and losing control.

Europe needs this rating – give European GA pilots the chance to go for it, and for UK pilots to be able to retain it!

.. .. .. we are getting some where.

Nothing would please me more if AOPA engaged everyone - all I have pointed out is they havent and sought to explain why. Prove to me they have and I will desist.

I know you dont like it - but if you think it is a done deal that the IMC rating is lost as the AOPA rep. dont be surprised if the rest of us are rather concerned!!

Moreover if that is what is in your mind how do you reconcile that with the campaign to save it?

[S-Works]

.......because you ignorant git if you had bother to read what I had said in the past rather than selectively highlighting things to make your own venomous attacks on AOPA you would realise that my OPINION is nothing to do with carrying on the fight. I don't want to see the IMCR lost just like everyone else however I am pragmatic enough to see the erosion of our liberties in the name of an intergrated Europe and realise that politicians follow their own agenda regardless of the dogs they pat and the babies they kiss.

I am perfectly entitled to express an opinion as you do so vociferously against AOPA.

You harass me into a posting stating AOPA's stand and then venomously post my refusal to post DOCUMENTS. Your are beneath contempt.

AOPA engage the MEMBERSHIP, if people choose to ignore it then that is there choice, if people outside of the AOPA membership expect to be engaged then they are on a hiding to nowhere.

As you can see from my post AOPA strongly support not only the case for retaining the IMCR but also for making it available across Europe.

Enough has been said on this subject now and I am getting tired of your endless childish insults. If you want to be taken seriously then concentrate on the game not trying to score points off those who have dedicated themselves to keeping up the fight without endless self trumpet blowing.

You want to save the IMCR then go ahead and do it. You are on your own.

[Fuji Abound]

You want to save the IMCR then go ahead and do it. You are on your own.

It would seem not.

I regret you think I have it in for AOPA - actually I say again I dont.

There would have been two outcomes to all this:

1. Lets leave it to AOPA

2. We had better do something about it ourselves, so that together with AOPA, the PPL IR, the GA Alliance and a few others we get what we want.

We already have links in place on our web site to all of these organisations, including AOPA - do you think they would be there if I had it in for AOPA for the sake of it.

You are so far involved with AOPA you cant see the wood for the trees.

If you cant or will not read the various forums and the comments here and indeed on AOPAs bulletins boards in which pilots set out what they want from AOPA then you are dangerously close to not understanding your job is to represent and engage with your members.

I promise you I dont make them up. They arent phantoms of my imagination.

I guarantee you I would like nothing more for AOPA to take on board these comments, tell us on their web site what they are doing, why they are doing it and how they are going about it.

[julian_storey]

Why on earth is everyone getting so angry?

Good grief!

It seems that just about everyone here would like to see the IMC rating saved. The only differences are that some of us believe that this is possible whilst others advocate capitualtion and acceptance of the 'inevitable'.

[Contacttower]

I know you dont like it - but if you think it is a done deal that the IMC rating is lost as the AOPA rep. dont be surprised if the rest of us are rather concerned!!


Enough has been said on this subject now and I am getting tired of your endless childish insults. If you want to be taken seriously then concentrate on the game not trying to score points off those who have dedicated themselves to keeping up the fight without endless self trumpet blowing.


This is exactly what EASA want.:ugh:

They want us to fight amongst ourselves so that we don't put across a good arguement!

[rustle]

Why on earth is everyone getting so angry?

I can't, obviously, speak for bose-x; however I don't think it is "anger" more frustration that FA, for whatever reason, has a bee in his/her bonnet about AOPA (as usual) and has tried to associate EASA's imposition of new licensing regs with his/her bee. (An imposition that was enabled due apathy when this was last discussed some years back)

(S)He was advised by various people to leave it out, but has gone on his/her usual ill-informed crusade against the very people who are arguing the case for the IMC's retention far more eloquently than (s)he.

No-one is suggesting "leave it to AOPA to sort", but it would be nice to think people might research their subject before "going off on one". :ugh:

"Answers, not egos".

[Fuji Abound]

Rustle

You just dont get it and never will.

However, I believe we all should lobby hard and petition hard to win this one because it is really important.

If AOPA, PPL IR, GAA and any of the other organisations also do a good job then we all win and if they dont we will.

It does mean working together for those who want to (and I hope that is everyone). There are many who have more knowledge and more expertise but none who this effects more than all of us.

Committees, politicians, representative groups et al all listen to the weight of opinion, (even if it is sometimes ill informed). I know.

Do not be persuaded otherwise.

[derekf]

Fuji,

What's the address of the website?

[Fuji Abound]

Derekf

Please just take 10.

It is up and running in its "introductory" form but being beta tested by a few top blokes on PPRuNe.

Watch this space and I will post up the link very shortly.

[S-Works]

I am curious Fuji, how old are you?

[Fuji Abound]

Why do you ask?

[S-Works]

Like I said, just curious.

[englishal]

Bose, let it lie. If I didn't know you were the same age as me, I'd say you were about 13 by the way you are acting...

PLease, just becuase some of us don't agree with AOPA UK then don't take it personally....

EA
(After a few nice cold "Jule" beers in denmark)...:)

[S-Works]

Let what lie Al? I would say I was pretty horizontal considering the constant abuse I am getting!

Good job I am thick skinned..... :p

[englishal]

No one is giving you abuse...you just perceive it that way.;)

Anyway, I highly recommend the Tuborg JuleOle..or whatever the hell it is called.....:zzz:

[rustle]

No one is giving you abuse...you just perceive it that way.;)


No, they were (and still are)

Don't know why bose bothers in all honesty.

Trying to help, offering a load of constructive criticism, and all he gets is kicked in the balls.

Pathetic, really.

But not altogether unexpected from the anti-AOPA rent-a-mob :yuk:

[englishal]

What is this, the new Timothy / Gerard side kick show :}

Bosey can give as good as he gets.....as he has proved.

Don't mention AOPA...oh you just did, there you go again. Do you want me to now go on about how good all the other European AOPA's are (and hence IAOPA) and how for €60 you can.....

Never mind.....you started it.......;)

[Fuji Abound]

Well I am not going to give up, so for those who dont like it, get out the fire.

I would sign up if it was not factually incorrect.

If you want to get support for something you need to state the facts correctly......

So there you go, you have got the whole post this time.

Let me sum up what I am trying to get over.

The IMCr is really important. It is worth fighting for because I really believe it makes for a safer pilot. I dont care if you have an IR and IMCr or neither it is worth fighting for. In my view sign the petition because you believe in what it seeks to achieve. Who really cares if the IMCr is 50, 40 or 30 years old.

I am really glad to see a lot already have. Is everyone who has signed - wrong? Should we have preferred to see no names on it because of a single inconsequential error?

and on the AOPA issue, I personally think AOPA have done a bad job on this issue. The reason I go on saying so is because I think it is important to examine the evidence and decide whether we should leave this to AOPA. I honestly believe I and many others have set out the evidence.

To repeat myself if many of your members are raising the said same issues on your own bulleting board I personally think their comments should be taken serioulsy. I would expect to see evidence of that, and I havent - sorry again, but that is the way I feel. Show me the evidence and I will change my tune - happily I might add!

You may disagree. It makes me no less of a friend of yours because you do.

[S-Works]

You truly are a crackpot..... :p

Nobody has ever suggested it is left to AOPA or anyone else for that matter.

You are perfectly at liberty to run your own campaign. We understand perfectly that you think AOPA have done a bad job, you have made it clear by using these forums as your personal anti AOPA soapbox.

You know what, I don't actually care anymore!

mad as a hatter.:sad::sad::sad:

[Fuji Abound]

Fair enough .. .. ..

.. .. .. lets just agree to disagree. It will make things a great deal more peaceful.

:)

[rustle]

What is this, the new Timothy / Gerard side kick show :}

Who? ;) :8 :rolleyes: :hmm: :D

[sunday driver]

Well, I saw the thread title, and excited by an opportunity to be informed, engaged, and motivated by some intelligent, active campaigners to save (my) IMCr, I have just read through all 143 posts (sorry, I was in Russia last week).

I have noted how the number of enthusiasts offering help in the first couple of pages has dwindled to practically zero.

My current status:-
Your joint efforts (and I mean ALL of you) leave most of my remaining hair torn out and on the floor.
I have yet to see benefit in being involved with ANY of you.
I await with interest your(plural) decision to use your energies constructively.

Yours
SD

PS yes, I have been aware of this issue for some time, yes I have seen a couple of recent low key aopa items on the subject, no I have not yet been persuaded to invest my 72 quid, no I do not have an axe to grind.

[Fuji Abound]

Sunday Driver

It is indeed a shame and I regret the way this thread has deteriorated. I am sorry. However you should not under estimate the strenght of support.

Firsly, in case you did not follow the thread you should visit the petition and note the number of pilots already signed up. This has occured with no publicity other than that which has taken place on PPRuNe.

Secondly, there are people who have a different agenda, or one that is less than clear. It is in the nature of debates of this sort that they will vent their views. This forms an important part of the debate. By definition they are likely to be as vociferous as those in favour. However, I can assure you by the number of emails and posts I have had that there are many, who although they have not posted, have closely followed and support this campaign.

Thirdly, there are already a few of us who are working together to increase the profile of this issue. There will very shortly be a dedicated web site. There is already a petition. There will be far wider representation.

Forthly, consider this as a starter for ten posted else where.

"Here are some observations to think about:

Controlled flight into terrain (CFIT) accounted for 30% of all fatalities between 1995 and 2004. There were 3,000 fatalities in consequence. (Source: CAA SRG 2006). In a similar length of time (1985 to 1994) CFIT and loss of control in IMC involving aircraft with a MTOW of 5,700 kg or less accounted for 28.5% of all accidents. (Source CAP 887 CAA Safety Regulation Group).

The SRG noted as follows:

“Typically, the CFIT accident involved the more mature and experienced pilot who, despite his experience, seemed to be oblivious to the dangers of continuing the flight into deteriorating weather conditions.”

The reports observes

“Usually, training for the Private Pilot’s Licence (PPL) takes place in good weather and with the advent of more candidates training for the PPL overseas, this trend is likely to increase”

and concludes

“It was considered that PPL training should be subjected to a greater level of CAA oversight to ensure that the best information is made available to candidates particularly in the areas of weather appreciation, calculation of safety altitude, flight planning and diversion techniques.”

The IMCr training syllabus incorporates all of the components of the SRG’s conclusion.

Loss of control in IMC was identified as the fourth most common accident type in the same report. The report states

"Three quarters of the pilots involved were attempting to fly in IMC when not qualified to do so."

IMCr training would have enabled the majoity of these pilots to avoid these accidents."

This is just part of the reason why preserving the IMCr is so important.

As has been pointed out on here on numerous occasions the JAA IR is not a viable alternative for most private pilots. The FAA IR is an attractive alternative but the concerns about its use in Europe continue unabated.

Moreover an IR extends the priviliges of an IMCr beyond that which many private pilots require.

If you believe in flight safety and take on board the statistics and findings above I think we have a duty to support this initiative.

I commend it to you.

Please let us know your views?

[Fuji Abound]

From another palce

"Have just been watching the (live) broadcast this evening from Strasbourg of the European Parliament reading / debate on the extension of EASA’s scope to Licensing, Operations and Third Country (i.e. non EU) Aircraft.
Several MEPs made reference to the importance of light aviation and the SME sector, the impact of EASA of costs particularly on maintenance (with a UK example quoted of a 60% increase). But most significant was UK MEP Philip Bradbourne’s speech which criticised EASA for its inefficiencies and failings, and the burden of red tape. “Not yet fit for purpose” he said, opposing the extension of EASA’s scope.

UK MEP Timothy Kirkhope (he is a private pilot) said EASA is incompetent, with delays in procedures and other difficulties and not yet fit for purpose. He said the UK costs were already high because of the CAA’s requirement to recover full cost. He referred particularly to the impact of EASA on private pilots and in particular the threat to UK pilots of possible withdrawal of the IMCR. He quoted Flyer Magazine, then referred to the UK weather which required the use of the IMCR . “Scrapping the ICR would be disastrous.” He asked the Commissioner (Jaques Barrot) to take a close look at this.
Barrot responded that he would be “at Mr Kirkhope’s disposal” to look at this.

The full Parliament vote on the 2nd reading is tomorrow.

I think the session was recorded and should be available at:

http://www.europarl.europa.eu/wps-eu...net/faces/vod/"

[Fuji Abound]

I thought this was an interesting comment from elsewhere worth repeating from a very well respected and very experienced avaition journalist:

It's disgraceful/shameful that the IMC rating was allowed to be led quietly and meekly to slaughter through a process not fit for purpose for these types of ratings. If the reps spotted this problem with the process, why weren't they alerting everyone to it months ago and objecting to it? Are they under self-agreed gagging orders or didn't they notice ?

2) Some of the other reps in the meeting 'deciding our IMC future' use VERY different classifications for their airspace, and their 'picture' of what really happens when pilots are let loose mixing it with commercials in IMC is not something you can break down that easily. I'd love to see the content of the UK pitch and perhaps even more interesting how long they had to get the message across. I suspect I will be shocked if I ever find out!

[Justiciar]

I have noted how the number of enthusiasts offering help in the first couple of pages has dwindled to practically zero.



I agree - how this has remained a sticky is beyond me. We now have two threads rehearsing the same arguments and trading the same insults. This thread should be for informed debate and nothing more.

Has anyone read the EASA literature on the proposed amendments and new regulations? I may be wrong (usually am) but some of the points to emerge seem to be:

Lightening of the Part M regulations for light aircraft maintenance (inherited from JAA)
More industry involvement in maintenance oversight and regulation at the expense of the local CAA
Proposal of a light aircraft pilot's licence (LAPL) with less onerous and less bureaucratic training requirements
The liklihood of additional ratings (and some form of instrument flying rating is mentioned in the consultation)I know it is fashionable to knock anything European ( and God knows, there is enough to knock) but it seems to me that the movement at EASA is in the right direction. They have inherited onerous regulations from the JAA which they appear to be addressing; the legislation giving them power over flight crew licensing is only now before the European Parliament and some of the changes they would like to make involve a change to the basic Regulation, i.e. it has the go back before the European Parliament. This takes time in Europe just as such changes would take time in the UK, the US or any other country.

Interestingly, a number of proposed changes are in the face of almost universal opposition from a number of national CAAs - perhaps because it involves a devolution of control and responsibility away from them in favour of national associations and industry bodies. Perhaps that has something to do with the hatchet job being performed on them by our own CAA. Lets face it, the boys at Gatwick are not exactly the most progressive bunch on the planet in certain areas.

The creation of a pan European Pilot's licence has alot to recommend it. It may in fact grant greater privileges than the current PPL (remember that the ICAO privileges for VFR flight are greater than the UK currently allows, e.g. VFR on top). It may well be that the loss of the IMCR will be a penalty of this common approach to licensing. I do wonder if this will be short term, until regulations are introduced provising for additional ratings to be added to the LAPL.

[IO540]

One thing I am curious about is what will happen to instrument training in the UK.

It's obvious almost nobody will do the "EASA IR" and anyway the vast majority of PPL schools cannot train the IR.

Presumably it will be possible to legally teach instrument flight but why would anybody bother if they don't get any privileges? It's like the various AOPA add-on module proposals from years ago - they fell flat because it was obvious nobody would do them in the absence of real benefits. Few PPLs train for the sake of it.

And if you can't log the lessons towards something, there is no benefit in going with an instructor. It will be just as good, in fact probably a lot better, to go up with an experienced private pilot and drill holes in clouds around some VOR etc. Lot cheaper too.

On the practical side, anybody instrument capable will still be able to fly in IMC under VFR, as people do all over the world. But, only with an OCAS departure, or only enroute. No instrument approaches in actual IMC, short of a mayday.

If all this comes about, things will get interesting...

Incidentally, Bose, the reason I did not believe the IMCR would end is because I never thought the VFR-only lobby would be able to "arrange" the committee votes to strip the LAPL of the IFR option, against EASA's express previous wishes. But they did it - a very clever move probably organised beforehand.

(posted on both threads)

Justiciar - the LAPL appears to have been stripped of the IFR add-on option.

[Fuji Abound]

Justicar


Some very interesting comments.

I think the key issue is that in the UK we need to preserve some form of accessible instrument rating.

It is easy to forget in the detail of the debate that there is no real alternative.

As matters stand the European IR has proved universally unpopular. That is not because of the existance of the IMCr in the UK either. There is almost zero uptake in the whole of Europe. The reasons for this are well rehearsed and there is nothing on the horizon to suggest this will change.

The choice is stark.

Accept that Europe will become all but devoid of private instrument flying, that many will simply break the law and risk their own lives or the lives of others, or fight to preserve and extend a very worth while rating.

Of course we could hope that with the new EASA license will come priviliges in the future that will address this issue - however it is usually far more diffiucult to achieve those changes down the road and the history in aviation of doing so is dreadful.

Finally, forgive me, but I dont think your comment about the offers of help having dried up is entirely correct. In the nature of things like this there is an initial flurry of interest and activity, then a hard look at the issues and perhaps a slower and wider appreciation of the consequences.

We are a nation in which it takes time for people to become sufficiently determined to address any restriction of their "rights", but I hope we are determined.

[dublinpilot]

As matters stand the European IR has proved universally unpopular.


Fuji,

I'm not sure that that is the full story. It's certainly the case that you don't have the rest of Europe getting worked up about this issue, but that's most likely because they aren't loosing anything. Therefore the issue doesn't get much 'airtime'. The local CAA's may not want the non IR, IFR flights, so are happy with the lack of 'airtime'.

However I suspect if the other European PILOTS (not the CAA's) were aware of the potential benefits, that they would be interested. I certainly have looked on the UK IMC rating with envy over the years. I asked the IAA would they consider something similar about two years ago, and was told no.

When you get everything up and running, if there is any spare capacity, it might be worth your while trying to make contact with other European pilot organisations (and publications to spread the word). If they were informed about the potential benefits, they may become useful allies, and be able to place pressure on their own representatives.

dp

[Fuji Abound]

Dublinpilot

It is intersting that I have had five emails from European pilots with regards the IMCr.

Of those three expressed the view that it was a dangerous rating. None of these were instrument rated.

I explained to them the advantages, the training involved and the way pilots in the UK used the rating. I believe I did so in a non biased way.

I can candidly say that they were amazed. They had no idea what was really involved and two of the three went on to say there was a fair amount of disinformation that they had heard about the rating.

In every case they have become strong supporters and would love to see the rating introduced in their country.

I think you might include yourself in those who would support their view?

[dublinpilot]

Absolutely. I'd love to see the rating adopted across Europe. I had tried to find out who the Irish representative is on the EASA working group so I could lobby them. Unfortunately, we don't have a representative on the committee!

I'll see about contacting our MEPs ;)

dp

[Fuji Abound]

Some very useful contributions to this debate:

1. EASA will not permit the CAA to issue any EASA licences or ratings with further 'UK airspace only' restrictions on them.

The reason I asked for information on this was that I saw a possibility of the CAA issuing (on behalf of EASA) EASA-FCL IRs restricted to existing IMCR privileges only and in UK airspace only. A simple way out of the currently looming mess - but not permitted under EASA regulations....

2. The only way to retain the IMCR is to convince the other EU states of its value. Otherwise it will be swept away.

I have seen a draft RIA (EASA, of course) which seems to think that the only way forward is to let UK IMCR holders 'convert' their IMCRs into EASA FCL IRs by an additional 5 hours training and testing and a 'theoretical examination'. However, this so-called Regulatory Impact Assessment has not given any cost estimates for this process, neither has it assessed the loss of business for those RFs currently teaching for the IMCR. It is a totally flawed draft RIA in every respect and is the product not of any GA organisations.

Personally I consider EASA fundamentally unfit for purpose - its whole rationale must be questioned by MEPs and this whole lunacy delayed.

When the NPA comes out, you must comment. But do NOT cut and paste the comments of others. Every single comment must be answered individually, so the more comments the better as this will slow everything down considerably... Beagle

Quote:
So please just answer the question.

I will answer it. There are two scenarios:

The European Parliament does not vote in that part of the amendment designed to give EASA exclusive competence in Flight Crew Licensing = national authorities retaining competence; or
They do but do not rubber stamp the draft regulations put before them, arrived at by what sounds increasingly like a cosy stitch-up, and instead provide a power for a for IFR ratings to be added to the euro sports licence (which I believe is what EASA originally envisaged).
In the first scenario the IMCR is retained; in the second a euro version will emerge. That may not be for some years, but the power will exist.

Of course the phasing of any EASA take over of licensing is an aspect we haven't really considered. It is possible that any amended Regulation will have a longer transition time that is envisaged.


Quote:
If you feel that the only way to press the case in favour of having an IMC rating is to quote stats and statements about the IMC rating then thank God you were not part of the team trying to establish the IMC rating in the first place because there was not much experience of how the IMC rating would work back then..............just like there is not much experience in the rest of Europe now.


No: you rely upon the evidence which is available at any particular point. Forget figures for a moment and tell us what anecdotal evidence there is thet pilots exercising the priviliges of the IMCR are causing a danger. I am unaware of any such evidence. The difference as regards Europe is that whilst they may not have experience themselves there is substantial evidence from the UK of how such a rating works in practice. Europe should therefore be in a better position to judge than the UK was when the rating was introduced. Of course it may not be desireable to transfer the concept wholesale. There are airspace differences, for example, and there may be valid issues on the degree of training. The may be a case for splitting the privileges into a number of different qualifications or sign offs, as I believe they do with approaches in Australia.

What we seem to have from Europe is a knee jerk reaction which fails to consider how such a rating would work in practice, how it works in the UK and whether it may be desirable as a means of increasing safety by enhancing pilot skills.


Quote:
All this talk of the IR being a professional rating is utter tosh. The IR is the qualifiecation for a PPL to fly IFR. It is not a professional qualification and confers nothing more than the ability to fly when VFR (or special VFR) is not possible.

So why do the theoretical knowledge requirements contain so much which is wholy irrelevant to PPLs? Why is there no credit for instrument flying already done, as is allowed by Annex 1 of ICAO (and is recognised in the FAA IR training)? I believe that recent proposals for modifying the knowledge requirements are on hold and may not see the light of day for some time, if at all.


Quote:
The fact that if a PPL holds an IR that get a credit for the training they have completed if they apply for a CPL simply makes sense...............or would you prefer that applicants for the CPL who hold an IR must sit the exams to demonstrate the knowledge they demonstrated previously.

Am I alone in not understanding the relevance this comment in relation to the issues Credit across the various aspects of the training is to be welcomed. However the existing system is cumbersome: for example, anyone initially getting a CPL or an IR and who later wants to go the ATPL route has to redo exams by sitting the full set of ATPLs. Why we do not have a progressive system of training and exams like the US is beyond me. Justiciar

[BEagle]

Incidentally, the so-called 'lighter regulation' EASA now proposes for the LAPL includes a mandatory proficiency check every 4 years.....

:hmm:

[Humaround]

I don't know if this has been posted elsewhere (the topic is spread across many threads and it's quite unwieldy) but I received this in response to an email Isent on the subject to the MEP in my area (rather more effective I hope than signing a petition, though I'll happily do that too)

It appears there is at least one MEP (Conservative Spokesman on Transport) who will be personally affected by this, which is a good sign....

"Pilot licenses under threat*from the new EU aviation safety agency

Strasbourg, 13th December 2007 --*Timothy Kirkhope MEP, Conservative Transport Spokesman in the European Parliament, warned that pilots of small planes and aircraft training schools*might face burdensome red tape if bad weather flying is*regulated by the new European Aviation Security Agency.

The Instrument Meteorological Conditions Rating (IMC) which allows UK pilots to fly in unfavourable weather conditions is now under threat from new powers given to the European Aviation Safety Agency - which is slowly replacing the current national regulator in the UK, the CAA. According to Mr Kirkhope the impact could be*serious*for the small aircraft industry.

He said: "The IMC Rating was designed for peculiarly British weather conditions. If the EU scraps it the British light aviation industry*could* be hit hard. It would mean that thousands of pilots*might either*have their flying*licence rating revoked or have to spend a lot of money and time obtaining a higher European rating.**

Mr Kirkhope, who*himself holds a pilot's license*and IMC rating,*addressed Transport Commissioner Jacques Barrot and said: "Please Commissioner, reassure me and other pilots about this. EASA's performance has been unacceptable and I am afraid it is not yet fit for purpose."*

Mr Kirkhope is now seeking an early meeting with Commissioner Barrot to discuss the issue*and to*try to find a solution to the problems. "*

[Fuji Abound]

Mr Kirkhope is now seeking an early meeting with Commissioner Barrot to discuss the issue*and to*try to find a solution to the problems

He has his meeting.

[davidd]

http://petitions.pm.gov.uk/IMC-Rating/

[Fuji Abound]

Well over 600 signatures now and still running at nearly 50 a day.

Please, if you have not done so, give your support.

and if you have, tell as many others about it as you can.

[DavidHayman]

The first I read of this was in Flyer this month - and yeah - this would put an end to about 80% of my flying. Will add signature and write to MP....

[stuartforrest]

Me too. Isnt it IMC every day in the UK? I cant remember my last flight that didnt have an element of IMC flight.

I will sell my plane if there is no sensible alternative.

[S-Works]

Me too. Isnt it IMC every day in the UK? I cant remember my last flight that didnt have an element of IMC flight.

I will sell my plane if there is no sensible alternative.

Won't your face look a bit odd with the nose missing?

[stuartforrest]

Strewth Bose-X I have no idea what that means but I wont really sell my plane if they change the rules. I will do what I always do, pay more and adapt because I love it.

On the day I cant afford th price they want me to pay then that is the day I will sell it but then I reckon I wont get a great price then as everyone will feel the same no doubt.

At the moment the Bonanza is safe because I do love the freedom of it sitting in the hangar waiting for me to go somewhere that I have not got time to go to.

Happy New Year!

[IO540]

Most "IFR regulars" will just continue to fly in IMC under VFR.

That's what I will do.

However, I will get the full TKS system installed because under VFR one often doesn't get CAS transit which means one cannot always remain VMC on top, and icing then becomes a hazard for the enroute section.

Imagine crossing the Alps at FL129 (the highest Zurich will let you do because their Class C base is FL130), the OAT is -10C, and the tops are FL160.

The gotcha is the usual VFR one which is that one needs to be able to arrive "officially VFR" at the destination. With an airport that is on the coast, or inland with no real terrain, and which has some Class E/G around it, this is normally achieved as follows:

1) When the last enroute unit asks you to contact the airport, ack the request, say goodbye, but don't call the dest airport right away.

2) While still in the OCAS section, descend (over water if possible) to below the cloud

3) Make the initial call to the airport. No lies need to be told at this point because you really are VFR.

Similarly if departing:

1) Depart "VFR"
2) When well out of sight and OCAS, climb up through cloud to VMC
3) Call up the next unit - now you are really VFR again

That is how it's done all over the world. You have to be a good instrument pilot with impeccable navigation, otherwise you will get killed.

Then you get the more crazy pilots who will switch off their Mode C if they want to climb higher....

[stuartforrest]

What a sad state of affairs it has come to when you have to fly like this rather than being honest and flying within the law. Its pathetic what these regulators come out with.

I could quite accept that they may not allow any new applications or that there is no extension of the coverage of the IMC but for goodness sake, to take away a rating that someone has spent good money earning and for no good reason but something called harmonisation is scandalous.

[Contacttower]

I've just received a very nice letter from the CAA (in reply to one I sent to them before Christmas) and the essentials of it are this:

The responsibility for FCL in Europe moving to EASA is a political decision and beyond the CAA. It is taking place under a revision of EC regulation 1592/2002.

Now that EASA is set to take over FCL the CAA, and the other 26 member states are helping EASA with the drafting of the new rules appertaining to FCL.

Under EASA there will be no national ratings so in the long term the only way to save the IMC rating will be for Europe to adopt it. The CAA is pushing EASA very hard for this but are one voice amongst 27 so may not succeed.




I know most already know all that but it just underlines that our dear CAA is doing the best it can for us. :ok:

[S-Works]

I did tell you this right at the start as I am a member of that working group.

[BEagle]

Which is why, unless a EU IMCR or Class2 IR is accepted at least in concept form, this political decision will require a political challenge.

There is no justification in the withdrawal of exisiting safety-enhancing privileges merely for 'harmonisation' purposes. Until EASA accepts that, they can only be considered as manifestly unfit for purpose.

[llanfairpg]

JULIAN

Can you update the links on your first post and perhaps put a direct link to the petition, save people wading through all this!

[Fuji Abound]

The web site for the campaign to save the IMC rating

www.ukimc.org

The petition

http://petitions.pm.gov.uk/IMC-Rating/?ref=imc-rating

[Fuji Abound]

20 more signatures on the petition and it will be in the second page of the most supported petitions currently running.

Some have criticised the petition.

However, the support for the petition is a window for what pilots really think - not just the usual suspects on here, but the wider pilot community.

Thank you for your support.

The IMC rating is now safe for the next four years, thanks to the support of the CAA and EASA.

The debate is underway what shape or form the IMCr will take in four years time, or perhaps even sooner.

Please continue to give us your support at www.ukimc.org.

Here are some good reasons:

1. We will be completely transparent with you, there are no hidden agendas, all we care about is at the very least preserving your IMC rating rights - you know that license you trained hard for and spent many thousands of pounds obtaining,

2. Fighting for a rating that has an impecable safety record so that other pilots in the future will be less likely to kill themselves.

3. and there is no subscritpion involved, we just ask for your support please.

Thank you.

[BEagle]

I am glad to report that the Master of the Guild of Air Pilots and Air Navigators has encourage the Guild's membership to register their support through the ukimc.org website.

To learn more about the Guild's function, see www.gapan.org (http://www.gapan.org) . You will not find a more highly qualified and experienced group of aviators in the UK!

[austerpilot]

Great start Fuji,
We need to be aware that the CAA are on the side of the Angels and will not let the IMCR go down in flames. Also EASA are not as bad as they might be painted, there is support for a form of PPL instrument qualification that is not the full (perhaps sightly over-blown IR) that we know in Europe.

The main anti's are not in the main the Eurocrats the principal opposition is coming from the Commercial operators and professional pilot associations that coupled with a complete lack of understanding of GA operations in Northern European non-regulated airspace by some of the EASA people means we have an uphill battle. The professional pilots civil & military along with the airlines were those who predicted mayhem when the IMCR was mooted and introduced - they were wrong then and are wrong again.

The IMCR had served us well but does need a little updating and putting on a bit of a pedistal if we are to convince the anti brigade. The JAA CPL/IR training has been set out in a modular form; we should think of promoting a new advanced PPL training scheme for restricted IFR operations (not valid for use in Class A airspace) giving privileges similar to the present IMC, Night and Multi Ratings. Modules could be taken direct from the CPL/IR syllabus with say the Departure and en-rote modules being mandatory and any 2 or possibly 3 others from the following 5 non precision approaches, precision approaches, GPS approaches, night operations & complex type/multi engine operations. I believe that such an approach would be politically acceptable to the majority with no loss of face by any party and we would have a better structured training course which would benefit the GA training industry.

I know that the CAA are thinking along these lines, hopefully IAOPA are going down a similar path. With such an approach we could demonstrate that European PPL's can be just as professional as some ATPL's from elsewhere and the pilot of say a G reg Arrow will be treated with as much, if not more, respect as his/her P(C)PL/IR counterparts in the "Land of the Free".http://www.pprune.org/forums/images/icons/mpangel.gif

[sunday driver]

Have now tried three times to add my name to the Downing St petition.
It asks for my e-mail address and postal address and promises me an e-mail which I have to reply to if I want to confirm my support for the petition (though all this doesn't seem to filter out M Mouse and his fellow petitioners).

No Downing St e-mail has arrived.

Note - I'm not a complete idiot because . . .

An early job of mine was designing computer hardware, software and firmware;
I've had e-mail accounts since the internet was first invented;
My e-mail accounts haven't been interrupted;
I always check the SPAM before deleting (saddo!)

Any ideas?

SD

[IO540]

Your ISP is probably dumping the automated emails. This happens a lot nowadays - stupid spam filters.

[bigbloke]

Just Had a look at the 10 Downing St petition site. It looks like with a few more signatures, this one will go over the 2000 mark before it closes on 5th March. :D

[SkyCamMK]

Phew, finally got to the end of the posts. My BP has been up and down, depression, laughter and frustation amongst other emotions. Thanks to all - I wish I knew who some of you characters really are but I suppose it does not really matter. Well done for the website UKIMC.org. The pressure must be kept up and I can see many doing so but 4 years can pass remarkably quickly. I too would fly as necessary but remaing in the spirit if not the letter would be my preferred approach if the rating goes. By then the average GPS would be capable of solving many of the perceived difficulties for those who had a reasonable skill in cloud. I still have some IMC students due to finish next month and they really are keen to get the real basic skills and they often do better on partial panel! Viva the rating! It has saved my bacon a few times in microlight and GA over the years. 'Nuff said!

[BEagle]

This response just in from No10:

The Civil Aviation Authority (CAA) has been successful in ensuring that the UK IMC rating will remain in place during the four-year transition period, from the national regulations on flight crew licensing to the regulatory system governed by European Aviation Safety Agency (EASA). EASA has agreed to establish a rulemaking group to consider proposals for a similar rating at the European level. The Department for Transport will be working closely with the CAA and EASA to identify a solution, prior to the end of the transition period, to ensure that the privileges of IMC rating holders are protected.

Which isn't bad at all. No real news, except that the DfT will be involved with CAA and EASA.

[poss]

That information was available a few months ago.
It sounds promising though and hopefully will result in us been able to keep our IMC rating intact.

[S-Works]

Nah, it's just Downing St blowing smoke up our arses telling us what we already know and what I said they would do at the start.

[KeyPilot]

Don't be so negative. For politicians, that's quite an affirmative stand. We shall see..

[derekf]

Don't be so negative. For politicians, that's quite an affirmative stand. We shall see..

So you think the politicians did this then? :ugh: